NC0079898_Regional Office Historical File Pre 2018

ATA
NCDENR
North Carolina Department of Environment and
Division of Water Quality
Michael F. Easley, Governor
December 3, 2008
Mr. Jeff Kirk
_ CAN Holdings (Needraore)
1601 West LBJ Freeway
Dallas, TX 75234
Natural Resources
et :
7 oleei H. Sullins, Director
DEC
L►l,l`:i: iris
DWQ-Surface WGtcr ,.:`�rQl1
Subject: Rescission of NPDES Permit NC0079898
Needmore Road Landfill
Rowan County
Dear Mr. Kirk:
Division staff has confirmed that the subject permit is no longer required. Therefore, in
accordance with your request, NPDES Permit NC0079898 is rescinded, effective immediately.
If in the future your company wishes to discharge wastewater to the State's surface waters, they
must first apply for and receive a new NPDES permit. Discharge of wastewater without a valid
NPDES permit will subject the responsible party to a civil penalty of up to $25,000 per day.
If you have questions about this matter, please contact Charles Weaver of my staff at the
telephone number or address listed below.
Sincerely,
cc: Central Files
Mooresville Regional Office / Mike Parker
NPDES Permit file
Fran McPherson, DWQ Budget Office
James Pullen / JCP Environmental Management [35089 Carnation Lane, Indian Land, SC 29707-59161
Bryon Dahlgren / AECOM 11455 Old Alabama Rd, Suite 170, Roswell, GA 300761
1617 Mail Service Center. Raleigh, North Carolina 27699-1617
512 North Salisbury Street, Raleigh, North Carolina 27604
Internet: www.ncwaterquality.org
Phone: [phone] / FAX [phone]
[e-mail]
One
NorthCarolina
Naturally
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper

�; �G Michael F. Easley, Governor
r William G. Ross,Jr..Secretary
North Carolina Department of Environment and Natural Resources
"C Alan W. Klimek, P.E.,Director
Division of Water Quality
DIVISION OF WATER QUALITY
April 19, 2004
Mr. Steve Olp
Site Manager
CNA Holