NC0005011_Regional Office Historical File Pre 2018 (2)

Gastonia Division
CBP Resources, Inc.
December 9, 1998
Mr. Matt Matthews, Supervisor
Aquatic Toxicology Unit
4401 Reedy Creek Road
Raleigh, NC 27607
Subject: Toxicity Reports
NPDES Permit No. NC00050l 1
CBP Resources
Gaston County, NC
Dear Mr. Matthews:
Enclosed you will find this facility's toxicity report for the month of November, 1998 and
a letter sent to Mr. Rex Gleason, of the Mooresville Regional Office, advising that on
December 1, 1998 this facility ceased it's discharge No. 001 to Crowders Creek.
Therefore, the referenced November test will be the final one.
Should there be any questions, please let me know.
Sincerely,
/an
Environmental Manager
cc: Mr. Rex Gle
enclosures
on. .
5533 S. York Rd. • Gastonia, NC 28052 • 7O4-864.9941 • Fax # 7o4-861-9252 • Direct DiarNumnber:

Effluent Toxicity R port Form - Chronic Pass/Fail and Acute LC58 Date o3_Dec-9e
CEP RESOURC FFLUENT rtPrtestr ..s_ NC��/Pipes County: GASTON
ETT Env ironmental#, Inc.
x
Signs re of Opponsible arge
x
Signature of Laboratory Supervisor
MAIL ORIGINAL TO
North Carolina C
CONTROL ORGANISMS
# Younp Produced
Adult (L31ve
Effluent %
NT 2 OR
d
hnia ChronicPass/Fail Reproduction Toxicity Test.
3.0©%©
NI
S Young Produced
e Adult (L)iv e (D)ead
_.
pH
Control
Treatment 2
D.O.
Control
Treatment 2
S
lst sample
7.7
7.7
7.7
7.8
start end
8.7
8.7
21
21
2
14
4
20
4
24
18
11
1st sample 2nd sample
8.0
8,0
start end start end
1st sample 2nd sample
8,6
8.4
7.7
7.7
8.1
8,8
8..2
8,7
8.2
7.8
8.2
8.3
LC5OIAcute Toxicity Test
(Mortality expressed as %, combining replicates)
LC5O =
95% Confidence Limits
Moving Average
Spearman Kerber
Method of De 'nation
Probit
Other
Organism Tested Ceriodaphriia dubia
7
18
15
Concentration
Mortality
18
15
ton (Sta
10
20
10
20
11
pie Type (Duration)
Envt
12.
14
Hardness (mglL)
Spec. Cond. (pmhos)
Chlorine (mg/L)
ample Temp. at receipt (`C)
T
Chronic Test Results
Calculated t= 2.032
Critical Value= 2,508
% Reduction 23%
% Mortality
Ar
4%
Control
18.0
Control
0%
13.9
Treatment 2
Control CV
11.8%
% 3rd Brood
100%
Treatment 2
PASS FAIL
Test Start Date
11.298
1st 2nd
Tox Tox
Dilution
start/end
Control
High Conc.
pH D.O.
DEM Form AT-1

919 North Main Street
State of North Carolina
Depart ent of E.,vir©nrnent and Natural Reso. rces
Division of Water Quality
Mooresville,, North Carolina
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Van M. Jones
CEP Resources - Gastonia Div,
5533 South York Road
Gastonia, North Carolina 28052
SU:I3JECT:
Dear Mr. Jones:
October 22, 1998
NOTICE OF VIOLATION
Effluent Toxicity Testing
NPDES Permit No, NC0005011
CEP Resources WWTP
Gaston County
This is to inform you that a review of your toxicity self -monitoring _report form for the
month of August 1998 indicates a violation of the toxicity limitation specified in your NPDES
Permit,
You should take whatever remedial actions are necessary to eliminate the conditions
causing the effluent toxicity violation(s). Your efforts may include conducting a Toxicity
Reduction Evaluation (TRE) 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
perrnit limitations and requirements.
Attached to this Notice is important infomration concerning your Whole Effluent
Toxicity Monitoring and Reporting Requirements. 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 [phone].
Sincerely,
D. Rex Gleason, P.E,
Regional Water Quality Supervisor
cc: Central Files
Aquatic Toxicology Unit

Division of Water Quality
1998
To: Rex Gleason
Through: Matt Matthews
From: Sandy Mort (A
Subject: Whole effluent toxicity test results
CBP Resources
NPDES Permit # NC0005011/001
Gaston County
The aquatic toxicity test using 24-hour composite samples of effluent discharged from CBP Resources
has been completed. CBP Resources has an effluent discharge permitted at 0.257 mullion. gallons per
day (MGD) entering Crowders Creek (7Q10 of 13 CFS). Whole effluent samples were collected. on
May 5 and 8 by John Lesley and Van Jones for use in a chronic Ceriodaphnia dubia pass/fail toxicity
test. The test using these samples resulted in a pass. Toxicity test information follows.
Test Type 3-Brood Ceriodaphnia dubia pass/fail.
Test Concentrations 3% sample
Test Result Pass
Control Survival 100%
Control Mean Reproduction 17.4 neonates
Test Treatment Survival 1.00%
Treatment Mean Reproduction 19.6 neonates
First Sample pH 7.75 SU
First Sample Conductivity 1860 micromhos/cm
First Sample Total Residual Chlorine <0.1. mgli
Second Sample pH 7.69 SU
Second Sample Conductivity 1850 m.icromhos/cm
Second. Sample Total Residual Chlorine <0.1 mg/1
Test results for these samples indicate that the effluent would not be predicted to have water quality
impacts on receiving water. Please contact us if further effluent toxicity monitoring is desired. We may
be reached at (919) 733-21.36.
Basin: CTB37
cc: Central Files
iironmenual Sciences Branch VPater Quality Section

Gastonia Div
CBP Resourc
June 18, 1998
Mr, Matt Matthews, Supervisor
Aquatic Toxicology Unit
4401 Reedy Creek Road
Raleigh, NC 27607
Dear Mr, Matthews:
This will acknowledge receipt of your letter of June 10, 1998 regarding this facility's May,
1998 chronic toxicity test,
This test was performed on a 24 hour composite, as well as any other specified parameters.
that our NPDES permit requires. The chain of custody form we used did not have a space
to show sample type. Therefore, the lab chose to show it as a grab. This will be corrected
in the future,
Should there be any other questions, please let me kno
Environmental Manager
cc: Mr. Rex Gleason.
5. York. Rd. • Gastonia, NC 28052 • 704-864-9941 • Fax # [phone] • Direct Dial Number:

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James 8, Hunt, Jr., Governor
Wayne McDevitt, Secretary
A, Preston Howard, Jr., P.E., Director
Mr, Van M. Jones, Environment
CBP Resources, Inc.
5533 S. York Road
Gastonia, N.C. 28052
June 10, 1998
onager
Subject NOTICE OF DEFICIENCY
Chronic Toxicity Testing
CBP Resources, Inc.
NPDES No. NC0005011
Gaston County
Mr. Jones:
My staff has received and reviewed. CBP Resources' 5/19/98 effluent toxicity
report. Upon review of the AT-1 form, it was noted the wrong type of sample was
collected for this toxicity test.
As per CBP Resources' permit requirernent effective 10/1/97, 24 hour composite
samples, instead of grab samples, should be collected for chronic toxicity testing, We have
recorded the 5/19/98 analysis as a "pass" as submitted, This letter is to inform you that you
should correct this discrepancy for future tests in order that they will be accepted.
If you have any questions regarding this matter, you are encouraged to call me or
Kristie Robeson at [phone],
cc: Rex Gleason-MRO
Robert Kelley-ETT Environ
Central Files
enta
Sincerely,
Matt Matthews, Supervisor
Aquatic Toxicology Unit
Inc.
Environmental Sciences Branch 4401 Reedy Creek Road
Telephone [phone]
An Equal Opportunity Affirmative Action Employer
Raleigh, North Carolina 27607
FAX [phone]
50% recycled/ lO% post consumer paper

PPFPF State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
919 North Main Street Mooresville, North Carolina 28115
January 23, 1998
CERTIFIED MAIL,
RETURN RECEIPT REQUESTED
Mr. Van M. Jones
CBP Resources - Gastonia Div.
5533 South York Road
Gastonia, North Carolina 28052
SUBJECT: NOTICE OF VIOLATION
Effluent Toxicity Testing
NPDES Permit No. NC000501.1
CBP Resources WWTP
Gaston County
Dear Mr. Jones:
This is to infouii you that a review of your toxicity self -monitoring report form
for the month of November 1997 indicates a violation of the toxicity limitation specified
in your NPDES Permit.
You should take whatever remedial actions are necessary to eliminate the
conditions causing the effluent toxicity violations. Please be aware that North Carolina.
General Statutes provide for assessment of civil penalties for violations of NPDES permit
limitations and requirements. If it would be helpful to discuss this situation or possible
solutions, please contact Mr. John Lesley with this office at [phone].
Sincerely,
D. Rex Gleason, P.E.
Acting Regional Supervisor
cc: Central Files
Aquatic Toxicology Unit

State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
919 North Main. Street Mooresville, North Carolina 2511.5
December 22, 1997
CERTIFIED MAIL
RE TI iRIRECEIPT REQUES I ED
Mr. Van M. Jones
CBP Resources - Gastonia Div:
5533 South York Road
Gastonia, North Carolina 28052
SUBJECT: NOTICE OF VIOLATION
Effluent Toxicity Testing
NPDES Permit No. NC0005011
CBP Resources WWTP
Gaston County
Dear Mr, Jone
This is to inform you that a review of your toxicity self -monitoring report form
for the month of October 1997 indicates a violation of the toxicity limitation specified in
your NPDES Permit.
You should take whatever remedial actions are necessary to eliminate the
conditions causing the effluent toxicity violations. Please be aware that North Carolina
General Statutes provide for assessment of civil penalties for violations of NPDES permit
limitations and requirements. If it would be helpful to discuss this situation or possible
solutions, please contact Mr. John Lesley with this office at [phone].
Sincerely,.
D. Rex Gleason, P.E.
Acting Regional Supervisor
cc: Central Files
Aquatic Toxicology Un.i

State of North Carolina
Department of Environment, Health and Natural Resources
Division of Water Quality
919 North Main Street Mooresville, North Carolina 28115
September 23, 1997
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Van M. Jones
CBP Resources - Gastonia Div,
5533 South York Road
Gastonia, North Carolina 28052
SUBJECT: NOTICE OF VIOLATION
Effluent Toxicity Testing
NPDES Pemlit No, NC000.5011
CBP Resources WWTP
Gaston County
Dear Mr. Jones:
This is to inform you that a review of your toxicity self -monitoring report form
for the month of July 1997 indicates a violation of the toxicity limitation specified in your
NPDES Permit,
You should take whatever remedial actions are necessary to eliminate the
conditions causing the effluent toxicity violations. Please be aware that North Carolina
General Statutes provide for assessment of civil penalties for violations of NPDES permit
limitations and requireme.nts. If it would be helpful to discuss this situation or possible
solutions, please contact Mr. John Lesley with this office at [phone].
Sincerely,
Barbara S. Christian, P.G.
Acting Regional Supervisor
cc: Central Files
Aquatic Toxicology Unit

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E,, Director
Decerrir 5, 1996.
Mr. Van Jones
CBP Resources
5533 S. York Road
Gastonia, NC. 28052
Subject: Chronic Toxicity Testing
CBP Resources
NPDES No. NC00050I1
Gaston County
Dear Mr. Jone
My staff has received and reviewed CBP Resources' 10/28/96 effluent toxicity report. During
review of the AT-1 form, our office noted the wrong effluent percentage was used. Therefore, we have
recorded the test as invalid.
As per CBP Resources' permit requirement effective 11/1/95, a chronic pass/fail test is to be
performed quarterly at an effluent concentration of 3%. The AT -I form indicates a chronic pass/fail test at a
concentration of 6%© was performed. This letter is to inform you that you should decrease the tested effluent
percentage to 3% for future tests, as specified in the permit requirement,
Ifa "fail" was submitted on CI3P Resources' monthly monitoring reports (DMR) for October
1996, we remind you that the DMR submitted to the Division's Central Files will need to be amended.
The effluent DMR facility information must be completely filled out (at the top of the sheet), and the form
should have "CORREC 1 hD COPY" written or typed at the top. The parameter code of your particular
toxicity test should be re-entered in an appropriate column with a brief explanation that the test was not
suitable as performed.
Please be aware of language present in your permit requirement that states, "Failure to achieve test
conditions as specified in the cited document, such as minimum control organism 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." Our office will be expecting a toxicity test to be submitted for the month of
November anyway as per your quarterly permit requirement.
If you have any questions regarding test protocols, you are encouraged to call me or Kristie Robeson at
[phone].
cc: Rex Gleasott.MRO
John Baumrner-Burlington. Research, Inc.
Shannon Langley -Facilities Assessment Unit
Central Files
Environmental Sciences Branch • 4401 Reedy Creek Road
Telephone [phone]
An Equal Opportunity Aiformotive Acton Employer
Sincerely,
Larry W. Ansley, Supervisor
Aquatic Survey and Toxicology Unit
Raleigh, North Carolina 27607
FAX # [phone]
5Q% recycled/x©% post consumer paper

NORTH CAR0 A DEFARTh!,? " OF
ENVIRONMENT HEALTH, AIL
RESOURCES
REGION L 0
Le 1e4
treat
'C 281.15
Phcae 704/603-1699
TAX 704/663 -6040
FAX
CV PAGZS

Divisio t cif Water Quality
December 13, 1996
ORANDUM
To: Rex Gleason
Through: Matt Matthews r
From: Sandy Mort
Subject: Ambient sample toxicity test results
Crowd.ers Creek downstream of Carolina Byproducts
Gaston County
The aquatic toxicity test using grab ambient samples collected on Crowders Creek downstrea
Carolina Byproducts has been completed. The ambient samples were collected on December
by John Lesley for use in a chronic Ceriodaphnia dubia pass/fail toxicity test. The test using
samples resulted in a pass. Toxicity test information follows.
Test "Type
Test Concentrations
Test Result
Control Survival
Control Mean Reproduction
Test Treatment Survival
Treatment Mean Reproduction
First Sample pH.
First Sample Conductivity
First Sample Total Residual Chlorine
Second Sample pH
Second Sample Conductivity
Second Sample Total Residual Chlorine
3-Brood Ceriodaphnia dubia pass/fail
1.0090 sample
Pass
100%
30..42 neonates
100%
29.08 neonates
7.29 SU
220.9 micromhos/cm
<0.1 mg/I.
7.24 SU
242,2 nnicromhos/call
<0..1 me
nd 6
se
Test results and measured waterquality parameters for these samples indicate that the ambient water
would not be predicted to have impaired water quality. Please contact us if further effluent toxicity
monitoring is desired. We may be reached at [phone].
Basin: CTB37
cc: Central Files
Environmental Sciences Branch l enter Y aiit Section

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„ E. Direc-or
February 29, 1996
Mr. Van M. Jones
CBP Resources, Inc.
5533 S. York Road
Gastonia, N.C. 28052
Subject: Chronic Toxicity Testing
CBP Resources, Inc.
NPDES No. NC0005011
Gaston County
Dear Mr. Jones,
My staff has received and reviewed CBP Resources' 118/96 effluent toxicity report.
Upon review of the AT-1 form., we noted the wrong effluent percentage was used. We
have recorded the test as a "pass", as submitted.
According to CBP Resources' penult requirement effective November 1, 1995, a
chronic pass/fail test is to be performed quarterly at an effluent concentration of 3%. The
AT-1 form shows a chronic pa..ss/faii test at a concentration of 6% was performed. You
should decrease the tested effluent percentag e to 3% for future tests as specified in the
,permit requirement,
If you have any questions regarding this matter, you are encouraged to call me or
Kristie Robeson at (919) .733-2136.
S
a
Aqu
cc: Rex Gleason-MRO
John Baummer-Burlington Rese.11-ch,
Central Files
Environmental Sciences Branch • 4401 Ro_fdy Creek Road
Telephone [phone]
An Equal Opportunity Affirmative Action Employer
y, Supervisor
and Toxicology Unit
Raleigh, North Carolina 27607
FAX [phone]
50% recycled/10% post cecrmlec paper

Stc:e. of North Carolina
Deoartment of Environment,
He ith and Nature! Resources
Div°on of Environmental Management
totGovernor
s, Secretary
, Jr., P.E., Director
CERTIFIED MAI1
REP:RN R.EC_E111
April 25. 1996
REQUESTED
\1r. ° ;tn M. Jones
CEP Sesources
5? ;;. orl Il«ad
Gals:.*=ails North Caro➢i
5U73,:ECT:
28052
NOTICE:01 VIOLATION
Effluent. Toxicity Testing
NPDES Permit No. NC0005011
CBP Resources Wastewater Treatment Facility
Gaston County
This is to inform
not - .eived your quartcrl
the North Carolina Admr
he Environmental raci aces Bunch of the Division of Environmental 3alata$gement has
g report for tie ';,anth of February 1996. This is in violation of Title :15 of
rative Code, Chapter 2, Subchapter 2B, Section .0506 (a)(1)(A) which states, "monthly
.d no later than 30 days after the end of the reporting period for which the report is made."
Dl reporting requirements exist for facilities. which are required to conduct toxicity -monitoring specified by
1 NPDES Permits, Facilities are required by the NPDES Permit to complete and submit an Aquatic Toxicity
the Environmental Sciences Branch as well as report the results of all effluent test characteristics
• a Discharge Monitoring Report Form (DMR) to the Division's Central Files,
• further action, please sttlttait. this report i7g May 15, 1996, or notify° this office of any problem which
anted the report from being received on time, You will be considered noncompliant with the reporting
stained in your NPDES Permit for the month of February until you snake acceptable dem..onstration to the
Sciences Branch that the February 1996 AT retort form was submitted to this office within the 30 day
addition, if within the next twelve (1.2) months, future reports are not received within the required
:'tame, you may he assessed a civil penalty.
Should there be no discharge of flow from the faculty dt ring a month in which toxicity m
}rat wx ould complete the information block located at the top cf fhe aquatic toxic'i,ty (AT) form indica
permit number, pipe number, county and the month/year of the subject report_ You should also wri
AT w.-'rru, sign the form, and submit following normal procedures_
You may wish to consider submitting future toxicit to t results via certified mail to the address located at the
hcmom of this pate to assist you in deternunirtw whether your toxi.ci.ty test resin
Environmental Sciences Branch.,
Lan.zuage present in your NPDES Perron sp
sine quarterly toxicity test failure. Please keep this
data after any single quarterly test failure, Upon pas
If you choose to respond to this; N
Ke?n Bowden at the address below, If yc
cc.: Rex Gleason -Mooresville Regional Office
Aquatic Survey and Toxicology Unit Files
Central Files
v rcrtatttsan. wri
ny questi; ss c
ring is required,
cility name,
"No Flow" on the
eivXer1 on time by the
monitoring frequency to monthly upon any
Environmental Sciences Branch will be expecting test
equirenrent will revert to quarterly.
n comments may be directed to the attention of Mr.
cerninr, this notice, please c tict Kevin Bowden at
Since,
reality Section
Environsnen't;:tl Sciences
h
4401. Rrt,cly° C'rce, R=.,:w
Ratesgri, North Caroir,ia 27(07
.».^ vr9mstj➢ aFsg.row'

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James 8. Hunt, Jr., Governor
Jonathan 8, Howes, Secretary
A. Preston Howard, Jr„ P.E., Director
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Van M. Jones
CBP Resources
5533 South York Road
Gastonia, North Carolina 28052
Subject: Effluent Toxicity Testing
NPDES Permit No. NC0005D1.1.
CBP Resources VvWTP
Gaston County
Dear Mr. Jones:
N.C. DEPT. OF
RCNMENT 1 rEA LTFt,
& NATURAL RES LI C S
This is to inform you that the Environmental Sciences Branch of the Division of Environmental
Management has not received your quarterly toxicity monitoring report for the month of January 1995.
Our records indicate an ad.mnistrative letter was issued to CBP Resources (formerly Carolina & Southern.
Processing) dated September 1, 1989, to perform chronic toxicity monitoring on a quarterly basis until
such time that significant toxicity reductions could be consistently achieved. The administrative letter
specifies Ceriodaphnia dubia be employed as the test organism.
Please be advised that toxicity test results shall be reported on the AT-1 State fort and sent to the
address below no later than 30 ,days following the month in which the test was performed.. Should no
discharge occur from the facility during a specified testing month., then the facility shall submit an AT-1
test form labeled "NO DISCHARGE" to the Environmental Sciences Branch and complete all appropriate
information at the top of the form_
NPDES Permit No_ NC000.50,11 is in the process of being reissued to the facility. It is our
understanding the proposed permit, upon. reissuance, will contain a chronic toxicity limitation. Although
the 'NPDES Permit has not reissued, you are reminded the facility should conduct toxicity monitoring
according to the requirements of the September 1, 195.9, administrative letter. Monitoring shall continue
according to the requirements of the administrative letter until such time that the NPDES Permit reissues
with an appropriate chronic toxicity perm limitation.
Should you have any questions concerning your reporting requirements, please contact either Mr.
Kevin Bowden at (919) '733-21.36 or Mr. John Lesley in our Mooresville Regional Office at (704) 663-
1699.
cc: Steve Tedder
Rex Gleason -Moore.
John Lesley -Moores
Larry Ansley
Central Files
Sinet
Assistant Water Quality Section Chief
for Environmental Sciences.
i le Regional Office
lie. Regional Office
Environmental Sciences Branch •
Telephone [phone]
AnEqual Opportunity Affirmative Action LEI ploycr
401 Reedy Creek Road 4 Raleigh, North Carolina 276C/7
FAX # [phone]
50W reercliid1U)% pate consumer paper

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr„ Governor
Jonathan B. Howes, Secretary
Aa. Preston Howard, Jr., P E„ Director
995
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Van M. Jones
CBP Resources
5533 South York Road
Gastonia, North Carolina 28052
Subject: Effluent Toxicity Testing
NPDES Permit No. NCO(J05011
CBP Resources WWTP
Gaston County
Dear Mr. Jones:
This is to inform you that the Environmental Sciences Branch of the Division of Environmental
Management has not received your quarterly toxicity monitoring report for the month of January 1995.
Our records indicate an administrative letter was issued to CBP .Resources (formerly Carolina & Southern
Processing) dated September 1, 1989, to perform chronic toxicity monitoring on a quarterly basis until
such time that significant toxicity reductions could be consistently achieved. The administrative letter
specifies Ceriodaphnia (labia be employed as the test organism.
Please be advised that toxicity test results shall be reported on the AT-1 State for nn and sent to the
address below no later than 30 days following the month in which the test was performed.. Should no
discharge occur from the facility during a specified testing month, then the facility shall submit an AT-1
test form labeled "NO DISCHARGE" to the Environmental Sciences Branch and complete ail appropriate
information at the top of the form.
NPDES Permit No. NC0005011 is in the process of being reissued to the facility. It is our
understanding the proposed permit, upon reissuance, will contain a chronic toxicity limitation.. Although
the NPDES Permit has not reissued, you are reminded the facility should conduct toxicity monitoring
according to the requirements of the September 1, 1989, administrative .letter. Monitoring shall continue
according to the requirements of the ,administrative letter until such time that the NPDES Permit reissues
with an appropriate chronic toxicity permit limitation.
Should you have any ques'uons concerning your reportingr'equirenreno, please contact either Mr.
Kevin Bowden at (919) '733-2'136 or Mr. John. Lesley in our Mooresville Regional Office at (704) 663-
1699.
cc: Steve Tedder
Rex Gleason -Mooresville Regional Office
John Lesley -Mooresville Regional Office
Larry Ansley
Central Files
Since
Assistant Water Quality Section Chief
for Environmental Sciences
Envhonrnental
Telephone 9a9-.
An Equal apportureiay ,4f
• 4401 Reedy Cntek, Road
coon Employer
Raleigh, North Carolina 27607
FAX [phone]
50 recy^cyc1/0 fY , post consumer paper,

Gastonia Division,
CBP Resources, Inc.
April 14, 1994
Mr. Ken Eagleson, Assistant Water Quality Chief
Environmental Sciences Branch
NC Division of Environmental Management
4401 Reedy Creek Rd
Raleigh, NC 27607-6445
Subject: Effluent Toxicity
Permit No, NC0005611
CBP Resources
Gaston County, NC
Dear Mr. Eagleson:
According to the enclosed chronic bioassay for March, 1994, this facility's
effluent passed. This was performed since the tests for January and February,
1994, did not pass.
There still does not seem to be a logical explanation for this deviation, To our
knowledge, there has been no changes in the characteristics of our effluent,
Again, I reaffirm my statements made to you previously about the validity of the
January and February test results.
Should there be any questions, please let me know.
bra
Mr. Van Jones
Plant Manager
cc: Mr. D Rex Gleason
5533 5,, York Rd. • Gastonia, NC 28052 • 704-864-9941 • Fax # [phone] • direct Dial Number:

Gastonia Division
CBP Resources, Inc..
February 9, 1994
Mr. Ken Eagleson, Assistant Water Quality Chief
Environmental Sciences Branch
NC Division of Environmental Management
4401 Reedy Creek Rd
Raleigh, NC 27607-6445
Subject: Effluent Toxicity Testing
Permit No. NC0005011
CBP Resources
Gaston County, NC
Dear Mr. Eagleson:
According to the results of the enclosed quarterly chronic bioassay test done in
January 1994, this facility's effluent did not pass. Therefore, we will follow the
guidelines prescribed in your letter of September 21, 1989, which states we
need to sample monthly until a single test passes.
Since initiating the chronic toxicity format in January 1990, we have consistently
passed these quarterly tests. There does not seem to be a logical explanation
for this last test not passing. I question the validity of the results and do not feel
this test is indicative of the quality of our effluent or its effect on the receiving
stream.
We will provide you with the results of the new test as soon as possible.
Should you have any questions, please let me know.
Sincerely,
Van M. Jones
Plant Manager
cc: D Rex Gleason
5533 S. York Rd. • Gastonia. NC 28052 • 704-864.9941 • Fax # [phone] • Direct Dial N rr rber

RECYCLIN
NATURE OF OUR BUsLNEss.
October 13. 1993
Mr. Ken Eagleson
Assistant Water Quality Section Chief
Environmental Services Branch
4401 Reedy Creek Rd
Raleigh, NC 27607
Subject: Effluent Toxicity Testing
NPDES Permit #NC0005011
Carolina Southern Processing
Gaston County, NC
Dear Mr. Eagleson:
RECE?v TIQ
Gastonia Division
CBP Resources, Inc.
This will confirm receipt of your letter dated October 5, 1993 to Mr, Gene
Olberding, with this company. Your letter advised the subject facility's July 1993
toxicity report had not been received by your office. Due to an oversight on our
part we have been conducting these tests quarterly without regard to the specific
month. As a matter of fact we have intentionally varied the month.
The enclosed toxicity test for third quarter 1993, was conducted in September,
Beginning in October 1993, we will sample during the prescribed months,
Thanks for bringing this to our attention and if there are any questions, please
let us know.
Sincerely,
Van M. Jones
Environmental Manager
VJ/kb
cc: Mooresville Regional Office
DEM Central Files
S. York Road • Gastonia, NC 28052 • 704-864-9941 • Fax # [phone] • Direct Dial Number:

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
October 5, 1993
CERTD MAIL
RETURN RECEIPT REQUESTED
Mr. Gene Oberding
CBP Resources
5533 S. York Highway
Gastonia, North Carolina 28052
SUBJECT: Effluent Toxicity Testing
NPDES Permit No. NC0005011
CBP Resources WWTP
Gaston County
Isar Mr. Oberding:
This letter is to inform you that the Environmental Sciences Branch of the Division of
Environmental Management has not received your quarterly toxicity testing report form for the month of
July 1993. Carolina and Southern Processing was required by administrative letter dated September 21,
1989, to conduct quarterly chronic toxicity testing during the months of October, January, April and July.
You are hereby requested to submit the July 1993 self -monitoring report form to the address located at the
bottom of this page no later than October 27, 1993, or notify this office in writing and provide a detailed
explanation why toxicity testing was not conducted during the month of July.
Additionally, if your facility is required to report during a month in which no discharge occurs,
you should complete the information block located at the top of the AT form indicating the facility name,
permit number, pipe number, county and the month/year of the subject report. The ApT form shall be
submitted to the address below and appropriately marked 'NO FLOW".
ATTN: ENVIRONMENTAL SCIENCES BRANCH
DIVISION OF ENVIRONMENTAL MANAGEMENT
DEHNR
44401 REEDY CREEK ROAD
RAI FIGH, NORTH CAROLINA 27607-6445
You may wish to consider submitting future toxicity test results via certified rail to assist you iri
determining whether your toxicity test results were received timely by the Environmental Sciences
B ranch.
If you have any questions concerning this correspondence, please contact en at (919)
733-2136.
Since
cc: Mooresville Regional Office
Central Files
Quality Section Chief
Environmental Sciences Branch • 4401 Reedy Creek Road • Raleigh, North Car l6ina 276C)7
Telephone [phone] FAX [phone]
An Equal Upportur ty AtNrnativeAction Employer 501% r®cycled/1C . post consumer paper

kt t6 of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr„ Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P,E., Director
Mr. E.R. t:lberding, e President
CBP Resources, Inc,
5533 South. York Road.
Gastonia, NC 28052
DENR
1998
Payment C-nowledgnreart
Civil. Penalty Assessment
NPDES Permit Number NCC10C1'
CBP Resources, Inc.
Gaston County
Case Numbers LM 9S-0Cl2 I..t
97-029 & AG 98-005
Dear Mr. Olberding:.
This letter is to ackno v°ledge receipt of check nun hers 257723,, 257724 in the amount of
S29,779,1 i0 received, from you on December I ,'1998,
this case
Division
es in. full the civil a sessrrent Cevied against CBP l:.esources. Inc. and
:Payment of this penal t ire no way precludes future action by this
f the NPDE.S
If you have any questions. please feel,free to contact Bob Sledge at'919) 73 3-5083,
extension 547.
SAW/sl.
cc:
Regional
t,'C. omplk
Sincerely,
A. Gilson, Supervisor
Source Compliance/:i nforcement Unit
P,0, Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post --consumer paper

1PTER L ii SECTION Fax 19-?16-6766
Nov 16 ° 16:01 F.01
MiiCI EL r. F.ASLEY
A T Nd.Y [irrLa AL
State of North Carolina
Department oG Justice
P. O. BOX 629
t tALE[OH
602•0629
November 16, 1998
Ramona Cunningham O'Bryent, Esq.
Smith Helms Mulliss & Moore, LLP
Post Office Box 21927
Greensboro, NC 27420
RE: CBP Resources, Inc. v. DENR, Division of Water 2.ualit
98 EHR C082 and 98 EHR 0552..
Dear Mona:
REPLY TO
Anita L1aVeaux_t1urg�aaea
Environmental Division
{9191 7 1 6-6600
1919) 716-6766 Fax
Its been a pleasure working with you, Hopefully, the follctvvirtg igiets your client's approval.
We are in receipt of your November 2, 1998 letter enumerating the terms of the settlement of CBP
Resources, Inc, v, DENR, Division of Water Quality. As previously discussed, your client will not be
receiving a separate civil penalty assessment for $5,850,00, i,e., the period beginning December 1,
1997 and ending June 30, 1998. Accordingly, we will be expecting two (2) checks from your client
one for $23,929.10 and one for $5,850,00, Receipt Of these monies along with full and complete
compliance as more specifically described In the settlement letter of November 2, 1998 will fully and
completely satisfy the civil penalty assessments for both cases, i.e., 98 EHR 0062 and 98 ENR 0552.
If you have any questions, please feel free to all.
Very truly yours,
Anita LeVeaux-Quigless
Assistant Attorney General
ALQ:sm
cc: Tommy Stevens
Susan Wilson
ReX aver
n

MLcHAEL P. EASLEY
ATTORNEY GENERAL
State of North Carolina
Department ofJustice
P. O. BOX 629
RALEIGH Reply tQ_
27602 29
October 23, 1998
SMITH HELMS MIJLLISS MOORS, LLP
Ramona Cunningham ©'Bryant, Esq.
Post Office Box 21927 BY+ SL
Greensboro, North Carolina 27420
RE: CBP Resources, Inc., Gaston County, 98 EFIR 0082
Dear Ramona:
EMT. C
&NV I R.ONMUNT, AI Th.
tt NATURAL IFCESOI, D tt C .*tt>
OCT 27 ti998
(01,5.0/141111,ITM, OMIPINfir
WIN IE ['MIK Etrilki
Mil. (,eYana-Quiet
Evittemw61Aitio1ow
(919) 7164600
[phone] (Pix)
This letter confirms our October 19; 1998 conversation. Your client, CBP Resources
Inc., has two outstanding civil penalty assessments. On December 16, 1997 an assessment for
eleven thousand and ninety-one dollars and thirty cents ($11, 091.30), including investigative
costs of two hundred and ninety-one dollars and thirty cents ($291.30) was mailed to your client.
On March 19, 1998, another assessment for eighteen thousand six hundred and seventy-two
dollars ($18,672.80), including investigative costs of two hundred and ninety-seven dollars and.
eighty cents ($297.80) was mailed to your client, As per our conversation yesterday and at my
client's, the Department of Environment and Natural Resources (DENR), direction, a settlement
for 800% of the assessments plus the investigative costs, twenty-three thousand nine hundred and
twenty-nine dollars and ten cents ($23,929.10) was reached between our clients.
Also discussed was a forthcoming assessment against your client from the end of the
period of review of the last case through the application date of the SOC, i.e., for violations from
December 1, 1997 through June 30, 1998. For these violations, we will agree to a full and
complete payment of five thousand eight hundred and fifty dollars ($5,850.00). This, I believe
your clients will agree, is more than fair. Finally, it was agreed that your client would
withdraw the SOC, firmly commit to cease discharge from outfall 001 by November 15, 1998,
and notify the city of Gastonia of the negotiated deadline.
I greatly appreciate your cooperation in the settlement of this matter. If you have any
questions, please feel free to call me at the number set out above.
y.
Anita LeVeaux-Quigless
wp6.1128269
17cc: Preston Howard
Tommy Stems

MICHAEL F. EASLEY
ATTORNEY GENERAL
State of North Carolina.
Department of Justice
P,©,BOX 629
RALEIGH Reply to,
27602-0629
October 23, 1998.
OCT 27 1996
Aniu LeVeare-Quigless
Environmental Division
n
(919) 716-66P0
[phone] (Fax)
SMITH HELMS MULLISS & MOORE, LLP
Ramona Cunningham ©'Bryant, Esq.
Post Office Box 21927 BY FACSIMILE I FIR'S "+ I ASS MAIL
Greensboro, North Carolina 27420
RE: CBP Resources, Inc., Gaston County, 98 EHR 0082
Dear Ramona:
This letter confirms our October 19, 1998 conversation. Your client, CBP Resources
Inc., has two outstanding civil penalty assessments., On December 16, 1997 an assessment for
eleven thousand and ninety-one dollars and thirty cents ($11, 091.30), including investigative
costs of two hundred and ninety-one dollars and thirty cents ($291.30) was mailed to your client.
On March 19, 1998, another assessment for eighteen thousand six hundred and seventy-two
dollars ($1.8,672.80), including investigative costs of two hundred and ninety-seven dollars and
eighty cents ($297.80) was mailed to your client. As per our conversation yesterday and at my
client's, the Department of Environment and Natural Resources (DENR), direction, a settlement
for 80% of the assessments plus the investigative costs, twenty-three thousand nine hundred and
twenty-nine dollars and ten cents ($23,929.10) was reached between our clients.
Also discussed was a forthcoming assessment against your client from the end of the
period of review of the last case through the application date of the SOC, i.e., for violations from
December 1, 1997 through June 30, 1998..For these violations, we will agree to a full and
complete payment of five thousand eight hundred and fifty dollars ($5,850.00). This, I believe
your clients will agree, is more than fair. Finally, it was agreed that your client would
withdraw the SOC, firmly commit to cease discharge from outfall 001 by November 15, 1998,
and notify the city of Gastonia of the negotiated deadline.
I greatly appreciate your cooperation in the settlement of this matter. If you have any
questions, please feel free to call me at the number set out above.
Anita LeVeaux-Quigless
wp6J\28269
bcc: Preston Howard
Tommy Stevens
Coleen. Sullins
Susan Wilson;

June 22, 1998.
Mr. D. Rex Gleason, P,E.
Regional. Supervisor
N.C. Division of Water Quality
919 N. Main Street
Mooresville, N.C. 28115
Dear Rex,
This letter will confirm our meeti
Mel Roshanravan, and myself
Gastonia Division
CBP Resotes, Inc.
on June 16, 1998 between you,
ohn Leslie, M
At this time all parties agreed to settle the two penalty assessments with CBP paying
eighty percent of the assessed penalty amounts. We also agreed that this settlement would
take care of any violations that had occurred since December, 1997 and allow us to
negotiate a Special Order by Consent (SOC) with interim limits lasting until our
connection to the City of Gastonia sewer system.
We have asked our attorney to pursue this with the State Attorney General's Office and a
SOC application will be submitted soon.
Thank -you for your assistance in this matter.
Environmental Manager
5533 5. York Rd, • Gastoni NC 28052 • 704-864-9941 • Fax # 704-86i -9252 • Direct Dial Number: _.

OM
ch 11, 1 •
TO: nS
J
o
Fast Track Enfor ent
Violation of NCGS 14 1 .1
DES Pe •t N. NC
CBP Resour
ton County, NC
BOD co
plo or

STATE OF NORTH CAROLINA
COUNTY OF GASTON
IN THE MATTER OF
CBP RESOURCES, INC.
FOR VIOLATIONS OF:
NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
File No. LM
FINDINGS AND DECISIONS
AND ASSESSMENT
OF CIVIL, PENALTIES
NPDES PERMIT
NO. NC0005OI1
AND NORTH CAROLINA GENERAL )
STATUTE 143-215.1 (a) (6)
Acting pursuant to North Carolina General Statutes (G.S.)
143-215.6A, I, A. Preston Howard, Jr., P.E., Director of the
Division of Water Quality (DWQ), make the following:
FINDINGS OF FACT:
A. CBP Resources, Inc. (the Company) is a corporation
organized and existing under the laws of the State of
North Carolina.
B. The Company operates a 0.257 MGD wastewater treatment
plant at Gastonia, North Carolina, which is located in
Gaston County.
C. The Company was issued NPDES Permit No. NC0005011 on
October 20, 1995, effective November 1, 1995, with an
expiration date of September 30, 1996. The renewed.
permit was issued on September 5, 1997, effective
October 1, 1997, with an expiration date of March 31,
1999.
D. Said permits contain the following relevant daily
maximum, monthly average, and chronic toxicity effluent
limitations:
Parameter
Dai
Fecal Coliform
BOD
BOD
BOD'
BOD1
Chronic Toxicity
Limitation
y Max Monthly Avg.
400 / no limit
680 / 340
317 / 158
612 / 306
285 / 143
Quarterly @ 3%2
1 The BOD limits changed in the renewed permit
2 Monitoring Frequency reverts to monthly after
failure.
Units
#/100 ml
lbs/day
mg/1
lbs/day
mg/1
Pass/Fail
a single test

CBP Resources, Findings and Decisions
Page 2
E. Monthly self -monitoring reports for the period from
April through November, 1997 have revealed the
following exceedances of the above -cited permit
effluent limits: (See Attachment A)
F. Notices of Violation concerning the monthly average
permit limitation violations and chronic toxicity
violations at the subject plant were sent to the
Company by DWQ's Mooresville Regional Office.
G. None of the above -cited exceedances of the permit
effluent limitations were the result of a bypass or
power failure at the plant as defined in the permit.
H. Said permit also contains the following relevant
reporting requirements:
Parameter Reporting Requi e ent Units
BOD Monthly Average mg/1
BOD Daily Maximum mg/1
From April through November, 1997 the Company's self -
monitoring reports contained insufficient values for
the BOD monthly average concentration. (See Attachment
A)
From April through November, 1997 the Company's self -
monitoring reports contained insufficient values for
the BOD daily maximum concentration. (See Attachment A)
K. The Company's prior record of compliance with programs
over which the Environmental Management Commission has
regulatory authority is as follows:
A civil penalty of $11,091.30 was assessed against the
Company on December 16, 1997 (Case No. LV 97-029). The
Company has filed a petition for an administrative
hearing. The Company was assessed a civil penalty of
$4,734.30 (Case No. LV 96-030) on February 3, 1997.
The penalty was paid on March 19, 1997. A civil
penalty was assessed for $500 (Case NO. LR 94-02) on
June 3, 1994. The penalty was paid on June 29, 1994.
In July, 1988, the Company (then named Carolina and
Southern Processing Company) was assessed a civil
penalty of $18.000 plus $2429.33 in enforcement costs
and $635.81 in damages (total = $21,065.14 Case No. 88-
49). The Company paid the assessment on October 12,
1988. The Division of Air Quality has documented 97
air permit limit violations for the period from January
through June, 1997.

CBP Resources, Findings and Decisions
Page 3
L. The cost to the State of the enforcement procedures in
this matter totaled $297.80
Based upon the above Findings of Fact, make the following:
II. CONCLUSIONS OF LAW:
A. The Company is a "person" within the meaning of G.S.
143-212(4).
B. NPDES Permit No. NC0005011 is required by G.S.
215.1.
C. The effluent limitations contained in the subject
permit are terms, conditions, or requirements of said
permit.
D. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on five (5) occasions during July
through November, 1997 in the manner and to the extent
described in Attachment A, when the permittee permitted
waste to be discharged into the waters of the State in
violation of the daily maximum permitted effluent limit
for Fecal Coliform.
E. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on three (3) occasions during May,
July, October, and November, 1997 in the manner and to
the extent described in Attachment A, when the
permittee permitted waste to be discharged into the
waters of the State in violation of the monthly average
permitted mass/based effluent limit for BOD.
F. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on two (2) occasions during July
and November, 1997 in the manner and to the extent
described in Attachment Aq when the, permittee permitted
waste to be discharged into the waters of the State in
violation of the daily maximum permitted mass/based
(lbs/day) effluent limit for BOD.
G. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on eight (8) occasions during
April through Novetber, 1997 in the manner and to the
extent described in Attachment A, when the permittee
permitted waste to be discharged into the waters of the
State in violation of the monthly average permitted
concentration (mg/1) effluent limit for BOD.

CBP Resources, Findings and Decisions
Page 4
H. The Company violated G.S. 143-215.1(a)(5) and NPDES
Permit No. NC0005O11 on eight (8) occasions during June
through October, 1997 in the manner and to the extent
described in Attachment A, when the permittee permitted
waste to be discharged into the waters of the State in
violation of the daily maximum permitted concentration
(mg/1) effluent limit for BOD.
1. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on five (5) occasions during May
through November, 1997 in the manner and to the extent
described in Attachment A, when the permittee permitted
waste to be discharged into the waters of the State in
violation of the permitted effluent limit for Chronic
Toxicity.
By reporting as described in I.(i) above the Company
violated the subject permit's reporting requirement for
BOD monthly average concentration on eight (8)
occasions from April through November, 1997.
K. By reporting as described in I.(J) above the Company
violated the subject permit's reporting requirement for
BOD daily maximum concentration on thirty-five (35)
occasions from April through November, 1997.
L. General Statute 143-215.6A(a) provides that a civil
penalty of not more than ten thousand dollars per
violation may be assessed against a person who violates
or fails to act in accordance with the terms,
conditions, or requirements of a permit required by
G.S. 143-215.1.
M. The State's enforcement costs in this matter may be
assessed against the Company pursuant to G.S. 143-
215.3(a)(9) and G.S. 143B-282.1(b)(8).
N. The Director, Division of Water Quality, pursuant to
delegation provided for by G.S. 143-215.6A(h) has the
authority to assess civil penalties.

CBP Resources, Findings and Decisions
Page 5
Based upon the above Findings of Fact and Conclusions of
Law, I make the following:
III. DECISION:
Accordingly, the Company is hereby assessed a civil penalty
of:
For of the five (5) violations of
G.S. 143-215.1(a) (6) and NPDES Permit
No. NC0005011, by discharging waste into
the waters of the State in violation of
the permit daily maximum effluent limit
for Fecal Coliform.
For of the three (3) violations of
G.S. 143-215.1(a)(6) and NPDES Permit
No. NC0005011, by discharging waste into
the waters of the State in violation of
the permit monthly average mass/based
(lbs/day) effluent limit for BOD.
For of the two (2) violations of
G.S. 143-215.1(a)(6) and NPDES Permit
No. NC0005011, by discharging waste into
the waters of the State in violation of
the permit daily maximum mass/based
(lbs/day) effluent limit for BOD.
For of the eight (8) violations of
G.S. 143-215.1(a)(6) and NPDES Permit
No. NC0005011, by discharging waste into
the waters of the State in violation of
the permit monthly average concentration
(mg/1) effluent limit for BOD.
For of the eight (8) violations of
G.S. 143-215.1(a)(6) and NPDES Permit
No. NC0005011, by discharging waste into
the waters of the State in violation of
the permit daily maximum concentration
(mg/1) effluent limit for BOD.
For of the five (5) violations of
G.S. 143-215.1(a)(6) and NPDES Permit
No. NC0005011, by discharging waste into
the waters of the State in violation of
the permit effluent limit for Chronic
Toxicity.

CBP Resources, Findings and Decisions
Page 6
For of the eight (8) failures to
report for BOD monthly average
concentration in violation of G.S. 143-
215.1(a) (6) and NPDES Permit No. NC
0005011 for the months of April through
November, 1997.
For of the thirty-five (35)
failures to report for BOD daily maximum
concentration in violation of G.S. 143-
215.1(a) (6) and NPDES Permit No.
NC0005011 for the months of April
through November, 1997.
TOTAL CIVIL PENALTY, which is
percent of the maximum penalty
authorized by G.S. 143-215.6A.
297. 0 Enforcement costs.
TOTAL AMOUNT DUE
Pursuant to G.S. 143-215.6A(c), in determining the amount of
the penalty I have taken into account the Findings of Fact and
Conclusions of Law and the factors set forth at G.S. 143B-
282.1(b), which are:
(1) The degree and extent of harm to the natural resources
of the State, to the public health, or to private
property resulting from the violations;
(2) The duration and gravity of the violations;
(3) The effect on ground or surface water quantity or
quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violations were committed willfully or
intentionally;
(7) The prior record of the violator in complying or
failing to comply with programs over which the,
Environmental Management Commission has regulatory
authority; and
(8) The cost to the State of the enforcement procedures.
(Date) A. Preston Howard, Jr., P.E., Director
Division of Water Quality

DIVISION OF WATER QUALITY
ENFORCEMENT CASE ASSESSMENT FACTORS
Type: (LV) Limit Violation
Violator: CBP Resources, Inc,
Address: 5533 South York Road
Gastonia, North Carolina 28052
Registered Agent: United States Corporation Company
Address: 327 Hillsborough Street
Raleigh, North Carolina 27602
Regional Office: Mooresville
The degree and extent of harm to the natural resources of the State, to the public health, or
to private property resulting from the violations:
There is no documented evidence of harm to the natural resources of the State, public health,
or to private property; however, violations of permit limits would predict a compromise of
water quality downstream of the discharge Ammonia as Nitrogen is toxic to aquatic life and
exerts an oxygen demand on the receiving stream. BOD limit violations would also indicate
an increased oxygen demand downstream of the discharge. Fecal Coliform limit violations
exceed the standard established to protect human health (200/100 m.1). Chronic Toxicity
violations would indicate that the discharge is having a negative impact on aquatic life
downstream of the discharge.
The duration and gravity of the violations:
The violations occurred during the period from April through November, 1997. NPDES
Permit limit violations have the potential to affect the designated uses of the receiving stream.
Fecal Coliform limit violations exceed water quality standards (200/100 ml) designed to
protect human health. Chronic Toxicity test failures would predict an adverse impact on
aquatic life downstream of the discharge.
The effect on ground or surface water quantity or quality or on air quality:
No adverse impacts on groundwater or surface water quantity or quality have been
documented. Adverse impacts on air quality have been documented through complaints filed
by residents near CBP Resources which has 97 air quality permit limit violations documented
by the Air Quality Section. NPDES Permit limit violations would predict that water quality
downstream of the facility is being compromised.

CBP, Case Assessment Factors
Page 2
4. The cost of rectifying the damage:
No damage has been documented.
The amount of money saved by noncompliance:
Money could have been saved by failing to construct, operate, or maintain facilities to meet
CBP Resources could have lowered the organic loading to the WWTP to prevent
noncompliance.
6. Whether the violations were committed willfully or intentionally:
The Company overloaded the wastewater treatment facility which resulted in noncompliance
with NPDES Permit limitations; therefore, the violations may be considered willful.
7. The prior record of the violator in complying or failing to comply with programs over which
the Environmental Management Commission has regulatory authority:
The Company has a poor compliance record. A civil penalty of $11,091.30 was assessed on
December 16, 1997 (Case No. LV 97-029). CBP Resources has requested an administrative
hearing. The Company was assessed a civil penalty of $4,734.30 on February 3, 1997 (Case
No. LV 96-030). The penalty was paid on March 19, 1997. A civil penalty of $500 (Case
No. LR 94-02) was assessed on June 3, 1994. The penalty was paid on June 29, 1994. The
Company (d.b.a. Carolina and Southern Processing Company) was assessed a civil penalty
in July, 1988, (Case No. 88-49) following the breech of a wastewater lagoon and subsequent
fish kill in Crowders Creek. The Company was assessed a civil penalty of $18,000 plus
$2429.33 in enforcement costs and $635.81 in damages. The Company paid the assessment
on October 12, 1988. In addition, the Division of Air Quality has documented 97 air permit
limit violations for the period from January through June, 1997.
The cost to the State of the enforcement procedures:
Central Office Review and Processing 100.00
6.0 hours by investigator for investigating and
drafting report @ $20.74/hour $ 124.44
1.0 hour by Water Quality Regional Supervisor
for review (4 $37.25/hour = $ 37.25
1.0 hour by Regional Supervisor for review
$25.18/hour $ 25.18
1.0 hour for clerical support © $10.93/hour $ 10.93
Total = $ 297.80

CBP, Case Assessment Factor
Page 3
9. Type of violator and general nature of business (i.e. individual vs. large
n
The Company is a corporation which operates a rendering plant for the manufacture of animal
feed ingredients.
10. Violator's degree of cooperation (including efforts to prevent or restore) or recalcitrance:
The preparation of this enforcement package consisted of file reviews; therefore, the violator
was neither cooperative or recalcitrant. The company did not include concentration values
on self -monitoring reports which made file review difficult.
11. Mitigating Circumstances:
Concentration values were not included on self -monitoring reports; however, concentration
values could be calculated using the mass -based (lbslday) data.
12. Assessment Factors:
a. IWC: 3%
b. Receiving. Stream: Crowders Creek
c. SOC/JOC status/negotiations: NA
d. Copy of MP Screen: Attach:'
e. Copy of Limits Page in Permit: Attached
f. Damage: None documented

Fecal Colifo
July 10, 1997
July 25, 1997
July 31, 1997
September 25, 1997
October 16, 1997
ATTACHMEI`T A
Daily Maximum Fermi
Reported Value
430/100 ml
460/100 ml
425/100 ml
485/100 ml
425/100 ml
imit Violations
Permit Limit
400/100 ml
400/100 mi
400/100 ml
400/100 mi
400/100 ml
BOD Monthly Average lbs/day Permit Limit Violations
Date
May, 1997
July, 1997
October, 1997
BOD - Daily
Date
July 31, 1997
October 16, 1997.
Reported V
389 lbs/day
518 lbs/day
441 lbs/day
Permit Limit
340 lbs/day
340 lbs/day
306 lbs/day'
um lbs/day Permit Limit Violations
Repor l Value
938 lbs/day
642 lbs/day
Permit Limit
680 lbs/day
612 lbs/day'
BOD - Monthly Average mg/1 Permit Limit Violations*
agg
April, 1997
May, 1997
June, 1997
July, 1997
August, 1997
September, 1997
October, 1997
November, 1997
Reported Value
160 mg/1
186 mg/1
246 mg/I
378 mg/1
173 mg/I
236 mg/I
266 mg/I
166 mg/1
Permit Li
158 mg/i
158 mg/1
158 mg/I
158ng/1
158 mg/1
158 mg/1
143 mg/1
143 mg/1

BOD - Daily Maxim
g/l Pea
Dag Repo rtcd Value
June 13, 1997
June 27, 1997
July 10, 1997
July 31, 1997
September 25, 1997
October 16, 1997
October 22, 1997
October 30, 1997
376 mg/l
330 mg/1
370 mg/1
370 mg/1
471 mg/1
351 mg/1
317 mg/l
350 mg/1
•
Violations'
Permit Limit
317 mg/1
317 mg/i
317 mg/1
317 mg/1
317 mg/1
285 mg/1.'
285 mg/1
285 mg/1
Chronic Toxicity Permit Limit Violations
May, 1997
June, 1997
July, 1997
August, 1997
September, 1997
October, 1997
November, 1997.
Reported Value
BAD TESTS
Fail @3%
Fail @3%©
Fail @ 3%
BAD TEST'
Fail @ 3%©
Fail @ 3%
Permit Limit
Pass @ 3%
Pass @ 3%
Pass @ 3%
Pass @ 3%
Pass @ 3%
Pass @ 3%
Pass @ 3%©
'The permit limits ( mass/based and concentration limits) for BOD changed on October 1, 197.
z Burlington Research documented that the September, 1997 chronic toxicity test failed to meet
Quality assurance criteria.
* Values for BOD concentration were not reported on Monthly Monitoring Reports by CBP
Resources. BOD concentrations were calculated as follows:
mg/t = reported value in lbs/day
MGD x 8.34 lbs/gal

ATTACM A ' u+
ConcentraIi n Report
ON MO Y A
Month
1997
y, 1997
1997
July, 1997
1997
September, 1997
October, 1997
Nov-y ber, 1997
u
OR G a
ber o
Total:
ROD CONCE'• TION D Y ORTING VIOLATIONS
Month
1997
1997
e, 1997
t, 1997
1997
St:$ber, l 7
October, 1997
November, 1997
Number of R olations
Total:
4
5
4
5
4

DIVISION OF WATER QUALITY
February 20, 1998
MEM©RANDIR°i TO: Dan Safrit
FROM: Barbara Christian
THROUGH: Rex Gleason
PREPARED BY: John Lesley
SUBJECT:
Fast. Track Enforcement
Violation of NCGS 143-215.1(a)(6) and
NPDES Permit No. NC0005011
CBP Resources WWTP
Gaston County, NC
Attached is an enforcement report which details violations ofNPDES Permit No. NC0005O11
and NCGS 143-215.1(aX6). The Company does not dispute the violations as stated in their response
to the Notice of Recommendation for Enforcement. CBP Resources has historically had perrnit limit
compliance problems which appear to be related to organic overloading of the WWTP. This Office
is of the opinion that the organic loading of the facility could be controlled by CBP Resources.
This 0 Once recommends that civil penalties be substantial to convince the Company that an
expeditious tie-in to the City of Gastonia collection system would be in their best financial interest.
If you have questions or require additional information, please contact John or me,
Attachments
cc: Colleen Sullins

STATE OF NORTH CAROLINA
COUNTY OF GASTON
IN THE MATTER OF
CEP RESOURCES, INC.
FOR VIOLATIONS OF:
NPDES PERMIT
NO. NC0005011
AND NORTH CAROLINA GENERAL
STATUTE 143-215.1 (a) (6)
NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
File No. LV
FINDINGS AND DECISIONS
AND ASSESSMENT
OF CIVIL PENALTIES
Acting pursuant to North Carolina General Statutes (G.S.)
143-215.6A, I, A. Preston Howard, Jr., P.E., Director of the
Division of Water Quality (DWQ), make the following:.
FINDINGS OF FACT:
A. CEP Resources, Inc. (the Company) is a corporation
organized and existing under the laws of the State of
North Carolina.
B. The Company operates a 0.257 MGD wastewater treatment
plant at Gastonia, North Carolina, which is located in
Gaston County.
C. The Company was issued NPDES Permit No. NC0005011 on
October 20, 1995, effective November 1, 1995, with an
expiration date of September 30, 1996. The renewed
permit was issued on September 5, 1997, effective
October 1, 1997, with an expiration date of March 31,
1999.
D.
1 The BOD
2 Monitor
failure.
Said permits contain the following relevant daily
maximum, monthly average, and chronic toxicity effluent
limitations:
Parameter
Dai
Fecal Coliform
BOD
BOD
BOD1
BOD1
Chronic Toxicity
Limitation Units
y Max/Monthly Avg.
400 / no limit
680 / 340
317 / 158
306 / 612
285 / 143
Quarterly @ 3%2
limits changed in the renewed permit.
ng Frequency reverts to monthly after
#/1©© ml
lbs/day
mg/1
lbs/day
mg/1
Pass/Fail
a single test

CBP Resources, Findings and Decisions
Page 2
E. Monthly self -monitoring reports for the period from
April through November, 1997 have revealed the
following exceedances of the above -cited permit
effluent limits: (See Attachment A)
F. Notices of Violation concerning the monthly average
permit limitation violations and chronic toxicity
violations at the subject plant were sent to the
Company by DWQ's Mooresville Regional Office.
G. None of the above -cited exceedances of the permit
effluent limitations were the result of a bypass or
power failure at the plant as defined in the permit.
H. The Company's prior record of compliance with programs
over which the Environmental Management Commission has
regulatory authority is as follows:
A civil penalty of $11,091.30 was assessed against the
Company on December 16, 1997 (Case No. LV 97-029). The
Company has filed a petition for an administrative
hearing. The Company was assessed a civil penalty of
$4,734.30 (Case No. LV 96-030) on February 3, 1997.
The penalty was paid on March 19, 1997. A civil
penalty was assessed for $500 (Case No. LR 94-02) on
June 3, 1994. The penalty was paid on June 29, 1994.
In July, 1988, the Company (then named Carolina and
Southern Processing Company) was assessed a civil
penalty of $18,000 plus $2429.33 in enforcement costs
and $635.81 in damages (total = $21,065.14 Case. No. 88-
49). The Company paid the assessment on October 12,
1988. The Division of Air Quality has documented 97
air permit limit violations for the period from January
through June, 1997.
I. Thee cost to the State of the enforcement procedures in
this matter totaled $297.80
Based upon the above Findings of Fact, I make the following;
II. CONCLUSIONS OF LAW:
A. The Company is a "person" within the meaning of G.S.
1.43-212 (4) .
B, NPDES Permit No. NC0005011 is required by G.S. 143-
215.1.
C. The effluent .limitations contained in the subject
permit are terms, conditions, or requirements of said
permit.

CBP Resources, Findings and Decisions
Page 3
D. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on five (5) occasions during July
through November, 1997 in the manner and to the extent
described in Attachment A, when the permittee permitted
waste to be discharged into the waters of the State in
violation of the daily maximum permitted effluent limit
for Fecal Coliform.
E. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on three (3) occasions during May,
July, October, and November, 1997 in the manner and to
the extent described in Attachment A, when the
permittee permitted waste to be discharged into the
waters of the State in violation of the monthly average
permitted mass/based effluent limit for BOD.
F. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on two (2) occasions during July
and November, 1997 in the manner and to the extent
described in Attachment A, when the permittee permitted
waste to be discharged into the waters of the State in
violation of the daily maximum permitted mass/based
(lbs/day) effluent limit for BOD.
G. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on eight (8) occasions during
April through November, 1997 in the manner and to the
extent described in Attachment A, when the permittee
permitted waste to be discharged into the waters of the
State in violation of the monthly average permitted
concentration (mg/1) effluent limit for BOD.
The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. N00005011 on eight (8) occasions during June
through October, 1997 in the manner and to the extent
described in Attachment A, when the permittee permitted
waste to be discharged into the waters of the State in
violation of the daily maximum permitted concentration
(mg/1) effluent limit for BOD.
. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on five (5) occasions during May
through November, 1997 in the manner and to the extent
described in Attachment A, when the permittee permitted
waste to be discharged into the waters of the State in
violation of the permitted effluent limit for Chronic
Toxicity.

CBP Resources, Findings and Decisions
Page 4
General Statute 143-215.6A(a) provides that a civil
penalty of not more than ten thousand dollars per
violation may be assessed against a person who violates
or fails to act in accordance with the terms,
conditions, or requirements of a permit required by
G.S. 143-215.1.
K. The State's enforcement costs in this matter may be
assessed against the Company pursuant to G.S. 143-
215.3(a)(9) and G.S. 143B-282.1(b)(8).
L. The Director, Division of Water Quality, pursuant to
delegation provided for by G.S. 143-215.6A(h), has the
authority to assess civil penalties.
Based upon the above Findings of Fact and Conclusions of
Law, I make the following:
III. DECISION:
Accordingly, the Company is hereby assessed a civil penalty
of:
For of five (5) violations of G.S.
143-215.1(a)(6) and NPDES Permit No.
NC0005011, by discharging waste into the
waters of the State in violation of the
permit daily maximum effluent limit for
Fecal Coliform.
For of the three (3) violations of
G.S. 143-215.1(a) (6) and NPDES Permit
No. NC0005011, by discharging waste into
the waters of the State in violation of
the permit monthly average mass/based
(lbs/day) effluent limit for BOD.
For of the two (2) violations of
G.S. 143-215.1(a)(6) and NPDES Permit
No. NC0005011, by discharging waste into
the waters of the State in violation of
the permit daily maximum mass/based
(lbs/day) effluent limit for BOD.

CBP Resources, Findings and Decisions
Page 5
For of the eight (8) violations of
G.S. 143-215.1(a)(6) and NPDES Permit
No. NC0005011, by discharging waste into
the waters of the State in violation of
the permit monthly average concentration
(mg/1) effluent limit for BOD.
For of the eight (8) violations of
G.S. 143-215.1(a)(6) and NPDES Permit
No. NC0005011, by discharging waste into
the waters of the State in violation of
the permit daily maximum concentration
(mg/1) effluent limit for BOD.
For of five (5) violations of G.S.
143-215.1(a) (6) and NPDES Permit No.
NC0005011, by discharging waste into the
waters of the State in violation of the
permit effluent limit for Chronic
Toxicity.
TOTAL CIVIL PENALTY, which is
percent of the maximum penalty
authorized by G.S. 143-215.6A.
297.80 Enforcement costs.
TOTAL AMOUNT DUE

CBP Resources, Findings and Decisions
Page 6
Pursuant to G.S. 143-215.6A(c), in determining the amount of
the penalty I have taken into account the Findings of Fact and
Conclusions of Law and the factors set forth at G.S. 143B-
282.1(b), which are:
(1) The degree and extent of harm to the natural resources
of the State, to the public health, or to private
property resulting from the violations;
(2) The duration and gravity of the violations;
(3) The effect on ground or surface water quantity or
quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violations were committed willfully or
intentionally;
(7) The prior record of the violator in complying or
failing to comply with programs over which the
Environmental Management Commission has regulatory
authority; and
(8) The cost to the State of the enforcement procedures.
(Date) A. Preston Howard, Jr., P.E. Director
Division of Water Quality

CERTIFICATION PAGE
I ce . the info nation in this report is true to the best of my knowledge.
All violations of self-rnortito • g data have been ve ed by liard copy reNnew of tlie
mori iy reports and the appropriate pe It t.
Si ature of ciple Investigator(s):
Date:

DIVISION OF WATER QUALITY
ENFORCEMENT CASE ASSESSMENT FA
Type: (LV) Limit Violation
Violator: CBP Resources, Inc.
Address: 5533 South York Road
Gastonia, North Carolina 28052
Registered Agent: United States Corporation Company
Address: 327 Hillsborough Street
Raleigh, North Carolina 27602
Regional Office: Mooresville
The degree and extent of ho the natural resources of the State, to the public health, or
to private property resulting from the violations:
There is no documented evidence of harm to the natural resources of the State, public health,
Or to private property; however, violations of permit limits would predict a compromise of
water quality downstream of the discharge. Ammonia as Nitrogen is toxic to aquatic life and
exerts an oxygen demand on the receiving stream. BOD limit violations would also indicate
an increased oxygen demand downstream of the discharge. Fecal Coliform limit violations
exceed the standard established to protect human health (200/100 ml). Chronic Toxicity
violations would indicate that the discharge is having a negative impact on aquatic life
downstream of the discharge.
2. The duration and gravity of the violations:
The violations occurred during the period from April through November, 1997, NPDES
Permit limit violations have the potential to affect the designated uses of the receiving stream.
Fecal Coliforrn limit violations exceed water quality standards (200/100 rnl) designed to
protect human health, Chronic Toxicity test failures would predict an adverse impact on
aquatic life downstream of the discharge.
The effect on ground or surface water quantity or quality or on air quality:
No adverse impacts on groundwater or surface water quantity or quality have been
documented. Adverse impacts on air quality have been documented through complaints filed
by residents near CBP Resources which has 97 air quality permit limit violations documented
by the Air Quality Section. NPDES Permit limit violations would predict that water quality
downstream of the facility is being compromised.

CBP, Case Assessment Factors
Page 2
4. The cost of rectifying the damage:
No damage has been documented.
The amount of money saved by noncompliance:
Money could have been saved by failing to construct, operate, or maintain facilities to meet
limits. CBP Resources could have lowered the organic loading to the W"WTP to prevent.
noncompliance.
6. Whether the violations were committed willfully or intentionally.
The Company overloaded the wastewater treatment facility which resulted in noncompliance
with NPDES Permit limitations; therefore, the violations may be considered willful.
The prior record of the violator in complying or failing to comply with programs over which
the Environmental Management Commission has regulatory authority:
The Company has a poor compliance record. A civil penalty of $11,091.30 was assessed on
December 16, 1997 (Case No. LV 97-029). CBP Resources has requested an administrative
hearing. The Company was assessed a civil penalty of $4,734.30 on February 3, 1997 (Case
No. LV 96-030). The penalty was paid on March 19, 1997..A civil penalty of $500 (Case
No. LR 94-02) was assessed on June 3, 1994. The penalty was paid on June 29, 1994. The
Company (d.b.a. Carolina and Southern Processing Company) was assessed a civil penalty
in July, 1988, (Case No. 88-49) following the breech of a wastewater lagoon and subsequent
fish kill in Crowders Creek. The Company was assessed a civil penalty of $18,000 plus
$2429.33 in enforcement costs and $635.81 in damages. The Company paid the assessment
on October 12, 1988. In addition, the Division of Air Quality has documented 97 air permit
linut violations for the period from January through June, 1997.
The cost to the State of the enforcement procedures:
Central Office Review and Processing = $ 100.00
6.0 hours by investigator for investigating and
drafting report @ $20.74/hour - $ 124.44
1.0 hour by Water Quality Regional Supervisor
for review @ $37.25/hour = $ 37.25
1.0 hour by Regional Supervisor for review
@ $25,18/hour — $ 25.18
1.0 hour for clerical support @ $10.93/hour $ 10.93
Total = $ 297.80

CBP, Case sessment Factors
Page 3
Type of violator
The Coin°. yi
feed ingredients.
d general nature of business i.e. individual vs
e corporation)
poration which operates a rendering plan t for e ofacture of
10. Violator's degree of coop eras
The prep. on of this enforce
as neither cooperative or repI
ftgating Circumstances:
none
12. Assess ent Fac
sluding efforts to prevent or
estore) or r
ent package consisted of file reviews; therefore, the violator
ucz7
ant
a :'
b. Receiving Stream. Crowders Creek
c. SOCBOC state one otiations: NA
d. Copy of MP Screen: Attached
e. Copy oft Limits Page in Permit: Attached
f D.. age: None documented

ATTACHMENT A
Fecal Colifomi Daily Maximum Permit Limit Violations
Date
July 10, 1997
July 25, 1997
July 31, 1997
September 25, 1997
October 16, 1997
Re ed Value Permit Limit
430/100 ml
460/100 ml
425/100 ml
485/100 ml
425/100 ml
400/100 md
400/100 ml
400/100 ml
400/100 rril
400/100 ml
BOD - Monthly Average lbsiday Permit Lirnit Violations
Date
May, 1997
JUly, 1997 -
October, 1997
Reported Value Permit Limit
389 lbs/day
518 lbs/day
441 lbs/day
340 lbs/day
340 lbs/day
306 lbs/dayl
BOD - Daily Maxirnuni lbs/day Permit Limit Violations
Date
July 31, 1997
October 16, 1997
Reported Value Permit Limit
938 lbs/day 680 lbsiday
642 lbs/day 612 lbsidayl
BOD - Monthly Average mg/I Permit Limit Violations*
Date
Apil, 1997
May, 1997
June, 1997
July, 1997
August, 1997
September, 1997
October, 1997
November, 1997
Reported Value Permit Limit
160 mg/1
186 me
246 mg/1
378 mg/1
173 me
236 mg/1
266 mv_il
166 mg/I
158 mg/1
158 mg/1
158 mg/1
158 mg/1
158 mg/1
158 mg/1
143 mg/I
143 ingil

BOD - Daily Maximum rugll Permit Limit Violations*
Date
June 13, 1997
June 27, 1997
July 10, 1997
July 31, 1997
September 25, 1997
October 16, 1997
October 22, 1997
October 30, 1997
Reported. Value
376 rngr1
330 mg/1
370 mg/1
370 mg/1
471 mg/1
351 rng/1
31.7 mgfl
350 mg/1
Permit Limit
317 mg/I
317 mg,/i
317 mg/1
317 mg/1
317 mg/1
285 mg/1'
285 mg/1
285 mg/1
Chronic Toxicity Permit Limit Violations
Date
May, 1997
June, 1997
July, 1997
August, 1997
September, 1997
October, 1997
November, 1997
Reporters Value
BAD TEST2
Fail @ 3%
Fail@3%
Fail @ 3%
BAD TEST'
Fail @3©/0
Fail @ 3%
Permit Limit
Pass @3%.
Pass @ 3%
Pass @ 3%
Pass @ 3%
Pass@3%
Pass @ 3%
Pass @ 3%
The permit limits ( mass/based and concentration lirnits for BOD changed on October 1, 1997.
2 Burlington Research documented that the September, 1997 chronic toxicity test failed to meet
Quality assurance criteria.
* Values for BOD concentration were rot reported on Monthly Monitoring Reports by CBP
Resources. BOD concentrations were calc ,laud as follows:
g/l = reported value in lbs/day
MGD x 8.34 lbs/gal

RECYCLINC. F0
January 2', 1998
Us
Mr. John Lesley
NC Division of Water Quality
919 N Main Street
Mooresville, NC 28115
Subject: Notice of Recommendation for Enforcement
CBP Resources WWTP
NPDES Permit No, NC0005011
Gaston County, NC
Dear ;i'ohn,
Gastonia Division
CBP Resources, Inc.
re wrtrt wta r, sparse to the January 8,1998 Notice of Recommendation. for
En .cement. "chile we do not dispute the facts that constitute the referenced violations,
we nexaeve that our ongoing efforts to achieve and maintain compliance and to eliminate
the direct disc►'are to Crowders Creek wei�g,h against the issuance of a penalty at this
time. We also believe that it would be in the best interest of all involved to discuss a
consent order with compliance schedule to address our facility's ongoing wastewater
situation and to provide for an acceptable timetable for the elimination of the discharge to
the creek.
As you are aware, our facility is in the process of making a connection to the City of
Gastonia's sewer system for our discharge, We have entered into a formal letter of intent
with the City and have agreed to the terms of our most recent NPDES permit renewal
which requires the elimination of our discharge to the creek by March 31, 1999, We have
been working diligently toward this connection and anticipate completion prior to the
permit deadline. We have and will spend considerable amounts of time and money on this
project. We believe we have shown good faith in our efforts to complete this task,
5533 S. Yor Rd. • Gastonia, NC 28052 • 704-864.9941 • Fax # [phone] • Direct Deal Number:

Page two
e have experienced so difficulties lties °ith our waste water treatment system in the past:
However, our monthly self monitoring data/report for December, 1998,showed
compliance.
n addition to the subject notice, lie recently received an Assessment of Civil Penalties fc r
earlier violations, We relieve it would be appropriate to deal with all our violations
ether and,in light of the strides that we have made toward compliance and our
ctm nt to connect to the City, we would like to enter a, consent older that will
address these issues.
We therefore request that you nut move fo and with the proposed enforcement
recommendation at this time and allow an opportunity for discussion regarding a consent
order.
Thank -you and should there be any questions, please advise.
'nvirortnentall araper

PerNo. NC000501 1
STATE OF NORTH CARO_INA.
DEPARTMENT OF ENVIRONMENT, HEALTH, 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,
CBP Resources, Inc.
s hereby authorized to discharge wastewater from a facility located at
Gastonia Division
US Highway 321
Gastonia
Gaston County
ing seaters designated as Crowders Creek in the Catawba River Basin
ordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I,
and IV hereof.
The permit shall become effective October 1, 1997
This permit and the authorization to discharge shall expire at midnight on March 31, 1999
Signed this day September 5, 199`7
A. Preston Howard, Jr.., P.E.. ector
Division of Water Quality
ByAuthority of the Environmental Management Commission

A.(1). EFFLUENT LIh IJA°I'IONS AND MONI1D ING 1tEQUll1
N1
FINAL„
During the period beginning on the etteclive dale of the permit anc;I lasting untif expiraliorrp the 1'
001. Such discharges shall be liflnI(ad and monitored by the l'errrritt c as slacc%fir d below:
EFFLUENT C AF ACTERIST
0
N
isolved Ox
Permit No, NC000501 1
torizcd to discharge: Irorlr aut all sepal nu
Iforrlhly
Averacn'
0.25 7
Drily
xir
•oe tbrta 1s13 lbsfd ry
7 6 ll shiny 252 II,a 3/ Liyn
wndcd l
esietue; 318 Ibex/day 7 a0 ILar'w/dray
180 Ibs/day 3F 0 It r31(tlay
NitrNO NO3 + 11{N)
a'l Phosphorus
xlcr
Ave
oily
0 rnl
Sample locations: E - Effluent, I - Influent, U - Upstream ighway 321, t - Downslre=arn •
be conducted weekly.
The pH shall not be less than 6.0 standard units r
than 9.0 standard ur
ChronicToxicity (Ceriodaphnia) P/F at 3%; August, November, February, and May;
and Monitoring Requirements Page.
There shall ill be no discharge of Ilaating solids or visible foam frr other dean trace arrrounls
taer ial perrr�rl conditions applicable to the subject facility are li,teacl ran I1rc Suoi l(anrerrl
ruM 0 N
rerll
cy..
G DFOU
ample
Types
Locatl
ous
cry
ly
cly
akly
ly
Of
order'
aosite
tor
Grab
Composite
Grab
Grab
fu U D
1.
l tr laway 65,4, Upstream and downstream nronilrorinq is Io
or Olio A.(3). on the Supplement la Effluerrl. Limit ions
ritaliorrs and Mondtorirre Rerluirerraerats rtue

Permit No. NC0005Q 11
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL Pt L I TAM- 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,
CBP Resources, Inc.
is hereby authorized to discharge wastewater from a facility located at
Gastonia Division
iJS Highway 321.
Gastonia
Gaston County
to receiving waters designated as Crowders Creek in the Catawba River Basin
in accordance with effluent limitations, rnonrtoring requh-en.eats, and other conditions set forth in
Parts I, II, and I11 hereof.
This permit shall become effective November 1, 1995
This permit and the authorization to discharge shall expire at midnight on September 30, 1996
Signed this day October 20, 1995
A. Preston Howard, Jr., P.E., Director
Division of Environmental Management
By Authority of the Environmental Management Comrnissian

1It�,NT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Du in the period beginning on the effective date of the permit and lasting until expiration, the
otttfall(s) serial number 001. Such discharges shall be limited and monitored by the permittee
1 111�ent C,hps i ii§.iics
Flow
BOD, 5 Day, 20 °C
NH3asN
Dissolved Oxygen
Total Suspended Residue
I=seal Coliform (geometric mean)
Oil and Grease
Total Nitrogen (NO2+N©3 TKN)
Total Phosphorus
Temperature, °C
Chronic Toxicity—
L k„s ld. ay
QI hnrgLiintti:.Li.o a
J.n115__(&.p e c i.f.y)
Mon. Avg., Daily Max Mon.,, A,yg. Deity Mrtx,
340
140
420
200
0.257 MGD
680 158 mg/I
280
840
400
rrnittec is authoriz
specified below:
M ©nitrs n_g8
Mg rs_m nt_
ErgniLgn.c.Y
Continuous
317 mg/I Weekly
Weekly
Weekly
Weekly
400 /100 ml Weekly
Weekly
Quarterly
Qu.uarterly
Weekly
Quarterly
* Sample locaEffluent, I - Influent, gl m Upstream tatT Tlwy 321, D - Downstream
monitoring is to he conducted three times per week during June, hilly, August, and September,
**Chronic Toxicity (Ceriodaphnia) PIE at 3%, August, November,. February, May, See Part, II
The, pH shall not he less than 6,(1 sltndard un
by grab sample.
There shall he no discharge of floa
g
g
mit No, NC00050
r1 ttr discharge from
T.yt?
Recorder
Composite
Composite
Grab
Composite
Grab
Grab
Composite
Composite
Grab
Composite
'Sa_rnple
Location
I or E
E
E
E
F
E
E
E
E,U,D
E
tt SC Hwy 654, pstream and Downstream
and once per week. daring the rest of the year
I, Condition E.
n 9.0 slrindard units and shall be monitored
r visible foam in other than trace amounts.
per week at the effluent

:MOLE FSFIa7_(.1'f:r4T"I"(1'LICITYTrIIiN(1 0 SF F-s145r10•r`(
NI'rwwkl72,1,66
(.:0nu111 y" 64ecklenh
NPR; NA
7010: 0.0
aessan
611'00111626/ik
County:Gaston
PP' 1,5
7010: 1.07
Frequency:
Seraisi
1R0
UWer:
F-naa .ioy; A
tiubb41444 ('[1134
4
IW('l iA:1 NA
All i Wail, Jan 14", WW1
NorWai ap: y'nodllc
NoaaCroop:
iegin; 1011/96 Frequency: ) Nele FPS 1^t1b my Aaf? N.n Nun('0mp1Singlo
Hegion: 61141) Suhhasln: C11).14
Special
i'4de,e
Penis car lint: 68"X;a upon ralue ('reiwdor's 7 rk i:hr hen 41'*1
7 /4' A Feb May A, up Nov Nuu(`un1)1: 5n1gkk
RO Suliaasin:("r1117
Spaces
r 11Jen.
97 l,:ad,
AO
94 Pass'
06 >100
07
00
07
I48
013
Foil
> 100(, a 1001
Pass
Pass
NO)
Fart
Pass
Paso W441iPaas
Fat
aloof
Pass
Pass
Puss
Pass
>100
N
Pao*
Fad foil Pass
a100
Pais
Pass
Pass
Pass
Pass
Foes
Pass
Puss .._ -_ F'a3ti <.. ._ Pass __. _.. Pons
Pass ..- -... Pass Pass ....,. »,_ Pasa
Pass --- —• Pass W— -- PASS --- a., Pass
Pass Pass Pass Faking
Fraquen y:f t?Wd "A.
ion: MR.(1 !iwlbbasin: YAFII1
04
95
06
97 11
11d
)4
H
al MI
Fl
41
4 11)11w1'eu
NO0025542)1001 vegnn:81enl5 Piagt>nmc7" )
(:aunty. C1anplu Region. MRO
PP:0,225 Spacial
7010: I5 1iVi'13 2 Order;
a
Aug Nov Non('oni.5ingk
Pass
05 M— Pass
Pass
97 Pass
943
Pass
Pass
Pass
Pass
Pass .... --- Paso
Pass .a._ ._. Pass
Pass -- -- Pass
Pablo Pass
N(IX)50117Ck)1 pegs
(: uunly'Cisstnn
NI'a 0:251
11'210: 1'S TOW
Pena tsar lino: 1P4a
1'rulk1a+neyt 12 PPP A lash May Aug Nrsv )5 Nnn C6mlrSingle
r, ta141f) 5uhhasin (71i17
Spacial
Orikr.
94 Fad Fat
96 FF4 Pass
041 Fuss Ki
07 Pa1s
041
Pass
Paws
Pass
Pass Pose
19v
rn4
Pass Pass
Pas: --a (sass
t ere Pad HP Fail Pass
Fall Use Lala Fall Fail Pass
(4('0012091/002 Ii
('ounsy; Merkknburg
NI': VAR
7(110: (10 {)h
I'crni 24 hr 1.C50 a:: 11101111 n
IJ96 I'r :Welncy: A
Region: hIRO Subhasin: (71334
Special
14n10,
1
Non("':1114)
A4
05
08 a 100
97
418
Gwlrla11k'tMna9)p,lam ,L lr peed I'nrani 241u 4) 1))) ac o •I1 ern, 11hd igrnh)
NI 919.16ll7/180 ❑elgm 1)4)7/9)4 p`napiency° 541W;INA Nam('omp.
(`.oussr,y; Meekkuhufg ttegion: Mat) Suhhawita cr374
r'IH:'VAH Specie'
)1"..r10: 0.0. IW73'Xr1: NA Bole•.,
94
OS
a4;
t17 a 1(17 > 100
60
aeafl >100
43irnslcal )ipaeis.Nlva, inr. 'Nernr 48hr l ('711an. Gm: 45"A rl.lnl
N(T)000S15I/1101 Ikgin:u0i195 isata taa r, Q 0 San Ape Jul Ott
l:'oumy: Cuban -us Region: MR0 Suhhasen: YAI)II
PP: 0.025 Specloi
7010:8,6 PNi'('XF1.0,45 Order.
NonCnmp:Single
le 94 xtlitpt
as It
06 .000
97 a100
96
harryvalle. 11eWT1' Pool Or lim::1411,
NC0044440/001 41.egio: k/1l0',.S Flregl.eoor (,l 104' © Mar 11rn Seer I ale
4°unniyt(yylan Regions MHO Sullhusin; cam
1'1 2.0 Special
71J10r 6, 1 IWCl1X,p°14 (Inge,
NonCoinp
05
AB
A/
98
Fail Pass
F1 )) Fad
Pass
Pass
68 01
Pass
1f
30.1 >100
NAM
>100
83
60
>100
Pass --- �- NA.'1.olo Puss --- Pe7s
Pass Paas -- Pass
P99a .•. _. Pass __. _.. Pass
Pasa Pass Pssal
41 Pau 1994 Oars Available
1 lidil-Nt);
11 14M I'enrdi Rcalei,,o,tnl 1 1 l" A.dinlnislm
Ileum a loisr month moiled '.910 Keraliving si
PP a I'ermilied flaw (146I)7 ll5('%, _ Issas -sal w
11ara Masson; 1 - Fansca1 Minn aV: - Csri¢)laplult.
14cp.untng Notation: -.. = Dais not re+pliredo NH - Noi
Fnvpleney = A4un'i(n)`ing lrrlpismeyr(
i:l l u5a ymn.rly nunioaring imr
P!F — Paas/FaiN 1111
p, (.'SV Chronic vslue; 1' M.nnaiity of $
ol`(Juancr Fa ably A1r1ivily 51.11.ns;
M- 11,1drrsonath
N . Newly 4ssued
"A, Sconnnoo illy, A. Annunli,y; (1WI)-(my when discharging, 1). Discontinued namarnring
ilia! ac) ng mael sw, :nr - i°a, lan, Ala, 4u1, (ha Nznd'unrp - Cut1011) 1'owpinmus°
Performed by 1)Wl2 Ailu1lic Tux einnup; at - pad test
11 _ Aci Iva but n.9 discharging; 1-14101z, data awallallk Inr monnll in ilueslinn f = C1Ra' saga
k)t
ling mass 1 c

EFFLUENT
NPDES PERMIT NO, DISCHARGE NO., C`� / MONTH
FACILITY NAME CLASS 1 COTY
OPERATOR IN RESPONSIBLE CHARGE (CtRC) / rt /)1 ,Jci 2c GRADE—j—v-- PHONE
CERTIFIED LABORATORIES (I)
CHECK BOX IF ORC HAS CHANGED PERSON COLLECTING SAa LES
Mail ORIGINAL and ONE COPY to,
ATTN: CENTRAL FILES
DI'1',OFENVIRONMENTAL MANAGEMENT
(SIGNATURE (?
F OPERATOR IN RESPONSIBLE CHAR E) /DATE/
BY THIS
SIGNATURE,
DEHNR
P.f}..BO% 29535 " I. CERTIFY THAT THLS REPORT IS
NC 27626 453 '
°tFc>rx MR-t.I
ACCURATE AND COMPLETE TO THE BEST OF MY KNOWL

Facility Status: (Please check one of the following)
Al] monitoring data and sampling frequencies meet perrnit requirements
All monitoring data and sampling frequencies do NOT meet permit requirements
Compliant
Noncompliant.
If the facility is noncompliant, please comment on corrective actions being taken in respect to equipment, operation, maintenance, etc.,
and a time table for improvements to be made.
"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."
Perminee Add
00010 Temperature
00076 Turbidity
00080 Color (Pt -Co)
00082 Color (ADMI)
00556
00600
00610
00625
00095 Conductivity 00630
00300 Dissolved Oxygen
00310 BOD5 00665
00340 COD 00720
00400 pH 00745
00530 Total Suspended 00927
Residue 00929
00545 Settleable Matter 00940
/27
Date
;/..; /VC '76/ r6
Phone Number
Pe itEpDace
PARAMETER CODES
Oil & Grease 00951
Total Nitrogen 01002
Ammonia Nitrogen
Total Kjeldhal 01027
Nitrogen
Nitrates/Nitrites 01032
01034
Total Phosphorous
Cyanide 01037
Total Sulfide 01042
Total Magnesium
Total Sodium 01045
Total Chloride 01051
Total Fluoride
Total Arsenic
Cadmium
Hexavalent Chromium
Chromium
Total Cobalt
Copper
Iron
Lead
01067 Nickel
01077 Silver
01092 Zinc
01105 Aluminum
01147 Total Selenium
31616 Fecal Coliform
32730 Total Phenolics
34235 Benzene
34481 Toluene
38260 MBAS
39516 PCBs
50050 Flow
Parameter Code assistance may obtained by calling the Water Quality Compliance Group at [phone], e,
50060 Total
Residual
Chlorine
71880 Formaldehyde
71900 Mercury
81551 Xylene
sion 581 or 534.
The monthly average for fecal colifonrn is to be reported as a GEOMETRIC rriean. Use only units designated in the reporting
facility's permit for reporting data.
* ORC must visit facility and document visitation of facility as required per 15A NCAC 8A .0202 (b) (5) (B),
7 /
** If signed by other than the pernuttee, delegation of signatory authority must be on file Ltia titestiiA
(2)(D).
15A NCAC 2B .0506 (b)

c I re -
'YEAR
CLASS / COLN Y
OPERATOR IN RESPONSIBLE CHAR3E (ORC) 137 el 7\ M 7Erli-,Is-G RAD PHONE
CERTIFIED LABORATORIES (1) 4 / &, c'‘-.ec A.. (2)
CHECK BOX IF ORC HAS CHANGED PERSO S) COLLECTING SAMPLES
EFFLUENT
NPDES PERMIT NO. /1/ 5-0 2/ DISCHARGE NO. 0 a ) MON
FACILITY NAME C(:) 4_se
Mail ORIGINAL and ONE COPY tO:
ATTN: CENTRAL FILF-S
DIV. OF ENVIRONMENTAL MANAGEMENT
DFHNR
P.O, BOX 29535
Enter Parameter Code
Above Name and UrbilS
Below
ERAGE
N1111'.
MLMUM
rab `G
Monthly Limit
DEN1 Form MR- l,1
(Rc,ised I
C'
x
NATURE OF OP RATOR IN RESPONSIBLE CHARGE)
BY THIS SIGNATURE, I CERTIFY THAT THIS REPORT IS
ACCURATE AND COMPLETE: TO THE BEST OF MY KNO

EFFLUENT �},
G 4© )1 DISCHARGE NCI. QQC) / M©NTH, / �`7
I±.pCILITY NAME © ,�V`Lp ._
r .s ^c�.S CLASS LL- C�7 TY' _
GE (ORC) /')rx YCi A 41. ]c A-L GRADE1V PHONE
PERSON S) COLLECTING SAMPLES J., "t
OPERATOR IN RESPONSIBLE CH
CERTIFIED LABORATORIES (I)
CHECK BOX IF ORC HAS CHANGED
I I I ORIGINAL and ONE COPY to:
A TTN: CENTRAL FILES
DIV. OF ENVIRONMENTAL MANAGEMENT J
DEHNR BY THIS SIGNATURE, I CERTIFY THATTHiS REPORT LS
P.O. BOX 29535 ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE.
EIGI3, NC Z1C+
(SIGRATURE OF OPERATOR LN RESPONSIBLE CHARGE)
Enter Parameter Cycle
Above Name and Units
Below
DEM Form MR-C.'!
(Rolled 12/94)
YEAR /790
Y 5' l 1 J
DA'

Facility Status: (Please check one of the following)
All monitoring data and sampling frequencies meet permit re ui
All monitoring data and sampling
If the facility is noncompliant, please cor
and a
table for improvements to be made.
u
ties do NOT meet permit requirement
on corrective actions being
Compliant
Noncompliant
n in respect to equipment, operation„ maintenance, etc,,
with..I certify, under penalty of law, that this document and all attachtnents were r
with a system designed to assure that qualifiedprepared under my direction or supervrsion in actor
a of d persons who personnel properly gather and evaluate the information submitted. 'Based on my dance
information of thesperson manage the system, or those persons directly responsible for gathering the information, the
red is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there one significantpenalties for submitting false information, including the possibility of fines and imprisonment for knowing „
violations.
Pe
A
s . /of
00010 Temperature
00076 Turbidity
00080 Color (Pt --Co)
00082 Color (ADM])
00556
00600
00610
00625
00095 Conductivity 00630
00300 Dissolved Oxygen
00310 BOD5 00665
00340 COD 00720
00400 pH 00745
00530 Total Suspended 00927
Residue 00929
00545 Settleable Matter 00940
PA KAnwrr R COD
Oil & Grease 00951 Total Fluoride
Total Nitrogen 0I002 Total Arsenic
Ammonia Nitrogen
Total Kjeldhal 01027 Cadmium
Nitrogen
Nitrates/Nitrites 01032 Nexavalent C
Total Phosphorous 01034 Chromium
Cyanide 01037 Total Cobalt
Total Sulfide 01042 Copper
Total 1vf agnes i u m
Total Sodium 01045 Iron
Total Chloride
o be reported
01051 Lead
Parameter Code assistance may obtained by calling the Water Quality Compliance
The monthly average for fecal colifor
facility's permit for reporting data.
* ORC must visit facility and document visitation of facility as
**If signed by other than the puttee, delegation of signatory
(2) (D),
0
01067 Nickel
01077 Silver
01 092 Zinc
01105 Aluminum
01147 Total Selenium
31616 Fecal Coliform
32730 Total Phenolics
34235 Benzene
3448I Toluene
38260 MBAS
39516 PCBs
50050 Flow
p. Date
50060 Total
Residual
Chlorine
71880
71900
81551
Group at [phone], extension 58
Formaldehyde
Mercury
Xylene
or 534,
GEOMETRIC mean. Use only units designated in the reporting
red 1 er 1.5A NCAC 8A .0202 (b) (5) (B).
ust be on file with the state per 15A NCAC 2B .0506 (b)

PERSON(
CLASS _ COUNTY
'.__ GRADE i PHONE
(2)'ir
COLLECTING SAMPLES
YEAR
IGNATURE OPERATOR IN RES ON; CHARGE) DATE
BY THLS SIGNATURE, I CERTIFY THAT THIS REPORT IS-
ACCURATE AND COMPLETE TO THE BEST OF MY-KNNOWLEDGE.
NPDES PERMIT NO,
FACILITY NAME
OPERATOR IN RESPONSIBLE CHARG
CERTIFIED LABORATORIES (1)
CHECK BOX IF ORC HAS CHANGED
Mali ORIGINAL and ONE COPY ID:
ATTN: CENTRAL FILES
DIV, OF ENVIRONMENTAL MANAGEMENT
DEHNR
P.O. BOX 29535
GH, NC
AVERAGE
MiAXIMUM
�UNI IUM
Grab (G)
Monthly Limit
EFFLUENT
DISCHARGE NO.0/ MONTH
ORC) /ham. L
Eater Parameter Code
Above Name and Units
Below

Facility Status: (Please check one of the following)
All monitoring data and sampling frequencies meet permit requirements
All monitoring data and sampling frequencies do NOT meet permit requirements
Compliant
Noncompliant
If the facility is noncompliant, please comment on corrective actions being taken in respect to equipment, o ration, maintenance etc,
and a time table for improvements to be made,
"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 rny
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. 1 am aware that there are significant
penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations,"
Per
Address
Permittee (Please rint o
Phone Number
Date
00010 Temperature
00076 Turbidity
00080 Color (Pt -Co)
00082 Color (ADIVII)
00556
00600
00610
00625
00095 Conductivity 00630
00300 Dissolved Oxygen
00310 BOD5 00665
00340 COD 00720
00400 pH 00745
00530 Total Suspended 00927
Residue 00929
00545 Settleable Matter 00940
PARAMETER CODES
Oil & Grease 00951 Total Fluoride
Total Nitrogen 01002 Total Arsenic
Ammonia Nitrogen
Total Kjeldhal 01027 Cadmium
Nitrogen
Nitrates/Nitrites 01032 Hexavalent Chromium
01034 Chromium
Total Phosphorous
Cyanide
Total Sulfide
Total Magnesium
Total Sodium
Total Chloride
01037 Total Cobalt
01042 Copper
01045 Iron
01051 Lead
01067 Nickel
01077 Silver
01092 Zinc
01105 Aluminum
01147 Total Selenium
31616 Fecal Coliforrn
32730 Total 'Phenolics
34235 Benzene
34481 Toluene
38260 MBAS
39516 PCBs
50050 Flow
Permit Exp, Date
50060 Total
Residual
Chlorine
71880
71900
81551
Formaldehyde
Mercury
Xylene
Parameter Code assistance may obtained by calling the Water Quality Compliance Group at [phone], extension 581 or 534.
The monthly average for fecal coliform
facility's permit for reporting data.
* ORC must visit facility and document
** If signed by other than the perrnittee,
(2) (D).
is to be reported as a GEOMETRIC mean. Use only units designated in the reporting
visitation of facility as required per 15A NCAC 8A .0202 (b) (5) (B).
delegation of sigridfory-authotjty must be on file with the state per 15A NCAC 2B .0506 (b)

NPDES PERMIT NO
FACILITY NAME C(' e
OPERATOR IN RESPONSIBLE CHARGE
CERTIFIED LABORATORIES (1)
CHECK BOX IF ORC HAS CHANGED
OF
Mail ORIGINAL anciONE--COPYlo-7,
Arrx, CENTRAL FILE.S
DIV, OF ENVIRONMENTAL MANAGEMENT
DEHNR
P.O. BOX 29535 SEP 1997
GH, NC 276
2
3 7C0
Co p. (C)
Monthly .Limit
DEM Form MR- I ,
(Ro,ised 1,9d)
(ORC)
EFFLUENT -
DISCHARGE NO. 00 MONTH V YEAR
CLASS -1-/— COUNTY' irrN,
41,1 AeC" GRADE -kJ"- PHONE ic/
(2) Z7.. rv.
PERSON(S) COLLECTING SAMPLES?,
Enter Parameter Code
Above Name and Unib
Below
9-C 0,3
27 o•
0,3
,----/
(SIG ATURE OF OPERATOR IN RESPONS LE CHARGE) D
BY THIS SIGNATURE, I CERTIFY THAT THIS REPORT LS
ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE.
03/C CT-3C •C).;75—(,.
„S
2,1 im1,
c.?
0

Facility Status: (Please check one of the following)
All monitoring data and sampling frequencies meet permit requirements
All monitoring data and sampling frequencies do NOT meet permit requirements
Compliant
Noncompliant
If the facility is noncompliant, please comment on corrective actions being taken in respect to equipment, operation, maintenance, etc.,
and a time table for improvements to be made..
"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."
Pe
3
Address
00010 Temperature
00076 Turbidity
00080 Color (Pt -Co)
00082 Color (ADNtI)
00556
00600
00610
00625
00095 Conductivity 00630
00300 Dissolved Oxygen
00310 BOD5 00665
00340 COD 00720
00400 pH 00745
00530 Total. Suspended 00927
Residue 00929
00545 Settleable Matter 00940
PA
Oil & Grease 00951
Total Nitrogen 01002
Ammonia Nitrogen
Total KjeIdhal 01027
Nitrogen
Nitrates/Nitrites 01032
01034
Total Phosphorous
Cyanide 01037
Total Sulfide 01042
Total Magnesium
Total Sodium 01045
Total Chloride 01051
P1
one
print or4ype
umber
ETFR CODE
Total Fluoride
Total Arsenic
Cadmium
Hexavalent Chromium
Chromium
Total Cobalt
Copper
Iron
Lead
Date
01067 Nickel
01077 Silver
01092 Zinc
01105 Aluminum
01 147 Total Selenium
31616 Fecal Colifottn
32730 Total Phenolics
34235 Benzene
34481 Toluene
38260 MBAS
3951.6 PCBs
50050 Flow
e 9
ermi Exp. Date
50060 Total
Residual
Chlorine
71880
71900
81551
Formaldehyde
Mercury
Xylene
Parameter Code assistance may obtained by calling the Water Quality Compliance Group at [phone], extension 581 or 534.
The monthly average for fecal coliform is to be reported as a GEOMETRIC me
facility's permit for reporting data,
* ORC must visit facility and docurnen
ion of facility as required
Use only units designated in the reporting
15A NCAC 8A ,0202 (b) (5) (B).
** if signeditt
by other than the permee, delegation of signatoryauthority must be on file with the state per 15A NCAC 28 .0506 (b)
(2) (D).

EFFLUENT
NPDES PERMIT NO. A/6- 0 o 6,50 /
FACILITY NAME C.
OPERATOR IN RESPONSIBLE CHARGE (ORC)
CERTIFIED LABORATORIES (1) 642'"
DISCHARGE NO, C) 0 1 MONTH
CLASS ITC°
elr. 76. JL GRADE ILT P ONE
CHECK BOX IF ORC HAS CHANGED PERSONS COLLECTING SAMPLES
Mail ORIGINAL, and ONE COPY to:
ATIN: CENTRAL FILES
D1V, OF EN VI R ONM EWA L MANAGEMENT
)EHNR OCT u 1997
P O. BOX 29535
LEIGH. NC 27
• FLO
16
17
18 3•0
kVERAGE
:MINT
G
Monthly Limit
DEM Form MR,
^,,.(sed I 2P94.)
tlo.
Enter ParameterParmeter Cuk
Above Name and Units
Below
c.'2
is
(SIGNATURE OF ERATOR IN RESPONSIBLE CHARGE)
BY THIS SIGNATURE, I CERTIFY THAT THIS REPORT IS
ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE.
YEAR /
DAT

Facility Status: (Please check one of the following)
All monitoring data and sampling frequencies meet permit requirements
Compliant
All .monitoring data and sampling frequencies do NOT meet perrrait requirements
If the facility is noncompliant, please comment on corrective actions being taken in respect to equipment, operation, maintenance, etc.,
and a time table for improvements to be made,
`1 t rtify, 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. 1 am aware that there are significant
penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations,"
00010 Temperature
00076 Turbidity
00080 Color (Pt -Co)
00082 Color (ADMI)
00095 Conductivity
00300 Dissolved Oxygen
00310 BOD5 00665
00340 COD 00720
00400 pH 00745
00530 Total Suspended 00927
Residue 00929
00545 Settleable Matter 00940
Parameter Code
Phone Number
PARAMETER CODES
00556 Oil & Grease 00951 Total Fluoride
00600 Total Nitrogen 01002 Total Arsenic
O0610 Ammonia Nitrogen
00625 Total Kjeldhal 01027 Cadmium
Nitrogen
00630 Nitrates/Nitrites 0I032 Hexavalent Chromium
01034 Chromium
Total Phosphorous
Cyanide 01037 Total Cobalt
Total Sulfide 01042 Copper
Total Magnesium
Total Sodium 01045 Iron
Total Chloride 01051 Lead
01067 Nickel
O1077 Silver
01092 Zinc
01105 Aluminum
01147 Total Selenium
31616 Fecal Coliforrn
32730 Total Phenolics
34235 Benzene
34481 Toluene
38260 MBAS
39516 PCBs
50050 Flow
50060 Total
Residual
Chlorine
71880
71900
81551
Formaldehyde
Mercury
Xylene
stance may obtained by calling the Water Quality Compliance Group at [phone], extension 581 or 534.
The monthly average for fecal coliforrrt is to be reported as a GEOMETRIC mean. Use only units designated in the reporting
facility's permit for reporting data.
* ORC must visit facility and document visitation of facility as required per 15A NCAC 8A .0202 (b) (5) (B).
** If signed by other than the permittee, delegation of s narciryCauthority must be on file with the state per 15A NCAC 2B .0506 (b)
(2) (D).

NPDES PERMIT NO,
FACILITY NAME C
OPERATOR IN RESPONSIBLE CHARGE
CERTIFIED LABORATORIES (I) C
CHECK BOX IF ORC HAS CHANGED
Mai] ORIGINAL and ONE COPY t©:- .
ATTN: CENTRAL FILES
DIV. OF ENVIRONMENTAL MANAGEMENT
DEHNR
P.O. BOX 29535
Ro LEIGH, NC 276
,Eater Parameter` Code
Above Willie and Units
Below
DE_ i Farm MR. i,
€ R:ti i,>ec1 1 `I94)
10
EFFLUENT
DISCHARGE NO, C O) M NTH
CLASS + L- COUi
S GRADE �r � PHONE
(2) q;-r-.J
PERSO
x
ECTING SAMPLES
(SIGNATURE OF OPERATOR I i RFSPONSI LE CHARGE)
BY THLS SIGNATURE, I CERTIFY THAT THIS REPORT LS
ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE.

Facility Status: (Please check one of the following)
All monitoring data and sampling frequencies meet permit requirements
All monitoring data and sampling frequencies do NOT meet permit requirements
Compliant
Noncompliant
If the facility is noncompliant, please comment on corrective actions being taken in respect to equipment, operation, maintenance, etc.,
and a time table for improvements to be made.
"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 imprisonrnent for knowing violations."
F, 0)-(_
S75-3 3
Permittee Address
00010 Temperature
00076 Turbidity
00080 Color (Pt -Co)
00082 Color (ADMI)
00556
00600
00610
00625
00095 Conductivity 00630
00300 Dissolved Oxygen
00310 BOD5 00665
80340 COD 00720
00400 pi-1 00745
00530 Total Suspended 00927
Residue 00929
00545 Settleable Matter 00940
Oil & Grease
Total Nitrogen
Permittee (Please print or sype)
S ignatur
of Permittee**
1 _ -
Phone Number
PAEAMETER CODES
00951 Total Fluoride
01002 Total Arsenic
Ammonia Nitrogen
Total Kjeldhal 01027
Nitrogen
Nitrates/Nitrites 01032
01034
Total Phosphorous
Cyanide 01037
Total Sulfide 01042
Total Magnesium
Total Sodium 01045
Total Chloride 01051
Cadmium
Hexavalent Chromium
Chromium
Total Cobalt
Copper
Iron
Lead
01067 Nickel
01077 Silver
01092 Zinc
01105 Aluminum
Date
01147 Total Selenium
31616 Fecal Coliform
32730 Total Phenolics
34235 Benzene
34481 Toluene
38260 MBAS
39516 PCBs
50050 Flow
nnit Exp. Date
50060 Total
Residual
Chlorine
71880
71900
81551
Formaldehyde
Mercury
X ylene
Parameter Code assistance may obtained by calling the Water Quality Compliance Group at [phone], extension 581 or 534.
The monthly average for fecal coliform is to be reported as a GEOMETRIC mean. Use only units designated in the reporting
facility's permit for reporting data_
* ORC must visit facility and document visitation of facility as required per 15A NCAC 8A ,0202 (b) (5) (B).
** If signed by other than the perrnittee, delegation of signatory authority must be on file with the state per 15A NCAC 2B .0506 (b)
(2) (D).

LINGTON
EARCH
October 1, 1997
Ms. Kristie Robeson
NC Division of Environmental Management
Environmental Services Branch
Aquatic Survey and Toxicology Unit
4401 Reedy Creek Road
Raleigh, North Carolina 27607
Re: CBP Resources (NC0005011)
September 24, 1997 Toxicity Test
Dear Ms. Robeson:
Aquatic Bioassay Testing
Aquatic Toxicity Reduction Evaluations
Chemical Product Environment Assessment4
'4PDES Testing
Reporting S. Data Handling Services
am writing this letter to inform you that CBP Resouces will not submit their Pass/Fail
chronic toxicity test on time for the month of September. The reason for the delay is that the
chronic test result was invalid due to greater than 20% males controls. Burlington Research
initiated this test September 24, 1997 and terminated the test on September 30, 1997, The
samples for this test were collected 9/22-23/97 and 9/25-26/97 for the first and second
samples, respectively. The test has been rescheduled for October 8, 1997. I regret any inconvenience this has caused you. If you have any questions please call me 910-570-4661
ext. 289.
Sincerely,
BUR INGTON RESEARCH, INC.
cT
C. Baummer III
Biomonitoring Laboratory Manager
cc. Van Jones - CBP Resources
1202 Perricnt S1re N TeL .`:910) 570-4661 . Fax (910,)

NPDES PERMIT Na /VC 0
FACILITY NAME ce /
OPERATOR IN RESPONSIBLE CH
CERTIFIED LABORATORIES (i)
CHECK .BOX IF ORC HAS CHANGED
Mail ORIGINAL and ONE COPY 6:
ATTN: CENTRAL FILES
DIV. OF ENVIRONMENTAL MANAGEMENT
DEHNR
PO. BOX 29535
RAI..EIOIi, NC 276
DE:M Fora MR-!.!
iilc ised I:I1" riy
i/
E (OR
EFFLUENT
DISCHARGE Na'C / MONTH OC:/u YEAR / 9 'i
CLASS COUNTY C1 i
tilr , s . GRAD) PHONE /76)(
ERSO
x
S)CO
ECTING SAMPLES. -*/
(SIGNATURE F OPERATOR IN RESPONSIBLE CHARGE)
BY THIS SIGNATURE, I CERTIFY THAT THIS REPORT LS
ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE.

Facility Status: (Please check one of the following)
All monitoring data and sampling frequencies meet permit requirements
All monitoring data and sampling frequencies do NOT meet permit requirements
Noncompliant
If the facility is noncompliant, please comment on corrective actions being taken in respect to equipment, operation, maintenance, etc,,
and a time table for improvements to be made.
"I certify, under penalty of law that this documentand 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."
F b o/12- o!,
Permittee (Please print o
Signature of P
00010 Temperature
00076 Turbidity
00080 Color (Pt -Co)
00082 Color (ADMI)
00610
00625
00095 Conductivity 00630
00300 Dissolved Oxygen
00310 BOD5 00665
00340 COD 00720
00400 pH 00745
00530 Total Suspended 00927
Residue 00929
00545 Settleable Matter 00940
00556 Oil & Grease
00600 Total Nitrogen
PARAMETER CODES
00951 Total Fluoride
01002 Total Arsenic
Ammonia Nitrogen
Total Kjeldhal 01027 Cadmium
Nitrogen
Nitrates/Nitrites 01032 Hexavalent Chromium
01034 Chromium
Total Phosphorous
Cyanide 01037 Total Cobalt.
Total Sulfide 0I042 Copper
Total Magnesium
Total Sodium 01045 Iron
Total Chloride 01051 Lead
01067 Nickel
01077 Silver
01092. Zinc
01I05 Aluminum
01147 Total Selenium
31616 Fecal Coliform
32730 Total Phenolics
34235 Benzene
34481 Toluene
38260 MBAS_
39516 PCBs
50050 Flow
50060 Total
Residual
Chlorine
71880
71900
81551
Formaldehyde
Mercury
Xylene
Parameter Code assistance may obtained by calling the Water Quality Compliance Group at [phone], extension 581 or 534.
The monthly average for fecal colifo
facility's permit for reporting data
* ORC must visit facility and docume
" If signed by other than the permits
(2) (D).
a GEOMERIC mean. Use only units designated in the reporting
visitation of facility as required per 15A NCAC 8A .0202 (b) (5) (B).
L5 I '7 0
delegation of signatory authority must be on file with the state per 15A NCAC 2B .0506 (b)

EFFLUENT
NPDES PERN1IT NO. /V C._ lap o 3-c ii, DISCHARGE NO. C C. / MONTH ''''n- YE
FAcarry NAME r /3 I-3 Az 56° c-r-r--2-s - Cr-- /6° ;(‘-- CLASS COUNTy. '
OPERATOR IN RESPONSIBLE CHARGE (0V)/,21r, LI i 111 ---)77-4-1-S GRADEj PHONE F-‘ CERTIFIED LABORATORIES (1) r its: 0, 40.-C. ,,, lf, S h'1% (2)
CHECK BOX IF ORC HAS CHANGED PERSQN(S)2OLLECT1NU SA
Mail ORIGINAL and ONE COPY to:
ATTN: CENTRAL:FBI-ES :
DIV. OF ENVIRONMENTAL MANAGEMENT
DEHNR
P.O. BOX 29535
NC V6
51
DEM FQ1-rn, MR-
R.viced 20,94)
ecio to c3ec,
Ruiir Parameter Code
Above Name 40 Units
Below
(SIGNATURE OF 0 -RATO. IN RESPONSIBLE CHARGE) .DA
BY THIS SIGNATURE I CERTIFY THAT THIS. REPORT IS
ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE.
./.1:/141,47,!

Facility Status: (Please check one of the following)
All monitoring data and sampling frequencies meet permit requirements
.All monitoring data and sampling frequencies do NOT meet permit requirements
and a Larne table for improvements to be made.
Compliant
Noncomph,
If the facility is noncompliant, please comment on corrective actions being taken in respect to equipment, operation, maintenance, etc,
"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 and belief, true, accurate, and complete. 1 arra aware that there are significant
penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations."
Permittee (Please print or
'...":"
Signamre Pe
YGr ic 0,/
Permirtee Address
Phone Nu
00010 Temperature
00076 Turbidity
00080 Color (Pt -Co)
00082 Color (ADMI)
00556
00600
00610
00625
00095 Conductivity 00630
00300 Dissolved Oxygen
00310 BOD5 00665
00340 COD 00720
00400 pH 00745
00530 Total Suspended 00927
Residue 00929 Total Sodium
00545 Settleable Matter 00940 Total Chloride
Parameter Code assistance may ob
PA
Oil & Grease 00951
Total Nitrogen 01002
Ammonia Nitrogen
Total Kjeldhal 01027
Nitrogen
Nitrates/Nitrites 01032
01034
Total Phosphorous
Cyanide 01037
Total Sulfide 01042
Total Magnesiu
R CODES
Total Fluoride
Total Arsenic
Cadmium
Hexavalent Chromium
Chromium
Total Cobalt
Copper
01045 Iron
01051 Lead
01067 Nickel
01077 Silver
01092 Zinc
01105 Aluminum
01147 Total Selenium
31616 Fecal Caliform
32730 Total Phenolics
34235 Benzene
34481 Toluene
38260 MBAS
39516 PCBs
50050 Flow
3 3/
Permit Exp. Date
50060 Total
Residual
Chlorine
71880
71900
81551
Formaldehyde
Mercury
X ylene
tained by calling the Water Quality Compliance Group at [phone], extension 581 or 534,
The monthly average for fecal colifoma is to be reported as a GEOMETRIC mean. Use only units designated in the reporting
facility's permit for reporting data.
* ORC must visit facility and documentvisitation of facility as required per 15A NCAC 8A .0202 (b) (5) (B).
(2) (D),
** If signed by other than the per -mince, delegation of signatory authority must be on file with the state per 15A NCAC 28 .0506 (b)

•
Violator
©r Farr #
28052
Chief Review
2 04/97
2/I t` 97
00.00
21.30
v Due By
Region
County
Remission Request:
Enf, Conf. Date:
Remission Amount:
Enf Conf Green:
Maj/Min
Subbasin
f NIRO
2
onM
30837
Gaston
Staff Review Complete
FAU Supervisor Review
Section Chief Review
Notification to appear
before EMC received:
EMC Hears Case:
EMC Remmision
Arno unt:
:ion Superior Court
Com
nts
Petition in ©AH:
Penalty
Withdrawn
Collection:
Injunction:
01/9
Total Paid:
Case Closed

ber
00 Violator
NC0005011
or Farm #
128052
ce Date o • in Date
or Review
of Review
--CEP Resources
WTP
Region '
County
109/05/96
10/09/9 i
Remission, Request.
Enf. Corn. Date;
Remission Amount:
Ent. Con f Green:
oa
appea
Maj/Min
Subbasin
MR0
2
onM
[030837
Gaston
Staff Review Complete
EAU Supervisor Review
Section Chief Review
©re EPIC received:
EMC Hears Case:
EMC Rernmision
Amount:
Comments
10/1.1 /9'6
Petition in OAH:
Penalty
Withdrawn
Collection;
Injunction:
Total Paid:
ase Closed
$4,734.30
03 ' l 9/97

INC0005011
53 SOUTH YORK HI�
ASTONIA
ce Date Lo
Violator
ar Farrn #
28052
in Date
e Supervisor Revi
ection Chief Revi
SOURCES
Region
County
10I194 Remission Request:
ffOlcl Enf. Conf. Date:
500.00 Remission Amount:
'0.00 Enf Conf Green:
Noatia n to appear
before EMC received:
yDueBy:
Pa nt Remission Petition
Settlement Collection Superior Court
Min
MRO
Subbasin
Mm.n/NonM
30837
GASTON
Staff Review Complete
EAU Supervisor Review
Section Chief Review
8/94
Comments
Petition in PAH::
Penalty
Wi thdrawn
Collection:
Injunction:
Total Paid:
Case Closed

STATE OF NORTH CAROLINA NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
COUNTY OF GASTON
IN THE MATTER OF
CBP RESOURCES, INC.
FOR VIOLATIONS OF:
NPDES PERMIT
NO. NC0005011
AN➢ NORTH CAROLINA GENERAL )
STATUTE 143-215.1 (a) (6)
File No. LV
FINDINGS AND DECISIONS
AND ASSESSMENT
OF CIVIL PENALTIES
Acting pursuant to North Carolina General Statutes (G.S.)
143-215.6A, I, A. Preston Howard, Jr., P.E., Director of the
Division of Water Quality (DWQ), make the following:
1.
FINDINGS OF FACT:
A. CBP Resources, Inc. (the Company) i a corporation
organized and existing under the laws of the State of
North Carolina.
B. The Company operates a 0.257 MGD wastewater treatment
plant at Gastonia, North Carolina, which is located in
Gaston County.
C. The Company was issued NP➢ES Permit No. NC0005611 on
October 20, 1995, effective November 1, 1995, with an
expiration date of September 30, 1996.
D. Said permit contains the following relevant dailyµ
maximum, monthly average, and chronic toxicity effluent
limitations:
Parameter
Limitation Units
Daily Max/Monthly Avg.
Ammonia as N
Fecal Coliform
HOD
Flow
Chronic Toxicity
280 / 140
400 / no l mit
NA / 340
NA / 0.257
*Quarterly @ 3%
lbs/day
#/100 ml
ibs/day
MGD
Pass/Fail
* Monitoring Frequency reverts to monthly after a single test
failure.

State of North Carolina
• Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
December 16, 1997
CER1°lFthD MAIL
RETURN RECEIPT REQUESTED
E. R. Glberding, Vice President
Carolina By -Products Resources
5533 South York Road
Gastonia, NC 28052
SUBJECT: Assessment of Civil Penalties for Violation(s) of
N.C. General Statute(s) 143-215.1(a)(6)
CBP Resources, Inc.
Gaston County
File No. LV 97-029
NPDES Perrnit No. NC0005011
Dear Mr. Olberding:
This letter transmits notice of a civil penalty assessed against CBP Resources, Inc. in the
amount of $11,091.30, including $291,30 in enforcement costs.
Attached is a copy of the assessment document explaining this penalty. This action was
taken under the authority vested in me pursuant to delegation provided by the Secretary of the
Department of Environment and Natural Resources. Any continuing violation(s) may be the
subject of a new enforcement action, including an additional penalty.
Within thirty days of receipt of this notice, you must do one of the following:
1. Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environment
and Natural Resources (do not include waiver form). Payment of the penalty will
not foreclose further enforcement action for any continuing or new vioiati©n(s).
Please submit payment to the attention of:
Mr. Steve W. Tedder
Water Quality Section Chief
P.O. Box 29535
Raleigh, North Carolina 27626-0535
OR
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

2. Submit a written request for remission or mitigation including a
detailed justification for such request:
A request for remission or mitigation is limited to consideration of the
reasonableness of the amount of the penalty and is not the proper procedure for
contesting the accuracy of any of the statements contained in the assessment
letter. Because a remission request forecloses the option of an administrative
hearing, such a request must be accompanied by a waiver of your right to an
administrative hearing and a stipulation that there are no factual or legal issues in
dispute. You must execute and return to this office the attached waiver and
stipulation form and a detailed statement which you believe establishes whether:
(a) one or more of the civil penalty assessment factors in G.S. 143B-
282.1(b) were wrongfully applied to the detriment of the petitioner;
(b) the violator promptly abated continuing environmental damage resulting
from the violation;
(c) the violation was inadvertent or a result of an accident;
(d) the violator had been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining
necessary remedial actions.
Please submit this information to the attention of:
Mr. Steve W. Tedder
Water Quality Section. Chief
Division of Water Quality
P.O. Box 29535
Raleigh, North Carolina 27626-0535
QR
Submit a written request for an administrative hearing:
If you wish to contest any statement in this assessment letter, you must request
an administrative hearing. This request must be in the form of a written petition
to the Office of Administrative Hearings and must conform to Chapter 150B of
the North Carolina. General Statutes. You must
File your original petition with the
Office of Administrative Hearings
P.O. Drawer 27447
Raleigh, North Carolina 27611-7447
and
Mail or hand -deliver a copy of the petition to
Mr. Richard B. Whisnant
Registered Agent
Department of Environment and Natural. Resources
P.O. Box 27687
Raleigh, North Carolina 27611-7687

Failure to exercise one of the options above within thi days, as evidenced by a date
stamp (not a postmark) indicating when we received your respose, will result in this matter
being referred to the Attorney eyGeneral's Office with a request to initiate a civil action to collect
the penalty Please be advised that additional assessments may be levied for violations which
occur after the review period of this assessment:
If you have any questions, please contact Bob Sledge al
233.
Sincerely,
A. Preston Ho
ATFAC
l
cc .: _ ents
Compliance nforce nt Filewi attachments
Central Files wit attachment
Public Information ee att ents
083, extension

STATE OF NORTH CAROLINA
COUNTY OF GASTON
IN THE MATTER OF
CBP RESOURCES, INC.
FOR VIOLATIONS OF:
NPDES PERMIT
NO. NC0005011
AND NORTH CAROLINA GENERAL )
STATUTE 143-215.1(a)(6) )
NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
File No. LV 97-029
FINDINGS AND DECISIONS
AND ASSESSMENT
OF CIVIL PENALTIES
Acting pursuant to North Carolina General Statutes (G.S.)
143-215.6A, I, A. Preston Howard, Jr., P.E., Director of the
Division of Water Quality (DWQ), make the following:
1.
FINDINGS OF FACT:
A. CBP Resources, Inc. (the Company) is a corporation
organized and existing under the laws of the State of
North Carolina.
B. The Company operates a 0.257 MGD wastewater treatment
plant at Gastonia, North Carolina, which is located in
Gaston County.
C. The Company was issued NPDES Permit No. NC0005011 on
October 20, 1995, effective November 1, 1995, with an
expiration date of September 30, 1996.
D. Said permit contains the following relevant daily
maximum, monthly average, and chronic toxicity effluent
limitations:
Parameter
Limitation Units
Daily Max/Monthly Avg.
Ammonia as N
Fecal Coliform
BOD
Flow
Chronic Toxicity
280 / 140
400 / no limit
NA / 340
NA / 0.257
*Quarterly @ 3%
lbs/day
4/100 ml
lbs/day
MGD
Pass/Fail
Monitoring Frequency reverts to monthly after a single test
failure.

Findings and Decisions
Page 2
E. Monthly self -monitoring reports for the period from
July, 1996 through March, 1997 have revealed the
following exceedances of the above -cited permit
effluent limits: (See Attachment A)
F. Notices of Violation concerning the monthly average
permit limitation violations and chronic toxicity
violations at the subject plant were sent to the
Company by DWQ's Mooresville Regional Office,
None r.F' the ,zhove-r-_ited exceedances of the permit
effluent limitations were the result of a bypass or
power failure at the plant as defined in the permit.
H. The Company's prior record of compliance with programs
over which the Environmental Management Commission has
regulatory authority is as follows:
The Company paid a civil penalty assessment of
$4,734.30 (Case No. LV 96-030) on March 19, 1997. A
civil penalty was assessed for $500 (Case No. LR 94-02)
on June 3, 1994. The penalty was paid on June 29,
1994. In July, 1988, the Company (then named Carolina
and Southern Processing Company) was assessed a civil
penalty following a breech in a wastewater storage
lagoon and. subsequent fish kill in Crowders Creek
(details of the enforcement are not available in the
Regional Office files). Penalties were paid in full
plus the cost of fish replacement.
1. The cost to the State of the enforcement procedures in
this matter totaled $ .91.30
Based upon the above Findings of Fact, I make the following:
II. CONCLUSIONS OF LAW:
A. The Company is a "person" within the meaning of G.S.
143-212(4).
B. NPDES Permit No. NC0005011 is required by G.S. 143-
215.1.
C. The effluent limitations contained in the. subject
permit are terms, conditions, or requirements of said.
permit.

Findings and Decisions
Page 3
D. The Company violated. G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on one (1) occasion during July,
1996 in the manner and to the extent described in
Attachment A, when the permittee permitted waste to be
dischargedinto the waters of the State in violation of
the monthly average permitted effluent limit for
Ammonia as Nitrogen.
E. The Company violated G.S. 143-215.1(a) (6) and NPDES
99.77.4t o. N7n0flF,01.1 n four (a\ occasions cThrincr JuTv,
1996 in the manner and to the extent described in
Attachment A, when the permittee permitted waste to be
discharged into the waters of the State in violation of
the daily maximum. permitted effluent limit for Ammonia
as Nitrogen.
F. The Company violated G.S. 143- 15.1(a) (6) and NPDES
Permit No. NC0005011 on twenty-five (25) occasions
during August, 1996 through March, 1997 in the manner
and to the extent described in Attachment A, when the
permittee permitted waste to be discharged into the
waters of the State in violation of the daily maximum
permitted effluent limit for Fecal Coliform.
G. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on one (1) occasion during
February, 1997 in the manner and to the extent
described in Attachment A, when the permittee permitted
waste to be discharged into the waters of the State in
violation of the monthly average permitted effluent
limit for BCD.
H. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on one (1) occasion during
February, 1997 in the manner and to the extent
described in Attachment A, when the permittee permitted
waste to be discharged into the waters of the State in
violation of the monthly average permitted effluent
limit for Flow.
1. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on two (2) occasions during
September and November, 1996 in the manner and to the
extent described in Attachment A, when the permittee
permitted waste to be discharged into the waters of the
State in violation of the permitted effluent limit for
Chronic Toxicity.

Findings and Decisions
Page 4
J. General Statute 143 -215.6A(a) provides that a civil
penalty of net more than ten thousand dollars per
violation may be assessed against a person who violates
or fails to act in accordance with theterms,
conditions, or requirements of a permit required by
.S. 143-215.1.
K. The State's enforcement costs in this matter may be
assessed against the Company pursuant. to G.S.
215.3(a)(9) and G.S. 143B -282.1(b0(8).
L. The Director, Division of Water Quality, pursuant to
delegation provided for by G.S. 14 -215.6A(h), has the
authority to assess civil penalties.
Based upon the above Findings mf Fact and Conclusions 0
Law 7 make the toloowir.
III. DECISION:
Accordingly, the Company is hereby assessed a civil penal
of:
For 2, of the one (I) violation of
C.S. 143 -219.1(a)(6) and NEDES Permit
No. NC0005011, by discharging waste into
the waters of the State in violation cf
permit monthly average effluent limit
for Aroronia as Nitrogen.
For 19 of four (4) violations of G.S.
143 -215.1(a)(6) and N2DES Permit No.
NC0005011, by discharging waste into the
waters of the State in violation of
daily maximum effluent limit for Ammonia
as Nitrogen.
e
Fi
Fr of wenty five (25) violations
of G.S. 143 -215.1(a)(B) and NEDFS Permit
No. NO0005011, by discharging waste into
the waters of the State in violation of
permit daily maximum effluent limit for
Fecal Coliform.

DIVISION F WATER OVA.
b S1ed. e
d Bridge
SUBJECT:di D pages
Enclosed please tnd the two modified en oree zntpackage,P es (page 5 of the Harbor
Estates and page
r assis ,v ee
of the CBP Fwhich you requested. Contact me if you need my

DIVISION OF 4 VATERQUALITY
August 6, 1997
TO: Kent Wiggins
FROM:
THROUGH.
PREP 4
SUBJECT:
CT:
Barbara Christian
Rex Gleason
Jahn Lesley >#..
Fast Track Enforcement
Violation of NCGS 1 3- 5.1 a){6 and
NPDES Permit No.NCD511
CBP Resources WWTP
Gaston County, NC
Attached is an enforcement report which details violations of NPDES Permit No,
NC0 05 11 and NCGS "1 3a 15.1 a 1. The Company does not dispute the violations as stated
in their response to the Notice of Recommendation for Enforcement, Although the inclusion of
the violations f"or July, 1996 may exceed the 1 -month window, this Office feels the violations
are serious enough to be included for the Director's consideration,
The cor rp .ny has moved rather slowly in taking steps te discharge. This
Office recommends penalties sufficient to convince the Company that an expeditious tie-in to the
City of Gastonia collection system would be in their best financial interest:
If you have questions or requite additional info ation please contact John or me,
Attachients

Findings and Decisions
Page 2
E. Monthly self -monitoring reports for the period_from
July, 1996 through March, 1997 have revealed the
following exceedances of the above -cited permit
effluent limits: (See Attachment A)
F. Notices of Violation concerning the monthly average
permit limitation violations and chronic toxicity
violations at the subject plant were sent to the
Company by DWQ's Mooresville Regional Office.
G. None of the above -cited exceedances of the permit
effluent limitations were the result of a bypass or
power failure at the plant as defined in the permit.
H. The Company's prior record of compliance with programs
over which the Environmental Management Commission has
regulatory authority is as follows:
The Company paid a civil penalty assessment of
$4,734.30 (Case No. LV 96-030) on March 19, 1997. A
civil penalty was assessed for $500 (Case No. LR 94-02)
on June 3, 1994. The penalty was paid on June 29,
1994. In July, 1988, the Company (then named Carolina
and Southern Processing Company) was assessed a civil
penalty following a breech in a wastewater storage
lagoon and subsequent fish kill in Crowders Creek
(details of the enforcement are not available in the
Regional Office files). Penalties were paid in full
plus th cost of fish replacement. ‘,2(5 K-41
cz \c-: -61 4,1 ,
The cost to the State of the enforcement procedures inl 9,
this matter totaled $291.30
Based upon the above Findings of Fact, 1 make the following:
I.I. CONCLUSIONS OF LAW:
A. The Company is a "person" within the :meaning of G.S.
143-212(4).
B. NPDES Permit No. NC0005O11 is required by G.S. 143-
215.1.
C. The effluent limitations contained in the subject
permit are terms, conditions, or requirements of said
permit.

Findings and Decisions
Page 3
D. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on one (1) occasion during July,
1996 in the manner and to the extent described in
Attachment A, when the permittee permitted waste to be
discharged into the waters of the State in violation of
the monthly average permitted effluent limit for
Ammonia as Nitrogen.
E. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on four (4) occasions during July,
1996 in the manner and to the extent described in
Attachment A, when the permittee permitted waste to be
discharged into the waters of the State in violation of
the daily maximum permitted effluent limit for Arnmonia
as Nitrogen.
F. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on twenty-five (25) occasions
during August, 1996 through March, 1997 in the manner
and to the extent described in Attachment A, when the
permittee permitted waste to be discharged into the
waters of the State in violation of the daily maximum
permittedeffluent limit for Fecal Coliform.
G. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on one (1) occasion during
February, 1997 in the manner and to the extent
described in Attachment A, when the permittee permitted
waste to be discharged into the waters of the State in
violation of the monthly average permitted effluent
limit for BCD.
H. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on one (1) occasion during
February, 1997 in the manner and to the extent
described in Attachment A, when the permittee permitted
waste to be discharged into the waters of the State in
violation of the monthly average permitted effluent
limit for Flow.
1. The Company violated G.S. 143-215.1(2)(6) and NPDES
Permit No. NC0005011 on two (2) occasions during
September and November, 1996 in the manner and to the
extent described in Attachment A, when the permittee
permitted waste to be discharged into the waters of the
State in violation of the permitted effluent limit for
Chronic Toxicity.

Findings end Decisions
Page
29
For
the ',1) violation c
1-11 1()and NEDED Permit
1C t 0 : 11 1 , by discha ging waste into
the waters of the Stake in violation of
permit it t.h s av age luent 1imNt
for BCD,
For
.S. 1 3-
No. NO0005
the watrs
permit for
for Flow.
the one 1} 'viclticn
' ) and NPDES Permit
b discharging
he State in violet
average effluent lim
For two vi 1
14 3-2 5 1 , and NDD S
005011,, by dicharin
tors of the State in;
permit affluent limit for
No ica t
TOTAL V
percent
authorised
Enforce
TOTAL_ 0
PENALTY, Which i
the maximum penalt1'
143-215,
costs.
7T DUE

State of North Carolina
Department of Environment
• and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Li Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
March 19, 1998
CER1IE1bD MAIL
RETURN RECEIPT REQUESTED
E.R. Olberding, Vice President
CBP Resources, Inc.
5533 South York Road
Gastonia, North Carolina 28052
SUBJECT: Assessment of Civil Penalties for Violation(s) of
N.C. General Statute(s) 143-215.1(a)(6)
CBP Resources, Inc.
Gastonia Division
Gaston County
File No. LM 98-002
NPDES Permit No. NC0005011
Dear Mr. Olberdin
This letter transmits notice of a civil penalty assessed against CBP Resources, Inc. in the
amount of $18,672.80, including $297.80 in enforcement costs.
Attached is a copy of the assessment document explaining this penalty. This action was
taken under the authority vested in me pursuant to delegation provided by the Secretary of the
Department of Environment and Natural Resources and the director of the Division of Water
Quality. Any continuing violation(s) may be the subject of a new enforcement action, including an
additional penalty.
Within thirty days of receipt of this notice, you must do one of the following:
1. Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environment
and Natural Resources (do not include waiverform). Payment of the penalty will
not foreclose further enforcement action for any continuing or new violation(s).
Please submit payment to the attention of:
Water Quality Section Chief
Division of Water Quality
P.O. Box 29535
Raleigh, North Carolina 27626-0535
o_R
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Failure to exercise one of the options above within thirty days, as evidenced by a date stamp
(not a postmark) indicating when we received your response, will result in this matter being referred to
the Attorney General's Office with a request to initiate a civil action to collect the penalty. Please e be
advised that additional assessments may be levied for violations which occur after the review period of
this assessment.
If you have any questions, please contact , Don Safrit Assistant Chief for Point Sources at
(919)-,, extension 519.
ATTAC
Sincerely,
A. Preston Howard, Jr, P.E.
Regional Supervisor v/ attachments
CompliancefEnforcement File w/ attachments
Central Files wir attachments
Public Information Office w/ attachments

2 . Submit a written request for remission or mitigation including a detailed
justification for such request:
A request for remission or mitigation is limited to consideration of the reasonableness of
the arnount of the penalty and is not the proper procedure for contesting the accuracy of
any of the statements contained in the assessment letter. Because a remission request
forecloses the option of an administrative hearing, such a request must be accompanied
by a waiver of your right to an administrative hearing and a stipulation that there are no
factual or legal issues in dispute. You must execute and return to this office the attached
waiver and stipulation form and a detailed statement which you believe establishes
whether:
(a) one or more of the civil penalty assessment factors in G.S. 143B-282.1(b) were
wrongfully applied to the detriment of the petitioner;
(b) the violator promptly abated continuing environmental damage resulting from
the violation;
(c) the violation was inadvertent or a result of an accident;
(d) the violator had been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary
remedial actions
Please submit this information to the attention of:
Water Quality Section Chief
Division of Water Quality
P.O. Box 29535
Raleigh, North Carolina 27626-0535
. Submit a written request for an administrative hearing:
If you wish to contest any statement in this assessment letter, you must request an
administrative hearing. This request must be in the form of a written petition to the
Office of Administrative Hearings and must conform to Chapter 150B of the North
Carolina General Statutes. You must
File your original petition with the
Office of Administrative Hearings
P.O. Drawer 27447
Raleigh, North Carolina 27611-7447
and
Mail or hand -deliver a copy of the petition to
General Counsel
Department of Environment and Natural Resources
P.O. Box 27687
Raleigh, North Carolina 27611-7687

• iTATE'OF NORTH CAROLINA NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
COUNTY OF GASTON
IN THE MATTER OF
CBP RESOURCES, INC.
FOR VIOLATIONS OF:
NPDES PERMIT
NO. NC0005011
AND NORTH CAROLINA GENERAL
STATUTE 143-215.1(a)(6)
File No. LM 98-002
FINDINGS AND DECISIONS
AND ASSESSMENT
OF CIVIL PENALTIES
Acting pursuant to North Carolina General Statutes (G.S.)
143-215.6A, I, A. Preston Howard, Jr., P.E., Director of the
Division of Water Quality (DWQ), make the following:
FINDINGS OF FACT:
CBP Resources, Inc. (the Company) is a corporation
organized and existing under the laws of the State of
North Carolina.
B. The Company operates a 0.257 MGD wastewater treatment
plant at Gastonia, North Carolina, which is located in
Gaston County.
C. The Company was issued NPDES Permit No. NC0005011 on
October 20, 1995, effective November 1, 1995, with an
expiration date of September 30, 1996. The renewed
permit was issued on September 5, 1997, effective
October 1, 1997, with an expiration date of March 31,
1999.
D. Said permits contain the foliowing relevant daily
maximum, monthly average, and chronic toxicity effluent
limitations:
Parameter
•imitation Units
Daily Max/Monthly Avg.
Fecal Coliform
BOD
BOD
BOD1
BOD1
Chronic Toxicity
400 / no limit
680 / 340
317 / 158
612 / 306
285 / 143
Quarterly @ 3%2
1 The BOD limits changedin the renewed permit
2 Monitoring Frequency reverts to monthly after
failure.
#/100 ml
lbs/day
mg/1
lbs/day
mg/1
Pass/Fail
a single test

CB? Resourcesf Findings and Decisions
Page 2
E. Monthly self -monitoring reports for the period from
April through November, 1997 have revealed the
following exceedances of the above -cited permit
effluent limits: (See Attachment A)
F. Notices of Violation concerning the monthly average
permit limitation violations and chronic toxicity
violations at the subject plant were sent to the
Company by DWQ's Mooresville Regional Office.
G. None of the above -cited exceedances of the permit
effluent limitations were the result of a bypass or
power failure at the, plant as defined in the permit.,
H. Said permit also contains the following relevant
reporting requirements:
Parameter Reporting Requirement Units
BOD Monthly Average mg/I
BOD Daily Maximum mg/1
1, From April through November, 1997 the Company's self -
monitoring reports contained insufficient values for
the BOD monthly average concentration. (See Attachment
A)
J. From April through November, 1997 the Company's self -
monitoring reports contained insufficient values for
the BOD daily maximum concentration. (See Attachment A)
K. The Company's prior record of compliance with programs
over which the Environmental Management Commission has
regulatory authority is as follows:
A civil penalty of $11,091.30 was assessed against the
Company on December 16, 1997 (Case No. LV 97-029). The ,
Company has filed a petition for an administrative
hearing. The Company was assessed a civil penalty of
$4,734.30 (Case No. LV 96-030) on February 3, 1997.
The penalty was paid on March 19, 1997. A civil
penalty was assessed for $500 (Case No. LR 94-02) on
June 3, 1994. The penalty was paid on June 29, 1994.
In July, 1988, the Company (then named Carolina and
Southern Processing Company) was assessed a civil
penalty of $18,000 plus $2429.33 in enforcement costs
and $635.81 in damages (total = $21,065,14 Case No. 88-
49). The Company paid the assessment on October 12,
1988. The Division of Air Quality has documented 97
air permit limit violations for the period from January
through June, 1997.

, CBE Resources, Findings and Decisions
Page 3
L. The cost to the State of the enforcement procedures in
this matter totaled $297.80
Based upon the above Findings of Fact, make the following:
II. CONCLUSIONS OF LAW:
A. The Company is a "person" within the meaning of G.S.
143-212 (4) .
B. NPDES Permit No. NC0005011 is required by G.S. 143-
215.1.
C. The effluent limitations contained in the subject
permit are terms, conditions, or requirements of said
permit.
D. The Company violated G.S. 143-215.1(a) (6) and NPDES
Permit No. NC0005011 on five (5) occasions during July
through November, 1997 in the manner and to the extent
described in Attachment A, when the permittee permitted
waste to be discharged into the waters of the State in
violation of the daily maximum permitted effluent limit
for Fecal Coliform.
. The Company violated G.S. 143-215.1(a) (6) and NPDES
Permit No. NC0005011 on three (3) occasions during May,
July, October, and November, 1997 in the manner and to
the extent described in Attachment A, when the
permittee permitted waste to be discharged into the
waters of the State in violation of the monthly average
permitted mass/based effluent limit for BOD.
F. The Company violated G.S. 143-215.1(a) (6) and NPDES
Permit -No. NC0005O11 on two (2) occasions during July
and November, 1997 in the manner and to the extent
described in Attachment A, when the permittee permitted
waste to be discharged into the waters of the State in
violation of the daily maximum permitted mass/based
(lbs/day) effluent limit for BOD.
G. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on eight (8) occasions during
April through November, 1997 in the manner and to the
extent described in Attachment A, when the permittee
permitted waste to be discharged into the waters of the
State in violation of the monthly average permitted
concentration (mg/1) effluent limit for BOD.

CB? Resources, Findings and Decisions
Page 4
H. The Company violated G.S. 143-215.1(a) (6) and NPDES
Permit No. NC0005011 on eight (8) occasions during June
through October, 1997 in the manner and to the extent
described in Attachment A, when the permittee permitted
waste to be discharged into the waters of the State in
violation of the daily maximum permitted concentration
(mg/1) effluent limit for BOD.
1. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on five (5) occasions during May
through November, 1997 in the manner and to the extent
described in Attachment A, when the permittee permitted
waste to be discharged into the waters of the State in
violation of the permitted effluent limit for Chronic
Toxicity.
• By reporting as described in I.(I) above the Company
violated the: subject permit's reporting requirement for
BOD monthly average concentration on eight (8)
occasions from April through November, 1997.
K. By reporting as described in I.(J) above the Company
violated the subject permit's reporting requirement for
BOD daily maximum concentration on thirty-five (35)
occasions from April through November, 1997.
. General Statute 143-215.6A(a) provides that a civil
penalty of not more than ten thousand dollars per
violation may be assessed against a person who violates
or fails to act in accordance with the terms,
conditions, or requirements of a permit required by
G.S. 143-215.1.
• The State's enforcement costs in this matter may be
assessed against the Company pursuant to G.S. 143-
215.3(a)(9) and G.S. 143B-282.1(b)(8).
N. The Director, Division of Water Quality, pursuant to
delegation provided for by G.S. 143-215.6A(h), has the
authority to assess civil penalties.

CBP Resources, Findings and Decisions
Page 5
Based upon the above Findings of Fact and Conclusions of
Law, I make the following:
III. DECISION:
Accordingly, the Company is hereby assessed a civil penalty
of:
$ 37,5: o
Itt) 4:s IC:s d=6 .0=to
//ZS-. or)
For the five (5) violations of
G.S. 143-215. (a)(6) and NPDES Permit
No. NC000SO11, by discharging waste into
the waters of the State in violation of
the permit daily maximum effluent limit
for Fecal Coliform.
For 2 of the three (3) violations of
G.S. 143-215.1(a) (6) and NPDES Permit
No. NC0005011, by discharging waste into
the waters of the State in violation of
the permit monthly average mass/based
(lbs/day) effluent limit for BOD.
For f the two (2) violations of
G.S. 143-215.1(a)(6) and NPDES Permit
No. NC0005O11, by discharging waste into
the waters of the State in violation of
the permit daily maximum mass/based
(lbs/day) effluent limit for BOD.
For of the eight (8) violations of
G.S. 143-215.1(a)(6) and NPDES Permit
No. NC0005O11, by discharging waste into
the waters of the State in violation of
the permit monthly average concentration
(mg/1) effluent limit for BOD.
For 25 of the eight (8) violations of
G.S. 143-215.1(a)(6) and NPDES Permit
No. NC0005O11, by discharging waste into
the waters of the State in violation of
the permit daily maximum concentration
(mg/I) effluent limit for BOD.
For of the five (5) violations of
G.S. 143-215.1(a)(6) and NPDES Permit
No. NC0005011, by discharging waste into
the waters of the State in violation of
the permit effluent limit for Chronic
Toxicity.

CDP Resources, Findings and Decisions
Page 6
For 2 of the eight (6) failures to
report for BOD monthly average
concentration in violation of G.S. 143-
215.1(a)(6) and NPDES Permit No. NC
0005011 for the months of April through
November, 1997.
For ..5157. of the thirty-five (35)
failures to report for BCD daily maximum
concentration in violation of G.S. 143-
215.1(a)(6) and NPDES Permit No.
NC0005011 for the months of April
through November, 1997.
TOTAL CIVIL PENALTY, which is X,444
percent of the maximum penalty
authorized by G.S. 143-215.6A.
297.60 Enforcement costs.
tr 4 7 .7 g TOTAL AMOUNT DUE
Pursuant to G.S. 143-215.6A(c), in determining the amount of
the penalty I have taken into account the Findings of Fact and
Conclusions of Law and the factors set forth at G.S. 143B-
262.1(b), which are:
(1) The degree and extent of harm to the natural resources
of the State, to the public health, or to private
property resulting from the violations;
(2) The duration and gravity of the violations;
(3) The effect on ground or surface water quantity or
quality or on air quality;
(4) The cost of rectifying the damage.;
(5) The amount of money saved by noncompliance;
(6) Whether the violations were committed willfully or
intentionally;
(7) The, prior record of the violator in complying or
failing to comply with programs over which the
Environmental Management Commission has regulatory
authority; and
(8) The cost to the State of the enforcement procedures.
A. Preston Howard, P.E., Director
Division of Water Quality

Fee Col
Date
ATTAC
July 10, 1997
July 25, 1997
July 31 197
September 25, 1997
October 16, 1997
BOD
Date
y, 1997
July, 1997
October, 1997
Daily
um Pe
Reported Value
430/100
460/100 nil
425/100 nil 1
485/100 nil
4 /1 0
on y Average lbs/day Pe
BOD Daily
Date
July 31, 1997
October 1 , 1997
Date'
Reported Value
389 lb `day
1 1 W
1 Ibsi dsy y
u lbs/day
Reported alu
938 lb"dy /
642 lbs/day
Monthly Average
1997
y, 1997
e, 1997
July, 1997
August, 1997
September, 1997
October, 1997
Nov• ber, 1997
Pe
Reported Value
160 mg/1
186
246 m.
378r
173 mgil
236 mg/1
166 ing/1
VioViolations
Permit
400/100
400/100
400/100
400/100
400/100 ml
VioIMtnus
it
340 lbs/day
340 lbs/day
306 lbsidayl
Violations
Perimt
680 lbsklay
612 lb' '
it ations*
ns
Assessed
158m*
18
1 m
158 mg/1
158 mg/1
1581
143
143

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
March 19, 1998
E.R, Merlin ice President
Cl3P Resource, L c..
5533 South York Road
Gastonia, North Carolina 28052
SUBJECT: Assessment of Civil Penalties for Vialation(s) of
N.C. General Statute(s) 143-215.1(a)(6)
CEP Resources, Inc.
Gastonia Division
Gaston County
Pile No. L.M 98-002
NPD1 S Permit No. NC0005011
tear Mr. Clberding:
This letter trans its notic of a civil penalty nss scd al
amount of $18,672.80, including $297.80 in enforcement cost
Attached is a copy of the assessment document explaining this tv. This action was
taken under the authority vested in me pursuant to delegation provided y the Secretary of the
Department of Environment and Natural Resources and the director of the Division of Water
Quality. Any continuing violation(s) tray be the subject of a new enforcement action, including an
additional penalty.
Within thirty days of receipt of this notice, you must do one of the following:
1. Submit payment of the penalty;
Payment should be made directly to the order of artment of Envunnrnent
and Natural Resources (do not include watverfonn)Payment of the penalty will
not foreclose further enforcement action for any continuimg or new violation(s).
Please submit payment to the attention of
Water Quality Seen Chief
Division of Water Quality
P.O. Box 29535
Raleigh, North Carolina 27626i535
P Resources, Inc. in the
P.O.7
Box
29535, Raleigh, North An Equal opportunity Carolina E
AffirmativeAdbnEmployer Sty% recycled/ in% po 35 Telephone t cu. em uer r -
TO 'd IV:6 86, aZ JeW
8V09- I -616: xEd DPI - HDNddH SNJIlbd]i0

Submit a written request for remission or raitiga
justification for such request:
A request for remission or mitigation ,s lar d to co s for co� of the g asacneBurney of
leness of
the amount of the penalty and is not the properprocedure
any of the statements contained in the assessment letter. Because a remission request
forecloses the option of an administrative hearing, such a request must be accompanied
by a waiver of your right to an administrative hearing and a stipulation that there are no
factual or legal issues in dispute. You must execute and return to this office the attached
waiver and stipulation form and a detailed statement which you believe establishes
whether
(a) one or more of the civil penalty assessment factors au G.S. 143B-282.1(b) were
wrongfully applied to the detriment of the petititauer
(b) the violator promptly abated continuing environmental damage resulting from
the violation;
(c) the violation was inadvertent or a result of an accident;
(d) the violator had been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary
remedial actions.
Please submit this information to the attention of:
Water Quality Section Chief
Division of Water Quality
P.C. Box 29535
Raleigh, North Carolina 27626-0535
Submit a written request for nn administrative hearing:
If you wish to contest any statement in this assessment letter, you must ,queat an
administrative hearing. This request must be in the form of a written petition to the
Office of Administrative Hearings and must conform to Chapter 1.50B af' the North
Carolina. General Statutes_ You must
File your original petition with the
Office of Administrative Hearings
P.O. Drawer 27447
Raleigh, North Canalina 27611-7447
and
ding, a detailed
Mail or hand -deliver a copy of tens peuuo i r'
General Counsel
Department of Environment and Natural Resos
P.O. Box 27687
Raleigh, North Carolina 27611-7687
LT/L0'd L1 6 86, aL JPW
8tO9-STL-6T6: xP. OM - HDNti I'd SN©ID 340

OPE TIMMS BR CH - Fax: I - I - 48 Mar9:42
P.
2
nos
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t011
Ins I dsal ICAO
.o oaf Jo ouoI

"STATE OF NORTH
COUNTY OF GASTON
N THE MATTER OF
RESOURCES, INC.
yI1LATI©NS OF:
PERMIT
e00©5011
ORTH CAROLINA GENERAL )
E 143-215.1(3) (6) )
Acting pursuant to North Carolina General Statutes (G.S. )
5.6A, I, A. Preston Howard, Jr., P.E.,
e
on of Welter Quality (DWQ) , make the following:
NORT
ENVIRONMENTAL
caMMI SS I ON
File No. LM 98-002
DLNG5 AND DECISIONS
s W ASSESSMIENT
OF CIVIL PENALTIES
INNINGS OF FACT:
A.
C!P Resources, Inc.
organized and existi
North Carolina.
The company operates
plant at Gastonia, No
Gaston County.
The Company was issued NPDES Pe
October 20, 1995, effective Nov
expiration date of September 30,
permit was issued on Septemberr
October 1, 1997, with an expirat
1999.
Company) is a corporat3.
under the laws of the Sta
of
0.257 MGD wastewater treatment
:h Carolina, which is located in
NC0005011 on
r 1, 1995, with an
996. The renewed
1997, effective
on date of March 31,
Said permits
average,e fand©chronicrelevant
toxicittyy1effluent
maximum, Y
limitations:
Parameter
D
Fecal Calif©rm
BOD
BOA
BOD'
BQD2
Chronic Toxicity
The HOD limits changed.in
2 Monitoring Frequency rever
failure.
Limitation
Max M4ntNN
400 / no
680 / 340
317 / 158
612 / 306
285 / 143
Quarterly @ 3%2
e renewed permit
to monthly after a single
on
#/100 ml
lbs/day
mg/1
l.bs/daY
mg/1
Pass/Fail
test
T/V0 "d
t7:6 86, QZ JPW
6I6:xed
- HJNldH SN©Ild?i3d0

CBP,Resources, Findings and DeCi5iOnS
Page 2
E.
Monthly aelf-monitoring reports for the period from
April through November, 1997 have revealed the
following exceedances of the above -cited permit
effluent
limits: (See Attachment A)
Notices of Violation concerning the monthly average
permit limitation violations and chronic toxicity
Violations at the subject plant were sent to the
Company by DIRQ's Mooresville Regional Office.
None of the above -cited exceedances of the permit
effluent limitations were the result of a bypass or
power failure at the plant as defined in the permit.
Said permit also contains the following relevant
reporting requirements:
BOD
DOD
From April through November, 1997 the Company's self -
monitoring reports contained insufficient values for
the ROD monthly average concentration. (see Attachment
From April through November, 1997 the Company's self -
monitoring reports contained insufficient values for
the HOD daily maximum concentration. (See Attachment A.)
K. The Company's prior record of compliance with programs
over which the Environmental Management Commisaion has
regulatory authority is as follows;
A civil penalty of *11,091.30 was assessed against the
Company on December 16, 1997 (Case No. LV 97-029). The
Company has filed a petition for an administrative .,
hearing. The Company was assessed a civil penalty of
$4,734.30 (Case No. IN 96-030) on February 3, 1997.
The penalty was paid on March 19, 1997. A, civil
penalty was assessed for $500 (Cae No. LR 94-02) on
June 3, 1994. The penalty was paid on aune 29, 1994.
In July, 19660 the Company (then named Carolina and
Southern Processing Company) W8S assessed a civil
penalty of 0181000 plus $2429.33 in enforcement costs
and $635.81 in damages (total e $211065.14 Case No. 00-
49). The Company paid the assessment on October 12,
1986. The Division of Air Quality has documented 97
air permit limit violations for the period from January
through June, 1997.
ter
Monthly Average mg/1
Daily Maximum mg/1
ZT/SO*d 2V:6 86, O J
81709-STL-6T5:xe.i OM - HJN SNOLM3d0

Findings and Decisions
The cost to the State of the enforcement procedures
this matter totaled $297.80
aged upon the above Findings of Fact, 1 eke the
CONCLUSIONS OF LAW
of G.3.
The Company is a "person" within the ea ing
14.3-212 (4) -
NPDES Permit No. NC0005011 is required by G.S. 1.43-
215.1.
The effluent iiinta4nditiQroiataarereqnihemens'eftsaid
permit are terms, c-
permit.
i. The Company violated G.S. 143-215.1 (a) (6) and NPDES
Permit No. NC0fl4Sa11��nipfive
the (maa�neroccasions
and todthenext nt
July
through November, 1997 described in Attachment A, when the permittee permitted
wants to be discharged i°i.�n�mepearm��edf egfTuenttl.i.mit
violation of the daily
for Fecal Cvlfarm.
The Company violated G.S. 143-235.1(a)(6) and NPDES
Permit No. NC0005011 on three (3) occasions during May,
July, October, and November, 1997 in the manner and to
the extent described in Attachment A, when the
permittee permitted waste to be discharged into the
rage
waters or the State in violation of the monthly
permitted mans/based effluent limit for BOD.
The Companyviolated G.S. 143--215.1 (a) (6) and NPDES
permit "No. NC00050111 an two (2) occasions during July
and November, 1997 in the manner and to the extent
described in Attachment A, when the permittee permitted
waste to be discharged into
iiaumepear�ittedf the State
mass/based
rn
violation of the doily
(1bs/day) effluent limit for BOD.
G. The Company violated G.S. 143-215.1(a)(6i and NPDES
Permit No. NC0005011 on. eight (8) occasions during
April through November, 1997 in then the a drntmanner and o the
extent described in Attachment A,
permitted waste to be �ecm©rri�3dyi�ver theg permitted
concentration the
State in violation
concentration (mg/1) effluent limit for BOP.
Ong
ZT/9O'd 2V:6
86, OZ AN
8b'O9-STD-616. xe3 0M - HOWdEl SNOIIL ?3dO

,s rces, i nciings and Decisions
4
H. The Company violated G.S. 143-215.1(a)(6) and N DES
Permit No. Nc0005011 on eight (8) occasions during June
through October, 1997 in the manner and to the extent
described in Attachment A, when the perittee permitted
Waste to be discharged into the waters of the State in
violation of the daily maximum permitted concentration
0nq/1) effluent limit for BCD.
The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NCOOO5O11 on five (5) occasions during May
through November, 1997 in the manner and to the extent
described in Attachment A, when the permittee permitted
Waste to be diScharoeffluen�elimit for Chronics of tha State
violation of the permitted
Toxicity.
By reporting as described in 1.(1) above the Company
violated the subject permit's reporting requirement for
20D monthly average concentration on eight (8)
occasions from April through November, 1997.
ny reporting as described in i. (J) above the Company
violated the subject permit's reporting requirement for
B©D daily maximum concentration on thirty-five (35)
occasions from April through November, 1997.
1,« General Statute 143-215.6A(a) provides that a civil
Penalty of not more than ten thousand dollars per
violation may be assessed against a person who violates
or fails to act in accordance with the terms,
conditions, or requirements of a permit required by
G.S. 143-215.1.
1. The State's enforcement costs in this matter may be
assessed against the Company pursuant to G.S. 143-
215.3 (a) (9) and G.S. 1435-282.1 (b) (8)
N. The Director, Division of Water Quality, pursuant to
delegation provided tor by G.S. 143-215.6A(h)► has the
authority to assess civil penalties.
t /Le 'd
bG:6 86, 0.,7, SEW
8VO9-ST2.-6T5: X .d OM - HONddd SNOI1d dO

CBP Res
Page 5
Based upon the above Findings of Fact and Conclusions of
ewr.t mike the following:
rces, Findings and Decisions
r ctSioN:
Accordingly, the Company is hereby assessed a ivi l Penalty
Oft
Far of the five (5) violatians of
G.S. 1.4i5.1. (a) (+6) and NPPES"errx t
No. NCO i©5©11, by discharging waste into
the waters or the State in violation of
the permit daily maximum effluent limit
for Fecal C+olifcrm-
For 2 of the three (3) violati ans of
G.S. -143 215.1(a) (6) and NPDES Permit
No. NC0005C11, by discharging waste into
the waters of the state in violation of
the permit monthly average muss/based
(lbs/day) effluent limit for BOD.
For / of the two (2) violations of
G.s. 14215.1 (a) (6) and NPDES Permit
No. NCO 5011., by discharging waste into
the waters of the State in violation of
the permit daily maximum mass/based
(lbs/daY) effluent limit for BOD.
rar of the eight (8) violations of
G.S. 1'43-2 5.1 (a) (6) and NPDES Permit
No. NC000501.1, by discharging waste into
the waters of the State in violation of
the permit monthly average concentration
(mg/ 1) effluent limit for BCD
For 1of the eight (8) °vivlatl.c's of
G.S. 143--215.1 (a) (6) and NPDES Permit
No. NC0005411, by discharging waste into
the waters of the State in violation of
the pelt daily maximum concentration
(mg/1) effluent limit for BOD.
For 5 of the five (5) violations of
G.S. -215.1 (a) (6) and PDFSwPermit
e tnto
No. NCO005el1, by clischarg
the waters of the State in violation of
the permit effluent limit for Chronic
Toxicity.
ZT/8O "d bP:6 86. OZ 811-6T6: xgd O -

CEP Resources, k indngs and Decisions
Page 6
..-- For of the eight (8) failures to
report .for BOD monthly average
concentration in violation of G.S. 143-
215.1 (a) (6) and NPDS 'Permit No. NC
0005011 for the months of April. through
November, 1997.
.. ... For 34.5r of the thirty-five (35)
failures to report for BCD daily maximum
concentration in violation of G.s. 143-
215.1(a) (6) and NPDES Permit No.
NC0005011 for the months of April
through Novembers
75. .4 ems► TOTAL Cr/IL PENALTY, which .5 �?• atf
percent of the maximum 'penalty
authorized by G.S. 143-215.6h.
297.80 Enforcement costs.
7 . -eQ TOTAL AMOUNT DOE
pursuant to G.S. 143-215.61thedetermining
afthe
Factoa � of
the penalty I have taken into account
Conclusions of Law and the factors set forth at G.S. 1438-
282.i(b), which are:
(1) The degree and extent of harm
healtheoratarai reseurCe3
of the State, to the public
property resulting from the violations:
(2) The duration and gravity of the violations,
(3) The effect on ground
alrts;rface water quantity or
quality or on air
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompiiance,t
(6) Whether the violations were committed willfully or
intentionally;
(7) The prior record of the violator in complying or
failing to damply with programs over which the
Environmental Management Commission has regulatory
authority; and
t The cost to the State of the enforcement procedures.
A. Prest n or ard,
Division of Water
F. w, D rector
Z T /60 'd
86, 0Z aeW
8t09-STZ-6i5:xvd
SNOIP 3dO

ATTACHMENT A
Fexai Ceiifunu Daily Maximcu0 Permit Limit Violations
P'errnit Lini t
9 ►7 430/100 ml
997 460/100 m
7 425/1.00 m1 #
Sept *15, 1997 485/100 ml
Oct° 1 , 1 7 425/100 mi
13 D Monthly Ave
nue
May, 1997
Ally, 1997
October. 1997
BOD-120 •
July 31, 1997
October 16, 1997
BOP -
pate
April, 1997
May, 1997
June, 1997
July, 1997
August, 1997
September, 1997
October, 1997
November, 1997
V
389 lbs/day
518 lbs/day
441 lbs/day
4001100 art
400/100 ml
400/ 100 mi
400/100 ml
400/100 ml
Permit Limit Violations
bs/dsi P
938 lbs/day
642 lbs/day
Av
160
186
246 rng/1 #
378 mg/1
173 mg/1
236 mg/I I/
266 mgtl #
166 mg/t
340
340
306
e>i
0
680 lbs/day
6121bslday1
we Permit Limit V'
158 mg/1.
158 rng/1
158 me
158 mgil
158 mg/1
158 rogn.
143 mg/1
143 mg/I
T/aT "d Gb.6 86, aZ
6
xpd OM - HDNUdg SNOI1dd dO

R0D - Daily Maximum mg/1 Perini
Repot e
Dune 13, 1997 376 argil
June 27,1997 ' 330 nigil
July 10, 1997 370 mg/I
July 31, 1997 370 mg/1
September 25, 1997 471 mg/l
October 16,1997 351 mg/1 #
October 22„ 1997 317 mg/1
October 30,1997 350 mgJl #
May, 1997
)une, 1997
July, 1997
August 1997
September, 1997
October, 1997
November, 1997
nic Toxicity Perini
gcd dales
BAD TEST
Fail @I 3%
Fail@3%
Fail @3%��
BAD TEST2
Fail @ 3%
Fasil (4 3% #
r The pit limits ( masslbasea d concentration limitss for
2 13urlingtcrn Research documented that the September, 199
Quality assurance criteria.
* Values for 130D concentraliofl were not arep orted on
Resources. BOD concentratio were calculated as follows:
10
P
317 mg/1
317
317 ngll
317 me
317 mg/1
285 mWt1
285 mg/1
285 mgli
P
P
Pass
Pass 3°%
Pass 3°
Pass
Pass
Pais (43
BOD changed on October 1, 1997.
7 chromic toxicity teat failed to rat
y Monit
+darts byP
ZT/TT 'd
9tr,6 86, 6Z JPW
8tO9-STL-
XPj am - H9NId8 SNOIlkd0

As
Total:
4
4
4
Total: 35
tolations

PREPARED BY:
SUBJECT:
DIVISION OF WATERQ I1
august 18, 1"
Linda Forehand, t"drnpli
Rex Gleason
John Lesley
Group
Fast Track Enforcement
rcer ez
Violation of1' % :1 rc 1 . ITa ( and
NPDES Permit No. NC0005011
BP Resources
Gaston County
ty
Linda, attached are the modified pages for the Findings d Decisions paragraph H. and
Case Assessment Factors Paragraph 7 of the enforcement package for CAP Resources. Thant
for the information concerning the fish kill in 1988 and subsequent penalty and payment Also
included is the copy of inspection report and the response to the that was not included
n your copy of the enforcement package.

State of North Carolina
Department of Environment,
Health and Natural Resources
Mooresville Regional Office
James B. Hunt, Jr„ Governor
Jonathan B, Howes, Secretary
➢TV SIGN OF " TER QUALITY
July 8, 1997
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. E.R. Qlberding, Vice President
Carolina By -Products Resources
5533 South. York Road
Gastonia, North Carolina 28052
Subject:
Qlberdin w
Notice of Recommendation
for Enforcement
Notice of Violation NCGS 143-215.1(a)(6)
Compliance Sampling Inspection
CBP WWTP
NPDES Permit No, NC000SO I 1
Gaston County, NC
Enclosed is a copy of the Compliance Sampling Inspection Report for the inspection
conducted at the subject facility on. June 26, 1997 by Mr. John Lesley of this Qffice. Sample analysis
results will be forwarded under separate cover when available. The report should be self-
explanatory.
This letter serves notice that the Mooresville Regional Office of the Division of Water
Qu.aIity is considering sending a recommendation for enforcement action to the Director of the
Division of Water Quality. The recommendation concerns the violation by this facility of North
Carolina General Statute 143-21.5.1 (a) (6) and NPDES Permit No. NC4005O11 for discharging
waste into the waters of the State in violation of monthly average and daily maximum permit limits
for Ammonia as Nitrogen, daily maximum effluent limits for Fecal Coliform, monthly average
limitations for Flow and BOD, and Chronic Toxicity limit violations (See the Self -Monitoring
Section of the subject report).
919 North Main Street,
twlooresvilse, North Carolsnc 28115
Voice 701-663-1699
r. r
FAX [phone]
An Equal Opportunity/AfticFnative Action Employer
50% recycleid/1D% past -consumer paper

CEP Res ur es NRE
Page
If you hae an explanation for the violations that you wish to present, please respond in
g within ten (10) days following receipt of this Notice, Your explanation will be reviewed and
enforcement action is still deemed appropriate, your explanation will be forwarded to the
Director with the enforcement package for his consideration. Please address your response to my
attention at the address shown on the letterhead.
If you hay any questions cone ing this Notice, please contact esley or at 704)
663 699.
Since
D. Rex Gleason, P.E.
Acting Regional Supervisor
Compliance,'Enf rcement Group
Central Files
Mooresville Regional Office
Gaston County Health Department

United States Environmental Protection Agency, Washington, D.C.:, 20460
NPDES Compliance Inspection Report
Transaction Code NPDES
NC000501 1
Section A: National Data System Coding
FormApproved
OMB No,2040-0003
Approval Expires 7-31-85
YR/MO:DA Y Inspection Type Inspector Facility
Type
97/06Q6 a 2
Reserved Facility Evaluation Rating BI QA
2.
Section .13: Facility Data
Name and Location of Facility Inspected
CBP Resources WWTP
Highway 321 South
' south of Gastonia, Gaston County, North Carolina
Entry Time:
2:00 pm
Permit Effective
Date:
November 1. 1995
Exit Time/Date: Pem-nt Expiration
3:00 pm Date:
97,106/26 September 30, 1996
Name(s) of On -Site Representative(s) Title(s) ------ Phone No(s)
Mr, Van Jones Environmental Manager/ [phone]
Name, Address of Responsible Official
Mr, ER, Olberding
CBP Resources
5533 South York Road
Gastonia. North Carolina 28052
Title
Vice President o
Phone No, Contacted?
[phone] NO
n C: Areas d During Inspection (S-Satisfac M-Marginal, U-Unsatisfactor), N-Not Evaluated, NA -Not Applicable)
NI Permit
a Records/Reports
5 Facility Site Review
5 Flow Measurement
N Laboratory
L EffluenuReceiving Waters
NA Pretreatment 5 Operations & Maintenance
NLA Compliance Schedules Sludge Disposal
a Self -Monitoring Program * Other: Sample analyses
Section D: Sumrnan of FindingsiCornments
See Attached Sheet(s) for Summary. * Sample analysis results will be forwarded under separate cover
when available.
Name(s) and Signature(s) of Inspectors j Agency/Office,,Telephone
'John Lesley
NCDWQ MR01(704) 663-1699
Signature of Reviewer Agency/Office
Date
July 8, 1997
Date
Date
Regu1ator 0 te Use Only
Action Taken
Date
Noncompliance
Compliance
EPA Forrn 3560-3 (Rev. 3- Previous editions are obsolete

Factlity.Name:
NPDES Perrnit Number:
CBP Resources WWTP
NC000501 1
The facility was last inspected by Patricia Beam of this Office on December 3, 1996. Joint
inspections were conducted by DWQ staff and Division of Air Quality staff on February 25 and 27
and March 3 and 20, 1997. The joint inspections were in response to numerous odor complaints
reported to this Office during the period from January through March, 1997,
PERMIT:
The permitted facility (outfall 001) is a 0,257 MGD activated sludge wastewater treatment
plant consisting of an aerated lagoon, secondary clarifier, effluent polishing ponds, a stormwater
lagoon, a chlorine contact chamber with gas chlorine disinfection, a sludge filter press, and
continuous flow measurement, The facility's NPDES Permit expired on September 30, 1996. An
application for renewal of the permit with all applicable fees was received by the Division on March
29, 1996. The facility continues to operate under the conditions of the expired permit,
Outfall 002 is a non -contact cooling water discharge. Cooling water is pumped from
Crowders Creek to the manufacturing plant's cooling system and discharged as described in the
Permit. The non -contact cooling water contains no biocides or chemical additives.
On January 14, 1997 CBP Resources submitted an Alternatives Analysis Report comparing
costs associated with meeting monthly nutrient limits of 1 mg./Total Phosphorus and 6 mg11 Total
Nitrogen to the cost of connection to the City of Gastonia collection system. Based upon the
Alternatives Analysis, CBP Resources has proposed a 5-year phased tie-in to the City of Gastonia
Crowders Creek WWTP contingent upon a pretreatment agreement with the City.
The existing permit limitations are based on the production based limits found in 40 CFR 432
Subpart J - Render Subcategory. The limitations found in 40 CFR 432.102(a) do not adequately
protect the receiving stream for fecal coliform. A water quality standard of 200/100 ml has been
established to protect human health [15A NCAC 2B4O211(e)] ; whereas, 40 CFR 432.102(a)
requires a 4001100 ml daily maximum limit for fecal coliform, It is recommended that the Division's
Perrnits and Engineering Group base the facility's fecal coliform limitations upon the water quality
standard to ensure adequate protection of human health at permit renewal.
FACILITY SITE REVIEW/OPERATION AND NL&INTENANCE:
The facility is adding four, 40 horsepower aerators to the aerobic lagoon. Electrical service
was upgraded by Duke Power Company on July 7, 1997 according to telephone notification from
the ORC on July 7, 1997.
The mixed liquor in the aeration lagoon appeared to be a dark brown color with no excessive
foaming. Dissolved oxygen concentrations in the basin are usually between 1.0 mg/land 0.5 mg]
according to process control records, Odors were consistent with the findings of the joint inspections
conducted in February and March, 1997 (see above) and were most noticeable at the influent end of
the aeration lagoon.
The effluent polishing ponds appeared to be a -red-purple" color. Red algae was the cause
of the discoloration according to the ORC. The effluent polishing ponds are operated in series.
Denitrification was observed in the first polishing pond.

CBP Resources NC0005011
Chlorine gas disinfection is accomplished by utilizing a one -ton chlorine cylinder located
approximately 100 yards from the chlorine contact chamber. The chlorine cylinder is on the ground
exposed to the elements. It is recommended that chlorine cylinders be stored in a building or other
secured area equipped with the proper safety devices (exhaust fan, chlorine gas leak detector, alarm
system, etc.).
A process control program consisting of dissolved oxygen, pH, settleable solids, and
temperature measurements and MLSS, MLVSS, TSS, and COD testing is used in the operation of
the facility,
SELF -MONITORING PROGRAM:
Monthly monitoring reports were reviewed for the period from July, 1996 through April,
1997. Twenty-four (24) daily maximum permit limit violations were reported for fecal coliform
during the period. Four daily maximum permit limit violations and one monthly average permit
limit violation for ammonia as nitrogen were reported in July, 1996. Toxicity failures were reported
in September and November, 1996. Monthly average limit violations for flow and BOD were
reported in February, 1997.
Time -based composite samples are collected. Part II, Section B, Paragraph 8 of the NTDES
Permit requires that samples be collected proportional to flow. Should the facility seek Division
approval to continue utilizing time -based composite sarnples for monitoring purposes, a written
request must be made to the Director, Supporting documentation which includes a description of
the flow measuring device, a representative sample of one week's flow data (chart recordings), a
description of the sampling method (constant time/constant volume, variable timelconstant volume,
constant time/variable volume, etc.), and a description of any flow equalization used at the treatment
facility 7111151 accompany the request.
Samples are collected on ice and stored at <-4C.
RECORDS AND REPORTS:
Records and reports consist of flow meter strip charts, ORC visitation calendar, operations
and maintenance log, laboratory reports, and monthly monitoring reports. All records and reports
are maintained in accordance with NPDES Permit requirements.
EFFLUENT/RECEIVING WATERS:
Samples were collected at the upstream, effluent discharge, and downstream locations.
Sample analysis results will be forwarded under separate cover when available.
The discharge was "red -purple" in color and very turbid. The upstream and downstream
were "red -purple- in color due to color impact from the City of Gastonia Crowders Creek WWTP
which discharges upstream of the facility. No adverse impact on the receiving stream was observed.
Continued noncompliance with permitted fecal coliform limitations (400/100m1; see Permit
and Self-monitorine, Sections of this report) would predict an exceedance of the water quality
standard for fecal coliform (2001100m1) downstream of the discharge; therefore, the effluent
discharge is rated as "unsatisfactory".

P Peoi
ORATORY:
e on -site laboratory is used for dissolved oxygen, temperature, anti rill measurements.
exempting the facility from certification for pH (dissolved oxygen and temperature are not
certifiable par eters) dated October 8, 1996 was issued by the Laboratory Section, them Bac
Laboratory (Certificate o. is used for all par, eters with the exception of Chronic Tonicity
testing which is performed by Burlington research (Certificate No. .
SLUDGE DISPOSAL:
Sludge born the DAT unit (for grease remo Eal) d filter press aye recycled into the rendering
process. Wastewater sludge is shared in the wastewater lagoons.
FLOW EASU 'ENT:
The floe measuring device is a Stephens float and cable t ye flow meter equipped with a
totalizer wid strip chan recorder. The flow meter is calibrated quarterl ° by in-house staff:
Calibration records and flow charts are maintained in the °s office,

TEL:
Jul 21'97 17:01 Nc.004 P.01
Itokiii4G:134E NATURE CIF CUL BILMNES
July 21, 1997
Mr. D. R.e Gleason, PE
Acting Regional Supervisor
Divisicct of Water Quality
919 N Main Street
Mooresville, NC 28115
Subject; Notice of Recommendation for Enforcement
CUP Resources
Gaston County, NC
Dear Rex,
Gastonia Division
CEP Resources, Inc.
This is in response to your July 8, 1997 Notice of Recommendation for Enforcement.
While we do not dispute the facts that constitute the referenced violations, we believe that
our ongoing efforts ( the addition afoul-, 40 horsepower aerators at a cost of $78,000) to
achieve and maintain compliance and to eliminate the direct dirge to Crowders creek
weigh against any recommendation for enforcement
We have been working diligently toward a tie-in to the City of Gastonia's municipal
system so that our direct discharge can be elirrrirmtpi our company also is committed to
making the financial hivestmeat necessary to remove the discharge from the creek as soon
as possible.
Wc request that your recommendation for enforciem be deferred at this time so that we
may concern:ate our efforts on coluiecting to the City. Presently, our design engineer is
working on plans to make this tie-in, Thank -you for your consideration.
Should there be any questioHis, please contact Mr. Van JOI3C3 or me_
5533 S. York Rd, • Gastonia, NC 28052 • T04444-9941 • Fax # [phone] Direct Dial Nwriur

CBP, Case Assessment Factors
Page 2
5. The amount of oney saved by noncompliance:
Money could have been saved by failing to construct, operate, aintain facilities to meet
limits.
6. Whether the violations were committed willfully or intentionally:
The violations do not appear to be intentional or willful.
7. The prior record of the violator in complying or failing to comply vvith programs over which
the Environmental Management Commission has regulatory authority:
The Company paid a civil penalty assessment (Case No. LV 96-030) of S4,734.30 on March
19, 1997. A civil penalty of S500 (Case No. LR 94-02) was assessed on June 3, 1994. The
penalty was paid on June 29, 1994. The Company (d.b.a. Carolina and Southern Processing
Company) was assessed a civil penalty in July, 1988, (Case No. 88-49) following the breech
of a wastewater lagoon and subsequent fish kill in Crowders Creek. The Company was
assessed a civil penalty of $18,000 plus $2429.33 in enforcement costs and S635.81 in
damages. The Company paid the assessement on October 12, 1988.
The cost to the State of the enforcement procedures:
Central Office Review and Processing = $100.00
6.0 hours by investigator for investigating and
drafting report @ $19,94thour = $119.64
1.0 hour by Water Quality Regional Supervisor
for review @ $36.52/hour = $ 36.52
1..0 hour by Regional Supervisor for review
@ $24.21/hour $ 24.21
1.0 hour for clerical support @ s10,93/hour = 5 10.93
TOTAL = $291.30
9. Type of violator and general nature of business(i.e. individual vs. large corporation):
The Company is a corporation which operates a rendering plant for the manufacture of
animal feed ingredients.
10. Violator's degree of cooperation (including efforts to prevent or restore) or recalcitrance:
The preparation of this enforcement package consisted of file reviews; therefore, the violator
was neither cooperative or recalcitrant.

Findings and Decisions
Page 2
E. Monthly self -monitoring reports for the period from
July, 1996 through March, 1997 have revealed the
following exceedances of the above -cited permit
effluent limits: (See Attachment A)
F. Notices of Violation concerning the monthly average
permit limitation violations and chronic toxicity
violations at the subject plant were sent to the
Company by DWQ's Mooresville Regional Office.
G. None of the above -cited exceedances of the permit
effluent limitations were the result of a bypass or
power failure at the plant as defined in the permit.
H. The Company's prior record of compliance with programs
over which the Environmental Management Commission has
regulatory authority is as follows:
The Company paid a civil penalty assessment of
$4,734.30 (Case No. LV 96-030) on. March 19, 1997. A
civil penalty was assessed for $500 (Case No. LR 94-02)
on June 3, 1994. The penalty was paid on June 29,
1994. In July, 1988, the Company (then named. Carolina
and Southern Processing Company) was assessed a civil
penalty of $18,000 plus $2429.33 in enforcement costs
and $635.81 in damages (total = $21,065.14 Case No. 88-
49). The Company paid, the assessement on October 12,
1988.
The cost to the State of the enforcement procedures in
this matter totaled $291.30
Based upon the above Findings of Fact, I make the fo11owing
CONCLUSIONS OF LAW:
A. The Company is a "person" within the meaning of G.S.
143-212(4).
B. NPDES Permit No. NC0005011 is required by G.S. 143-
215.1.
C. The effluent limitations contained in the subject
permit are terms, conditions, or requirements of said
permit.

DIVISION OF VATER QUWATERA ITV
August 6, 199
MOIL TO: Kent Wiggins
FROM: Barbara Christian
THROUGH: Rex Gleason
PREPARED BY:
SUBJECT:
John Lesley
Fast Track Eforc e
Violation of NCGS 14 -2 5.1(u ) and
*DES Permit No, N( 0005 11
CBP Resources WW P
Gaston County, NC
Attached is an enforcement report which details violations of NPDES Permit No.
N '00 5011 and NCGS 14- 5. a)()• The Company does not dispute the violations as stated
in their response to the Notice of Recommendation for Enforcement, Although the inclusion of
the violations for July, 1996 may exceed the 1 w onth window, , this Office feels the violations
are serious enough to be included for the Director's consideration.
The company has moved rather slowly in taking steps to rernove the discharge. This
Office recommends penalties sufficient to convince the Company that an expeditious tie-in to
City of Gastonia collection system would be in their best financial interest.
If you ha ee questions or require additional info an pie econtact John or me.
Attachments

STATE OF NORTH CAROLINA NORTH CAROLINA.
ENVIRONMENTAL MANAGEMENT COMMISSION
COUNTY OF GASTON
IN THE MATTER OF
CBP RESOURCES, INC.
FOR VIOLATIONS OF:
)
NPDES PERMIT
NO. NC00 5O11
AND NORTH CAROLINA GENE AL )
STATUTE 143-215.1(a) (6)
File No. LV
FINDINGS AND DECISIONS
AND ASSESSMENT
OF CIVIL PENALTIES
Acting pursuant to North Carolina General Statutes G.
143-215,6A, I, A. Preston Howard, Jr., F.E., Director of the
Division of Water Quality (DWQ), make the following:
FINDINGS OF FACT:
A. CBP Resources, Inc. (the Company) is a corporation
organized and existing under the laws of the State
North Carolina.
The Company operates a 0.257
plant at Gastonia, North Caro
Gaston County.
D wastewater treatment
na, which is located i
C. The Company was issued NPDES Permit. No. NC0005c 11 on
October 20, 1995, effective November 1, 1995, with an
expiration date of September 30, 1996 (permit renewal
is in progress at this time).
D. Said permit contains the following relevant daily
maximum, monthly average, and chronic toxicity effluent
limitations:
ration. Unit
ly Mai/Monthly Avg.
Sonia as N 280 / 140 lbs/day
Fecal Coliform 400 / no limit #/140 :mi.
'SOD NA / 340 lbs/day
Flow NA / 0.257 MGD
Chronic Toxicity *Quarterly @ 3% Pass/Fail
4onitoring Frequency reverts to monthly after a single test
ilure.

Findings and Decisions
Page 2
E. Monthly self -monitoring reports for the period_from
July, 1996 through March, 1997 have revealed the
following exceedances of the above -cited permit
effluent limits: (See Attachment Al
F. Notices of Violation concerning the monthly average
permit limitation violations and chronic toxicity
violations at the subject plant were sent to the
Company by DWQ's Mooresville Regional Office.
G. None of the above -cited exceedances of the permit
effluent limitations were the result of a bypass or
power failure at the plant as defined in the permit.
H. The Company's prior record of compliance with programs
over which the Environmental Management Commission has
regulatory authority is as follows:
The Company paid a civil penalty assessment of
$4,734.30 (Case No. LV 96-030) on March. 19, 1997. A
civil penalty was assessed for $500 (Case No. LR. 94-02)
on June 3, 1994. The penalty was paid on June 29,
1994. In July, 1988, the Company (then named Carolina
and. Southern Processing Company) was assessed a civil
penalty following a breech in a wastewater storage
lagoon and subsequent fish kill in Crowders Creek
(details of the enforcement are not available in the
Regional Office files). Penalties were paid in full
plus the cost of fish replacement.
1. The cost to the State of the enforcement procedures in
this matter totaled $291.30
Based upon the above Findings of Fact, I make the fo 1 ,ing:
II. CONCLUSIONS OF LAW:
A. The Company is a "person" within the meaning of G.S.
143-212(4).
B. NPDES Permit No. NC L'5011 is required by G.S. 143-
215.1.
C. The effluent. limitations contained in the subject
permit are terms, conditions, or requirements of said
permit.

Findings and Decisions
Page 3
D. The Company. violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on one (1) occasion during July,
1996 in. the manner and to the extent described in
Attachment A, when the permittee permitted waste to be
discharged into the waters of the State in violation of
the monthly average permitted effluent limit for
Ammonia as Nitrogen.
E. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on four (4) occasions during July,
1996 in the manner and to the extent described in
Attachment A, when the permittee permitted waste tobe
discharged intothe waters of the State in violation of
the daily maximum permitted effluent limit for krnmonia
as Nitrogen.
F. The Company violated G.S. 143-215.1 and NPDES
Permit No. NC0005011 on twenty-five (25) occasions
during August, 1996 through. March, 1997 in the manner
and to the extent described in Attachment A, when the
permittee permitted waste to be discharged into the
waters of the State in violation of the daily maximum
permitted effluent limit for Fecal Coliform.
G. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on one (1) occasion during
February, 1997 in the manner and to the extent
described in Attachment A, when the permittee permitted
waste to be discharged into the waters of the State in
violation of the monthly average permitted effluent
limit for BOD.
H. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on one (1) occasion during
February, 1997 in the manner and to the extent
described in Attachment A, when the permittee permitted
waste to be discharged into the waters of the State in
violation of the monthly average permitted effluent
limit for Flow.
1. The Company violated G.S. 143-215.1(a)(6) and. NPDES
Permit No. NC0005011 on two (2) occasions during
September and November, 1996 in the manner and. to the
extent described in Attachment A, when. the permittee
permitted waste to be discharged into the waters of the
State in violation of the permitted effluent limit for
Chronic Toxicity.

Findings and Decisions
Page 4
General Statute 143-215.6A(a) provides that a.civil
penalty of not more than. ten thousand dollars per
violation may be assessed against. a person who violates
or fails to act in accordance with the terms,
conditions, or requirements of a permit required by
G.S. 143-215.1.
K. The State's enforcement costs in this matter may be
assessed against the Company pursuant to G.S. 143-
215.3 (a) (9) and G.S. 1438-282.1(b) (8) .
The Director, Division of Water Quality, pursuant to
delegation provided for by G.S. 143-215.6A(h), has the
authority to assess civil penalties.
Based upon the above Findings of Fact and Conclusions of
Law, I make the following:
III. DECISION:
Accordingly, the Company is hereby assessed. a civil penalty
of:
Eor of the one (1) violation of
G.S. 143-21 a.1(a)(6) and NPDES Permit
No. NC000551., by discharging waste into
the waters of the State in violation of
permit monthly average effluent limit
for .rronia as Nitrogen.
For of four (4) violations of G.S.
143-215.1(a)(6) and NPDES Permit No.
NC000SO11, by discharging waste into the
waters of the State in violation of
daily maximum effluent limit for nia
as Nitrogen.
For of twenty five (25) violations
of G.S. 143-215.1(a)(6) and NPDES Permit
No. N00005011, by discharging waste into
the waters of the State in violation of
permit daily maximum effluent limit for
Fecal Coliform.

Findings and Decisions
Page 5
For of the one (1) violation cf
G.S. 143 -215.1(a)(6) and NPDES Permit
No. NC0005011, by discharging waste into
the waters of the State in violation of
permit monthly average effluent limit
for BODu
For ot the one (1) violation of
G.S. 143 -215.1(a)(6) and NPDES Permit
No. NO000.5011, by discharging waste into
the waters of the State in violation of
permit monthly average effluent limit
for Flow.
For of two (2) violations of G.S.
143 -215.1(a)(6) and NPDES Permit No.
NC0005011, by discharging waste into the
waters of the State in violation of
permit effluent limit for Chronic
Toxicity.
TOTAL CIVIL PENALTY, which is
percent of the maximum penalty
authorized by G.S. 143-215.6A-
291.30 Enforcement costs.
TOTAL OUNT DUE

ind ngs and De s.ion
Page
Lursuant tc I43-2 5.6A(c), in determaning the amount
the penalty I have taken in o account the Findings f Pact and
Conclusions of Lam and the factors set forth at G.S. 1 -
282.1(b), which r
(l) The degree and extent of harm to the natural re
of the State, to the public health, r t. private
property resulting from the violations;
The duration and gravity of the violations
The effect can ground or surface water quantity car
quality or can air quality;
() The oast of rectifying the damage;
The amount of money saved by nuncorrr. lian
Whether the iolat ons were committedwillful' tip
intentional'
The prior record of the violator in complying car
failing to comply with programs over which the
Environmental Management ont Commission has r c ulatory
authority; and
The cast. tt -he State of the nfo cement procedures.
ate;
A. 1"ruston Howard, fir., E., Lire
Livisicr of Water Quali

CERTIFICATION FITTD PAGE
I certify that the info titan in this report is rue to the hest of
violations of selFrrionitoting data have been verified by hard copy revie
and the appropriate permit
ttrrc cf Principal l Iitvstitnrf s
sl, ETI. SpeCIalISI. lI
edge, All
the monthly r

DIVISION OF WATER QUALITY
ENFORCEMENT CASE ASSESSMENT FACTORS
Type: (LV) Limit Violation
Violator: CBP Resources, Inc.
Address: 5533 South York Road
Gastonia, North Carolina 28052
Registered Agent:
Address:
United States Corporation Company
327 Hillsborough Street
Raleigh, North Carolina 27602
Regional Office: Mooresville
The degree and extent ofharm to the natural resources ofthe State, to the public health, or
to private property resulting from the violations:
There is no documented evidence of harm to the natural resources of the State, public health,
or to private property; however, violations ofpermit limits would predict a compromise of
water quality downstream of the discharge. Ammonia as Nitrogen is toxic to aquatic life
and exerts an oxygen demand on the receiving stream, Fecal Coliform limit violations
exceed the standard established to protect human health (200/100 m1). Chronic Toxicity
violations would indicate that the discharge is having a negative impact on aquatic life
downstream of the discharge.
2. The duration and gravity of the violations:
The violations occurred during the period from July, 1996 through March, 1997. NPDES
Permit limit violations have the potential to affect the designated uses of the receiving
stream. Fecal Coliform limit violations violate water quality standards designed to protect
human health. Chronic Toxicity test failures would predict an adverse impact on aquatic life
downstream of the discharge.
3. The effect on ground or surface water quantity or quality or on air quality:
No adverse impacts on groundwater or surface water quantity or quality have been
documented. Adverse impacts on air quality have been documented through complaints filed
by residents near CBP resources. NPDES Permit limit violations would predict that water
quality downstream of the facility is compromised.
4, The cost of rectifying the darnage:
No damage has been documented,

CBP, Case .Assessment Factors
Page 2
The amount of money saved by noncompliance::
Money could have been saved by failing to construct, operate, or maintain facilities to meet
limits.
6. Whether the violations were committed willfully or intentionally:
The violations do not appear to be intentional or willful.
7. The prior record of the violator in complying or failing to comply with programs over which
the Environmental Management Commission has regulatory authority:
The Company paid a civil penalty assessment (Case No. LV 96-030) of $4,734.30 on March
19, 1997..A civil penalty of $500 (Case No. LR 94-02) was assessed on June 3, 1994. The
penalty was paid on June 29, 1994, The Company (d.b.a. Carolina and Southern Processing
Company) was assessed a civil penalty in July, 1988,.following the breech of a wastewater
lagoon and subsequent fish kill in Crowders Creek (details of the enforcement case are not
available in the Regional Office files). The Company, paid the civil penalty plus the cost of
fish replacement.
The cost to the State of the enforcement procedures:
Central. Office Review and Processing =— $100.00
6.0 hours by investigator for investigating and
drafting report @ $19.94/hour = $119.64
1.0 hour by Water Quality Regional Supervisor
for review C; $36.52/hour $ 36.52
1..0 hour by Regional Supervisor for review
@ $24.21 /hour = $ 24.21
1.0 hour for clerical support @ $10.93/hour = $ 10.93
TOTAL = $291.30
9. Type of violator and general nature of business (i.e. individual vs. large corporation):
The Company is a corporation which operates a rendering plant for the manufacture of
animal feed ingredients.
10. Violator's degree of cooperation (including efforts to prevent or restore) or recalcitrance:
The preparation of this enforcement package consisted of file reviews; therefore, the violator
was neither cooperative or recalcitrant.

CBP, Case Assess ent Factors
Page
Mitigating Ciro ` st cis:
none
12. Assessment Factors:
rs:
a _ IBC; °
b. Deceiving Stream: Crowders Creek
. SOC/JOC status/negotiations: NA
d, Copy of "" Screen. Attached
e. Copy ofLimits page in Ise it; attached
f D age; None documented

ATTACHMENT A
MONTHLY AVERAGE PERMIT EFFLUENT LIMIT VIOLATIONS
Month Reported
July, 1996
February, 1997
February, 1997
DAT
Date Reported
July 5, 1996
July 12, 1996
July 19, 1996
July 26, 1996
August 30, 1996
September 4, 1996
September 11, 1996
September 18, 1996
September 24, 1996
October 2, 1996
October 10, 1996
October 25, 1996
November 1, 1996
November 8, 1996
November 15, 1996
November 22, 1996
November 26, 1996
December 3, 1996
December 10, 1996
December 20, 1996
December 26, 1996
January 3, 1997
January 10, 1997
January 17, 1997
January 24, 1997
January 31, 1997
February 7, 1997
February 14, 1997
March 7, 1997
p.,ameter
Ammonia as N
BOD
Flow
Reported Value
420.2 lbs/day
365 lbs/day
0,302 MGD
AX MUM PERMJTEI UENT L IT VIOLATIONS
Ammonia as N
Ammonia as N
Ammonia as N
Ammonia as N
Fecal Coliform
Fecal Coliform
Fecal Coll form
Fecal Coliform
Fecal Coliform
Fecal Coliform
Fecal Coliform
Fecal Coliform
Fecal Coliform
Fecal Coliform
Fecal Conform
Fecal Coliform
Fecal Coliform
Fecal Coliform
Fecal Coliform
Fecal Coliform
Fecal Coliform
Fecal Coliform
Fecal Coliform
Fecal Coliform
Fecal Coliform
Fecal Coliform
Fecal Coliform
Fecal Coliform
Fecal Coliform
Reported Valuo
394 lbs/day
515 lbs/day
322 lbs/day
450 ibs/day
520/100 ml
1450/100 nil
1150/100 ml
790/100 ml
820/100 nil
645/100 ml
1220/100 ml
410/100 ml
1400/100 ml
1950/100 mi
1450/100 ml
1900/100 ml
960/100 ml
1290/100 ml
860/100 ml
1600/100 ml
1800/100 mi
1450/100 mi
1160/100 mi
1490/100 mi
2250/100 mi
1750/100 mi
680/100 ml
510/100 ml
520/100 ml
Permit Limit
140 lbs/day
340 lbsiday
0.257 MGD
Permit Limit
280 lbs/day
280 lbs/day
280 lbs/day
280 lbs/day
400/100 ml
400/100 ml
400/100 nil
400/100 ml
400/100 ml
400/100 ml
400/100 ml
400/100 ml
400/100 ml
400/100 ml
400/100 ml
400/100 mi
400/100 mi
400/100 ml
400/100 ml
400/100 ml
400/100 mi
400/100 ml
400/100 ml
400/100 ml
400/100 ml
400/100 nil
400/100 ml
400/100 ml
400/100 ml

"FL TOXICITY I°T VIOLATIONS
,rate Reported
Septe berg 1996
November, 1996
Reported Value Perm
Taal @ 3% Pass @ 3
Fail 3 r Pass @ 3°

JAMES B. HUNT JR.
GOVERNOR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
MOORESVILLE REGIONAL OFFICE
DIVISION OF WATER QUALITY
March 30, 1999
Mr. Richard Pennigar
Post Office Box 839
Gastonia, North Carolina 28053
Subject Permit Request
CBP Resources
NPDES Permit No, NC0005011
Gaston County, NC
Dear Mr, Pennigar:
Enclosed, as requested, is a copy of the first page of CBP's NPDES permit. This
facility was inspected by Mr. Roberto Scheller of this Office on December 2, 1998,.At
the time of the inspection all flow from Outfall# 001 was being pumped to the City of
Gastonia's Crowders Creek Wastewater Treatment Plant (WWTP), The permit for the
subject facility became effective on October 1. 1997 and expired on March 31, 1999.
Should you have any questions concerning the subject permit, please do not
hesitate to contact Mr. Scheller at [phone].
Enclosure.
ris
Sincerely.
Roberto L. Scheller
Environmental Technician IV
919 NORTH MAIN STREET, MOORESVILLE, NORTH CAROLINA 281 15
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10% POST -CONSUMER PAPER

DEPAT
NAT
Permit No, NO000501,1
STATE OF NORTH CAROLINA
ENVIRONMENT, HeALT-H, AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
ONAL POLLUTANT D
HAR E E MINATION TE
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
Comnaission, and the Federal Water Pollution Control Act, as amended,
CBP Resources, Inc.
is hereby authorized to discharge wastewater from a facility located at
Gastonia Division
US Highway 321
Gastonia
Gaston County
to receiving waters designated as Crowders Creelz in the Catawba Rive
r Bash
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I,
IL, ILI and W hereof,
The permit shall become effective October 1, 1997
This permit and the authorization to discharge shail expireat midnight on March 31, 1999
Signed this day September 5,,1997
A. Preston Howard, Jr,, P.
Division of Water Quality
By Authority of the Environmental Management Commission
TO/IO'd Sp:LT 66, 6z JPW
6T2,0-222-646:xPj

VNC TT Y GENERAL Fax:[phone] Oct 2 '98 16:31 P.01
To:
FAX TRANSMISSION
NC DEPARTMENT OF JUSTICE
Pod MOS Box 829
Raleigh, NC 27602-0929
919/716-0600
Fax: [phone]
PRESTON HOWARD Date: Otober 2, i99
REX GLEASON
JOHN LESLEY
Fax Oh [N] 9-733-2496 Pages:
(C) 704/663-6040
[C] 704/663-6040
From: Judy A. Collier
Water and Land Quality Pra1cgai
Subject CBP RESOURCES, INC.
GASTONIA DIVISION
v. NC DENR, DIV. OF WATER QUALITY
OAII CASE NOS. 98 EIIR 0082 AND 98 MIR
RE WQ FILES LV 97-029 AND LM 98-002
COMMENTS:
3 Pages (including cover sheet)]
Following please find a NOTICE OF ITEAFUNG re the above -referenced contested cases
which schedules the Hewing for October 26-27,1998, James K. Polk Building, Sth Floor Hearing
Room, 500 W. Trade Street, Charlotte, NC at 9:00 a.m,
Should you have arty qucctions, please contact Anita LaVeaux-Quistess at 919
WP6.11.279133VAC

9TT R GENERAL Fax :[phone] Oct 2 98 1 :31 02
STATEi
OUNTY F GASTON
OUR,
'IV
eta
ASTONLA
FILED.o"a
NTakIny
NC DEPARTMENT OF ENVIRONME
rtd NATO SOUC. , DIVISION OP
WATER QUAL"IPI,
Respondent.
NOTICES
Y GIVEN that
1
DATE:t b r - `, 1998
IM
Polk
M►�
Rearde St
Chariotte„
the of Septa, ber,
mutes
THE OFFICE
ng

Fax ;919- 16-69 9
f the fh oing was
Ramona Cunnt.r()Bryan.
Smith Helms Mulli
PO Box 21927
on°. NC 27420
Attorney forPetitioner
Anita LeVeaux-Quigless, E q
Assistant Att ey Gen .
NC Department ofiu ti
PO Box 629
Raleigh, NC 27602
Attorney for R
t ttj
day
29 16 2 P. 6
0fft f : tt
Raleig .. 76 1-7447
719/733.2698
Pax: 7 - 407

VNC ATTORNEY GENERAL Fax:[phone] Oct 2 '98 16:33 P.01
FAX TRANSMISSION
NC DEFARiMENT OF JUSTICE
Poet Office Box 629
ROleigh, NG 2/602-062,9
91 ea 16-6600
Fax [phone]
To: PRESTON HOWARD
REX OLEASON
JOHN LESLEY
Fax ; [NI 9-733-2496
[C] 704/663-6040
(C] 704/663-6040
From; Judy A. Collier
Water and Land Quality Paralegal
Subject; CBP RESOURCES, INC.
GASTONIA DIVISION
v. NC DENR, DIV. OF WATER QUALITY
OAH CASE NOS. 98 EUR 0082 AND 98 ERR 0552
RE WQ FILES LV 97-029 AND LM 98-002
COMMENTS:
Date; October 2, 1998
Pages: [3 Pages (including cover sheet)]
Following please find a NOTICE OF HEARING re the above-refereneed contested cases
which schedules the nearing for October 26-27, 1998, James K. Polk Buildin 5da Floor Hearing
Room, 500 W. Trade Street, Charlotte, NC at 9:00 a.m.
Should you have any cpcationa, plc ont&t Anita LeVeaux-Quislaw at 010/71G-6600.
WP6.1+.219$3 \JA,C

Fax: - 716 9 Oct 2 1
STATE F NORTH
COUNTY T...
U:INC., ASTO
DIVISION,
Ftiti
FLED►
ADRIN
NC DEPARTMENT OF E VIRONMENT
'd AT MC T t i
WATER U ITY,
ondent.
NaricEis HEREBY GIVENthat the above con
DATE: Oetc
TIME- :00
This
day of pte
27,
NOV. OF
HE
cheduled

tTT
Fax m9-
A copy of th ng
;
na Contain a ntn
Smt It
PO Box 21927
Greensboro, NC 27420
Attorney for Petitioner
Anita a -i
A i tant Attorney Gene
NC Department of Justice
PO Box 629
Raleigh, NC 27602
Attorney for Rz�dat
tti day tof September,
d to:
It t
P.O. . 7
Raleigh, NC 27611- 44
919r733-2698
3

T:
AND SECTION Fax : 1 - 16-6 66 Oct 28 ' :12 P. 01
Buse
Toi y tns
Rex Ole
Subject:Resources, Inc.
ENVIRO Era,t
Mita L` veauxa
.w o
919-7 0
Date: t
CObe vises that have 0l
i ady fi : , ~; s 'Bryant ()fay cone
Thanks.
including is cove shed.

!plpr WATER & LRND SECTION Fax:[phone]
z4/94 11 : 4IS .F.,LE 33E3700430 SMITH HELMS MULLISS GS0_,
Oct 28 '98 14:12 P.02
/003
SMITH HCLMS MUILLIO$ ftr Moo,RE L L
ATT OR N E YS AT LAW
C 1.1 AR lOTTE GrICCINSCIOno, NQRTM C.AnoLiNA rsewgicill
PozT Orr= BOK 3ZAT WIMP orrice 16.1.1. *Me%
C.I.IAPILCA.12 ., N.
MAILI Me AZDIWA1 ETTIL CT AO MEMO fl,A1M,Hati. ,*, C- .,,c./
Witt OFF/GE EIOX 219a7 41-4 OW mac'
TELF.Pil ONE 79Arama./Ma9 nra..s.N43 .4 a .1=0,41111-11750
PACIVM Le 70-413.1441‘, Vrftfi 160101 liM U. PC, Q, gr4iim a00 HOET4 lifiELly E 3TRELT
IIRERY4illeata, hl , 6, a A.01 r ^GINN I id wrairytoomo
vrairsm. wardionaboarar
WPS ITT FIC evr ;AL
335/37&5227
Anita LeVeaux-Qtfigless Esq.
Department of Justice
Environmental Division
1`.0_ Ws 629
Raleigh, North Carolina 27601-0629
Dear Anita:
TELE16.6...c, MI-11,11031.741,4FINK.
FAC.00 !LC 3-pc/7794MM,
October 28, 1998
CAP Rosources, Inc. Y. Diviaion vfWater Quality
Settlement of 98 ERR 0082 and 98 EHR 0552
immiLeliniul.lown
1 received and have &cussed with my client your letter dated October 23, 199R Rased
on my discussions with my client and subsequent conversations with you, this letter will confirm
our understanding Of the Settlement of the above -referenced contested cases.
1. CBP will pay % af the °amending penalty amourdated Deo:nib:x*16, 1997
and March 19, 1998, plus investigative costs, which Vale $23, 929.10. This payment will be
made to the Departinent no law than December 1, 1998.
2, For any and all NPDBS permit vioiations for the period from December 1, 1997
tittOugli June 30, 1998, the Depot:mesa will assess a Mal penalty of $5,8.50.00. CRP'S payment
of this amount by Dezember 1, 1998 will reptesent fall settlement of these violations.
3. me Department aames that lime will be nu penalty assasment for violations that
havor miy,ht occur during tho pedod foam* cBral atsbulissioa tif SOC appliation Ott Juno
30, 1998 through termination of the company's discharge from outfall 001.
4,60 ClilLit
4. The Department agrees that CDP may thscharga from ()Wall 001
until December 1, 1998, at which time ttieternptuty agrees to terminate the discharge,
inform the Department in writing of such ternitueine and withdraw the SOC applicadon.
LAW flRM roR role tese Specula_ OLYMPiCa WORLO GAME:9

Ld TER
ea�ua 1
ECTIrN Fax 66
33PS379U4394 S? IITTR
Oct 28 "98 14:13
LLISS GSC .,
P.03
LeVeaux-Qtdilemi Esq
October 7.8, 1998
Page 2
S.
receipt or written
ttegotiat©d deadline
Thank you for your
cc: Mr. Van Jones
zb
th«o
Very truly y
SMITH HELMS MUL :_ISS & M 0

WATER i LAND SECTION Fax:[phone] Nov 16 '98 16:05 P.01
M1CHA111.r.RA I,f'rY
n7-Tfl NPV U NFJ A
Ramona Cunningham 0' iryertt, Esq.
Smith Helms Mulliss & Mr cx , LLP
Post Office Box 21927
Greensboro, NC 27420
e of North Carolina
vepEirrment of Justice
P. U. 130X 629
RALEIGH
2 7602-062 g
November 16, 1998
RE: CBP Resources, Inc. v. DENR, Division of Water Quality
98 EHR 0082 and 98 EHR 0552
Dear Mona:
REPLY TO:
Anita LeVeaux-Quiglaas
Etw ron,nonto! division
[phone]
[phone] Fax
It's be a pleasure working with you. Hopefully, the following meets your client's approval.
We are in receipt of your November 2r 1998 letter enumerating the terms of the settlement of CBP
Resources, Inc. v. DENR, Division of Water Quality. As previously discussed, your client will not be
receiving a separate civil penalty assessment for $5,850.00, i.e., the period beginning December 1,
1997 and ending June 30, 1998. Accordingly, we will be expecting two i2i checks from your client:
one for $23,929.10 and one for $5,850.00, Receipt of these monies along with full and complete
compliance as more specifically described in the settlement letter of November 2, 1998 will fully and
completely satisfy the civil penalty assessments for both cases, i.e.; 98 EHR 0082 and 98 ENR 0552.
If you have any questions, please feel free to call.
ALQ sin
Tommy Stevens
Susan Wilson
Rex Gleason
EP•28920
Very truly yours,
Anita LeVeaux-Qui
Assistant Attorney nerai

1995
MICH.AEL F. EASLEY
ATTORNEY GENERAL
State of North Carolina
Department of Justice
P. O. BOX 629
RALEIGH Reply to:
27602-0629
October 23, 1998
.Anita LcVcwa-Quillen
Environmental Division
[phone]
[phone] (Fax)
SMITH HELMS MULL MOORS, F,LP
Ramona Cunningham O'Bryant, Esq.
Post Office Box 21927 BY FACSIM.. E 'B! . 'I T L4 S 4
Greensboro, North Carolina 27420
RE: CBP Resources, Inc., Gaston County, 98 EHR 0082
Dear Ramona:
This letter confirms our October 19, 1998 conversation. Your client, CBP Resources
Inc., has two outstanding civil penalty assessments. On. December 16, 1997 an assessment for
eleven thousand and ninety-one dollars and thirty cents ($11, 091.30), including investigative
costs of two hundred and ninety-one dollars and thirty cents ($291.30) was mailed to your client.
On March 19, 1998, another assessment for eighteen thousand six hundred and seventy-two
dollars ($18,672.80), including investigative costs of two hundred and ninety-seven dollars and
eighty cents ($297.80) was mailed to your client. As per our conversation yesterday and at my
client's, the Department of Environment and Natural Resources (DENR), direction, a settlement
for 80% of the assessments plus the investigative costs, twenty-three thousand nine hundred and
twenty-nine dollars and ten cents ($23,929.10) was reached between our clients.
Also discussed was a forthcoming assessment against your client from the end of the
period of review of the last case through the application date of the SOC, i.e., for violations from
December 1, 1997 through June 30, 1998. For these violations, we will agree to a full and
complete payment of five thousand eight hundred and fifty dollars ($5,850.00). This, I believe
your clients will agree, is more than fair. Finally, it was agreed that your client would
withdraw the SOC, firmly commit to cease discharge from outfall 001 by November 15, 1998,
and notify the city of Gastonia of the negotiated deadline.
I greatly appreciate your cooperation in the settlement of this matter. If you have any
questions, please feel free to call me at the number set out above.
wp6.1128269
bcc: Preston Howard
Tommy Stevens
Coleen Sullins
Susan Wilson; Rex Gleason

From:
Di
SecTionn
C* E * 'TMENT OF
OFFICE
919 North Main Street
Mooresville,North Carolina 23115
Phone: [phone]
Fax: [phone]
To
Fax number
Subject;`___
Number
(including cover)

Items for Disclosure from CBP Resources
1. Pounds per day of raw materials processed over the past 3-year period.
2. Logs detailing time in for materials and time materials processed.
3. Documentation of new process equipment installed for water conservation.
4. BOD, TSS, and NH3-N concentrations entering the WWTP.
All laboratory bench sheets, QA/QC data, and analytical results from the contract la1 and
from the on -site lab which were used for reporting during the past 3 years.
WWTP process control data.
7. Water use records and/or influent flow records.
Questions
1. Do you dispute that the violations occurred?
2. Are you challenging the validity of the data? If so why?
3. What is the basis for the Administrative Hearing request?
4. Would you settle for a reduction in the penalty should the Director agree to offer a
reduction?
5. What is the basis for requesting an SOC? What interim limits would you seek?
6, How long will it take to complete the sewer connection to Gastonia?
7. The City of Gastonia and CBP are currently negotiating a permit. What difficulties are you
having reaching acceptable permit limits and other conditions?
8, How will the additional WWTP equipment currently under construction reduce the influent
loading on the facility?
9 Has production increased beyond that given in the permit application? Provide
documentation.
10. How long do raw materials wait prior to processing? Provide documentation. Is there a
refrigerated storage area available? What do you do with raw materials that set out and
begin decomposing?
11. The aerated lagoon appeared to be much improved during the last inspection. How has this
been accomplished? felD,
12. Permit Limit violations occurred in March and,..-1998. Why did CBP cease sending
the blood and feather wastewater (high strength BOD waste) to Gastonia for treatment? Do
you plan on this waste stream to the City since these violations occurred? Are you
compliant for May 19' M ? ,^ t c`f
ch
13. How have Toxicity limit failures been addressed?
14 Describe the wastewater treatment processes that will be kept in service after connection to
the City of Gastonia.
15. What measures is CBP taking to ensure compliance with its NPDES Permit?
16. Explain why CBP cannot meet the permit limits (i.e. why is an SOC needed)?

did BP
using a c b to p o.: pie
prior to s to r i lab?

Tit
cr3.1)
castro,ma
‘+: C
P. O. BOX I74e
tern, artI Caralitut 28053-1748
DEPARTMENT or
Pusuc WoRks AND UTILITIES
May 13, 1998
Mr. Mel Roshanraven
Post Office Drawer 20687
Greensboro, NC 27420
Dear Mr. Roshanraven:
In the autumn and early winter of 1996, CBP proposed elimination of its biological treatment. As a
result, the City had J.N. Pease provide estimated costs of building a SBR treatment unit on the
Crowders Creek WWTP property, which would be necessary if CBP eliminated treatment. CBP
declined this proposal. From that point forward, the City understood that CBP would maintain their
current biological treatment or add to the current treatment if deemed necessary. No information
was provided to indicate otherwise. This is further confirmed by the permit application which
indicates current processes to remain in service. In a letter dated 2/20/98, resulting from the permit
application review, City Pretreatment requested CBP to provide information from your consultant
engineers as to what changes will be made to your current Gaston facility and what concentrations of
pollutants are expected to be discharged per their recommended changes. No treatment changes
were reported. Conversations with Van Jones on 3/18/98 , 3/20/98, and 3/24/98 specifically dealt
with this issue and, on each occasion, Van stated that no treatment changes would occur.
The purpose of the meeting held at the Catawba Creek WWTP on April 17 was for discussion of the
draft SIU permit developed by City Pretreatment and for discussion of written documentation that
CIO was to provide, at the meeting, regarding its needs. During the meeting, you and Van
announced CBP's plans to discontinue some treatment and the need for permit limits above those
proposed in the City's draft permit, but provided no written information, City Pretreatment agreed to
review any written documentation that CBP would provide and then consider the extent of any
revisions to the draft permit.
On May 7, you delivered a brief letter to City Pretreatment which lists data of your primary effluent.
There is no statement of request or intent, but the inference is that you would like to discharge such
flow to the City without further treatment. Such discharge would not be within the limits that you
have requested. For example, you have requested a 1000 mg/1 BOD limit expressed in lb/day, an
amount significantly higher than the 250 mg/1 proposed by the City. Yet, according to the figures in
your 5/7/98 letter, CBP would violate the 1000 mg/I, expressed in lb/day, by discharging an average
of 235% above that amount of Ib/day. The lb/day would be significantly higher with increased flow,
discharging 475% more lbs at the permitted flow than you have requested in your permit application.

1. Permit limit if established per CBP's request:
0.417 MGD x 1000 mg/1 BOD x 8.34 lb/gal = 3,478 lb/day.
2. Actual discharge per your 5/7/98 letter and using average '97 flow:
0.203 MGD x 4867 mg/1 BOD x 8.34 lb/gal = 8,240 lb/day.
3. At maximum flow:
0.417 MGD x 4867 mg/I BOD x 8.34 lb/gal = 16,926 lb/day:
These numbers clearly indicate that the existing biological treatment must be kept in service, Your
proposal to decommission the biological treatment system is not acceptable. The biological
treatment process is an integral component of your pretreatment system and must be maintained
according to permit requirements.
We desire to assist CBP in meeting its wastewater treatment needs and plan to issue the SIU Permit
in the near future. Per your request, the City is considering revision of the draft permit as follows:
1. Delay the effective date of the permit from July 1, 1998 to September 1, 1998..
2. Establish monthly average limits with increased daily maximum limits. The draft permit
listed daily maximums for BOD and TSS of 250 mg/I, O&G of 50 mg/I, and NH3-N of
100. We are now considering the following: BOD daily max of 1.200 with monthly avg
of 400; TSS daily max of 1200 with monthly avg of 400; O&G. daily max of 150 with
monthly avg of 50; N1-13-N daily max of 300 with monthly avg of 100.
3 Require 1 screening per the City's protocol to occur within 90 days following
connection. This will be the case only if CBP passes. the. May toxicity tests. if CBP does
not pass the May toxicity tests, the City wili require toxicity screenings during each of
the first three months of discharge. The result of the City's toxicity screening(s) will
affect the subsequent frequency of testing and such frequency will be at the discretion of
the POTW Director.
4. Revise page 18, dealing with maintenance of the flow meter. Equipment shall be
installed and maintained either at the permittee's sole expense, or in accordance with any
agreement between Permittee and City.
Based upon extensive analysis of information provided by CBP, your SIU permit will be issued June
1, 1998 with changes as indicated above. Please call if you have questions.
Sincerely,
CITY OF GASTONIA
Nancy iTMa
industrial Chemist
pc: Don Carmichael, Director of Public Works & Utilities
John R. Sheller, Asst. Director of Public Utilities
Coleman Keeter, Superintendent WWTD
Larry Curn mings, Asst. Superintendent WWTD
Dennis Redwing, Deputy City Attorney
Van Jones, CBP
Gene Olberding, CBP
John Lesley, NCDWQ
Certified Mail Z 010 627 828

Mr. l rry Cummings
City of Gastonia
Wastewater Treatment Division
P.O. Box 1748
Gastonia, NC 28 53-1 8
Dear Mr. Cummings -
Gastonia Division
CBP Resources, Inc.
Pursuant to our meeting P April 20, 1998, CBP resources, Inc; (CBP) requests mass
based wastewater at r discharge limits in the Industrial User Discharge Permit (P it) for the
Gastonia plant of CBP.
luring the week of. April 20, 1998, the effluent nt from the pan -site primary waste vat r
treatment system was sampled and the analytical data in ppm is asfollows;
BOD
TSS
FOG 39 2
Phosphorus 1
Ammonia -Nitrogen 360
/21 /8 /22/8 /23/8
7,000 3,600 4,000
970 1,200 840
5
If you havu any questions pi se let us %r<i
Sine
Van Junes
l nvirc nmental anage
54 3
"ork RrS Gast+ rreia„NC 28t752 704•84- r Fax 704t86i 252 Direct Dial Number

P. O.BOX 174A
ORPARTMENT or
minute WORKS AND LITRArt
April 6, 1998
Mr. Gene 011 ending
CI P Resources
533 South York lid,
Gastonia, NC 28052
bear Mr. Cilla rding:
748
draft Sig l ,; I l tri l User Per it f r C P Resources, Inc. is enclosed. t 'lc ditica ions of,
and additions to, the previous permit were made throughout. Please note that this permit replaces the
previous SID pert if and no longer authorizes the hauling of wastewater to the CrowderCrowders WWTP via
tamer.
Toxicity is listed in the permit as being r ai ored at a frequency designated by the POTW Director.
Due to'Cars history of toxicity problems, fire POT ' Director has determined that the City will
have toxicity screening perfumed on your discharge during each of the first three months of
discharge via this permit. The coast for each screening is $1300 in addition to the composite
sampling fee of 00 each. At your option, you may retake suitable arrangements fora laboratory o
your choice to conduct the screening, however, the City of Gastonia Protocol enclosed must be
utilized.
City staff encourages you to review the tatodificatioans attd identify any concerns informally. Please
respond by April 20, 998 so that we may proceed Nr°ith finalizing the penult. Please contact rite at
66-6t 5 .
noel,
an OF C AS fONI
Nancy math
Industrial Chemist

SW INSPECTION FORM
Name of Industry: CRP Resources, Inc.
Address of Industry: 5533 South York Rd
Gastonia, NC 28052
Industry Representatives: Van Jones
POTW Representatives: Nancy Mather!'
Date of Inspection: 3/24/98
KIP 1047
Expiration Date:
Title: Environmental Alanager
Title: Industrial Chemist
Time of Inspection: 900 am.
Purpose of tnspection: Annual X Other(describe) Prior to permitting- new discharge
POTW to which IU discharges: Crowders Creek PVIVIP NPDES # NC0074268
Is SIU currently is SNC? No. If yes, for what parameters and what corrective action is being taken?
Part I - INITIAL INTERVIEW
1. Has anything changed since the last inspectLofl or IUP application in the following:
Comments
Product Yes/No
Raw materials used Yes/No
Manufacturing processes Yes/No
Categorical, if applicable Yes/No
Production rate Yes/No
Number of employees Yes/No
Number of shifts Yes/No
Shift information: Hours Days # Employees
lst
2nd
3rd
Comments: Two 12. hr s s work 7:00 - 7:00 fo average of 65 days/Week,
90 employees,
3, Has the facility implemented any of the fol 3wi g? Yes/No If so, detail:
water conservation techniques:
recycling, reusing, selling pollutants:
Iledisposal methods of pollutants:
Comments:
4. Is the facility currently operating under any other environmental control permits, i.e, RCRA,
groundwater, air, etc:? NPDES NC000501 1; Air 3509R14; Stornn ater „i'VCG060173
, Does the. facility anticipate any changes in plant operations which could change present production rates,
water use, or wastewater characteristics? Yes/No Comments: User has been hauling one
wastestream to the POTPV via tankers, User has recently applied to discharge all wastewater except
non -contact cooling to the POTTY. User mar further increase low, discharge in future,

Part II - Plant Tour - Visit all areas where wastewater is gencrated or where there are drains to the
POTW.
Plant Tour Section A - Production and Storage Areas
1. Are all processes operating normally today? Yes/No Comments:
2. Are there floor drains in the production area? Yes/No Where, do they go? Gravity ow to liftstatiot
and then to pretreatment
3 Are production areas diked, contained, or otherwise constructed in such a way as to prevent harm to the
W\VTP, especially from spills or slugs? Yes/No Comments: Valves can be shut so that spilled
product can be re-claimed. Animal and vegetable oil tanks are all diked or are located inside the plant.
4. Are there floor drains in the storage area? Yes/No Where do they discharge to?
5. Are storage tanks and areas diked, contained, or otherwise constructed in such a way as to prevent harm
to the WWTP, especially from spills or slugs? Yes/No Comments: All diked except .114g0H.
6. Are process and storage tanks and pipes labeled? Yes/No
7. Hol,,v are off -spec raw materials, and products disposed of? Utilized anyway.
8. When is the production area cleaned'? Daily.
Is the wastewater from cleaning the production area discharged to the POTW? Yes/No
Describe the facility's floor and equipment washdown procedures.
frequency: Daily.
What detergents/solvents/degreasers are used? None; use caustic soda and hot 'water.
Are high pressure sprays used? Yes.
How is wash Water disposed? Pretreatment,
9. What non -process wastewaters are discharged to POTW?
Number of boilers: 3 Number of cooling towers: 0
Frequency of blowdown: Daily Frequency of blowdown:
Volume of blowdown: 25,000 gpd Volume of blowdown:
Additives: IWO provided; no biocides used. Additives:
What other non -contact cooling water is utilized? Heat exchanger,
What is the disposal method of non -contact- cooling water? Discharged to Crowders Creek via NPDES,
What contact cooling water is utilized? Cooling,
Is contact cooling Water treated prior to disposal? Yes„ques through pretreatment.
'What contaminants are present?
10. Are chemicals handled or stored outside the -facility? Yes,
If so, Where does rainwater from these areas dram! Crowder, creek.
Are hazardous wastes generated or stored on site?
if yes, attach sheet cursorily addressing the following for each hazardous Nv aste:
a. name of waste
type of waste petroleum; 25% caustic;
c, hazardous characteristics WWI ibr pond adjustment;
d„ annual quantity generated Sodium chlorite.fin. air scrubbers.
e. waste source Also uses alum; polymer; boiler
f, average quantity stored additives.' animal & vegetable
g., storage method and location
1-1, disposal method

Part II - Plant Tour Section B Pretreatment System
Ask the operator to describe pretreatment system.
1. Does operator seem knowledgeable about the system? Yes/No Comments:
2. Are all units operational? Yes/No Comments:
3. How often does operator/maintenance person check system? Daily,
4. Is there an operator for each shift? Yes/No
5. How and when is sludge disposed of? Sludge is rendered.
6. Is there a schedule for preventative maintenance? YesfNo
7. What is the facility's equalization capacity in gallons? .10.5 MG (3 ponds)
8.. Has the facility added any pretreatment since the previous inspection? Yes/No
If so, why? NA
What are they treating?
What are the by-products, if any?
What is the method of disposal?
9. Describe the pretreatment system used by this facility.
Current: gravity separator, flocculazion, dissolved air ion, activated sludge, clarifier, pH
adjustment.
Planned Changes: Will addflow equalization basin, Will replace: gravity separator, DAF, cla .er.
Notes:
Thefirst 2030.-minutes ofstorrnwaier is collected and sent to the User's wastewater treatment system.
- The biofilter treats airfrom the blood and _feathers. Condensate and irrigation water om the biotilter
flows to the activated sludge lagoon.
10, Pretreatment Facility
a. Is standby power available? No.
b. Do alarm systems exist for equipment failures? No, but will infuture.
c. Is there adequate disposal of sludge and solids? NA
d. Are all treatment systems operational? Yes
e. Has system experienced operational problems? Yes. If yes, explain. ilas had numerous problems
meeting NPDES limits.- received fines from NCDWQ.
f. Are emergency notification procedures posted? Yes/No Comment PVillpost infuture upon
discharge,
Part 11 - Plant Tour Section C - Sampling 'ruing's) and Flow Measurement
Does an outside lab complete sampling? Yes/No if yes, name of lab: Prism,
2. If industry completes sampling, ask the industry representative to describe sampling procedures.
Comments:
Which meter is being utilized, City water meter or effluent meter (in future) ?
What was date of last effluent meter calibration?
Did Pretreatment receive vvritten notification? Yes/No City will calibrate meter infu(ure.
4. Is flow measurement equipment operational? Yes/No Comments:
5. Is there a calibration log for the flow meter? Yes/No Comments:
6. Are the facility's domestic and process wastewaters segregated? Yes/No
7, Does the facility have a sampling point which is representative of the process wastewaters discharged?
Yes/No Comments: Will in future.

Update of ow nnforrrration: See per atrit ap ac° to r. Avg d st rge is 203 GD..
GPD Estimated or
Measured "?
Domestic wastes (r str corns, showers, Estimate 25
gallons per person per shift, if unknown.
Non contact cooling water
Boiler/Cooling Tower blowdorvn
Contract cooling water
Process
l quipment / ftacility \ al rdocvn
r Pollution Control
Storm water runoff to sever
Other .cecrifad
E aporatt
Other
,v
e ie\v MOT
Are
Are s
o res
Do aft cl
Col
antes discharged?
tier
ords aand other; IU records retiuirccl by 1UP,
ell organized? Yes/Io Comments.
tale collection chain of custody forms filled out properly`? No Corn
is in lilts agrees With reports sent to POT `? Yes/No Comments; NA
its match data reported?` Yes rho Comments: N 1
oted date and time on charts"? 't'cst"No NA'
ror ty° to shut down production should a spilt or slug diseharge occur? Any E management
ts"
s does SIU inftrrnt rnployc es of °laotn to call ttt P0'1 W €n case of
City number s c rxc?1rst in SPCC fry
ady required by P0T €, rev`ie procedures.
rtplctrrcrrtin lu ispill plans? lesiNo Com gents:
v violations year to date. Failed tra scrirrlrlcr l f called l a tr-ovid
rchain of etr.slod)
P
ants.
neratatian on dais insectir
onitor'i
tot be sr
eor
'quires s r
a Ns
colic c;ticar and analysis procedures,
hart.
retriesmast he

10, Have reports been deficient? I " o, note deficiencies,
Categorical standards
OCPSF
Electroplaters and Metal ]°mi hers Verifieation
Order of Consent,
Administrative Order
Notice of 'iolation Response
X Self-Mortitoring User has failed to roil
s
Li Demi
any reports v lricl were required that have not been submitted.
petition Resa
a /Spill Control Plan needed? s/No 0,0411e,
Comments 1 Required or Recomcnetided Actions:
Required Action: rr ictaare, upon dischazrg,
following ?lumbers be atll&/ in eitse of,slug or ill o the ,se
beeper 0389 at any time The City may r require additional
naal i
in the neaar azure
n
nerous occasions
ocata n an site, aanul llst it S`p C, that
system- 86-6r05i' during -5 or 65-0099,
f be zna:lutlad it t aeSlu "pill Control Mon

X f 7x
PART T
13, 1998
N1r, lvlel Roshan van
Cf P Resources, aurces, Incorporated
7410 Randolph Road
Greensboro, North Carolin. 7446-7910
Reference, Utility Service Account
Average Water Charge for 106 and 97
Dear Mr. ltshararavaat;
In r-spans e tca aaur eaalier rec3atest l any ftarwaardm a s
Average and relaateal revenue. "1`la s as you
usage rates which wi1I be inccarlaartated a
Average
laa,atlaly 'rater Usag
ry of ealculatirtn to det raaaine dater Usage
is basis for estaablisli
Service Agreement.
aaaaaaaaaary of Calcula
and sewa*.....r
aid Revenue has d upon 1996 arid 1 97 utility records: .856 MI
Customer Charge
Availability Charge laased aupctia <a ''
Tot al I fixed l" ee
Volume Charg 500,000 Gal as 3.34/Tv'
Volume Charge 356,000 Gal ct 3.14,,t °
3"utal Voluirte Naar e: 17,20 :00
I would hope this as
Sincerel
66,40
6.61
1,6700
®3,00
Total fixed Fees and Volum Cka rge; 12 276,66'
Rate Adju
e
of 6 % for fiscal year 1 '7 / : S13,013.00
r gasestion lataavever if you desire to discuss please advise;
As sta..nt Directcar of ljtilitie
pc: Donald E. tti"arnaiclaael
Dennis I edkvin
Larry Cummings
Gene C lberding„ C 13P
uacrces4 Inc:

Gastonia Division
OW Resources, Inc.
March 3, 1998
Ms, Nancy Matherly, Industrial Chemist
City of Gastonia
PO Box 1748
Gastonia, NC 28053-1748
Subject: CBP Resources, Inc., Gaston County, NC
Industrial User Wastewater Discharge Permit Application
Dear Nancy:
This is in response to your February 20, 1998 letter to Mr, Gene Olberding, which
addressed the need for some additional information regarding the subject application,
Please note the following based on your request:
1, The Gastonia facility of CBP Resources, Inc. (CBP) has 90 employees working daily.
2, Although production averages six (6) days per week, flow equalization accounts for
the stated seven (7) days per week industrial discharge.
3. The attached 1996/1997 NPDES Discharge Monitoring Reports provide the necessary
information required by Page 14 of the application,
4, Pertinent information has been completed on page 7 of the application.
5. Appropriate information is provided for pages 11-13 of the application.
5533 S. York Rd, • Gastonia, NC 2i3CJ52 • 704 864.9941 • Fax # 704
61-9252 • ©iTect ©ia1 Number:

Page two
6, Over the past year, CBP has negotiated in good faith with the City to establish
the permit limits in pounds per day for the pollutants known to be present in CBP's
discharge, This issue was discussed at length during the February 23, l998 meeting
attended by John Shuler, Coleman Keeter, and Larry Cummings of the City of
Gastonia Department of Public Works and Mel Roshanravan and Van Jones of CBP.
At the conclusion of the meeting, CBP was assured that the attached projected eflluent
values will be used to establish CBP's SIU permit limits and not the data from its
NPDES discharge to Crowders Creek,
Should further information be necessary, please let me know.
Van M Jones
Environmental Manager
Enclosures

P.©.B©X t748
lartlj (Enrolinn 28053-1748
DEPARTMENT O
PUBLIC WORKS AND UTILITIES
February 20, 1998
Mr, Gene Olberding
CBP Resources
5533 South. York Rd.
Gastonia, NC 28052
Dear Mr, Olberding:
The City has received on this date your permit application for wastewater discharge via the City
sewer system. A preliminary review indicates that additional information is needed. As required by
the City of Gastonia Sewer Use and Industrial Wastewater Pretreatment ordinance, your application
is being returned to you along with our request for additional information. Please provide the
following as soon as possible so that we can begin a formal review of the application:
1. Question #5 of the application: Please provide the average number of employees working daily.
2. Question #5 of the application: The application states that production is 6 days/week. The cover
letter says industrial discharge occurs 7 days/week. What is the source of discharge on the 7th
day?
3. Question # 10 of the application was not answered. Attach a copy of laboratory analyses
performed in the last year on the wastewater discharges from your facilities. This must include
toxicity testing.
4. Page 7 of the application must be filled in as completely and accurately as possible.
5. The Wastewater Pollutant Checklist, pages 11-13 of the application, were marked as being not
applicable. This information must be provided..
6. Information from your consultant engineers as to what changes will be made to your current
facility and what concentrations of pollutants are expected to be discharged per their
recommended changes. (An Authorization to Construct is required prior to construction.)
Sincerely',
CITY OF GAST©NIA
44
Nancy R. , atherly
Industrial Chemist
Certified Mail: Z 010 627 820

2/19 el phoned, Van showed him my later dated
€7, and #8 as they are trot any of our business:
a/98. Me!' says it
uses
provide items 2,

EPRTT
PUBLIC WORKS h 0 UTILITIES
February 13,998
IdaVan Jones
CBP resources
5533 South York Rd,
Gastonia, NBC 28052
1 Mr. dosses.
Please compile and return tlae inftaaaaaatiora listed below. These items are needed as part of the
perinitting process. If you have any questions, please contact arse at 866-6058.
Perm application.
. Copy of the latest I PDES perm
List of chemicals that could be iratentioraally or acc tdentaa ly discharged. Designate which of
these are considered hazardous.
I ISI S for all boiler or cooling tower additives that would be discharged to the City sewer. T ist
amount used per period of bane for each. Designate nate which ones are used in boiler and which in
cooling tower. Designate naate which ones are considered biocides.
5. lours of discharge per day; days of discharge per week.
h. Statement as to whether the process rand domestic wa testreanas are combined,
. Tonicity reports for 1 7.
. [ FIR reports for the most recent ] aaaonths.
Sincerely,
CITY OF GASTONIA
Iaadustria'Chemist

P. O. Box 1740
=firm 28053-1748
DEPARTMENT OF
PUBLIC WORKS AND UTILITIES
December 24, 1997
Glenn Sheffield
Reid Engineering Company, Incorporated
12.10 Princess Anne Street
Fredericksburg, Virginia 22401
Subject: CBP Sewer Project
Dear Mr, Sheffield:
The City of Gastonia Utilities Division has completed the review of the proposed sewer
connection for CBP Resources. The only comment that needs to be addressed is the
configuration of the connection of the force main to the metering manhole.
1 have discussed the configuration with Roger Lyman ofJohnston, Inc., the local
representative for the metering manhole manufacturer. Plastifah recommends that the
velocity of the effluent through the metering manhole be no greater than 2'/A to 3 feet per
second, Higher velocities will affect the accuracy of the metering point. Please confirm
that the velocities entering the metering manhole are within the manufacturers'
recommendations. It is also requested that a representative of the metering manhole
manufacturer review the configuration of the line entering the manhole to confirm in
writing that it meets their specifications. There are no other changes required to the plans.
Upon receipt of the conf rrr ration of the configuration of the connection to the manhole
and the appropriate permit applications and fees the plans can be approved. Please sent
the information to my office and I will coordinate the final review and approval of the
plans with the Engineering Division,

It should be noted that authorization to construct the sewer line will not be issued unti
the required agreements and permits are completed.
If you have any questquestions or need additional infor ation, please contact me at 4- -
0.,
Sineer
y,
ie .ael Bynum, IT
Utilities Division
PC: John Shuler
Lamy Cummings
Margaret Hallman
CBPss03

DEPARTMENT OF
PUBLIC WORKS AND UTILITIE
June 5, 1997
Ir, gene Olberding
BP Resources
.zrces
5533 South' 'or: Toad
Gastonia, NC 28052
Tear Mr ll erdin:
A permit application is enclosed for your completion d return. In your previous
application, many questions were u pans eercd as they were not applicable due to the fact that
wastewater was being hauled via tanner. This time, please complete this document in regard
o the long term discharge of l,s wastewater through the sanitary sever collection system
and answer all questions. If you have any questions, contact me at -6058.
Sincerely,
CITY OF GASH ONIA
Taney i . Ivlatherly
Industrial Chemist

DEPARTMENT OF
PUBLIC WORKS AND UTILITIES
September 5 1997
r. Van Jones
p Resources
5533 Truth York Road
Gastonia, NC 2.11052
Dear Mr. Josses:
City Pretreat has been in owned that your'feed is interested in discharging all rf your
avastewater try the City sanitary sewer system via connected pipeline as soon as this is feasible.
Please complete and return the enclosedparrot application as soon as possible. This will inform u
of your playas and will enable the City to progress with plans try accommodate your needs.
Dec
permits, l
Sincere
ra
er, your
1997. Al
t SID Perm and your Hauled Wastewater Perrnit both expire
n request is necessary if'you wish the City to consider renewal
mastions, please contact me at - 05
CITY Y 1 GAS l'C Nl
Nancyatherwl
Industrial Chemis
pc:
t I. Shirley Asst. l ir etc r fI'antic i tilitae
,tashar raven CBP
lberding, CBP

DEPARTM OF
PUOTTC WORKS ANrs tI
1' ecen ber 1 t 1996
rae C316rdin, +Genera!
f 1', lncttr}tnatcd
5533 South York Road
Gastonia, North Carolina 28052
Hager
Reference: Waste ter System 1rta rtverraents
C1313, incorporated
Crowbars Creek NAlastewater'1`reatnaent Plant
Gastonia, North Carolina
J.67: Pease e Associates Cttrrtntoion No. 97011
Sub
c
Acre}, t,f \Vast:C Fate
Dear 1v1r, C lbcrdin :
nary ttf Dec 6 996 Tw cetitt
agtltreciate ttteetiatg t trr staff an Deceit ther d, 1996 at wlticl
C131', incorporated beeontit
wer customer of the City of Gastonia,
discussed the lacassibi8ityof
J.bi 1'casc Associates (the City's consulting engineer) be att tlae ttteetin t °i11t an intt°ttditclion and review
estirrtat d cap grad operating costs associated with constructing an tttt sits ireatraterit facility at the
Cro ders Creek ' astcsvatcr Treatment Plant, ulalcd be funded by CBP corporatcd. The capital
costs presented were based cart a Sequence Batch Re 131) process with steel tanks and a scrubber
y^stern for odor coaatrol. The total estimated capital cost is$5,564,400 and includes contingency andl
technical services,
CBP, tricot-portred questioned
The City indicated that they
additional information oldie ;inflict
studies.
In addition to t
sys
y 0t tare
final deter
actcristies to
ouid be borne by CE3P, 1ncorpc
0
control syste , zwinch is cstitnated at $700,000,
gat°earn regarding the odor control sy^stern based ory
from C BP or as determit7ed 1>yF Pilot Plant
capital outlay alas Cit), revictitFed the estirttined annual operating budget' fur the treatinent
cd, The annual estimated operating cost is as ftallnws4

DESCRIPTION COST
Electrical $245,780.00
Electrical Pcak 122,900.00
Labor 29,900.00
Sludge Disposal 160,300.00
Administration 55,900.00
Renewal/Replacement Fund 61,500..00
Chemical Cost 25.044).M
Estimated Annual Operating Cost $701,308.00*
*Note. - Annual Operating Cost would be lo a dition. to typical sewer charges as established in the City's
Water and Sewer Rate Schedule,.
Mr. Donald Carmichael, the City's POTW Director, reviewed the current policy of the City regarding
industrial dischargers into a POTW. The current policy states that if the characteristics of wastewater
discharged from an industry are within current regulated parameters, the City will provide the treatment
process at the POTW site. If the wastewater characteristics exceed current regulated parameters, then the
industry is requited to provide the treatment process at their facility. The City indicated. that the proposed
SBR facility at Crowdcrs Creek Wastewater Treatment Plant deviates from this policy, but the City is
willing to leave the option of constructing the SEW, Crowders open for discussion.
The meeting continued with a review of the wastewater characteristics. of the waste of Cl3P„ Incorporated.
The maximum levels as provided by CBP are as follows:
Phosphorus 30 PPM
Ammonia 100 PPM
1301) 5,000 PPM
TSS 1,000 PPM
CBP, Incorporated noted a concern expressed by the City with accepting the waste without a pilot study to
determine the effects of the wastewater on the Crowdcrs Creek Wastewater Treatment Plant. A suggestion
was made that the City comaet the cities of Greensboro and Fayetteville', North Carolina which arc
currently accepting waste from the facilities of CL3P, Incorporated, The City svill follow up on this
recommendation, but still keep open the possible use for a Pilot Study.
City staff advised C13P, incorporated reuse of eMilent .water from Crowdcrs is possible. However, the
parameters required by NCI)EM !nay require additional. treatment The enhanced treatment of effluent
water may result in an excessive cost which would eliminate this supply option. Further discussions with
appropriate. State agencies svill be ongoing,
CBP, Incorporated requested that the City investigate the possibility of accepting 5,000 GPD of high -
strength waste into the Crowders Creek facility. The City agreed to run the calculatiori. to determine the
effect on the facility and the cost of disposing of the waste. The period of discharge will be for a maximum
of 60 days and if agreed upon by both parties, a discharge permit will be executed.
CBP, Incorporated stated that if the City did not want to accept the waste at the Crowders Creek
'Wastewater Treatment Plant site, they needed to know. Mr., Carmichael informed CBP, Incorporated that
the City wanted to work with CBP, Incorporated and that, at this time, n.o option is disregarded. The City
needed additional tinie to work out the specifies regarding the costs to operate the S13R facility on the
Crowdcrs Creek Wastewater Treatment Plant site.
2

In conclusion, the City indicated that they would investigate the possibility of accepting the $,000 GPD of
high -strength waste from CBP, Incorporated. A decision will he forthcoming from he City on December
I 1, 1996. The City also agreed to continue discussion of the permanent solution for the waste from CBP,
Incorporated.
We trust that this is your understanding of our meeting, if there are any corrections or additions, pease
contact us.
incSincpSe1y,
Donald E. Carmichael, P.E.
Director of Public Works and Utilities
pc: Danny Crew, City Manager
Donald Garbrick, IN. Pease Associates
Dennis Redwing, Deputy City Attorney
John Studer, Assistant Director of Utilities
CBPINCidsp

iE NATURE OF OUR BUSINESS.
October I, 1996
Mr, Donald E. Carmichael, P.E.
Director of Public Works and Oti
City of Gastonia
1300 North Broad Street
P.O. Box 1748
Gastonia, NC 28053-1748
Re CE3P Resources, inc., Gastonia, NC,
Dear Mr, Carmichael;
/1S
a. 1C-Ctt\^,
rv, rj -7 Of e
Fftv;cr- c 047 ir:-04z
pP.0‘,„irnir0c,
c 0-4 u te-1 ATE •
Oc 5 7(
4444. 400404 000
PI4v1444,4441004.4 , 404,4141
JUN 0 4 1998
'414)te Office 4,4
li.sourcci,;14)c,
IECEIVED
OCT 02 1n6
CITY OF GASTONIA
2U6LIC WORKS DEPT,
behalf of CI3P Resources, Inc, (CI3P), I Want to thank you and your staff for the cordial atmosphere of
our September 27, 1996 meeting during which the subject of a sewer tie-in between the City of Gastonia
Crowders Creek ‘vastesvater treatment plant and ibe Gastonia plant of CUP was discussed,
With this letter, CBIis making a formal request to the City to explore the, feasibility of such a tie-in as well
as the degree of service the City can provide vis-a-vis the wastewater generated by the CI3P Gastonia
operation.
CRP looks forward to engaging in meaningful negotiations with the City that would ultimately
long term business relationship between CI3P and the City,
In the mean time, if you or your staff need additional information about the qua
Wastewater discharge from the CBI' Gastonia operations, please let us know.
Sincerely,
Mel Rushanravan
Vice President, Environment & Science
cc:Gene Otherding
Van Jones
ad to a
y and quantity of
Direct Dial Number:
Corporate.
Post Office Drawer 20687
Greensboro, NC 27120
910-333•1000
f it 9 10- 3 18-013
Divisions:
Carolina By Products Co.
Greensboro. NC
Cape 1 ear Feed Products, Co,
Fayetteville, NC
Gastonia Division
Gastonia, NC
Knoxville Division
Strawberry Plains, TN
Norfolk Tallow Co
Chesapeal(e, VI\
Ctiemol Co
Greensboro, NC

TEL : [phone]
January 27, 1998
Mr_ John Lesley
NC Division of Water Quality
919NMainSt
Mooresville, NC 28115
Subject: Noce of Recommendation for Enforcement
CBP Resources WWTP
NPDES Permit No. NC0005011
Gaston County, NC
Dear John,
Jan 28'98 11:15 No,007 P.©1
Gaston Division
CRP Resources, Inc.
We are writing in response to the Janua1.y 8,1998 Notice of commendation for
Enforcement While we do not dispute the facts that constitute the referenced violations,
we believe that our ongoing et its to achieve and maintain compliance and to eliminate.
the dir'eet disc!wge to Crowders Creek weigh against the issuance of a penalty at this
time. We also believe that it would be ui the best Interest of all involved to discuss a
consent order with compliance schedule to address our facility's ongoing wastewater
situation and to provide $ar an acceptable timetable for the elimination of the discharge to
the creek.
As you are awl © the City of
Gastonia's scwcr system letter oftram t
with the City and have agreed to the terms of our most rent 1+i11>i p it renewal
which requires the elimination of our discharge to the creek ty h 1, I999. We have
been working diligently toward this connection and anticipate cot l ¢.ort prior to the
permit deadline. We have and will spend c012siderable amounts of a can y on this
project, We believe we have shown good fleith in our efforts to complete this task
5533 S. York Rd. • Gastrula, NC 28052 • 104464•9941 • Fax # 1t}4- 61-9252 • Di ta t DOI Number

RCES TEL:[phone] Jan 28'98 11:16 Na.007 P.02
Page two
lied Notice, e, we recently received an Assessment of Civil Penalties for
e believe it would be appropriate to deal with all our violations
of the strides that we have made toward compliance and ow
commitment to owned to the City, we would like to enter a consent order that will
address these issues.
We therefore request y
recommendation at this time and allow an op
order.
Thank you attd sho d

Jul 21'97 17:01 Na.© 4 F
Gastonia Division
CRP Resources, Inc.
July 21, 1997
Mr. D. Rex Gleason, PE
RegionalActing Division of Y
Supervisor
919 N Main Street
Mooresville, NC 281.15
Subject: Notice of Recommendation for Erforcemmat
CBP Resources
Gaston County; NC
ion for Enforcement.
we believe that
of $78,000) to
o Crowders creek
our ongo
achieve and
weigh against Any recon
We have been working dilipantlYto a
system so our di
the financial :rect discharge can be � maldng .
as possibly avestment necessary to reeve the discharge from the creek as soon
Wc r
may concentrate cau
working on plans to make this ties.
Should there be any q na please contact Mr, Van Jane or me.
5533 S. *MC Rd, • C,asitw. NC 28052 • 7Q4-344.994r • f 0 704•S6i 9 .5

JAMES B. HUNT JR.
GOVERNOR
WAYNE McDevIrr
Sacitirraave
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
MOORESVILLE REGIONAL OFFICE
DIVISION OF WATER QUALITY
January 15, 1998
CERTIFIED.„MALL
RETURNRE.CEIPT REQUESTED
Mr. ER. Olberding, Vice President
CBP Resources
5533 South York Road
Gastonia, North Carolina 28052
Subject:
Dear Mr. Olberding:
Notice of Recommendation
for Enforcement
Notice of Violation
NCGS I43-215.1(a)(6)
CBP Resources WWTP
NPDES Permit No, NC0005011
Gaston County, NC
This letter serves notice that the Mooresville Regional Office of the Division of
Water Quality is considering sending a recommendation for enforcement action to the
Director of the Division of Water Quality. The recommendation concerns the violations
by this facility of North Carolina General Statute 143-215.1 (a) (6) and NPDES Permit
No. NC0005011 for discharging waste into the waters of the State in violation of the
monthly average limit for BOD, daily maximum limits for BOD and fecal colifomi, and
the chronic toxicity limitation during the period from April through October, 1997.
If you have an explanation for these violations that you wish to present, please
respond in writing within ten (10) days following receipt of this Notice. Your explanation
will be reviewed and if an enforcement action is still deemed appropriate, your
explanation will be forwarded to the Director with the enforcement package for his
consideration. Please address your response to my attention at the address shown on the
letterhead.
919 NORTH MAIN STREET, MOORESVILLE. NORTH CAROLINA 28115
PHONE 704.,-663.1699 FAX [phone],40
AN EQUAL OP RTUNITY1 AFFIRMATIVE ACTION EMPLOYER 50% RECYCLED/10% POST -CONSUMER PAPER

CBP Resourees
Page
Ifyou
6 -1699.
Notl ofRecommen o for E, ores eat
questionso conce gthis tl , pleas
Complianc
Central Files
Kevin Bowden, Aquatic Toxicology oup
Gaston County Health Department
Sincerely,
Rex G1e.
A" g Region Supervisor
°reorient Group
t
s
r or
et

• 4 (L-LA;(:) ? CS• '
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
!MOORESVILLE REGIONAL OFFICE
DIVISION OF WATER QUALITY
January 8, 1998
CER1114 ItD MAIL
RETURN RECEIPT REQUESTED
ER. Olberding, Vice President
CBP Resources
5533 South York Road
Gastonia, North Carolina 28052
Subject: Notice of Recommendation
for Enforcement
Notice of Violation
NCGS 143-215.1(a)(6)
CBP Resources WWTP
NPDES Permit No. NC0005011
Gaston County, NC
Dear Mr, Olberding:
This letter serves notice that the Mooresville Regional Ohce of the Division of
Water Quality is considering sending a recommendation for enforcement action to the
Director of the Division of Water Quality. The recommendation concerns the violations
by this facility of North Carolina General. Statute 143-215.1 (a) (6) and NPDES Permit
No. NC0005011 for discharging waste into the waters of the State in violation of the
monthly average limit for BOD, daily maximum limits for BOD and fecal col.iform, and the
chro • • toxicity limitation during the period from April through October, 1997.
If you have an explanation for these violations that you wish to present, please
respond in writing within ten (10) days following receipt of this Notice. Your explanation.
will be reviewed and ifan enforcement action is still deemed appropriate, your explanation
will be forwarded to the Director with the enforcement package for his consideration.
Please address your response to my attention at the address shown on the letterhead..
019 NORTH MAIN STREET, MOORESVILLE, NORTH CAROLINA 28115
PHONE 7'04-663-R 699 FAX [phone]
AN EQUAL OPPORTUNITY AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLE0i10% POST-CONsuMER. PAPER

CBP ResourcePags
e,
you
663-1 ,.
c:
Notice nd tion for Enforcement
any questions con e"n otice, pty .>c contact
Cornplian
Central Files
Ke Bowden, Aquatic Toxicolo oup
ton CountyHealth Depaitment
Sincerely,
esley or one
D. Rey Gleason, P.E...
Acting Regional pe `sor
:orce�
et Group
704)

DIV S ON Of WATER UA
Septe
2 EM0 TO. Diann 6 theme
FROM 3. Keith Overcas
THROUGH: D. Rey laaCn"
PREPARED BY: Patricia U. Beam
SUBJECT: Enforcement Action
Fast Track (
Violation of I.C. General Statute
1 1 .1(a)(
and NPDES Permit No. NC9005011
BP Resources
Gaston County, NC
burn
Attached please flhd one C copy of the subject enforcement
document. f you have any questions, please contact ither Rex or
°aria,
Aa eats
prm

STATE OF NORTH CAROLINA NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
COUNTY OF GASTON File No. LV
IN THE MATTER OF
CBP RESOURCES, INC.
FOR VIOLATIONS OF:
NPDES PERMIT NO. NC0005O11
AND NORTH CAROLINA GENERAL
STATUTE 143-215.1(a)(6)
FINDINGS AND DECISIONS
AND ASSESSMENT OF
CIVIL PENALTIES
Acting pursuant to North Carolina General Statute (G.S.)
143-215.6A, I, A. Preston Howard, Jr., P.E., Director of the
Division of Water Quality (DWQ), make the following:
I. FINDINGS OF FACT:
A. CBP Resources, Inc. (the Company) is a corporation
organized and existing under the laws of the State of
North Carolina.
B. The Company operates a 0.257 MGD wastewater treatment
plant at Gastonia, which is located in Gaston County,
North Carolina.
C. The Company was issued NPDES Permit No. NC0005O11 on
October 20, 1995, with an effective date of November 1
1995 and an expiration date of September 30, 1996.
D. Said permit contains the following relevant monthly
average and daily maximum effluent limitations:
Parameter Limitation. Units
Monthly Average
Flow 0.257 MGD
NH3-N 140 lbs/day
Parameter
NH3-N
Fecal Coliform
Limitation
Daily Maximum
280
400
NH3-N = Ammonia Nitrogen
Units
lbs/day
colonies/100 ml
E. Monthly self monitoring reports since July 1995 have
revealed exceedances of the above -cited permit effluent
limits as detailed in Attachment A.
F. Notices of Violation concerning the permit monthly
average limitations violations at the subject plant were
sent to the Company by DWQ"s Mooresville Regional Office.

CBP Resources
Page Two
G. None of the above -cited exceedances of the permit
effluent limitations were the result of a bypass or power
failure at the plant as defined by the permit.
H. A civil penalty assessment of $500.00 (Case No. LR 94-02)
was made for late submission of a monthly monitoring
report. An enforcement case was filed and civil
penalties were assessed against Carolina By -Products
(then known as Carolina and Southern Processing Company)
following a storage lagoon breech and subsequent fish
kill in Crowders Creek in July 1988.
. The costs to the State of the enforcement procedures in
this matter totalled $ 284.30.
Based upon the above Findings of Fact, I make the following:
II. CONCLUSIONS OF LAW:
A. The Company is a "person" within the meaning of G.S. 143-
212(4).
B. NPDES PermitNo. NC0005011 is required by G.S. 143-215.1.
C. The effluent limitations contained in the subject permit
are terms, conditions, or requirements of said permits.
D. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on three (3) occasions during the
period July 1995 through June 1996 in the manner and to
the extent described in Attachment A, when the permittee
permitted waste to be discharged into the waters of the
State in violation of the monthly average permitted
effluent limit for Flow.
E. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on five (5) occasions during the
period July 1995 through June 1996 in the manner and to
the extent described in Attachment A, when the permittee
permitted waste to be discharged into the waters of the
State in violation of the monthly average permitted
effluent limit for NH -N (Ammonia Nitrogen).

CBP Resources
Page Three
F.. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit N9. NC0005011 on eleven (11) occasions during the
period Jply 1995 through June 1996 in the manner and, to
the extent described in Attachment A, when the permittee
permitted waste to be discharged into the waters of the
State in violation of the daily maximum permitted
effluent limit for NH3-N.
G. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005O11 on three (3) occasions during the
period July 1995 through June 1996 in the manner and to
the extent described in Attachment A, when the permittee
permitted waste to be discharged into the waters of the
State in violation of the daily maximum permitted
effluent limit for Fecal Coliform.
H. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC000SO11 by failing to submit an Alternatives
Nutrient 0 Analysis (for Total Nitrogen and Total
Phosphots) by the June 30, 1996 due date.
I. General Statute 143-215.6A(a)(2) provides that a civil
penalty of not more than ten thousand dollars per
violation may be assessed against a person who violates
or fails to act in accordance with the terms, conditions,
or requirements of a permit required by G.S. 143-215.1.
The State's enforcement costs in this matter may be
assessed against the Company pursuant to G.S. 143-
215.3(a)(9) and G.S. 143B-282.1(b)(8).
The Director, Division of Water Quality, pursuant to
delegation provided for by G.S. 143-215.6A(h), has the
authority to assess civil penalties.
Based upon the above Findings of Fact and Conclusions of Law
I make the following:
III. DECISION:
Accordingly, the Company is hereby assessed a civil penalty
of:
For of the three (3) subject violations
of G.S. 143-215.1(a)(6) and NPDES Permit No.
NC000SO11, by discharging waste into the waters
ot the State in violation of the monthly
average permit effluent limit for Flow.

CBP Resources
Page Four
284.30
For of the five (5) subject violations of
G.S. 143-215.1(a)(6) and NPDES Permit No.
NC0005011, by discharging waste into the waters
of the State in violation of the monthly
average permit limit for NH3-N.
For of the eleven (11) subject vio ations
of G.S. 143-215.1(a)(6) and NPDES Permit No,
NC0005011, by discharging waste into the waters
of the State in violation of the daily maximum
permit effluent limit for NH3-N.
For of the three (3) subject violations
of G.S. 143-215.1(a)(6) and NPDES Permit No.
NC0005011, by discharging waste into the waters
of the State in violation of the daily maximum
permit effluent limit for Fecal Coliform.
For failure to submit an alternatives nutrient
analysis as required by NPDES Permit No.
NC0005011.
TOTAL CIVIL PENALTY, which is percent of
the maximum penalty authorized by G.S. 143-
215.6A.
Enforcement costs
TOTAL AMOIJNT DUE
Pursuant to G.S. 143-215.6A(c), in determining the amount of
the penalty I have taken into account the Findings of Fact and
Conclusions of Law and the factors set forth at G.S. 143B-
282.1(b), which are:
(1) The degree and extent of harm to the natural resources of
the State, to the public health, or to private property
resulting from the violations;
(2) The duration and gravity of the violations;
(3) The effect on ground or surface water quantity or quality
or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;

Pur
Page Five
Whether the violations w e co t + willfully or
intentionally;
The prior record of the violator in complying or f,ili
to comply with programs over which the Environmental
Management o i n has regulatory authorit ; and
The cost to the State of the enforcement procedures.
(Date)
A Preston Howard, `r,, P*E it of
Division of Water Quality

ATTACHMENT A
Violator: Carolina By -Products WWTP
NPDES Permit No. NC0005011
MONTHLY AVERAGE LIMITS VIOLATIONS
Flow PERMIT LIMIT = 0.257 MGD
December 1995
February 1996
March 1996
NHS-N
January 1996
February 1996
March 1996
April 1996
June 1996
0.2580
0.2750
0.3450
PERMIT LIMIT = 140 lbs/day
232.8
145.0
429.0
273.0
46©.0
DAILY MAXIMUM LIMITS VIOLATIONS
NH3-N PERMIT LIMIT = 280 lbslday
January 22, 1996.
February 1, 1996
March 6, 1996
March 20, 1996
March 27, 1996
April 4, 1996
April 19, 1996.
June 6, 1996
June 14, 1996
June 21, 1996
June 28, 1996
327.0
294.7
298.0
867.0
444.8
415.0
315.0
452.6
646.0
336.0
406.0
Fecal Coliform PERMIT LIMIT = 400 colonies/100 ml
March 13, 1996
April 11, 1996
June 21, 1996
TNTC ("too numerous to count")t
TNTC
TNTC
t In accordance with North Carolina Administrative Code T15A: 02B
.0506(b)(3)(I), the reporting of "too numerous to count (TNTC) as
a fecal coliform value will constitute a violation.
PERMIT CONDITION VIOLATION
Failure to submit an alternatives analysis nutrient study by
June 30, 1996 as required by NPDES Permit No. NC0005O11.

ENFORCEMENT CASE ASSESSMENT FACTORS
Type: (LV) Limits Violations
Violator: CBP Resources, Inc.
Address: 5533 South York Road
Gastonia, N.C. 28052
Registered Agent: United States Corporation Company
327 Hillsborough Street
Raleigh, N.C. 27602
Regional Office: Mooresville
1. The degree and extent of harm to the natural resources of the
State, to the public health, or to private property resulting
from the violations:
No harm has been measured or quantified. NPDES Permit limit
violations have the potential to affect the designated uses of
the receiving stream (i.e. recreation, agriculture, water
supply, etc.) and may cause water quality standards to be
exceeded.
2. The duration and gravity of the violations:
Effluent limits violations occurred from July 1995 through
June 1996. Fifteen of the twenty-two limits violations were
Technical Review Criteria violations.
The: effect on ground or surface water quantity or quality or
on 'air quality:
Adverse effects to air quality have been documented through
complaints filed from residents near CBP Resources. It is
possible that the limits violations could impact surface water
quality.
4. The cost of rectifying the damage:
No environmental damage has been established.
5. The amount of money saved by noncompliance:
Money may have been saved, by not providing adequate operation
and maintenance of the facility or by not constructing
additional facilities to maintain compliance.
6. Whether the violations were committed willfully or
intentionally:
There is no evidence to suggest that the violations were
committed intentionally.
7. The prior record of the violator in complying or failing to
comply with programs over which the Environmental Management
Commission has regulatory authority:

CBP Resources
Assessment Factors
Page Two
A civil penalty assessment of $500.00 (Case No. LR 94-02)
was made for late submission of a monthly monitoring report.
An enforcement case was filed and a civil penalty assessed
against Carolina By -Products (then known as Carolina and
Southern Processing Company) following a storage lagoon breech
and subsequent fish kill in Crowders Creek in July 1988.
8. The cost to the State of the enforcement procedures:
6.0 hours by investigator for investigating and
drafting report @ $16.85/hour
1 hour by Water Quality Regional Supervisor
for review @ $36.52
1 hour by Regional Supervisor for review
@ $35.75
1 hour for clerical support @ $10.93
Central Office Review and Processing:
TOTAL COST OF THE ENFORCEMENT PROCEDURES:
$ 101.10
36.52
$ 35.75
$ 10.93
$ 100.00
$ 284.30
9. Type of violator and general nature of business (i.e.
individual vs. large corporation):
The company operates a rendering and recycling plant. Animal
by-products (obtained from meat packing, poultry processing
plants, etc.) are used in the production of animal feed
ingredients and animal fats.
10. Violators degree of cooperation (including efforts to prevent
or restore) or recalcitrance:
The violator has responded to the Notice of Recommendation for
Enforcement. The response addresses the options of an upgrade
of the wastewater treatment plant in an effort to prevent
future violations or connection to the City of Gastonia POTW.
A suspension of the nutrient analysis requirement has also
been requested by the violator.
11. Mitigating Circumstances:
None that we are aware.
12. Assessment Factors:
a) IWC: 61%
b) Receiving Stream: Crowders Creek
c) SOC/JOC status/negotiations: N/A
d) Copy of MP Screen: Attached.
e) Copy of Limits Page in Permit: Attached.
f) Damage: None Known.

CERTIFICATION PAGE
tify that the information in this report is true to the
best 0f' my knowledge. All violations of self -monitoring data have
been verified hy hard copy review of the monthly reports and the
appropriate e it.
e of Principal Investigator

CT:
BY:
D ON F WA R
hT
Febmaly 20,1998
Barbara Cluistian
on
Fast Track Enforcement
"violation of NCGS 1-1.106
DES Permit No,1` G . 1
ResourcesCBP l
Gaston County, NC
Attached is or ant r .a rt which d vio orsofNPOES Pennit No. NC0005011
d NCGS 1 - 1 . l a (). The Company y does not dispute the violations as stated in their response
to the Notice of R endation for Enforcement: CBP R: .ures has historically pe a "t . .t
compliance problems which app : to be related to organic overloading of i
is of the opinion that the or c loading of the facility could be controlled by CBP Reso
This Office recoimnends that civil penalties be substantial to n " c the Company that an
lows tie-in to the City of Gastonia collection system would be in their* best 'al texest
If you have questio or require additional info : tion, pl . n Jo or e.
Artaclinierits
olleenSullins

STATE OF NORTH CAROLINA NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
COUNTY OF GASTON File No. LV
IN THE, MATTER OF ) FINDINGS AND DECISIONS
) AND ASSESSMENT
CBP RESOURCES, INC. ) OF CIVIL PENALTIES
)
FOR VIOLATIONS OF: )
)
NPDES PERMIT )
NO. NC0005011 )
AND NORTH CAROLINA GENERAL )
STATUTE 143-215.1(a)(6) )
Acting pursuant to North Carolina General Statutes (G.S.)
143-215.6A, I, A. Preston Howard, Jr., P.E., Director of the
Division of Water Quality (DWQ), make the following:
. FINDINGS OF FACT:
A. CBP Resources, Inc. (the Company) is a corporation
organized and existing under the laws of the State of
North Carolina.
B. The Company operates a 0.257 MGD wastewater treatment
plant at Gastonia, North Carolina, which is located in
Gaston County.
C. The Company was issued NPDES Permit No. NC0005011 on
October 20, 1995, effective November 1, 1995, with an
expiration date of September 30, 1996. The renewed
permit was issued on September 5, 1997, effective
October 1, 1997, with an expiration date of March 31,
1999.
D. Said permits contain. the following relevant daily
maximum, monthly average, and chronic toxicity effluent
limitations:
Parameter
Limitation Units
Daily Max/Monthly Avg.
Fecal Conform 400 / no limit
BOD 680 / 340
BOD 317 / 158
BOD' 306 / 612
BOD' 285 / 143
Chronic Toxicity Quarterly @ 3%2
I The BOD limits changed in the renewed permit
2 Monitoring Frequency reverts to monthly after a single te"
failure.
#/100 ml
lbs/day
mg/1
lbs/day
mg/1
Pass/Fail

CBP Resources► Findings and Decisions
Page 2
E. Monthly self -monitoring reports for the period from
April through November, 1997 have revealed the
following exceedances of the above -cited permit
effluent limits: (See Attachment A)
F. Notices of Violation concerning the monthly average,
permit limitation violations and chronic toxicity
violations at the subject plant were sent to the
Company by DWQ's Mooresville Regional Office.
G. None of the above -cited exceedances of the permt
effluent limitations were the result of a bypass or
power failure at the plant as defined in the permit.
H. The Company's prior record of compliance with programs
over which the Environmental Management Commission has
regulatory authority is as follows:
A civil penalty of $11,091.30 was assessed against the
Company on December 16, 1997 (Case No. LV 97-029). The
Company has filed a petition for an administrative
hearing. The Company was assessed a civil penalty of
$4,734.30 (Case No. LV 96-030) on February 3, 1997.
The penalty was paid on March 19, 1997. A civil
penalty was assessed for $500 (Case No. LR 94-02) on
June 3, 1994. The penalty was paid on June 29, 1994.
In July, 1988, the Company (then named Carolina and
Southern Processing Company) was assessed a civil
penalty of $18,000 plus $2429.33 in enforcement costs
and $635.81 in damages (total = $21,065.14 Case No. 88-
49). The Company paid the assessment on October 12,
1988. The Division of Air Quality has documented 97
air permit limit violations for the period from, January
through June, 1997.
1. The cost to the State of the enforcement procedures in
this matter totaled $297.80
Based upon the above Findings of Fact, 1 make the following:
II. CONCLUSIONS OF LAW:
A. The Company is a "person" within the meaning of G.S.
143-212 (4) .
B. NPDES Permit No. NC0005011 is required by G.S. 143-
215.1.
C. The effluent limitations contained in the subject
permit are terms, conditions, or requirements of said
permit.

CBP Resources, Findings and Decisions
Page 3
D. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on five (5) occasions during July
through November, 1997 in the manner and to the extent
described in Attachment A, when the permittee permitted
waste to be discharged into the waters of the State in
violation of the daily maximum permitted effluent limit
for Fecal Conform.
E. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on three (3) occasions during May,
July, October, and November, 1997 in the manner and to
the extent described in Attachment A, when the
permittee permitted waste to be discharged into the
waters of the State in violation of the monthly average
permitted mass/based effluent limit for BOD.
F. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on two (2) occasions during July
and November, 1997 in the manner and to the extent
described in Attachment A, when the permittee permitted
waste to be discharged into the waters of the State in
violation of the daily maximum permitted mass/based
(lbs/day) effluent limit for BOD.
G. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on eight (8) occasions during
April through November, 1997 in the manner and to the
extent described in Attachment A, when the permittee
permitted waste to be discharged into the waters of the
State in violation of the monthly average permitted
concentration (mg/1) effluent limit for BOD.
H. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on eight (8) occasions during June
through October, 1997 in the manner and to the extent
described in Attachment A, when the permittee permitted
waste to be discharged into the waters of the State in
violation of the daily maximum permitted concentration
(mg/I) effluent limit for BOD.
The Company violated G.S. 143-215.1(a) (6) and NPDES
Permit No. NC0005011 on five (5) occasions during May
through November, 1997 in the manner and to the extent
described in Attachment A, when the permittee permitted
waste to be discharged into the waters of the State in
violation of the permitted effluent limit for Chronic
Toxicity.

CBP Resources, Findings and Decisions
Page 4
General Statute 143-215.6A(a) provides that a civil
penalty of not more than ten thousand dollars per
violation may be assessed against a person who violates
or fails to act in accordance with the terms,
conditions, or requirements of a permit required by
G.S. 143-215.1.
K. The State's enforcement costs in this matter may be
assessed against the Company pursuant to G.S. 143-
215.3(a)(9) and G.S. 143B-282.1(b)(8).
L. The Director, Division of Water Quality, pursuant to
delegation provided for by G.S. 143-215.6A(h), has the
authority to assess civil penalties.
Based upon the above Findings of Fact and Conclusions of
Law, I make the following:
III. DECISION:
Accordingly, the Company is hereby assessed a civil penalty
of:
For of five (5) violations of G.S.
143-215.1(a) (6) and NPDES Permit No.
NC0005011, by discharging waste into the
waters of the State in violation of the
permit daily maximum effluent limit for
Fecal Conform.
For of the three (3) violations of
G.S. 143-215.1(a)(6) and NPDES Permit
No. NC0005011, by discharging waste into
the waters of the State in violation of
the permit monthly average mass/based
(lbs/day) effluent limit for BOD.
For of the two (2) violations of
G.S. 143-215.1(a)(6) and NPDES Permit
No. NC0005011, by discharging waste into
the waters of the State in violation of
the permit daily maximum mass/based
(lbs/day) effluent limit for BOD.

CEP Reces, Findings and Decisions
Page 5
For of the eight () violations of
G.S. 143 15.1 ( ) ( ) and NPDES Pe # it
O. NC0005011, by discharging waste into
the waters of the State in violation of
the permit monthly average concentration
(mg/1) effluent limit for BOD.
For of the eight (8) violations of
C.S. 143- 15..1 (.) ( ) - d NPDES Pe it
No. NC0005011, by discharging waste into
the waters of the State in violation of
the permit daily maximum concentration
(mg/1) effluent limit for BOD.
297
For of five (5) violations of C.S.
143 - 15.1 ( ) ( ) and NPDFS Permit No.
NC0005011, by discharging waste into the
waters of the State in violation of the
permit effluent limit for Chronic
Toxicity.
TOTAL CIVIL PE , which is
percent of the maximum penalty
authorized by G.S. 143-215.8A.,
En o ce ent posts.
TOT
T �

GBP Re ources, Findings and De isi ns
Page
Pursuant to t S. 1 - 1 . A () , in determining the .count of
the penalty I have taken into account the Findings of Fact and
Conclusions f Law and the factors set forth at G.S. 1
.1 ( ) which are:
The degree and extent of harm to the natural, resources
of the State, to the public health, or to private
property resulting from the violations;
The duration and gravity of the violations;
The effect on ground or surface water quant it or
quality or . air quality;
The cost of rectifying the damage;
The amount of money saved by nonompliane
Whether the violations were committed willfully or
intentionally;
The prior record of the violator in complying or
failing to comply with programz over which the
Environmental Management Commission has regulatory
authority; and
The coat to the State of the enforcement procedures.
(Date)
.. Preston Toward, r , ,P.E. iet
Division of Water Quality

CERT ICATIO PAGE
I ce e info i ation s report is true to the best of my knowledge .
violations of self-monitonrigdata have been verified by hard copy review of
monthly reports d the appropriate pe
Signature of ' ' « iple e ti ator( :
Date:

DIVISION OF WATER QUALITY
ENFORCEMENT CASE ASSESSMENT FACTORS
Type: (LV) Limit Violation
Violator: CBP Resources, Inc.
Address: 5533 South York Road
Gastonia, North Carolina 28052
Registered Agent: United States Corporation Company
Address: 327 Hillsborough Street
Raleigh, North Carolina 27602
Regional Office: Mooresville
The degree and extent of harm to the natural resources of the State, to the public health, or
to private property resulting from the violations:
There is no documented evidence of harm to the natural resources of the State, public health,
or to private property; however, violations of permit limits would predict a compromise of
water quality downstream of the discharge. Ammonia as Nitrogen is toxic to aquatic life and
exerts an oxygen demand on the receiving stream. BOD limit violations would also indicate
an increased oxygen demand downstream of the discharge. Fecal Coliform limit violations
exceed the standard established to protect human health (200/100 ml). Chronic Toxicity
violations would indicate that the discharge is having a negative impact on aquatic life
downstream of the discharge.
2. The duration and gravity of the violations:
The violations occurred during the period from April through November, 1997. NPDES
Permit limit violations have the potential to affect the designated uses of the receiving stream.
Fecal Coliform limit violations exceed water quality standards (200/100 ml) designed to
protect human health. Chronic Toxicity test failures would predict an adverse impact on
aquatic life downstream of the discharge.
3 The effect on ground or surface water quantity or quality or on air quality:
No adverse impacts on groundwater or surface water quantity or quality have been
documented. Adverse impacts on air quality have been documented through complaints filed
by residents near CBP Resources which has 97 air quality permit limit violations documented
by the Air Quality Section. NPDES Permit limit violations would predict that water quality
downstream of the facility is being compromised.

CBP, Case Assessment Factors
Page 2
4. The cost of rectifying the damage:
No damage has been docurnented.
5. The amount of money saved by noncompliance:
Money could have been saved by failing to construct, operate, or maintain facilities to meet
limits. CBP Resources could have lowered the organic loading to the WWTP to prevent
noncompliance.
6, Whether the violations were committed willfully or intentionally:
The Company overloaded the wastewater treatment facility which resulted in noncompliance
with NPDES Permit limitations; therefore, the violations may be considered willful.
7. The prior record of the violator in complying or failing to comply with programs over which
the Environmental Management Commission has regulatory authority:
The Company has a poor compliance record. A civil penalty of $11,091.30 was assessed on
December 16, 1997 (Case No. LV 97-029). CBP Resources has requested an administrative
hearing. The Company was assessed a civil penalty of $4,734.30 on February 3, 1997 (Case
No. LV 96-030). The penalty was paid on March 19, 1997. A civil penalty of $500 (Case
No. LR 94-02) was assessed on June 3, 1994, The penalty was paid on June 29, 1994. The
Company (d.b.a. Carolina and Southern Processing Cornpany) was assessed a civil penalty
in July, 1988, (Case No. 88-49) following the breech of a wastewater lagoon and subsequent
fish kill in Crowders Creek, The Company was assessed a civil penalty of $18,000 plus
$2429,33 in enforcement costs and $635.81 in damages. The Company paid the assessment
on October 12, 1988. In addition, the Division of Air Quality has documented 97 air permit
limit violations for the period from January through June, 1997,
8. The cost to the State of the enforcement procedures:
Central Office Review and Processing = $ 100.00
6.0 hours by investigator for investigating and
drafting report @ $20.74/hour = $ 124.44
1.0 hour by Water Quality Regional Supervisor
for review @ $37.25/hour $ 37.25
1.0 hour by Regional Supervisor for review
@ $25.18/hour =$ 25.18
1.0 hour for clerical support @ $10.93/hour $ 10.93
Total $ 297.80

lase
Page
sus;
ment Factors
Type of violator and general nature of bus
:, indi idua1 ` s. large corporation)
Company is a tporation which operates a rendering l t for the iri ufacture of
feed ingredients.
Violator's degree of cooperation (including -efforts to prevent or restore) or re citr ce
The prep• . on of this enforcement ent package of file re *ews therefore, the violator
neither cooperative or recalcitrant.
l tigating ircust cs
none
1, Assessrneht Facttorsu
: d'
. Receiving Stream: Crowders Creek
c.SOCLIDC status/negotiations: CIA
d; Copy of MP Screen: Attached
e, Copy of Limits Page in Permit: Attached
f D age: None documented

Fecal Co!ift
4te
10, 1997
July 25, 1997
July 31, 1997`
September 25, 1997
October 16, 1997
ATTACH A,C ENT
m Daily Maximum Per
Reported Value
43 /100 ml
460/1 0 ird
425/100 rl
4 6/1 0 ml
5/10
t Violations
Permit L`
BOD nthly Average 1bs/day Perm
Dee
y, 1997
Jury, 1997
October, 1997
Reported Value
391bs/day
518 lbs/day
441 lb/day
BOD Daily 1VJxinu
Date
July 31, 1997
October 16, 1997
BOD nt
Date
1ri1; 1997
May, 1997
June, 1997
July, 1997
August, 199°
September, 1997
October,1997
November, 1997
Ibs/day Permit
Reported Value
93 115s/day
64 1bslday
sly Average m /1 Per
Reported Value
160 me
186 mg/1
.46 mg/1
37b t
173 m
66 mizil
166 m'
400/100 nil
4/ 1
1/1
0J/1
4/10
t Violations
Per
340 lbday
340 lbs/day
361bs/dyr
Violations
Pew
680 lbs/day
612 Os/day'
it Viola ti0s*
Perini
16
158 m
15
16
158 m
143 rrr
143

BOD - Daily in mgil Permit Limit Violations*
Date Reported Value Permit Limit
June 13, 1997 376 m1 17 m1
June 27, 1997 330 inpA 317 mgn
July 10, 1997 370 nigq 317 mg/1
July 31, 1997 370 mgil 317 mgil
September 25, 1997 471 mg/1 317 mgd
October 16, 1997 351 mg/I 285 met
October 22 1997 317 rrizil 285 mgd
October 30, 1997 350 mg/I 285 mg/1
Chronic Toxicity Permit Limit Violations
Date Reported Value P rmit Limit
May, 1997 BAD TEST2 Pass @ 3%
Jtme, 1997 Fail a 3% Pass @ 3%
July, 199'7 Fail @ 3tY0 Pass @ 3%
August, 1997 Fail @ 3°/ Pass @ 3%
September, 1997 BAD TEST2 Pass @ 3%
Octber, 1997 Fail @ 3% Pass @ 3%
November, 1997 Fail @ 3% Pass @ 3%
The permit limits ( masOased and concentration limits) for BOD changed on October 1, 1997.
2 Burlington Research documented that the September, 1997 chronic toxicity test failed to meet
Quality assurance criteria,
Values for BOD concentration were rot reported on Monthly Monitoring Reports by CBP
Resources, BOD concentrations were calculated as follows:
reported value in lbsIday
MOD x 8 34 lin/gal

JAMES B. HUN
GOVEROOR
14.4040"'"'
R
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES -
MOORESVILLE REGIONAL OFFICE
DIVISION OF WATER QUALITY
February 10, 1998
Mr. Van Jones
CBP Resources
5533 South York Road
Gastonia, North Carolina 28052
Subject: Review of Response to
Notice of Recommendation for Enforcement
CBP Resources WWTP
NPDES Permit No, NC0005011
Gaston County, NC
Dear Mr. Olberding:
CBP Resources was issued a Notice of Recommendation for Enforcement on
January 8, 1998 for violation of limits contained in the facility's NPDES Permit. The
Company's response dated January 27, 1998 has been reviewed by Mooresville
Regional Office staff According to the response, CBP is considering making
application for a Special Order by Consent.
This Office has concluded that the permittee does not meet the criteria for SOC
eligibility. 15A NCAC 21-1.1206(b)(1) states that CBP must demonstrate that the
noncompliance is not due to failure by the permittee to properly operate, manage, and
maintain the wastewater treatment system and that the existing wastewater treatment
system is being operated in such a way as to attain the highest degree of treatment
possible under the existing conditions. Because most of the problems are associated
with organic overloading of the facility and inadequate disinfection of the discharge,
this Office is of the opinion that the noncompliance is related to facility operation.
Furthermore, an enforceable schedule for the elimination of the discharge is included in
the facility's NPDES Permit.
919 NORTH MAIN STREET, MOORESVILLE, NORTH CAROLINA 20115
PHONE 704-663- f 699 FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% IREYCLEO/ I 0% POST -CONSUMER PAPER

P Resources
ICES Permit No. NC00050
e
Should CBP Resources desire a. mee to ails s sissu e, pI w e do not
hesitate to contact John Lesley or me.
merel
D. Rex GI
Wate
e: Diane Lon
ob Sledge, mpli ee Unit
Central Files
s, P.E.
Re "anal Supervisor

DIVISION OF WATER QUALITY
August 18, 1997
Linda Forehand, Compliance Group
Rex Gleason
PIZ„EP D BY: John Lesley C
SUBJECT: Fast Track Enforcement
Violation of NCGS 143-215.10)(6) and
NPDES Permit No. NC0005011
CBP Resources
Gaston County
Linda, attached are the modified pages for the Findings and Decisions paragraph H and
Case Assessment Factors Paragraph 7 of the enforcement package for CBP Resources, Thanks
for the inforination concerning the fish kill in 1988 and subsequent penalty and payment. Also
included is the copy of the inspection report and the response to the E that was not included
in your copy of the enforcement package,

State of No h Carolina
Department of Environment,
Health and Natural Resources
Mooresville Regional Office
James B. Hunt, Jr.., Governor
Jonathan B, Howes, Secretary
SION OF WATER QUALITY
1997
CERTIFIED D MAIL
RETURN RECEIPT REQUEST II
Mr. E.R. Olberding, Vice President
Carolina By -Products Resources
5533 South York Road
Gastonia, North Carolina 28052
Subject:
Dear Mr. Olberding.
Notice of Recommendation
for Enforcement
Notice of Violation NCGS I43-215.1(a)(6)
Compliance Sampling Inspection
CBP WWTP
NPDES Permit No. NC000SO11
Gaston County, NC
Enclosed is a copy of the Compliance Sampling Inspection Report for the inspection
conducted at the subject facility on June 26, 1997 by Mr. John Lesley of this Office. Sample analysis
results will be forwarded under separate cover when available. The report should be self-
explanatory.
This letter serves notice that the Mooresville Regional Office of the Division of Water
Quality is considering sending a recommendation for enforcement action to the Director of the
Division of Water Quality. The recommendation concerns the violation by this facility of North
Carolina General Statute 143-215.1 (a) (6) and NPDES Permit No. NC0005O11 for discharging
waste into the waters of the State in violation of monthly average and daily maximum permit limits
for Ammonia as Nitrogen, daily maximum effluent limits for Fecal Coliforrn, monthly average
limitations for Flow and BOD, and Chronic Toxicity limit violations (See the Self -Monitoring ..
Section of the subject report).
919 North Main Street,
Mooresville, North Carolina 28115
Voice 7044-663-1699
FAX [phone]
An Equal Opportunity/Aftuznative Action Employer
50% recycled/10 post -consumer paper

CBP Resources, NRE
Page 2
If you have an explanation for the violations that you wish to present, please respond in
writing within 'ten (10) days following receipt of this Notice, Your explanation will be reviewed and
if an enforcement action is still deemed appropriate, your explanation will be forwarded to the
Director with the enforcement package for his consideration. Please address your response to my
attentIn at the address shown on the letterhead.
If you have any questions concerning this Notice, please contact Mr -Lesley or me at (704)
663-1699.
incerely,
D. Rex Gleason, P„E.
Acting Regional Supervisor
cc: CompliancerEnforcement Group
Central Files
Mooresville Regional Office
Gaston County Health Department

United States Environmental Protection Agency, Washington, D.C., 2i6
NPDES Compliance Inspection Report
Form Approved
Cttvtl too.7o4O-0003
Approval Expares 7-3I-85
Transaction Code NPD
1C©Q05©11
Section A: Ntirtnl Data Systetttt Coding
©?DAY tspectictn Type Inspector
97/06/26
a
Focht
Type
2
Reserved
Facility Evaluation Rating
2
Bl t A .Reserved.
iecfiott B: Facilit Da
Nine and Location of Facility° Inspected
CBP Resources WWTP
Highway 321 South
south of Gastonia, Gaston County, North Carolina
Entry Time:
2:00 pm
Permit Effective
Date:
November 1, 1995
Exit Time, a
3:00 pm
971©6'26
�atne(s l of On -Site Representati
Title(s)----... Phone No)s)
fan ,tones / Environmental Manager 1 [phone]
Permit Expiration
Date:
September 3, 1996
"*game, Address of Responsible Off cial
©lberding
CBP Resources
53 South York Road
Gastonia, North Carolina 28d�2
Tit
President oft taerations
Phone No.
[phone]
Section Ct Areas Evaluated During Inspection {Sgatisfac
arginal,
Contacted?
NO
of Evaluated, NA -Not Applicable
Flow Measurement
RecordsReports Laboratory
Facility Site Review
Effluent/Receiving Waters
w.4 Pretreatment Operations Maintenance
NA Compliance Schedules N Sludge Disposal
S Self -Monitoring Program * Other: Sample analyses
Section D: Summary of Findings/Comments
See Attached Sheet(s) for Summ lr 1. * Sample analysis results t i ll be forwarded under separate cover
when available.
e(s) and Signature(s) oflnspectors.
r
Agency/Gffice/Teieplsone
NCDWQ(MR0I(704) 663-1699
Date
July 8, 1997
Date
Signature of Reviewer
Agency/Offic
Regulatory ©[Bce E€se Only
Action. Taken
Date
Date
Noncompliance
Compliance
EPA Form 3560-
Rev 3-85) Prevsous editions are obsolete

Facility Name:
NPDES Permit Number:
CBP Resources WWTP
NC0005011
The facility was last inspected by Patricia Beam of this Office on December 3, 1996. Joint
inspections were conducted by DWQ staff and Division of Air Quality staff on February 25 and 27
and March 3 and 20, 1997. The joint inspections were in response to numerous odor complaints
reported to this Office during the period from January through March, 1997.
PERMIT:
The permitted facility (outfall 001) is a 0.257 MGD activated sludge wastewater treatment
plant consisting of an aerated lagoon, secondary clarifier, effluent polishing ponds, a stormwater
lagoon, a chlorine contact chamber with gas chlorine disinfection, a sludge filter press, and
continuous flow measurement. The facility's NPDES Permit expired on September 30, 1996. An
application for renewal of the permit with all applicable fees was received by the Division on March
29, 1996. The facility continues to operate under the conditions of the expired permit.
Outfall 002 is a non -contact cooling water discharge. Cooling water is pumped from
Crowders Creek to the manufacturing plant's cooling system and discharged as described in the.
Permit. The non -contact cooling water contains no biocides or chemical additives.
On January 14, 1997 CBP Resources submitted an Alternatives Analysis Report comparing
costs associated with meeting monthly nutrient limits of 1 mg11 Total Phosphorus and 6 mg/1 Total
Nitrogen to the cost of connection to the City of Gastonia collection system. Based upon the
Alternatives Analysis. CBP Resources has proposed a 5-year phased tie-in to the City of Gastonia
Crowders Creek WWTP contingent upon a pretreatment agreement with the City.
The existing permit limitations are based on the production based limits found in 40 CFR 432
Subpart J - Render Subcategory, The limitations found in 40 CFR 432.102(a) do not adequately
protect the receiving stream for fecal coliform. A water quality standard of 200/100 ml has been
established to protect human health [15A NCAC 2B.0211(e)] ; whereas, 40 CFR 432.102(a)
requires a 400/100 ml daily maximum limit for fecal coliform. It is recommended that the Division's
Permits and Engineering Group base the facility's fecal coliform limitations upon the water quality
standard to ensure adequate protection of human health at permit renewal.
FACILITY SITE REVIEW/OPERATION AND MAINTENANCE:
The facility, is adding four, 40 horsepower aerators to the aerobic lagoon. Electrical service
was upgraded by Duke Power Company on July 7, 1997 according to telephone notification from
the ORC on July 7, 1997.
The mixed liquor in the aeration lagoon appeared to be a dark brown color with no excessive
foaming. Dissolved oxygen concentrations in the basin are usually between 1.0 mg/1 and 0.5 mg'l
according to process control records. Odors were consistent with the findings of the joint inspections
conducted in February. and March, 1997 (see above) and were most noticeable at the influent end of
the aeration lagoon,
The effluent polishing ponds appeared to be a "red -purple" color. Red algae was the cause
of the discoloration according to the ORC. The effluent polishing ponds are operated in series.
Denitrification was observed in the first polishing pond.

CBP Resources NC0005011
Chlorine gas disinfection is accomplished by utilizing a one -ton chlorine cylinder located
approximately 100 yards from the chlorine contact chamber. The chlorine cylinder is on the ground
exposed to the elements, It is recommended that chlorine cylinders be stored in a building or other
secured area equipped with the proper safety devices (exhaust fan, chlorine gas leak detector, alarm
system, etc.).
A process control program consisting of dissolved oxygen, pH, settleable solids. and
temperature measurements and MLSS, MLVSS, TSS, and COD testing is used in the operation of
the facility.
SELF -MONITORING PROGRAM:
Monthly monitoring reports were reviewed for the period from July, 1996 through April,
1997, Twenty-four (24) daily maximum permit limit violations were reported for fecal coliform
during the period. Four daily maximum permit limit violations and one monthly average permit
limit violation for ammonia as nitrogen were reported in July, 1996. Toxicity failures were reported
in September and November, 1996_ Monthly average limit violations for flow and BOD were
reported in Februaly,,, 1997.
Time -based composite samples are collected. Part II, Section B, Paragraph 8 of the NPDES
Permit requires that samples be collected proportional to flow. Should the facility seek Division
approval to continue utilizing time -based composite samples for monitoring purposes, a written
request must be made to the Director. Supporting documentation which includes a description of
the flow measuring device, a representative sample of one week's flow data (chart recordings), a
description of the sarnpling method (constant time/constant volume, variable time/constant volume,
constant time/variable volume, etc.), and a description of any flow equalization used at the treatment
facility P7114.51 accompany the request.
Samples are collected on ice and stored at <4'C.
RECORDS AND REPORTS:
Records and reports consist of flow meter strip charts, ORC visitation calendar, operations
and maintenance log, laboratory reports, and monthly monitoring reports. All records and reports
are maintained in accordance with NPDES Permit requirements.
EFFLUENT/RECEIVING WATERS:
Samples were collected at the upstream, effluent discharge, and downstream locations
Sample analysis results will be forwarded under separate cover when available.
The discharge was "red -purple" in color and very turbid. The upstream and downstream
were "red -purple" in color due to color impact from the City of Gastonia Crowders Creek WWTP
which discharges upstream of the facility. No adverse impact on the receiving stream was observed.
Continued noncompliance with permitted fecal coliform limitations (400/100m1; see Permit
and Self -monitoring Sections of this report) would predict an exceedance of the water quality
standard for fecal coliform (200/100m1) downstrearn of the discharge; therefore, the effluent
discharge is rated as "unsatisfactory".

CEP Resources 11C0005011
LABORATORYii
The on -site laboratory is used for dissolved oxygen, temperatiare, and pH measurenterits.
fetter exempting the facility„ froriti certification for pH (dissolved oxygen and temperature are not
certifiat)le par eters) dated October 8, 1996 was issued by the Laboratory Sectiori. Cheri: Bac
Laratory, (Ceritificate No, 35) is used ftar all paranieters with the exception of Chronic Toxicity
testing which is perfornileiii hy Burlirigtori Research (Certificate No, 85),
SLUDGE DISPOSAL:
Sludge from the DAF unit (for grease removal) and filter press are recycled into the rendering
process, Wastewater sludae is stored in the wastewater lagoons.
FLOW MEASU* ,MENT:
The flow measuring device is a Stephens float and cable type flow meter equipped with a
totalizer and strip chart recorder. The flow meter is calibrated quarterly by in-house staff
Calibration records and flow charts are maintained in the ORC's office.

TEL:
Jul 21'97 1.7:01 No.004 P.4i
Jury 21, 1997
Mr. D. Rex Gleason, PE
Acting Regional Supervisor
Division, of Water Quality
91.9 NMain Street
Mooresville, NC 28115
Subject; Notice of Recoffimendation for Rear
CBP Resources
Gaon County, NC
Gastonia Division
C SF Resources, Inc.
qt.is your July 8, 1997 N+ e o l c tae aura for Enforcement.
ute the facts that constitute the iefeitnions, we believe that
the addition of four, 40 horsepower aerators at a cost of $78,000) to
compliance and to eliminate the direct disc;hvge to Crowders creek
y r mmendation for enforcement.
We have wca diligently toward a tie-in to the City ofGastonia's municipal
system so outs +tiit'ect discharge can be eliminated Our company also is committed to
rr�aTCing the 1invesunem accessary to remove the discharge from the creek as soon
as possible.
We resqueatt1 your rdeft
may concentrate our efforts on cormi
working to Plans to make this tie-in.
uld there be any questions, please
y
Van Iones or me.
• Castora,a, NC 28052 • 704-B64-4941 • Fax TQ4. 92 a2 • d rrttt dial NartSer.

CBP, Case Assessment Factors
Page 2
5. The amount of money saved by noncompliance:
Money could have been saved by failing to construct, operate, or maintain facilities to meet
limits.
Whether the violations were committed willfully or intentionally:
The violations do not appear to be intentional or willful.
7. The prior record of the violator in complying or failing to comply with programs over which
the Environmental Management Commission has regulatory authority:
The Company paid a civil penalty assessment (Case No. LV 96-030) of $4,734.30 on March
19, 1997, A civil penalty of $500 (Case No. LR 94-02) was assessed on June 3, 1994. The
penalty was paid on June 29, 1994, The Company (d.b.a. Carolina and Southern Processing
Company) was assessed a civil penalty in July, 1988, (Case No. 88-49) following the breech
of a wastewater lagoon and subsequent fish kill in Crowders Creek. The Company was
assessed a civil penalty of $18,000 plus $2429.33 in enforcement costs and $635.81 in
damages. The Company paid the assessement on October 12, 1988,
The cost to the State of the enforcement procedures:
Central Office Review and Processing = $100.00
6.0 hours by investigator for investigating and
drafting report @ $19.94/hour —$119.64
1,0 hour by Water Quality Regional Supervisor
for review @, $36.52/hour = $ 36.52
1.0 hour by Regional Supervisor for review
$24.21/hour = $ 24.21
1.0 hour for clerical support @ $10.93/hour $ 10.93
TOTAL = $291.30
9. Type of violator and general nature of business (i.e. individual vs. large corporation):
The Company is a corporation which operates a rendering plant for the manufacture of
animal feed ingredients.
10. Violator's degree of cooperation (including efforts to prevent or restore) or recalcitrance,:
The preparation of this enforcement package consisted of file reviews; therefore, the violator
was neither cooperative or recalcitrant.

Findings and Decisions
Page 2
E. Monthly self -monitoring reports for the period from
July, 1996 through March, 1997 have revealed the
following exceedances of the above -cited permit
effluent limits: (See Attachment A)
F. Notices of. Violation concerning the monthly average
permit limitation violations and chronic toxicity
violations at the subject plant were sent to the
Company by DWQ's Mooresville Regional Office.
G. None of the above -cited exceedances of the permit
effluent limitations were the result of a bypass or
power failure at the plant as defined in the permit.
H. The Company's prior record of compliance with programs
over which the Environmental Management Commission has
regulatory authority is as follows:
The Company paiL., a civil penalty assessment of
$4,734.30 (Case No. LV 96-030) on March. 19, 1997. A
civil penalty was assessed for $500 (Case No. LR 94-02)
on June 3, 1994. The penalty was paid on June 29,
1994, In July, 1988, the Company (then named Carolina
and Southern Processing Company) was assessed a civil
penalty of $18,000 plus $2429.33 in enforcement costs
and. $635.81 in damages (total = $21,065.14 Case No. 68-
49). The Company paidthe assessement on October 12,
1988.
1. The cost to the State of the, enforcement procedures in.
this matter totaled $291.30
Based upon the above Findings of Fact, I make the following:
II. CONCLUSIONS OF LAW:
A. The Company is a "person" within the meaning of G.S.
143-212(4).
E. NPDES Permit No. NC0005011 is required by G.S. 143-
215.1.
The effluent limitations contained in the subject
permit are terms, conditions, or requirements of said
permit.

P ` "
DIVISION OF A R
c� s
ues. If you have qutiu or
F Track Enforce
Violation of NCGS 143-21
DES P `t Nos NC
CBP Resources
on Courttv.NC
A. _ cats

STATE OF NORTH CAROLINA NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
COUNTY OF GASTON File No. LM
IN THE MATTER OF ) FINDINGS AND DECISIONS
) AND ASSESSMENT
CBP RESOURCES, INC. ) OF CIVIL PENALTIES
)
FOR VIOLATIONS OF: )
)
NPDES PERMIT )
NO. NC0005011 )
AND NORTH CAROLINA GENERAL )
STATUTE 143-215.1(a)(6) )
Acting pursuant to North Carolina General Statutes (G.S.)
143-215.6A, I, A. Preston Howard, Jr., P.E., Director of the
Division of Water Quality (DWQ), make the following:
I. FINDINGS OF FACT:
A. CBP Resources, Inc. (the Company) is a corporation
organized and existing under the laws of the State of
North Carolina.
B. The Company operates a 0.257 MGD wastewater treatment
plant at Gastonia, North Carolina, which is located in
Gaston County.
C. The Company was issued NPDES Permit No. NC0005011 on
October 20, 1995, effective November 1, 1995, with an
expiration date of September 30, 1996. The renewed
permit was issued on September 5, 1997, effective
October 1, 1997, with an expiration date of March 31,
1999.
Said permits contain the following relevant daily
maximum, monthly average, and chronic toxicity effluent
limitations:
Parameter
Limitation Units
Daily Max/Monthly Avg.
Fecal Coliform 400 / no limit #/100 ml
BOD 680 / 340 lbs/day
BOD 317 / 158 mg/1
BOD1 612 / 306 lbs/day
BOD1 285 / 143 mg/1
Chronic Toxicity Quarterly @ 3%2 Pass/Fail
1 The BOD limits changed in the renewed permit
2 Monitoring Frequency reverts to monthly after a single test
failure.

CBP Resources, Findings and Decisions
Page 2
E. Monthly self -monitoring reports for the period from
April through November, 1997 have revealed the
following exceedances of the above -cited permit
effluent limits: (See Attachment A)
F. Notices of Violation concerning the monthly average
permit limitation violations and chronic toxicity
violations at the subject plant were sent to the
Company by DWQ's Mooresville Regional Office.
G. None of the above -cited exceedances of the permit
effluent limitations were the result of a bypass or
power failure at the plant as defined in the permit.
H. Said permit also contains the following relevant
reporting requirements:
Parameter
BOD
BOD
Monthly Average
Reporting Requirement Units
mg/1
Daily Maximum mg/1
From April through November, 1997 the Company's self -
monitoring reports contained insufficient values for
the BOD monthly average concentration. (See Attachment
A)
From April through November, 1997 the Company's self -
monitoring reports contained insufficient values for
the BOD daily maximum concentration. (See Attachment A)
K. The Company's prior record of compliance with programs
over which the Environmental Management Commission has
regulatory authority is as follows:
A civil penalty of $11,091.30 was assessed against the
Company on December 16, 1997 (Case No. LV 97-029). The
Company has filed a petition for an administrative
hearing. The Company was assessed a civil penalty of
$4,734.30 (Case No. LV 96-030) on February 3, 1997.
The penalty was paid on March 19, 1997. A civil
penalty was assessed for $500 (Case No. LR 94-02) on
June 3, 1994. The penalty was paid on June 29, 1994.
In July, 1988, the Company (then named Carolina and
Southern Processing Company) was assessed a civil
penalty of $18,000 plus $2429.33 in enforcement costs
and $635.81 in damages (total = $21,065.14 Case No. 88-
49). The Company paid the assessment on October 12,
1988. The Division of Air Quality has documented 97
air permit limit violations for the period from January
through June, 1997.

CBP Resources,, Findings and Decisions
Page 3
L. The cost to the State of the enforcement procedures in
this matter totaled $297.80
Based upon the above Findings of Fact, make, the following:
II. CONCLUSIONS OF LAW:
A. The Company is a "person" within the meaning of G.S.
143-212(4).
B. NPDES Permit No. NC0005011 is required by G.S. 143-
215.1.
C. The effluent limitations contained in the subject
permit are terms, conditions, or requirements of said
permit.
D. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on five (5) occasions during July
through November, 1997 in the manner and to the extent
described in Attachment A, when the permittee permitted
waste to be discharged into the waters of the State in
violation of the daily maximum permitted effluent limit
for Fecal Coliform.
E. The Company violated G.S. 143-215.1(a) (6) and NPDES
Permit No. NC0005011 on three (3) occasions during May,
July, October, and November, 1997 in the manner and to
the extent described in Attachment A, when the
permittee permitted waste to be discharged into the
waters of the State in violation of the monthly average
permitted mass/based effluent limit for BOD.
F. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on two (2) occasions during July
and November, 1997 in the manner and to the extent
described in Attachment A, when the permittee permitted
waste to be discharged into the waters of the State in
violation of the daily maximum permitted mass/based
(lbs/day) effluent limit for BOD.
G. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on eight (8) occasions during
April through November, 1997 in the manner and to the
extent described in Attachment A, when the permittee
permitted waste to be discharged into the waters of the
State in violation of the monthly average permitted
concentration (mg/I) effluent limit for BOD.

CBP Resources, Findings and Decisions
Page 4
H. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on eight (8) occasions during June
through October, 1997 in the manner and to the extent
described in Attachment A, when the permittee permitted
waste to be discharged into the waters of the State in
violation of the daily maximum permitted concentration
(mg/1) effluent limit for BOD.
1. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on five (5) occasions during May
through November, 1997 in the manner and to the extent
described in Attachment A, when the permittee permitted
waste to be discharged into the waters of the State in
violation of the permitted effluent limit for Chronic
Toxicity.
By reporting as described in I.(I) above the Company
violated the subject permit's reporting requirement for
BOD monthly average concentration on eight (8)
occasions from April through November, 1997.
K. By reporting as described in I.(j) above the Company
violated the subject permit's reporting requirement for
BOD daily maximum concentration on thirty-five (35)
occasions from April through November, 1997.
General Statute 143-215.6A(a) provides that a civil
penalty of not more than ten thousand dollars per
violation may be assessed against a person who violates
or fails to act in accordance with the terms,
conditions, or requirements of a permit required by
G.S. 143-215.1.
The State's enforcement costs in this matter may be
assessed against the Company pursuant to G.S. 143-
215.3(a))) and G.S. 143B-282.1(b)(8).
N. The Director, Division of Water Quality, pursuant to
delegation provided for by G.S. 143-215.6A(h), has the
authority to assess civil penalties.

CBP Resources, Findings and Decisions
Page 5
Based upon the above Findings of Fact and Conclusions of
Law, I make the following:
III. DECISION:
Accordingly, the Company is hereby assessed a civil penalty
of:
For of the five (5) violations of
G.S. 143-215.1(a)(6) and NPDES Permit
No. NC0005011, by discharging waste into
the waters of the State in violation of
the permit daily maximum effluent limit
for Fecal Coliform.
For of the three (3) violations of
G.S. 143-215.1(a)(6) and NPDES Permit
No. NC0005011, by discharging waste into,
the waters of the State in violation of
the permit monthly average mass/based
(lbs/day) effluent limit for BOD.
For of the two (2) violations of
G.S. 143-215.1(a)(6) and NPDES Permit
No. NC0005011, by discharging waste into
the waters of the State in violation of
the permit daily maximum mass/based
(lbs/day) effluent limit for BOD.
For of the eight (8) violations of
G.S. 143-215.1(a)(6) and NPDES Permit
No. NC0005011, by discharging waste into
the waters of the State in violation of
the permit monthly average concentration
(mg/1) effluent limit for BOD.
For of the eight (8) violations of
G.S. 143-215.1(a)(6) and NPDES Permit
No. NC0005011, by discharging waste into
the waters of the State in violation of
the permit daily maximum concentration
(mg/1) effluent limit for BOD.
For of the five (5) violations of
G.S. 143-215.1(a)(6) and NPDES Permit
No. NC0005011, by discharging waste into
the waters of the State in violation of
the permit effluent limit for Chronic
Toxicity.

CBP Resources, Findings and Decisions
Page 6
For of the eight (8) failures to
report for BOD monthly average
concentration in violation of G.S. 143-
215.1(a)(6) and NPDES Permit No. NC
0005011 for the months of April through
November, 1997.
For of the thirty-five (35)
failures to report for BOD daily maximum
concentration in violation of G.S. 143-
215.1(a)(6) and NPDES Permit No.
NC0005011 for the months of April
through November, 1997.
TOTAL CIVIL PENALTY, which is
percent of the maximum penalty
authorized by G.S. 143-215.6A.
297.80 Enforcement costs.
TOTAL »4OONT DUE
Pursuant to G.S. 143-215.6A(c), in determining the amount of
the penalty I have taken into account the Findings of Fact and
Conclusions of Law and the factors set forth at G.S. 143B-
282.1(b), which are:
(1) The degree and extent of harm to the natural resources
of the State, to the public health, or to private
property resulting from the violations;
(2) The duration and gravity of the violations;
(3) The effect on ground or surface water quantity or
quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violations were committed willfully or
intentionally;
(7) The prior record of the violator in complying or
failing to comply with programs over which the
Environmental Management Commission has regulatory
authority; and
(8) The cost to the State of the enforcement procedures.
(Date) A. Preston Howard, Jr., P.E., Director
Division of Water Quality

URTER & SECTION Fax:919
6
Apr 9 '98 14:50 P.01
MICHAEL P. EA.5sL Y
Ar'rowr:eY GENERAL
TO:
Don
Gis
FAX NUMBER:
FROM:
DATE:
f North Caroina.
rcmemt of Justice
P. O. BQX e29
RALEIGH
276U2 t9
0
Phone: [phone]U4
Fax: [phone]
ohn Lesley
Anite LV a,ux-Quigiess
4
NUMBER OF PAGES (INCLUDING
CONFIRM RECEIPT OF DOCUMENT(S) IF MAR10ED HERE: ..
COMMENTS:
Petit onerrs prehe®ring statement. Ca11 if you have any
Attached please find the Respondent's and
An Equal Opportunity / Affirmative Acflon Ernpi)yer

ItIRTER &L1 SECTIONFax : 9- 16- Rpr 9 '98 14:50 P.02
STATE OF NORTH CAROLINA
COUNTY OF GASTON
CBP RESOUR
DIVISION.
v.
C., G
Fetifipner,
NORTH CAROLINA DENR,
DIVLSION OF WATER QUALITY
Respondent.
)
) '
MOP 2P199a
In accordance with the Order for Preheating Statements in the above -captioned vase,
Petitioner CBP Re.$011rODS, Inc., Gastonia Division (CBP) respectfully submits to the Office of
Administrative Hearings the following Prehearing Statement. Petitioner reserves the right to
supplement or modify the flatten addressed in this Preheating Statement as the proceediug
pewessat.
1. The issues to be resolved, involved.
TOM'S tAlwitesolvpii
a. Did Respondent inappropriately issue an Assessment of Civil Penalties dated
February 4, 1997, thereby depriving -petitioner libtolity?
. Did Respondent excateriti;aradtority or jtnisdiction in issuing an Assessment
of Civil Penalies dated February 4, 4997, therekipbstantially prejudicing petitioner's rights?
c. Did Respand4 'issuing an Assessment of Civil Penaiie
rn.
dated February 4, 1997?

WATER 8 LAND SECTION Fax:919-?1.6-6766 Apr 9 '98 14:51 P.03
Civil. Pen
dated February 4, 1997?
c. Did Respondent fail to act as
Apt of Civil Pelios dated February 4, 19977
1 +}tlt+ _
n 1 UiiI I:vnlynl
N.C. Gen. Stat. 6 143-215
N.C. Gen. Staff. £t 143-215.1
N.C. Gen. Slat. § 143-215.3
N.C. Gen. Stat. § 143-215.6
N.C. Gen. Stat. § 150B-22
N.C. Gen. Stat. § 150B-23
15A N.C.A.C. 1B.(i2A0
15A N.C.A.C. ¢ 2I
15A N.C.A.C. § 2.1
2. Statement of the facts and .
capriciously in issuing an As
by rule or law i
Petitioner's
t
a, Petitioner is a North Celina corporation with a render fttt ity in
Gastonia, Gtn County, North Carolina.
b. Petitioner was assessed�� �ca� © S11,t�1•� a
December 4, 1997 Amessrnc nt of Civil Penalties issued by Respondent.
c. The Aft of Civil Penalties did not address all violations that a is d
at that time and Petitioner has since received notice of a subsequent recordation for
+enfor t.

T
ACTION Fax :-..-
4: P.4
Ro
-.i
CBP
e by
tc
y
'41!:_
Petition
Mir ovei

OF
CTIONa;71 -: 14 2 P
a' ., of any at
y of l

ACTION F : 1 - 16-67
CA OF S
14:52 F. 06
8.

WATER & LRND SECTION Fax 919E716E6766 Rpr 9 '98 14 :53 P. 07
MICHAEL,P EA
A * NEY
State of North Carolina to maiowslask.
Department of Justice Env
(71
P. a BOX 629
ALEIGH
27 o' 0028
The Hone le Doi O. $ 'th
oo of Admini„, ,tive He
424 N. Blo t Street
eigh, MC. 27601-28 I 7
Dear Judge Smith:
Enclosed p1 e fnd non,
Constitu Agency Action, which
contested
you for your
°
26, 1
&tato. era and T omission of Doc
being filed i y in connection with the above ref
on.
ent
need

WATER &LRND SECTIi Fax:[phone]
Rpr 9 193 14:53
STATE OF NORTH CAROLINA
COUNTY OF GASTON
NDW.11-
13..
4B I.
THE OFFICE OF
ISTRATIVE HEARINGS
98 •EliF. 0082
CBP RESOURCES, INC., )
Petitioner, )
) STATEMENT
v. ) OF RESPONDENT
)
NORTH CAROLITNA DEPARTMENT OF )
ENVIRONMENT AND )
NATURAL RESOURCES, DIVISION )
OF LAND RESOURCES, )
)
Respondent )
NOW COMES the Division of Water Quality (DWQ), formerly the Division of
Environmental Management, of the North Carolina Department of Environment and Natural
Resources, Respondent, by and through the undersigned pursuant to G.S. 15013-33(b)(4) and 26
NCAC 3 .0004, and files this Prehearing Statement in accordance with the Order of the
Administrative Law Judge.
I . This matter involves the assessment of civil penalties dated December 4, 1997,
against CBP Resources, Inc., in Gaston. County, North Carolina by the Director of the Division
of Water Quality, A. Preston Howard, Jr., P.E., Director, Division of Water Quality. Controlling
statutes, rules, etc. are thosc cited in the Director's civil penalty assessment in addition to G.S.
150B and Title 26, Chapter 3 of the North Carolina Administrative Code.
The issues to be resolved are whether the Respondent, in assessing the civil penalty
assessment:
a. deprived petitioner of property;
b. acted erroneously by ordering petitioner to pay a fine or eivil penalty;
c. acted arbitrarily and capriciously; and
d. substantially prejudiced the petitioner's rights.
2. The Respondent contends that Petitioner violated North Carolina General Statutes
143-2I 5 et seq. for violations of their NPDES pit, in t manner and to the extent described
hy the Director's civil penalty assessment
3. Witnesses for the Respondent include, but are not limited to, the following
Division of Water Quality employees:

WATER & LAND SECTION Fax:919-716-- 7
14:53 P. O9
A. Preston Howard, Jr..
Rex Gleason
John Lesley
Additionally, Respondent may call as a witness aoy person familiar witlr Petitioner's
water quality permit violations, as well as any person Warned a witness by any other party.
Respondent reserves the right to supplement this list as it prepares for hearing.
4. Respondent, wishes to pursue discovery, the length of time set forth in the
Scheduling Order is acceptable.
Respondent has no objection to the hearing b' sing held in aarlc tie, NC.
The estimated length of the hearing is one day.
7. Not applicable.
8. Respondent will be ready to lave a hearing in this case on the date set fo
Scheduling Order.
9. There are no special
ply submitted this the W day c
MICHAEE F. EASL
ey General
1
"ts L eVeaux-Quigl'
Assistant Attorney General
N.C. Department of Justice
Environmental Division
Post Office Box 629
Raleigh, NC 27602-0629
[phone]
Bar No.13667,

Fax :1-1-
9 98 1 : :1t
RPCI l
States
s
y of
vi
y-Produiot's R.
tth York Ro
NC 28052
h0
foregoing P
STA OF
Pei $ * y depositing a copyin 1.Tred
do
Po
1gh, NC 27602-0629
1 716-6600
Bar N. 13667

MICHAEL F EASLEY
A TT(IRNEY GENERAL
MEMORANDUM
TO:
Don Safrit
John Lesley
State of North Carolina
i)epartmeni tit estiCe
I' 10 BOX M29
RALEIG11
2 7002 tni29
FROM: Anita LeVeaux-Quigless
RE: CBP Resources
CV 97-029
DATE: April 1, 1998
REPLY roAnita LeVeaux-Quigless
Environmental Division
enQuig@mailjus,state.nc.us
Tel [phone]
Fax [phone]
APR
You all should have received a notice from my office indicating that this matter is
scheduled for hearing the week beginning June 1, 1998. In that regard, it is my understanding
that we need documents and other information from the Petitioner. Since we are presently in
discovery, please let me know which documents you would like to review, Also, if you all have
any unanswered questions you would like the Petitioner to answer, interrogatories may be
appropriate. Finally, we may want to depose key personnel,
Please advise.
Thanks.

M1C t\L L F. A L 4'
ATTORNEY GENERAL,
ME
State North Carol
Department of Justice
P O. BOX 629
RALEIGH
60 -0t 9
TO: Division of Water Quality
Preston Howard Jr.
Don Safrit
John Lesley
FROM: Anita LeVeaux-Quigle
DATE:
CBP Resources
CV 97-029
April t., 1998
na
PLY TO; Anita L vcaux twigless
Environmental Division
enQuig @mail us
Tel. [phone]
Pan. [phone]
This natter is scheduled for hearing the week beginning e 1, 1998. A date certain will
be subsequently determined. Please let us know, as soon as possible, whether this date presents a
conflict with your schedule:
Thanks.

iI HA 'L, R EASLEY,
ATTORNEY GENERAL
tR. L
ME
TO:
State of North Caro r.a
)t a riment of tI
t'.O. BOX6 9
RALEIGH
2 602 002
Preston Howard
Don Safrit
John Lesley`
Rex .ale sson
FROM: Anita LeVeaux-Quig
RE: CRP Resources, Inc..
98 EHR 0082
DATE: May 4, 1998
REPLY 1`C1: r nit 1 Vvatt tiu6 1c ti
Environmental Disunion
unQuig a grail. us staitnuc.us
Tel1 ) 716- 600
1=aa. { 19) 7(6)693
As per Preston Howard's request that this matter be:eontinued, a Min to Continue this
tier wwens filed with the Office of Administrative Hearings. As per the attached, the Motion
was allowed. Please mark your calendars accordingly. If the designated date is inappropriate
please notify me immediately.
Thankings° a in advance.
L :c p
attachment
24531

STATE OF NORTH CAROLINA
COUNTY OF GASTON
APR 33.
IN THE OFFICE OF
ADMINISTRATIVE HEARINGS
7 ?S'O 98 EHR 0082
07333
CBP RESOURCES, INC. A514/478)) T) T13
GA NI DIVISTON )
Petitioner, )
)
) ORDER
)
N.C. DEPARTMENT OF ENVIRONMENT AND )
NATURAL RESOURCES, DIVISION OF
WATER QUALITY )
Respondent.
0 1993
N.C. ATTORNEY GENERAL
Environmental DiViSiOTI
UPON CONSIDERATION' of Respondent's Motion Se Continue
and for good cause shown, the. Motionis hereby ALLOWED as
follows:
1- The hearing is rescheduled for July 1-2, 1998 at
10:90 a.m. in Salisbury or Kannanolis, North Carolina with a
detailed Notice of Hearing to follw.
. Discovery shall he completed on or before June 23,
3 .„ Final witness lists and exhibits shall be
exchanged on or before June 19, 1998.
Ts is so Ordered.
This the.„ day of April, 1998.
Dolores 0. Smis
Administrative Law Judge
) -

Ramona Cunningham C Y Bryant
as mailed to:
Smith, Helms, Mullis & Moore LLP
Attorneys at Law
P. O . Box 21927
Graonboro NC 2127
Attorney for Pet i t loner`
LeVeaux-Quigiess
igie
Assistant Attorney General
N.C. Department of Justice
Environmental Division
P.C. Box 629
Raleigh C 27 t 2 - 629
Attorney for Repan.dent
Th1 the
day of April, 19
Off ioe of Administrativ Hee,ings
Post Office Drawe 27447
Raleigh, North Carolina 2711-74447
919/733-2698
Fax: [phone]

JAMES B. HUNT JR.
G©VCRNOR
NORTH CAROLINA DEPARTMENT CIF
ENVIRONMENT AND NATURAL RESOURCES
MOORESVILLE REGIONAL OFFICE
DIVISION OF WATER QUALITY
December 11, 1998.
Mr. E.R. Olberding
CBP Resources, Inc.
5533 South York Road
Gastoina, North Carolina 28056
Subject: Compliance Evaluation. Inspection
CBP Resources WWTP
NPDES Permit No. NC000501 '1
Gaston County, NC
Dear Mr. Olberding:
Enclosed is a copy of the Compliance Evaluation Inspection Report for the
inspection conducted at the subject facility on December 2, 1998, by Mr. Roberto L.
Scheller of this Office.
It was confirmed by this Office that discharge from the subject facility has ceased
and all flow from outfall #001 is being sent to the City of Gastonia's Crowders Creek
WWTP for treatment. Please note in the inspection report the necessity of applying for
a General Permit for outfall #002.
The report should be self-explanatory; however, should you have any questions
concerning this matter, please do not hesitate to contact Mr. Scheller or me at (704) 663-
1699.
Enclosure
Sincer
y,
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
cc: Ms. Melinda Greene, EPA -NC State Coordinator
Gaston County Health Department
is
919 NORTH MAIN STREET, MOOiRESVILLE, NORTH CA.ROLINA 28 915
PHONE 7O4-663-1999 FAX. 7O4.,663-6040
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER . 50% RECYCLED/I Q% POST -CONSUMER PAPER

74.
."S 'Environmental Protection Agency, Washington, D.C., 20460
NPDES Compliance inspection Report
NC: Division of Water Quality / Mooresville Regional Office NCDEN
Secton A: National Dat
IS
Coding
Form Approved
OMB No.2040-0003 Approval
Expires 7-31-85
Transaction ()site NPDES No. Yr/Mo/Day Inspection Type Inspector Facility Type
N NC0005011 98/12/02 C S 2
Re arks:
Reserved
Facility Evaluation Rating BI QA
4
..........Reserved...........
Section B: Facility Da
Name and Location (it Facility Inspected:
CBP Resources WWTP
5533 South Yourk Road (1.1\,,,y, 3 2 1 )
Gaston County, North 'arol
Entry Time: 01:20 p.
Permit Effective Date:
10/01/97
't Time/Date: 03:40
Permit piration Date:
03/31/99
Name(s) of On -Site
Mr. Van Jones
ep res c ative
Title(s) Phone No(s):
ORC (704) 86.4-9941
Name and Address in Responsible Official:
Mr, ER, Olberding
CBP Resources, Inc
5533 South York Rrai'
Gastonia, North Can 28052
Title: Vice President of Operations
Phone No: [phone]
Contacted?
No
tion C: Areas Ev:iloioed During Inspect o ct ry, M-Marginal, U-Unsatisfactory,N-tot Evaluated, NA -Not Applicable
Permit NA Flow Measurement N Pretreatment NA Operations & Maintenance
Records/Reports N PI Laboratory ...NA Compliance Schedules NA Sludge Disposal.
' Facility Site RevieNs NA EffluentiRec '.1! g Waters NA Self -Monitoring Program NA Other:
Section D: Summary of Findings/Comments
See Attached - eet() for Summar).
Name(s) and Signany of -inspectors: 1 Agency/Office/Telephone No:
Roberto L. Scitgl ler
NCDWQ/MOORESVILLE/(704)663- 1699
Date:
98/12/09
Date:
Signature of Reviess-e:::Ag
0 ce:
Date:
Regulatory0"7 sesOnly
Action Taken:
Date:
Noncompliance
Compliance
EPA Form 3560-3 (Res 3-851 .'revic
s are obsolete

CBP Resources '' "TP'
Page Two
This facility vas last inspected by l r. Fohn Z esley of this Office on May , 1998
PER . IT
The permat for the subject facility became effective on October 1, 1997 and expires at
midnight on March 31, 1999. At the time of the inspection all discharge from outfall #001
had ceased and solids were being pumped out of the chlorine contract basin. The OR , Mr.
Van Jones, indicated that Carolina By Products plans to rescind 181PDES Permit No.
NC0005011 for outfall 001. Outfall #002 will continue to discharge cooling tower water
and boiler blowdown It will therefore be necessary to apply for coverage under General
Permit No. NCG500000 for the existing outfall #002 prior to the per its: expiration (March
31, '1999).
Records and reports were available for inspection in the treatment facility's office, Mr. Van
Jones was advised to maintain all l'qPDES records for the required three years and sludge
records for the required five years or longer if required to do so. All flow is being sent to
the City of Gastonia's Crowder Creek Wastewater Treatment Plant. Treatment units are
being used to pretreat wastewater before pumping it to Crowders Creek WWTP.

NCDENR
JAMES B. HUNT JR,
GOVERNOR
WAYN E McDevirr
SECRETARY
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
MOORESVILLE REGIONAL OFFICE
DIVISION OF WATER QUALITY
July 16, 1998
Mr. Van Jones
CBP Resources
5533 South York Road
Gastonia, North Carolina 28052
Subject: Request fir more infon-nation
SOC Application.
CBP Resources
NPDES Permit No. NC000.5011
Gaston County, North Carolina
Dear Mr. Jones:
Staffhas completed a review ofthe Special Order by Consent (SOC)
Application submitted by CBP Resources on June 30, 1998 and received in this Office
on July 14, 1998. Monthly Monitoring Reports for the period June 1997 through May
1998 indicate that no violations of the permitted TSS limit have occurred and only one
violation of the ammonia limit was reported. Be advised that SOC interim limits can
only be granted for those parameters that can be demonstrated to be in chronic non-
' compliance.
Please provide justification for the suggested SOC interim monthly average
limitation (900-lbs. monthly average) for BOD contained in the application. No interim
limitations were requested for BOD concentration based limits. Monthly Monitoring
Reports for the period June 1997.through May 1998 indicate that the maximum BOD
monthly average reported was 5181.bs, in July 1997. The average monthly average
value for BOD during the same period is 275 lbs.
Should you have any questions regarding this request, please do not hesitate to
contact Mr. John Lesley or me.
Sincerely,
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Cc:
Marcie Lieber, PSB CIE Unit
Susan Wilson, Central Office
Central Files
Gaston County Health Department
910 NORTH MAIN STREET, MOORESVILLE, NORTH CAROLINA 28115
PHONE [phone] FAX 704•663-6040
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED110% 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
A. Preston Howard, Jr., P.E., Director
July 9, 1998
The Honorable E.R. Olberding, Vice President
Gastonia Division
CBP Resources, Inc.
5533 S. York Road
Gastonia, NC 28052
The Honorable Olberding:
Q
E N R
0 1998
Subject: Non Refundable Processing Fee
Special Order by Consent
EMC SOC 98-006
CBP Resources, Inc.
Permit Number NC0005011
Gaston County
This is to acknowledge receipt of your application for a Special Order by Consent (SOC)
and check number 160999 in the amount of four hundred dollars ($400.00) received on
July 7, 1998.
If you have questions concerning this Special Order by Consent you may contact the Water
Quality staff at our Mooresville office at.[phone] or Marcia Lieber in our Raleigh Central.
Office at [phone], extension 530.
Sincerely,
. Susan A. Wilson, Supervisor
Point Source Compliance/Enforcement Unit
SAW/s1
cc: 11/oores:iltvi,Region .' Office,
SOC Files
Central Files
P.O. Box 295 5, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

LtNG.T?1ENr t EC3EOUR BUSINESS
January " , 1998
Mr, John Lesley
NC Division of Water Quality
919 N Main Street
Mooresville, NC 28115
Subject: Notice of Recommendation for Enforcement
CBP Resources WWTP
NPDES Permit No. NC0005011
Gaston County, NC
Dear Jo
Gaston t Division
CBP Resources, Inc.
We are writing in response to the January 8,1998 Notice of Recommendation for
1 nforcemeru. While we do not dispute the facts that constitute the referenced violations,
we believe that our ongoing. efforts to achieve and maintain compliance and to eliminate
the direct discharge to Crowders Creek weigh against the issuance of a penalty at this
time. We also believe that it would be in the best interest of all involved to discuss a
consent order with compliance schedule to address our facility's ongoing wastewater
situation and to provide for an acceptable timetable for the elimination of the discharge to
the creek.
As you are aware, our facility is in the process of making a connection to the City of
Gastonia's sewer system for our discharge. We have entered into a formal letter of intent
with the City and have agreed to the terms of our most recent NPDES permit renewal
which requires the elimination of our discharge to the creek by March 31, 1999. We have
been working diligently toward this connection and anticipate completion prior to the
permit deadline, We have and will spend considerahle amounts of time and money on this
project. We believe we have shown good faith in our efforts to complete this task.
5533 5. York Rd. • GaStronia, NC 78052 • 704 86 -9941 • Fax # [phone] • Direct D aF Number: .

Page two
We have experienced some difficulties with our wastewater treatment system in the past.
However, our monthly self monitoring data/report for December, 1998, showed
compliance.
In addition to the subject Notice, we recently received an Assessment of Civil Penalties for
earlier violations. We believe it would be appropriate to deal with all our violations
together and, in light of the strides that we have made toward compliance and our
commitment to connect to the City, we would like to enter a consent order that will
address these issues.
We therefore request that you not move forward with the proposed enforcement
recommendation at this time and allow an opportunity for discussion regarding a consent
order..
Thank -you and should there be any questions, please advise..
Sincerely,
''fan M Jones
Environmental Manager

A7411
NCDENR
JAMESF, HUNTJR,
GOVERNOR
WAYNE MCDEVITT
SECRETARY
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
MOORESVILLE REGIONAL OFFICE
DIVISION OF WATER QUALITY
September 9, 1998
CERTIFIERMAIL
RETURNAR. ECEIPT„REQIUESIED
Mr. E.R. Olberding, Vice President.
CBP Resources
5533 South York Road
Gastonia, NC 28052
Subject: Notice of Violation - Effluent Limitations
CBP Resources
NPDES Permit No, NC0005011
Gaston County
Dear Mr, Olberding:
A review of the June 1998 self -monitoring report for the subject facility
revealed violations of the following parameters:
Pipe Parameter Re:parted..Xalue Limit
001 Amrnonia Nitrogen 602 It's/day 252 lbs/day
001 Ammonia Nitrogen 260 lbs/day 252 lbs/day
001. Ammonia Nitrogen 298.5 lbs/day 126 lbsiday
001 Fecal Coliform 426/100 ml 400/1.00 ml
Remedial actions, if not already implemented, should be taken to correct any
problems, The Division of Water Quality may pursue enforcement actions for this and
any additional violations,
If you have questions concerning this matter, please do not hesitate to contact
me at 704/663-1699.
Sincerely,
D. Rex Gleason,
Water Quality Regional Supervisor
cc: Point Source Complianee/Einforcment Unit
919 NORTH MAIN STREET, MoORESYILLE, NORTH CAROLINA 28115
PRONE 704-663-1699 FAX 704-663=-6040
Al EquAL, OFFoRTUNuTY ;AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10% POST -CONSUMER PAPER

NCDENR
JAMEEI B. HUNT JR.
GOVERNOR
WAYNE MCDEVITT
SECRETARY
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
MOORESVILLE REGIONAL OFFICE
DIVISION OF WATER QUALITY
January 15, 1998
CERTIFIED MAIL
RETURN RECEIPT, REQUESTED
Mr, E.R. Olberding, Vice President
CBP Resources
5533 South York Road
Gastonia, North Carolina 28052
Subject: Notice of Recommendation
for Enforcement
Notice of Violation
NCGS 143-21.5_1(a)(6)
CBP Resources WWTP
NPDES Permit No, NC0005011
Gaston County, NC
Dear Mr. Olberding:
This letter serves notice that the Mooresville Regional Office of the Division of
Water Quality is considering sending a recommendation for enforcement action to the
Director of the Division of Water Quality. The recommendation concerns the violations
by this facility of North Carolina General Statute 143-215.1 (a) (6) and NPDES Permit
No. NC0005011 for discharging waste into the waters of the State in violation of the
monthly average limit for BOD, daily maximum limits for BOD and fecal coliforrn, and
the chronic toxicity limitation during the period from April through October, 1997.
If you have an explanation for these violations that you wish to present, please
respond in writing within ten (10) days following receipt of this Notice, Your explanation
will be reviewed and if an enforcement action is still deemed appropriate, your
explanation will be forwarded to the Director with the enforcement package for his
consideration. Please address your response to my attention at the address shown on the
letterhead.
919 NORTH MAIN STREE1% MOORESVILLE, NORTH CAROLINA 2815
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10% POST -CONSUMER. PAPER

CBP Reso ces
P• e
Noti of Recoend ti n for E;
re
ent
If you ve any questions ncernin concerning'Notice, p" .e contact Mt e ey
663 699 e at704)
Sincerely,
rear*t
D.
Rex le on,PE.
Acting . , Supenns
cc: Cornplianc oreernent Group
Central Files
Kevin v en, Aquatic Toxicology Group
ton County Health Dept w .:

-01104,0
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
MOORESVILLE REGIONAL OFFICE
DIVISION OF WATER QUALITY
January 8, 1998
RETURN RECEIPT REOUESTED
Mr, E.R. Olberding, Vice President
CBP Resources
5533 South York Road
Gastonia, North Carolina 28052
Subject: Notice of Recommendation
for Enforcement
Notice of Violation
NCGS 143-215.1(a)(6)
CBP Resources WWTP
NPDES Permit No. NC0005011
Gaston County, NC
Dear Mr. Olberding:
This letter serves notice that the Mooresville Regional Office of the Division of
Water Quality is considering sending a recommendation for enforcement action to the
Director of the Division of Water Quality The recommendation concerns the violations
by this facility of North Carolina General Statute 143-215.1 (a) (6) and NPDES Permit
No. NC0005011 for discharging waste into the waters of the State in violation of the
monthly average limit for BOD, daily maximum limits for BOD and fecal colifomi, and the
chronic toxicity limitation during the period from April through October, 1997.
If you have an explanation for these violations that you wish to present, please
respond in writing within ten (10) days following receipt of this Notice. Your explanation
will be reviewed and if an enforcement action is still deemed appropriate, your explanation
will be forwarded to the Director with the enforcement package for his consideration.
Please address your response to my attention at the address shown on the letterhead.
919 NORTH MAIN STREET, MOORESVILLE, NORTH CAROLINA. 28115
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY /AFFIRMATIVE.ACTION EMPLOYER • SO% P..8.cYcLED/f 0% POST -CONSUMER PAPER

Air,X;WHOSP‘
Mr. E. R. Olberding
CBP Resources
5533 South York Road
Gastonia, North Carolina 28052
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
MOORESVILLE REGIONAL OFFICE
DIVISION OF WATER QUALITY
May 11, 1998
Subject: Compliance Evaluation Inspection
CBP Resources WWTP
NPDES Permit No. NC0005011
Gaston County, NC
Enclosed is a copy of the Compliance Evaluation Inspection Report for the
ection conducted at the subject facility on May 5, 1998 by Mr. John Lesley of this
ce. Please inform the Operator -in -Responsible Charge of our findings by forwarding
a copy of the enclosed report,
The facility has reported numerous NPDES Permit limit violations during the 12-
nth review period relative to this report. Because actions have been taken by the
'vision regarding the violations, this report is not being issued as a Notice of Violation.
The report should be self-explanatory; however, should you have any questions
concerning this report, please do not hesitate to contact Mr. Lesley or me at (704) 663-
699.
Sincerely,
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
: Melinda Greene, EPA -NC State Coordinator, Clean Water Act Enforcement Section
Gaston County Health Department
519NORTH MAIN STREET, MOORESVILLE, NORTH CAROLINA 2E3115
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY AFFIRMATIVE ACTION EMPLOYER - 5.0% RECYCLED/10% POST-CONSAJMER. PAPER

United. States Environmental Protection. Agency, Washington , DC 20460
NPDES Compliance Inspection Report
North Carolina Department of Environment and Natural Resources
Division of Water Quality, Mooresville Regional Office
Form Approved
OMB No. 2040-0003
Approval Expires
7/31/85
Transaction Code NPDES Permit No. YRJMO/DAY Inspection Type Inspector Facility Type
N 5 NC000St111 98/05/05 C S 2
Name and Location of Facility inspected::
CBI' Resources WWTP
5533 South York Road (Highway 321 North)
Gaston County, North Carolina
Name(s) of On -Site RepTide(s) Phone No(s):
Mr. Van Jones / Environmental Manager — ORC / [phone]
Name and Address of 1
Mr. E.R. Olb riling.
CBP Resources, Inc.
5533 South York Road
Gastonia, North Carolina
052
ibi
Official:
Entry Time:
10:20
Exit Time:
1:45
Date:
98/05/05
Permit Effective Date:
October 1, 1997.
Title:
Vice President of Operati
Phone No.
[phone]
Contacted?
Yes
S Permit
S Records
S Facility Site
S Flow 141suretraettt
N Laboratory
U E tt'tnent/Receiving Waters
S Operations and Maintenance
NA Compliance Schedule NA Sludge Disposal
M Self -Monitoring Program. * Other: Toxicity
NA Pretreatment
See Attached Sheet(s) for Summsu
*Chronic Toxicity test results will
Agency/Office/Tekphone:
DENR-DWQ/MRO/[phone] FAX: [phone]
Agency/Office
Action Taken
Date:
D
May 11, 1998
Date:
Noncompliance
Compliance
EPA Form 3560-3 (Revis
5
or

CBP Resources
NPDES Permit No. NC0005011
Page 2
John Lesley of this Office last inspected the facility on June 26, 1997.
Permit:
The effluent from the activated sludge WWTP discharges from outfall 001 to Crowders
Creek (IWC 3%, Class C). The facility consists of an aerobic lagoon, a clarifier, four polishing
ponds, chlorine gas disinfection, and a chlorine contact chamber.
Non -contact cooling water is discharged to Crowders Creek at outfall 002.
The discharge from the WWTP (001) must be eliminated by March 31, 1999, Six months
prior to permit expiration (March 31, 1999) CBP is required to apply for coverage under General
Permit No. NCG500000 for the existing outfall 002. NCG500000 is the NPDES general permit
that provides coverage for non -contact cooling water, cooling tower and boiler blowdown,
condensate and similar discharges.
Facility Site Review/Operations and Maintenance:
The facility appeared to be well operated and maintained. No offensive odors were
noticed at the time of this inspection. The quality of the mixed liquor is much improved since the
previous inspection. Four additional aerators have been installed in the aerated lagoon. The "red -
purple" color of the polishing ponds noted in the previous inspection report was not observed at
the time of this inspection.
The City of Gastonia is preparing an Industrial User Permit for CBP. A pretreatment
system, which consists of an oil/grease water separator, a DAF unit, a flow equalization tank, and
an additional clarifier, is under construction. CBP has been issued a non -discharge permit (Permit
No. WQ0014944) for the construction of a pump station and force main connecting to the City of
Gastonia collection system.
Dissolved oxygen, pH, settleable solids, and temperature measurements, and MLSS,
MLVSS, TSS, and COD testing are performed as process control at the facility.
High strength wastewater from the blood and feather processing has been treated on site
since March 18, 1998. This waste stream had been trucked to the City of Gastonia Crowders
Creek WWTP prior to March 1998.
Records and Reports:
Records and reports consistof flow meter strip charts, an ORC visitation calendar,
operations and maintenance log, laboratory reports, and monthly self -monitoring reports.
Self -Monitoring Program:
Monthly Monitoring Reports were reviewed for the period April 1997 through March
1998. Permit limit violations for the period April through November 1997 were included in two
enforcement cases, Case No. LV 97-029 and Case No. LM 98-002, The Company was assessed
$11,091.30 on December 16, 1997 for Case No, LV 97-029 and $18,672.80 on March 19, 1998
for Case No. LM 98-002. CBP has filed a request for an Administrative Hearing regarding these
cases.

CBP Resources
NPDES Permit No. NC0005011
Page 3
Violations reported in the period December 1997 through March 1998 are
fo
Date
Februarv, 1998
Feb ary, 1998
ch 13, 1998
March 13, 1998
March, 1998
March, 1998
BOD5
BOD5
BOD5
BOD5
BOD5
BOD5
Report
Vaiue
316 ibs/day
192 mg/I
728 lbs/day
389 mg/1
413 ibs/day
244
Monthly Average 306 lbs/day
Monthly Average 285 mg/I
Daily Maximum 612 lbs/day
_Daily Maximum 285 mg/1
Monthly Average 306 lbsiday
Monthly Average 285 mg/1
The facility submitted a request with the appropriate supporting documentation for
utilizing time -based composite samples rather than flow proportional samples. In a memo dated
October 23, 1997 this Office recommended approval. The Central Office has not notified CBP of
the approval or disapproval of their request.
The concentration values for BOD are not being entered on the Discharge Monitoring
Report (DMR) forms. Be advised that all permitted parameters must be included in the DMR.
The self -monitoring program is rated "marginal".
Effluent/Receiving Waters:
The effluent appeared to be cloudy and light brown in color. The facility harges to an
effluent channel that enters the receiving stream approximately one-half mile below the WWTP.
The effluent is rated "unsatisfactory" because the facility had numerous permit limit
violations during the review period.
Laboratory:
The on -site laboratory is used for process control testm . The facility has been exempted
from the Laboratory Certification rules for pH measurement. ETT Laboratories conducts chronic
toxicity testing. Chem Bac Laboratories performs all other analyses required by the permit.
Sludge Disposal:
Sludge is dewatered using a belt press and returned to the manufacturing plant to be
incorporated into the product.
Flow Measurement:
Flow is measured by means of a Stephens float and cable type flow meter wit
chart recorder and totalizer. The flow meter is calibrated quarterly by in-house staff.
ip

STATE OF NORTH CAROL I NA
DEPARTMENT ENT F ENVIRONMENT, EAL `H AND NATURAL RESOURCES
Division of Water Quality
919 North Main Street Mooresville, North Carolina 28115
July 20, 1998
V C. JONES
P RESOURCES - GASTONIA L.I.V.
55J SOUTH YORK ROAD
GASTONIA NC 28052
SUBJECT: Notice of Violation Effluent Liri .cations
NPDES No. NC0005011
CBP RESOURCES - GASTONIA DIV.
GASTON County
Dear VAN M. JONES:
Review
of May, 1998
parameter(a)a...
Pipe Par
subject self -monitoring report for the month
vealed violation(s) of the fc 1_lo wing
001 00610 3-N
Reported Limits
Value/Unit
Value/Type/Unit
.00 LBS/DA 126 <00 FIN LBS/DA
Remedial action, if not already implemented, should be
taken to correct the pro blem(a). The Division of Water
Quality may pursue enforcement actions for this and any
additional violations of State Law. If you have questions or i
you need assistance, please call D. Rex Gleason, Regional ater
Quality Supervisor, at 704/663 1699,
Central Fil
KBDE 9 , 'EL
ely,
D. Rex Geason, Acting
Regional Supervi nor

eid2Engineering Company, Inc
Consiii tin
Design an
February 17, 1998
Mooreville Regional WQ Supervisor
North Carolina Department of Environmental Management
919 North Main Street
Mooresville, NC 28115
SUBJECT: CBP RESOURCES, INC., GAST©NIA, NC
Gentlemen,
On behalf of CBP Resources, Inc., Gastonia, NC, Reid Engineering
Company is forwarding page 5 of 8 of FORM GSPSA-02195 for the Regional Water
Quality Supervisor to provide the stream classification. A 8.5" x 11 " Location Map
is attached for your use.
Your expedited return of this document would be appreciated as CBP
Resources is ready to submit the complete application to the NC Division of
Environmental Management in Raleigh, NC. In the event that you can return this
by Federal Express, I am enclosing a self-addressed Federal Express package for
your convenience. Please call me if you have any questions.
Sincerely,
REID ENGINEERING COMPANY, INC.
hn H. Reid, P.E.
President
JHR/ca
Enclosures
1210 Princess Anne Street • Fredericksburg,. Virginia 22 X 540-371 T 570
��.�Jltr. £'+a8a,�trrsrca.p'c=vznsc'Rg.rr k.1,.Sdrt,FtEaC6�¢a:ait°ua. Fe urr::.cc,T
Vi rtan in

Y oOO ?000 3O 4000/
FROM U,S.C.S. "GASTt +MA S Tt "QUA RAM 199
ROWERS CREEK
!WTP .
R S UF3CES INC,
JTM GRID AND 1996 MAGNETIC NORTH
DECLINATION AT CENTER OF SHEET
mILE
1 0,,QMr4ETRE
FIGURE I
LOCATION MAP

This form must be completed b, the appropriate DEM regional office and included as a part of the project
submittal information.
INSTRUCTIONS TO NC PROFESSIONAL ENGINEER:
The classification of the downslope surface waters (the surface waters that any overflow from the facility would flow toward)
in which these sewers will be constructed must be determined by the appropriate DEM regional office, Therefore, you are
required, prior to submittal of the application package, to submit this form, with items 1 through 7 completed, to
the ippropriate Division of Environmental Management Regional Water Quality Supervisor (see page 8 of 8). At a
minimum, you must include an 8.5" by 11" copy of the portion of a 7.5 minute USGS Topographic Map which shows the
location of these sewers and the downslope surface waters in which they will be located. Identify the closest downslope
surface waters on the attached map copy. Once the regional office has completed the classification,
reincorporate this completed page and the topographic map into the complete application form and
submit the application package.
,
1, Appli specify name of the municipality, corporation, individual, etc.): CBP ResourcesInc.
2. Name & complete address of engineering firm:
Telephone number:
3. Project name:
4.
Name of closest downslope surface waters: Crowders Creek
5. County(ies) where sewers and surface waters are located,
6. Map name and date:
7. NC Proflf
#irti4att
7—C/1
TO REGIONAL WATER QUALITY SUPERVISOR
Gaston Conn
Gastonia South Quadrangle. 1993
's Seal. Signature, and Date:
Reid Engineering Com a
1210 Princess Anne St.
Fredericksburg, VA 22401
540 7 —8500
nc
CBP RESOURCES WASTEWATER TREATME T PLANT IMeROVEMENTS, Gastonia
NC
Please provide me with the classification of the watershed where these sewers will be constructed, as identified on the attached
map segment:
Name of surface waters: rouicte (5
6
Classification (as established by the Environmental Manacement Commission):
Proposed classification, if applicable:
Signature of regional office personnel:
FORM: GSPSA 02/95 Page 5 of 8

RECYCLING. THE N YLitLtEOF C,ri2 BUSINESS.
January 19, 1998
Mr. John Lesley
NCDivision of Water Quality
919 'N Main Street
Mooresville, NC 28115
Subject: Notice of Recommendation for Enforcement
CBP Resources WWTP
NPDES Permit No. NC0005011
Gaston County, NC
Dear John,
. Gastonia Division
CBP Resources, Inc.
This will acknowledge receipt of the subject letter, received on Janu
requested a response within ten days.
1998, which
I would like to request a seven day extension to prepare our response to you. Therefore,.
we will respond by January 29, 1998. Should you object to this, please let me know
promptly.
Thank -you and should there be any questions, please advise.
Sincerely,
Van M Jones
Environmental Manager
5533 5, York Rd, • Gastonia, NC 28052 • 704-864-9941 • Fax 7 ;4 861-9252 • Dorect Dial Number: _

NATURE OF OUR BUSINESS
April 17, 1998
Mr, D. Rex Gleason, P. E
Water Quality Regional Supervisor
N. C. Division of Water Quality
919 N. Main Street
Mooresville, N. C. 28115
Subject; Special Order By Consent
CBP Resources
Gaston County, N. C.
Dear Rex:
Gastonia
CBP Resources,
r
I.ilt''tlF
We received your letter of February 10, 1998 regarding our request to meet with your
office to discuss a Special Order by Consent (SOC), Your letter indicates that an SOC is
not appropriate in our situation in light of certain regulatory requirements. We have
reviewed the regulation that you cited and believe that it does not preclude the negotiation
of an SOC to address the problems that have been encountered at our facility. We would
like the opportunity to meet with you to discuss this matter.
Although we have experienced difficulties with the wastewater treatment system in
meeting our permit limits, these excursions have not been caused by a "failure to ...
operate, manage, and maintain the wastewater treatment system" and we believe that the
system is "being operated in such a way as to attain the highest degree of treatment
possible under the existed conditions" (citing 15A NCAC 2H--H.1206(b)(1). As we
understand your reading of the regulation, a company would be required to shut down or
significantly decrease operationsbefore negotiation of an SOC would be appropriate.
We do not believe that such drastic action is the intent of the regulation, but that, the
focus is on the proper operation of the treatment system itself rather than the entire
operation of the facility.
5533 S. Yeti< Rd., •��a nua, i- 28052 • 704-864.994i • Fax # 704-86i 9252 • Direct Dial Nrrcaber: _.
1998

Please call r Van M, Jones or r ae to schedule tirr e try rr et with your office to discuss
this tattereappreciate your cooperation.
. heri
Vice -President as Lama Divisi
e osha aar CAP sauces

te of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
April 3, 1998
Mr. Van M. Jones, Environmental Manager
CBP Resources, Inc.
5533 South York Road
Gastonia, NC 28052
Dear Mr. Jones:
Subject:
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AN D NATURAL RESOURCES
AP P,
Permit No, WQ0014944
CBP Resources, Inc.
Wastewater Collection System
Gaston County
In accordance with your application received January 30, 1998, we are forwarding herewith Permit No.
WQ0014944 dated April 3, 1998, to CBP Resources, Inc. for the construction and operation of the subject
wastewater collection extension.
This permit shall be effective from the date of issuance until rescinded and shall be subject to the
conditions and limitations as specified therein.
If any parts, requirements, or limitations contained in this permit are unacceptable, you have the right to
request an adjudicatory hearing upon written request within thirty (30) days following receipt of this permit. This
request must be in the form of a written petition, conforming to Chapter 150B of the North Carolina General
Statutes, and filed with the Office of Administrative Hearings, P.O. Drawer 27447, Raleigh, NC 27611-7447.
Unless such demands are made this permit shall be final and binding.
One set of approved plans and specifications is being forwarded to you. If you need additional information
concerning this matter, please contact Mr. Randy Kepler at [phone] extension 544.
Sincerely,
A. Preston Howard, Jr., P.E.
cc: Gaston County Health Department
Mooresville Regional Office, Water 'Quality Section
John Reid, Reid Engineering Co., Inc.
PO Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
WASTEWATER COLLECTION PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as amended,
and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
CBP Resources, Inc.
Gaston County
FOR THE
construction and operation of approximately 253 linear feet of eight inch gravity sewer, a 400 GPM pump station
with duplex pumps, on -site audible and visual high water alarms, and approximately 1,080 linear feet of six inch
force main to serve CBP Resources, Inc., and the discharge of 400,000 GPD of collected industrial wastewater
into the City of Gastonia's existing sewerage system, pursuant to the application received January 30, 1998, and
in conformity with the project plan„ specifications, and other supporting data subsequently filed and approved by
the Department of Environment and Natural Resources and considered a part of this permit.
This permit shall be effective from the date of issuance until rescinded and shall be subject to the following
specified conditions and limitations:
1. This permit shall become voidable unless the facilities are constructed in accordance with the conditions of
this pernlit, the approved plans and specifications, and other supporting data.
2. This permit is effective only with respect to the nature and volume of wastes described in the application
and other supporting data.
3 The facilities must be properly maintained and operated at all times.
4. The sewage and wastewater collected by this system shall be treated in the City of Gastonia's Crowders
Creek Wastewater Treatment Facility prior to being discharged into the receiving stream.
5. This permit is not transferable. In the event there is a desire for the facilities to change ownership, or there
is a name change of the Permittee, a formal permit request must be submitted to the Division of Water
Quality (Division) accompanied by an application fee, documentation from the parties involved, and other
supporting materials as may be appropriate. The approval of this request will be considered on its merits
and may or may not be approved.
6. Construction of the sewers, pump station(s) and force main shall be scheduled so as not to interrupt service
by the existing utilities nor result in an overflow or bypass discharge of wastewater to the surface waters of
the State.

7. Upon completion of construction and prior to operation of this permitted facility, a certification must be
received from a professional engineer certifying that the permitted facility has been installed in accordance
with this permit, the approved plans and specifications, and other supporting materials, If this project is to
be completed in phases and partially certified, you shall retain the responsibility to track further
construction approved under the same permit, and shall provide a final certificate of completion once the
entire project has been completed, Mail the Certification to the Non -Discharge Permitting Unit, P.O. Box
29535, Raleigh, NC 27626-0535.
8. A copy of the approved plans and specifications shall be maintained on file by the Penn ittee for a minimum
of five years from the date of the completion of construction.
9. Failure to abide by the conditions and limitations contained in this permit may subject the Permittee to an
enforcement action by the Division, in accordance with North Carolina General Statute I43-215.6A to 143-
215.6C.
10. The issuance of this permit does not preclude the Permittee from complying with any and all statutes, rules,
regulations, or ordinances which may be imposed by other government agencies (local, state, and federal)
which have jurisdiction.
I I. The Permittee shall provide for the pump station and force main the following items:
a.. An air relief valve located at all high points along the force main,
b. A screened vent for the wet well,
c. Fillets located in the wet well at the intersection of the flooring and sidewafls,
d. Three feet of cover (minimum) over the force main or the use of ferrous material where three feet
cannot be maintained,
e. Sufficient devices which will protect the pump station from vandals, and
f. Flood protection if the pump station is located below the 100-year flood elevation.
12. In the event that the facilities fail to perform satisfactorily, including the creation of nuisance conditions, the
Permittee shall take immediate corrective action, including those as may be required by this Division, such
as the construction of additional or replacement wastewater collection facilities.
13. NONCOMPLIANCE NOTIFICATION:
The Permittee shall report by telephone to the Mooresville Regional Office, telephone number 704-663-
1699, 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 either of the following:
a. Any process unit failure, due to known or unknown reasons, that renders the facility incapable of
adequate wastewater transport, such as mechanical or electrical failures of pumps, line blockage or
breakage, etc.; or
b. Any failure of a pumping station or sewer line 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 five (5)
days following first knowledge of the occurrence. This report must outline the actions taken or proposed to
be taken to ensure that the problem does not recur.
2

14. This permit shall become voidable unless the agreement between CBP Resources, Inc. and the City of
Gastonia for the collection and final treatment of wastewater is in full force and effect.
Permit issued this the Third day of April, 1998
NORTH CAROL INA ENVIRONMENTAL MANAGEMENT COMMISSION
Preston Hwar, Jr, P.E., Diretor
ivision of Water Quality
By Authority of the Environmental Management Corninission
Permit Number WQ0014944

Permit No, WQ0014944
April 3, 1998
ENGINEER'S CERTIFICATION
Partial
Final
1, , as a duly registered Professional Engineer in the State of
North Carolina, having been authorized to observe (periodically, weekly, full time) the construction of the project,
Project Name
Location and County
for the Perm ittee hereby state that, to the best of my abilities, due care and diligence was used in the observation
of the construction such that the construction was observed to be built within substantial compliance and intent of
this permit, the approved plans and specifications, and other supporting materials.
Signature Registration No,
Date

RECYCLING. ME NATU" O tt 1311tNESS.
November 24, 1998
Mr_ D. Rex Gleason, PE
Regional Water Quality Supervisor
91.9 N Main Street
Mooresville, NC 2811.5
Subject: Self Monitoring Report for October, 1998
NPF)ES Permit Number 0005011.
CBP Resources
Gaston County, NC
Dear Rex,
Gast �nia I. vats n
CBIResources, Inc.
For some reason we managed to misplace some stream monitoring data for the subject
report. Therefore, the enclosed report is missing some data for upstream and downstream
sampling.
We regret: this occurred, but I will not report data
Should there be any questiot
enclosure
please let me know,
appropriate documentation.
5533 5, York Rd, Gastonia. NC. 28052 704-861-9941 • Fax # [phone]? • D flct Dhal INt b

NPDES PERMIT NO. Alf -
FACILITY NAME C. 3
OPERATOR IN RESPONSIBLE CH
CERTIFIED LABORATORIES (1) _ ..?
CHECK BOX IF ORC HAS CHANGED
Mail ORIGINAL and ONE COPY to:
ATTN: CENTRAL FILES
DIV. OF ENVIRONMENTAL MANAGEMENT
DEHNR
P.O. BOX 2953S
EFFLUENT II
DISCHARGE NO, 00 / MONTH oho
CLASS, COUNTYS
OR i. Ja.t 7:5At? . GRAD PHONE �t'Y
(2)
PERSON(COLLECTING S
x
(SIGNATURE OF ERATOR IN RESPONSIBLE CI -
BY THIS SIGNATURE, I CERTIFY THAT THIS REPORT IS
ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE.
RGE)
EAR
Foy'%
DEM Form MR. I.
(Revised. I V94)

Facility Status: (Please check one of the following)
All monitoring data and sampling frequencies meet permit requirements
All monitoring data and sampling frequencies do NOT meet permit requirements
Compliant
If the facility is noncompliant, please comment on corrective actions being taken in respect to equipment, operation, maintenance, etc.,
and a time table for improvements to be made.
"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."
55)5 s--
Permittee Address
Permittee (Please print or type)
Signaure. Permittee** Date
.70(7/1 v
Phone Number
00010 Temperature
00076 Turbidity
00080 Color (Pt -Co)
00082 Color (ADMI)
00556
00600
00610
00625
00095 Conductivity 00630
00300 Dissolved Oxygen
00310 BOD5 00665
00340 COD 00720
00400 pH 00745
00530 Total Suspended 00927
Residue 00929
00545 Settleable Matter 00940
PARAMETER CODES
Oil & Grease 00951
Total Nitrogen 01002
Ammonia Nitrogen
Total Kjeldhal 01027
Nitrogen
Nitrates/Ni trites
01032
01034
Total Phosphorous
Cyanide 01037
Total Sulfide 01042
Total Magnesium
Total Sodium 01045
Total Chloride 01051
Total Fluoride
Total Arsenic
Cadmium
Hexavalent Chromium
Chromium
Total Cobalt
Copper
Iron
Lead
ermi
x . Date
01067 Nickel
01077 Silver
01092 Zinc
01105 Aluminum
01147 Total Selenium
31616 Fecal Coliform
32730 Total Phenolics
34235 Benzene
34481 Toluene
38260 MBAS
39516 PCBs
50050 Flow
50060 Total
Residual
Chlorine
71880
71900
81551
Formaldehyde
Mercury
Xylene
Parameter Code assistance may obtained by calling the Water Quality Compliance Group at [phone], extension 581
5 4.
The monthly average for fecal conform is to be reported as a GEOMETRIC mean. Use only units designated in the reporting
facility's permit for reporting data.
• ORC must visit facility and document visitation of facility as required per 15A NCAC 8A .0202 (b) (5) (B).
** If signed by other than the permittee, delegation of signatory authority must be on file with the state per 15A NCAC 2B .0506 (b)
(2) (D).

NPI ES N©. / d 4 d; j Q
FACILITY NAME ez ,
STREAM Crow w ei cr
LOCATION
DISCHARGE NO.
a/ S
Upstream
STREAM Cro
LOCATION S G 6
Downstream
Enter Parameter C
Above Name and
Units Below

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
Jaynes B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr.„ P.E. Director
September 5,
Mr. Van N,I. Jones, Environmental Manager
CBP Resources, Inc.
5533 S. York Road.
Gastonia, North Carolina :28(i5
Dear NSr. Jot e„
997
)LC E PT, or
IlkiNRr NIdE,'tiT, WEA1:1't
a' NATURAL RESOU NCit;
SEP 5 1997
INYI L1Jl or NlYt.4 ,1 U Tll itausur
►r 3t4tsvmdE "am ME
Subject: `NPDES Permit Issuance
Pernufi Nifiiber: NC0005011
CBP Resources, Inc.
Gaston County
In accordance with the application for a discharge hermit received on March 29, 1996, the
Division is forwarding herewith t he subject NPDES permit. `(This permit is issued pursuant to the
requirements of North Carolina General Statute 1.43-715.1 and the Memorandum of Agreement
between North Carolina and the U.S. Environmental Protection Agency dated December 6, 1983.
Gastor
the dra
.spouse to continents and concerns raised by members of the public,
and CBP concerning NPDES draft permit no, NC000501.1 for CBP Resource
permit was revised, Please note the following:
The pern it will be issued for a period not to exceed 18 months from September 30,
Based on the alternatives analysis submitted to the Division, this permit will 11
renewed..
Plans and
submitted
Condition
forcemeat
fications for ti
the Division of Water
(4).
Six months pri
coverage under General .Perini
NPDES general permit that prov
boiler blowdown. condensate and
y be
97.
•tion to the City of Gastonia's wastewater s, stem he
on or before. January 31, 1998. See Special
ed if either of the dates mentioned above au°e not met,
is permit, CBP will be required to apply for
the existing 002 outfall. NCG500000 is the
:outdo cooling water, cooling tower and
waters.
If any parts, measurenleat frequencies or sampling requirements contained in this permit
are unacceptable to you, you have the right to an adjudicatory hearing upon written request within
thirty (30) days following receipt of this letter. This request must be in the form of a written
petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the
Office of Administrative Hearings, 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 27626-0535 Telephone [phone] FAX [phone]
An Equal opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

req
Please take note that
his pc►
is to be followed in caseof change in r
ship
Part .[ , I . ad 1r s; .s
hangs.
)er nit does no a feet the legal rct rrircmerits to ohtain other lac r sits which) y
d he Division f t`ity or pet -e quireel ley tlr I i °i i n tal` Lrrrrd Resources or
y other Federal or Local govern ental permit th t rrtay he required
en-
)73
gardin this
resin 51 e
Sincerely
Water Q al
os velt Childress, EPA
Bobby Bic -me
NPDES Unit
Complian e l .n t rcern n..t L. mt
Aquatic " oxi ology Unit
"1'eclrnical As, cc & Corti l eati ti n
11
'rHo
eel
contact Steven [ . Pell ei at

STATE OF NORTHCAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, NATURALRESOURC
DIVISION OF WATER QUALITY
ci No, l 011
PERMIT
TO DISCHARGE WASTEWATER UNDER G THE
NATIONAL PLL TANT DISCHARGE ELI Ii NATION SYSTEM
In c oniplicanee e pr a vision of North carcr.lirrra enet
and regulations prornut ated and adopted by the rth Caro
`onamissican, and the Federal "Water Pollution Control Act,
-ehy a
horir
e 11:-21.1, other lawful star
1vironmental Managemertt
bided,
CBI) Rescaar°ces, Irr;
to t ogee a f raciiity located at
ica Elie°ii
US flihwv<ay
tonic
Gast can {v turity
iving waters deli i areal cats "r°,reek it
in ace
and 1 here(`
The perrra:
This per-rr^,
,a:
orn re
rraitatic1ras, mot ttrrira regimen
etctoher1;1 97
tau
tire, cautho �i action t
y Sur teraaher y 19 17
can
wwh a River Basilr
her
hall expire cat r -aidnieht c
A. Preston Howard
Division ofW.ter
By Authority of the
eetor
aental Management Commis
S
Pa
Oat

ifsChereby.:authorized !tot •
SUPPLEMENT ClTPERMIT COVER SHEET
CBP Resources, Inc.
Permit No. NC000501
1. Continue to operate the existing 0,257 IVIGL) wastewater treatment facility (outtall 001)
consisting of an activated sludge W\VTP, Polishing ponds, and chlorination facilities, and
3. Discharge non contact coixlingb water (outfall 002) from facilities located at Gastonia Division,
US Highway 321 Gastonia, Gaston County (See Part CH of this Permit), and
Discharge front said treatment works at the locations specified on the attached map into
Crowders Creek which is classified C waters in the Catawba River 13 tisin.

ROAD CLASSIFICATION
PRIMARY HIGHWAY
HARD SURFACE
LIGHT -DUTY ROAD HARD OR
IMPROVED SURFACE
SECONDARY HIGHWAY
HARD SURFACE UNIMPROVED R4JAD
Latitude 35°09'41" Longitude
Map # G14NW Sub -basin 030836
Stream Class C
Discharge Class oI : u3, z. aa1 :14
Receiving Stream Crowders Creek / Catawba. River
Design Q 0.257 MGD Permit expires 9/30/01
"F A
SCALE 1:24 ON
CONTOUR INTERVAL 10 FEET

A (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Permit No. N00005011
During the period beginning on the effective dale of the permit and la ting until expiration, 11•' Permiltee is authorized lo disc large from .outfail serial number
001. Such discharges shall be limited and monitored by the Permitlee as specified below:
EFFLUENT CHARACTERISTICS
-Flow
BOD, 5 day, 20°C
NI h as N
Dissolved Oxygen
'uspended Residue
Fecal Colilorm (geometric
Oil & Grease
Totai Nilroqen (NO2
Total Phosphorus
Temperature
pi
Chronic Toxicity3
ttQlea:
an)
NO3+ TKN)
IVlonthly
Average
0,257 MGD
306 lbs/day •
lb day
378 bsiday
LIMITS
Da 1 y
aximUrn
Monthly
Average
Daily
Maximum
/day 143 rrig/I 285 mcvl
_a
756 lbsiday
360 lbsida
400 / 100 rill
MONITORING REQUIREMENTS
Measurement
Frequency
Continuous
Weekly
Weekly
Weekly
Week ly
eelsi
OLkly
Weekly
sample
Type
Recorder
Composite
Composite
Grab
Composite
Grab
Grab
Compo,5ite
Composite
Grab
Grab
Composite
Sample
Location'
or E
E, U, D
E, U, D
E
Sample locations: E Effluent, I - Influent, U - Upstream al US Highway 321, D - Downstream al SC Highway 654, Upstream and downstream monitoring is to
be conducted weekly.
2 The pH shall not be less than 6,0 standard units nor greater than 9 0 standard units,
Chronic Toxicity (Ceriodaphnia) PiF at 3%; August, November, February, and May: See special condition A (3). on the Supplement to Effluent Limitations
and Monitoring Requirements Page.
There shall be no discharge of floating solids or visible foam in other than trace amounts,
Special permit conditions applicable to the subject facility are listed on the Supplement to Effluent tjmhtalions and Monitoring Requirements page.

A(.2), EFFLUENT UMITATIONS AND MONITORING REQUIREMENTS - FINAL Permit No. NC0005011
During the period beginning on the effective date of the permit and lasting until expra0on, the Pern-illee is authorized to discharge from out fall(s) numbered .serial number 002, Such discharges shall be limited and monitored by the. Penniflee as specified below:
Flow
femperature*
-Intel residual lorine'•
onthly
verage
Weekly
Average
Daily
Maximum
MONITORING REQUIREMENTS
tileasurement
Frequency
Semi-annually
Semi-annually
Sample
Type
Grab
Grab
Sample
Location
1E111w:1r-it
FlIflocir11
There shall be no chromium, zinc or copper added to the treatment system except as pre -approved additives to biocide'
compounds.
• The temperature of the effluent will be regulated so that the temperature 01 the receivnq stream does not increase more than 2.8C above the riatup:11 water
temperature and not exceed a maximum of 29C,
•" Monitoring requirements apply only if chlorine is added to the treatment system„
The permiltee shall obtain authorization from the Division prior to any use of biocide in the cooling water. The permittee shall notify the Director in. writing at least
ninety (90) days prior to instituting use of any additional biocide in the treatment system which may he Toxic to aquatic life (other than biocides previously
reported to the Division), Such notification shall include completion of Biocide WorRsheet Form 101 and a map indicating the dischargepoint and receiving
stream.
The pHshall not be less than 6.0 standard units nor
han 9..0 standard units,
There shall be no discharge of floating solids or visible loam in other than trace amounts,

Part 1 Permit Na. N(„70( „
Supplement to the Effluent Limitations and \tonitorng
Requirements - Special Con
A (3). CHRONIC TOXICITY PASS/FAIL PERMIT umrr (QRTRLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in the "North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised November 1995, or subsequent
versions.
Hie effluent concentration at which .there may be no observable inhibition of reproduction or significant
mortality is 3.0% (defined as treatment two in the procedure document). 'Elie permit holder shall perform
quarterly monitoring using this procedure to establish compliance with the permit condition* The tests will be
performed during the months rif February, May, August, and November. Effluent sampling for this
testing shall be performed at the N.PDES permitted final effluent discharge below alt 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, DWQ Form ATLI. (original) is to he sent to the following address:
Attention: Environmental Sciences Branch
North Carolina Division of Water Quality
4401 Reedy Creek Road
Raleigh, North Carolina 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 stream*
Should there he 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 lop of the aquatic toxicity (AT) test forrn 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 Corm. The report shall he submitted to the Environmental Sciences
Branch at the address cited above.
Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly monitoring will
begin immediately until such nine that a single test is passed. Upon passing, this monthly test requirement
will revert to quarterly in the months specified a.bove*
Should the permittee fail to monitor during a. month in which toxicity monitoring is required, then monthly
monitoririg, will begin immediately until such time that a single test is passed. Upon passing, this monthly test
requirement will revert to quarterly in the months specified above.
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 he 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, mininium 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.
OCL, P/P 'Version 9/96

Pecmot]No, NC0]005011
"^
AND
- _____-N OF PLANS�_SPECIFICATIONS_FOR CONNECT ION
-__~_"connection--_---,___- to the - -°~-_~_'~�

tion 13. rile of om lian
I. The permittee 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 permit unless
specified below.
2. Permittee shall at all times provide the operation and maintenance necessary to operate the
existing facilities at optimum efficiency,
PART I
3No later than 14 calendar days following a date identified in
the permittee shall submit either a report of progress or, in
required by identified dates, a written notice of compliance or
the notice shall include the cause of noncompliance, any
probability of meeting the next schedule requirements.
the above schedule of compliance.,
the case of specific actions being
noncompliance. In the latter case,
remedial actions taken, and the

Part II
Page 1 of 14
PART II
STANDARD CONDITIONS FOR NPDES PERMITS
SECTION A. DEFINITIONS
1. Permit Issuing .Authority
The Director of the Division of Water Quality.
2. DEM or "the Division"
Means the Division of Water Quality, Department of Environment, Health and Natural Resources.
3. EMC
Used herein means the North Carolina Environmental Management Comrnission.
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 andior 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 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 1 of the permit.

Part Il
Page 2 of 14
6. icentration Measurement
a. The "average monthly concentration," other than for fecal conform 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 conform 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". lt 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'claily 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 1 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.
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 ot 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 I1
Page 3 of 14
2. Other Measurements
a. Flow, (MGM: 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.
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 samples are individual samples collected over a period of time nut
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).
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.

Put II
Page 4 of 14
10. Calendar 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. Toxic Pollutant
A toxic pollutant is any pollut
n
sted as toxic under Section 307 of the Clean Water Act.
SECTION B. GENERAL CONDITIONS
1. Duty to Comply
The permittee must comply with all conditions of this permit Any permit noncompliance
constitutes a violation of the 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)1
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 "§ 143-215.6AI
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 I 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 II penalty not to exceed $125,000,

Part II
Page 5 of 14
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.
Civil and Criminal Liability
Except as provided in permit conditions on "Bypassing" (Part II, C-4) and "Power Failures" (Part I1,
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.
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 1.43-215.75 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.
Duty to Reapply
If the permittee wishes to continue an activity regulated by this permit titter the expiration date of
this permit, the permittee must apply for and obtain a new permit.

Pan 11
Page of [4
10. Expiration of Permit
The perrnittee 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 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 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
(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:
"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_ t am aware that there are significant penalties for submitting false
inforrnation, including the possibility of fines and imprisonment for knowing violations."

Part 11
Page 7 of 14
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 Reissuanet‘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 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 Cade, Subchapter 2H .0100; and North
Carolina General Statute 143-215.1 et. al.
14, Previous Permits
All previous National Pollutant Discharge Elimination System Pcrmts sued to this facili y;
whether for operation or discharge, are hereby revoked by issuance of this permit. IThe 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. I 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 1.vtAINTENANCE 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 (ORO 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, 111, 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.
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 a Defense
It shall not be a defense for a permittee in an enforcement action that it would have been necessa
to halt or reduce the permitted activity in order to maintain compliance with the condition ot tl
permit.
Bypa sing of Treatment Facilities
a. Definitions
y
(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
(i) Anticipated bypass. If the permittee knows ire advance of the
submit prior notice, if possible at least ten days before the date
evaluation of the anticipated quality and affect of the bypass.
(2) Unanticipated bypass. The permittee shall submit notice of a
required in Part II, F. 6. of this permit.. (24 hour notice).
d. Prohibition of Bypass
(1) Bypass is prohibited and the Per
a permittee for bypass, unless:
(A) Bypass was unavoidable to prevent loss of 1
damage;
(B) There were no feasible alternat
need for a
of the bypas
pass, it shall
including an.
n unanticipated bypass as
ssuing Authority may take enforcement action against
personal injury or see€ere property
to the bypass, such as the use of auxiliary treatment
facilities,. retention of untreated wastes or maintenance during normal periods cif
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.
The Permit Issuing Authority may approve n anticipated bypass, atte
adverse affects, if the Permit Issuing Authority determines that it wit
conditions listed above in Paragraph d. (l) of this section.
considering tts
meet the three

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 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 11, E. 6. (b) (B) 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 permitteeseeking, to establish, the kfccurrence of all 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 NCGS 143-215J 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 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 permittee shall notify the Permit Issuing
Authority of any significant change in its sludge use or disposal practices.
7. Power 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.

Part II
Page 10 of 14
SECTION D. MQNITQINGANDRORDS
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) Form (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 Water Quality
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 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 al)
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 ll
Page l 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.
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 WOO 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. R
ds Retefto
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. Inspe tion 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 perrnittee's premises where a regulated facility or act vity 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
Page
SECTION E. REPORTING REQUIREMENTS
, 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 cnteria for deterrnming
whether a facility is a new source in 40 CFR Part 122.29 (b); or
b. The alteration or addition could significantiy change the nature or increase the quantity oi
pollutants discharged. This notification applies to pollutants which are subject neither to
effluent limitations in the permit, nor to notification requirements .under 4(1 CFR Part 122,42 ta)
(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.
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,
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) (sec part 11. D. 2
of this permit) or forms provided by the Director for reporting results of monitoring of sludge use
or disposal pra.ctices.
b. If the perrnittee 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.

Part 11
Page 13 of 14
6. Twenty4our 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 tirne 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 n the permit.
(.3). Violation of a maximum daily discharge limitation for any of the pollutants hsted 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.
8. Other 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.

Part I
Page 1 oaf 14
Persons reporting such occurrences by telephone steal
5 days following first knowledge of the occurrence.
10, Availability of Reports,
Except for data determined to be confidential under NCGS 4-213.3(alt . 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 irrapositiorc of criminal penalties as provided for in NCGS 143-21 .1(b)() or
in Section 309 of the Federal Act,.
tten 'report in later to y athin
I1. Penalties for Falsification of Reports
The Clean Water Act provides that any persori who knowm ly makes any fare 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 Ui
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.
13, Groundwater Monitoring
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. Chan in Dischares of Toxic Substane
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 micrograms per liter (100 ug/ I);
(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 u.g/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. Re ui inu • tiate Altern o e
The permittee 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 suchform and detail as required by the
Division evaluating these alternatives and a plan of action within sixty (60) days of notification by the
Division.

'_#
The
.„.
revoke
ITIUSt pay ual te g plian
being billed the Division. F to spay t oe r
.01050)(4,1 may cause this Division to wit,
30
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action t

STATE OF NORTH A OLINA
DEPARTMENT E E ENVIRO ENT, HEALTH AND ATURAL RESOURCES
Division of Water Quality
919 North Main Street Mooresville, Nnrth Carolina 28115
y 11, 1998
VAN M._JE-
P RESOURCES - GASTONIA IV
5533 SOUTH YORK OAI
GASTONIA NC 28052
SUBJECT. Notice of Violation Effluent
NPDES No, NC0005011
CEP RESOURCES - GASTONIA DI.
GASTON unty
Dear VAN M. JONES:
Review of subject self -monitoring report
of March, 1998 revealed violation(s) of the fo
parameter( :
Pipe Parameter
001 00310 ai
Reported
Value/Unit
413,00 LBS/DA
Remedial a ti one, if not already ,imp
taken to correct the problem . The Div
Quality may pursue enforcement actions for
additional violations of State Law. If you
you need assistance, please call CB Rex Gle=
Quality Supervisor, at 704'3-16.
Sincerely,
r l
Ac
Regional SupeiM
cc Central Files
GRBDEX96/BL
at i ons
the men
ing
mits
" alue/T pe/ "ni
306.00 FINLBS/DA
entedshould be
on of Water
and any
havequestions or 1
son, RegionalWater
1n
or

STATE F NORTH CAROLINA
DEPARTMENT ENVIRONMENT, HEALTH AND NATUR L RESOURCES
Division of Water Quality
919 North Main Street. Mooresville, Nrtia rol.
Apr' 13, 1998
VAN M. JONES
CBP RESOURCES __ GASTONIA DI'..
5533 SOUTH'YORK ROAD
GASTONIA N. 2 052
Ca
SUBJECT': Notice of Violation -m Effluent
NBDES No. NC0005011
CBI' RESOURCES - GASTONIA DIV.
GASTON County
Dear VAN EL I NE ::
a
ations
Review of subject elf--moni oo ° f' / the month
f February, 1998 revealed violation ) of th following
parameter(s)w
Pipe Parameter
001 00310
Reported mite
Value Unit Vl /Typ 'Un:
16 .0Q LBS/DA 306.00 FIN LBS DA
Remedial actions, if not al.eady implemented, 1ould be
tak n to correct the problem( ) . The Division of Water,
may pursue enforcement actions for tAt is and any
additional violations of State Law. If you 'e questionsor
you need assistance, please call D. Rex Gleao Regional i t. ,
Quality Supervisor, at 7/3-1"
cc: CenCentral 'i to
BDE. 6 E
Sincerely,
B. Christian, _Acting
Regional Supervisor

NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
MOORESVILLE REGIONAL OFFICE
DIVISION OF WATER QUALITY
May 20, 1998.
Mr. E.R. Olberding
CBP Resources, Inc.
5533 South York Road
Gastonia, North Carolina 28052
SUBJECT: Compliance Biornanitoring
Inspection Report
CBP Resources WWTP
NPDES Permit No. NC0005O11
Gaston County, NC
Dear Mr. Olberding:
Enclosed is a copy of the Compliance Biomonitoring Inspection Report for the
inspection conducted at the subject facility on May 8, 1998 by Mr. John Lesley of this
Office. Samples were collected on May 4-5 and 7-8, 1998 for use in a chronic
Ceriodaphnia dubia pass/fail toxicity test. The test utilizing these samples resulted in a
pass .
The report should be self-explanatory; however, should you have any questions
ncerning this report, please do not hesitate to contact Mr. Lesley or me.
Sincerely,
D. Rex Gleason, P.E.
--`Water Quality Regional Supervisor
c: Gaston County Health Department
Aquatic Toxicology
Central Files
919 NORTH MAIN STREET,. MCIORESVILLE, NORTH CAROLINA 28115
PHONE [phone],99 FAX [phone]
AN EQUAL O1 PORTUNITY / AFFIRMATIVE ACTIN EMPLOYER « SO% RECYCLE©/1 ©% POST -CONSUMER PAPER

United States Environmental Protection Agency, Washington , DC 20460
NPDES Compliance Inspection Report
North Carolina Department of Environment and Natural
Division of Water Quality, Mooresville Regional Office
Form Approved
a No. 2040-0003
Transaction Code NPDES Permit No. YR/MO AY Inspection Type Inspector Facility Type
N 5 NC0005011 98/05/08 B S 2
Entry Time:
Name and Location of Facility Inspected: 11:30
CBP Resources WWII' Exit Time:
5533 South York. Road 12:00
Gaston County, North Carolina Date:
98/05/08
Name(s) of On -Site Representatives -----Titles) Phone No(s):
Van _Tones / Environmental Manager-ORC / (704) 864- '941
Name and Address of Res
Mr. E.R. Olberding
CBP Resources, Inc.
5533 South. York Road
Gasto i N • ,
sibte Official:
Title:
Vice President of l rations
Phone No, Contacted?
[phone] No
N Permit N Flow Measurement NA Pretreatment N Operations and Maintenance
N Records N Laboratory NA Compliance Schedule N Sludge Disposal
N Facility Site Review N Effluent/Receiving Waters N Self -Monitoring Program S Other: Toxicity
Signature(s) of In
John .Lesley
Agency/Office/Telephone: Date:
DEI+1Pt-DWQ/MR©/[phone] FAX: [phone] May 20, 1998
ncy/wee Date:
ion Taken Date:
EPA Form 3560-3 (Revised 3-85) Previous Editions are Obsolete

CBP Resources, Inc
NPDES Permit No, NC4005011
Page 2
CBP Resources has an effluent discharge permitted at 0,257 MGD entering Crowders
Creek (7Q10 of 13 cfs). Whole effluent samples were collected on May 4-5 and May 7-8, 1998
by CBP staff for use in a chronic Ceriadaphn a dubia pass/fail toxicity test. The test using these
samples resulted in a pass. Toxicity test information follows:
Test T
Test Concentration
Test Result
Control Sury
-Brood Ceri+ daphnia dubia pas
P
0
p
e
Con
Re roduction
Test Treatment Surviv
Trea rent Mean Reproduction 19.6 neonate
First Sample pH
First Sample Conductivity
First Sample TRC
Second Sample pH
Second Sample Condu
17,4 neonat
10 '"0
7.75 s.u.
860 micromhosic
0.1m
7.69 s.u.
1850 micromhos/cm
Second Sample TRC <0.1 mg/1
Test results for these samples indicate that the effluent would not be predicted to have
water quality impacts on the receiving stream.

DIVISION OF ENVIRONMENTAL MANAGEMENT WATER QUALITY FIELD -LAB FORM (DM1)
Shipped by:
COLLECTOR(S):
Estimated BOO Range: 0-S/5.25(2 40-130 or 100 plus
Setdr Yee D"No ] Chlorinated: Yes Eli No 0
PRIORITY
['AMBIENT
E 3 MPLIANCE
0EMERGENCY
STATION LOCATION:
REMARKS:
Date Begin (yy/mm/dd}
0
2
CO
40
mg/1
oliiorm:
/10
Conform: MF Toted 31504
/100ml
Time Begin
QA
CHAIN
OF CUSTODY
SAMPLE TYPE
0 STREAM LJ EFFLU
Q LAKE INFLUENT
0 ESTUARY
F
DATA ENTRY BY:
CK:
DATE REPORTED:
End
Time
Chloride 940
h1 a, Trl 32217
Chi as Corr 322
Pheophytln a 32213
Color: True 80
6
7
;Residue: Toted
615
67
100
0
9
Volatile 505
10
Fixed 510
oviduct Suspends
12
Volatile 535
13
4
Ftxed 540
pH 40
5
Acidity to pH 4.5 436
16
Acldlty to pH 8.3 435
17
Alkalinity to pll 8.3 415
18
kallnity to pH 4.5 410
OC 680
20
idlty 76
Colore(pH
ug/l
Pt -Co
83
Colon pH 7.6 82
ADMI
ADMI.
nlda 720
de 71880
Grease an
Hardness Total 900
Spaclilc Cond. 95
u
Phenols 32730
74
ng Point X
4
5
480
2
r Terri
10
Pre
d Cover X
D
d 10/86
pit 8.3
d
Dep
DM DO DBM
Value Type
A H L
NH3 aeN610
TKNaaN6
NO2 pins NO3 us N 6
P: Total as P 66
4 as P 70507
P
tl
dmium 1027
C
T
Cu-Copper 1042
NI -Nickel 106
Ph -Lead 10•a1
Zr-Z1nc 1092
u
ug/i
Al -Aluminum
ug/1
Be -Beryllium 1012
Ca iu
bait 1037
ron 104
u
rpost
T
Li-Ltthlum 1132
Mg Magt 4elum 927
Ole Type
C G GNXX
ug/I
Mn-Mangane►e 1055
Se -Selenium 1147
Hg-Mercury 71900
Pesticides
Extractable Organics
Acid Extractable Organics
i
ug/I
ug/I
Purgeable Organics (VOA bottle reg'd)
4
4.5
2243
Acldlty
pH 8.3
Turbidity Severity
d Velocity M
Alt Tetn
82242 _,
Mean Stream Depth it.
64

COUNTY t GASTON
RILRI3ASINi
REPORT TO
hIRO Regional 01336it "
Other
COILECTORIS3 BEAN.'
Estimated BOD Range: 2$45
Seed: Y
Sahon
NC 01
Chlorinated, Y
ate Hoin ilyyr
X ROD 310
310 mat
COO High 340 mat
COD Low 335
Coliform: hIF Feral 33616 /100ml
Cola-0m:
Toiat 31504
Coliform: tube Fecal 31615
Col Worm: Fecal Soto 31673
Residue: Total 500
Volatile 503
fixed 510
li,s0m1
100ml
+110Orril
iota
nogtL
ma/L.
asidtat 2 0 rog/L
,olotile 35 mad_
hoed 340
mg&
pH 403
Acidity:to p 35 436
Acidity In pH 8 3 43
Alkalinity to pH 8,3 415
Alkalinity to pll 4 5 410
TOC 680
Ilona
404
nig,1
0943.
Hfurhirlity 70
COMMENTS
DIVISION OF ENVIRONMENTAL NIANAGEMENT
Chemistry Laboratory Report Water paiiility
PRIORITY
M313TIPNT
r'i CHAIN OF al:STUDY
Ej EMERGENCY
nte End I yyrnil iordili
idnride 9311
Chl lo32217
Station Location, CBI"
14(,011116E
Time begin
SAMPLE 'TYPE
Lil
STRE.A151
11 LAKE
0 ESTUARY
itne En
hla Coir 32200
phyrin a 32213
Color True 80
C0101, $3 pil
Calm pH 7,6 32
milif„.
1911.
c u
C L4
Cyanide 720
ide 931
Formaldehyde 7 t 880
asa and Oils 556
mg,lt
ingri
malt
1f ard rims 'Toth! 900
Specific. Cond 95 ohlhos, ern':
IlOAS 38260
Phenols 32730
rogiL
Sulfate 9.45
Sulfide 745
Boron
Coliforin 1 owl It
'.)1 00 rola
oplh -
EFFLUENT
VallAf Type - A.11,
N 13 na N 6 0
N I an N 625
0
02 plus N01 as ,30
A Itiminu 1
Fit Iron 1045
Lab Numlier 61V723 I
09o10 Recetaed : I 244,^516
Time Received 9 05 AM
Receii ed Ily 4115151
Ifrain Released 151
Dale Reported if! 0,97
Sample r,pe
1,i1kliurn 1132
13114- 1,1.4,01.000/01 927
Mniklanganese 3055 °WI
NEk- Willa, 9'29 nt
Arsenic:Total 1002 ogIL
Se- Set into 1147 0361.
11g- hleicuri, 71900
Ila
Orgaraighlorine Pesticides
Orgonuplansphoios Pcsiicides
Acid Herbicides
isral&Acid atmetill3. It3 g
TP11 Diesel Range
Purgrable Oraanies (VOA hook rect'dll
-FPI! Gasoline Range
'1P1111TEX Gasoline Range
Pio inplarikinn

e of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
Mr. Gene Olberding, VP, Gastonia Division
CBP Resources, Inc.
5533 South York Road
Gastonia, NC 28052
Dear Mr. Olberding:
The Division of Water Quality has received your package for sewer extension from CBP
Resources to the City of Gastonia sewer collection system. Construction and operation of a sewer
extension in the State of North Carolina requires a formal permit application, application :fee and
supporting documents must be submitted for review. The following items remain be submitted/addressed
before the Division, can complete the review:
1. Please submit. a completed application form with all the appropriate signatures and attachments..
(Copy of application attached),
2. Please submit a $400.00 application fee for a new permit.
3. Please submit fully completed plans showing the plan and profile views of all pump stations,
force mains and gravity sewers for this project.
4. Please submit a set of specifications for this project.
I have also attached, along with the application, a copy of the state's Gravity Sewer Minimum
Design Criteria and a copy of the Division of Water Quality's Administrative Code Section specific to non -
discharge systems and sewer extensions. This information should help in completion of this package.
Please refer to the subject permit application number when providing the requested information.
Please submit two (2) copies of all information to my attention at the address below.
Also, please note that failure to provide this additional information on or before March 20, 1998 will
subject your application to being returned as incomplete, in accordance with 15A NCAC 2H .0208.
February 6, 1998
Subject: Application No. WQ0014944
Additional Information Request
CBP Resources, Inc.
Sewer Extension
Gaston. County
If you have any questions on this matter, please call me at [phone] ext. 544.
cc: Mooresville Regional Office, Water Quality
Reid Engineering Co., Inc, (with attachments)
Permit File WQ0014944
Si
Randy L. Kepler, P.:f., Environmental Engineer
Non Discharge Permitting Unit
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An EqualOpportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

State of North Carolina
Department of Environment and
Natural Resources
Division of Water Quality - Non Discharge Branch
Non-Dishcharge Permitting Unit
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
MR. GENE OLBERDING
CBP RESOURCES RECYCLING
GASTON DIVISION
5533 S. YORK ROAD
GASTONIA, NORTH CAROLINA 28052
Dear MR. OLBERDING:
February 4, 1998
Subject: Application No. WQ0014944
CBP Resources/Crowders Creek Site
Sewers -Private
Gaston County
The Division's Permits and Engineering Unit acknowledges receipt of your permit application arid
supporting materials on January 30, 1998. This application has been assigned the number listed
above.
Your project has been assigned to Mr. Randy L Kepler, P.E. for a detailed engineering review. Should
there be any questions concerning your project, the reviewer will contact you with a request for additional
information.
<Be aware that the Division's regional office, copied below, must provide recommendations .from the
Regional Supervisor or a Procedure Four Evaluation for this project, prior to final action by the
Division.
If you have any questions, please contact Mr. Randy L. Kepler, P.E. at [phone] extension 544.
If the engineer is unavailable., you may leave a :message on their voice mail and they will respond.
nrnmnti
PLEASE REFER TO THE ABOVE APPLICATION NUMBER WHEN MAKING.
INQUIRIES ON THIS PROJECT.
CC:
Mooresville Regional Office
Reid Engineering Co., Inc
Sincerely,
Mr. Kim Colson, P.E.
Supervisor, Non -Discharge Branch, PermitUnit
AfC) eA\i:
Pollution Prevention Pays
1),O. Box 29.535, Raleigh North Carolina 27626-053.5 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
MOORESVILLE REGIONAL OFFICE
DIVISION OF WATER QUALITY
February 10, 1998
Mr. Van Jones
AWE MCDEVITT CBP Resources
SECRETARY 5533 South York Road
'• Gastonia, North Carolina 28052
11.1104
JEATEMMEMMA
EINAESTAMV
Subject: Review of Response to
Notice of Recommendation for Enforcement
CBP Resources WWTP
NPDES Permit No. NC0005011
Gaston Countv. NC
Dear Mr. Olberding:
CBP Resources was issued a Notice of Recommendation for Enforcement on
January 8, 1998 for violation of limits contained in the facility's NPDES Permit. The
Company's response dated January 27, 1998 has been reviewed by Mooresville
Regional Office staff. According to the response, CBP is considering making
application for a Special Order by Consent.
This Office has concluded that the permittee does not meet the criteria for SOC
• eatibility. 15A NCAC 2H.1206(b)(1) states that CBP must demonstrate that the
noncompliance is not due to failure by the permittee to properly operate, manage., and
maintain the wastewater treatment system and that the existing wastewater treatment
system is being operated in such a way as to attain the highest degree of treatment
possible under the existing conditions. Because most of the problems are associated
with organic overloading of the facility and inadequate disinfection of the discharge,
this Office is of the opinion that the noncompliance is related to facility operation.
Furthermore, an enforceable schedule for the elimination ofthe discharge is included in
the facility's NPDES Permit.
919 NORTH MAIN STREET, MOORESVILLE, NORTH CAROL/NA 28115
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY / APERMATIVE ACTION EMPLOYER - SO% RECYCLEIDII POST -CONSUMER PAPER

CBP sres
DES Permit No, NC00050
Should CBP Resources desire a m g to discuss
hesitate to contact John Lesley or me.
Sincerely,
ss
D. RexGleason, P.E.
Water a ty c on Supervisor
DianeLon
Bob Sledge, Compliance Unit
Central Plus

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
Division of Water Quality
919 North Main Street Mooresville, Narthh. Carolina 28115
VAN M. JONES
January 12, 1998
CBP RESOURCES - GASTONIA DIV
5533 SOUTH YORK ROAD
GASTONIA NC 28052
SUBJECT, Notice of Violation - Effluent Limi
NPDES No. NC0005011
CBP RESOURCES - GASTONIA DIV.
GASTON County
Dear VAN M. JONES:
ns
Review of subject self- oni or n9 report for
af` October, 1997 revealed violation(s) of the fal
parameter(s)
Pipe Pa
am
ter
001 00310 BOD
Reported
Value/Unit
441.00 LBS/DA 340.00 FIN LBS/DA
month
ng
is
Value/Type/Uni. t
Remedial actions, if not already implemented,. should be
taken to correct the problems). The Division of Water
Quality may pursue enforcement actions for -this and any
additional violations of State Law. If you l ave question o
you need assistance, please call D. Rex Gleason, Regional Way
Duality Supervisor, at 70 / 63-1 99_
Cent;
GMBDEX96/BL
es
Sincerely
0. Rex Cle so ; Acting
Regional Supervisor

N. C. DIVISION OF ENVIRONMENTAL MANAGEMENT
EMERGENCY REPORT FORM
rialennIC
q
Report taken bv: e +� �+' Da .�
(Name)
nine of ir�cideRl:
+1 ntiined(Y(N).:
Contact Namew_„__,..
Phone.
Re as►t4 for Spill
On_ et con►a+ct,
Phone #t
Cleanup Began (YIN,): AST/UST:
Regional 1ff ce: ARC FR0
Name:
Address:
City:
Agency:
0 WARO WIRO WSRO
Other agencies involae(I/contacted: Circle appropriate agency
EPA Region Iv - 404/347-4062-24 hrs
Emergency Ma,agement-[phone] or 800-85B-0368
Solid and Haaza dour Waste-(919)733.2 ] 78
�--. Water Suppi -(919 )733-2321
Pesticides-(919 '33.3556
wildL.ife Res, orr►res.-(919)75:-7291 or 80C-662-7231
Marine Fisherie,-(919)7?6•702l
Date/Time.
'e contact name,date,timc of contact.
ox M
6h.1-1611-
TO/IQ Li? unf'
8V09-SIL-6I6: xeJ OM - H 2i8 SNOIib 3d0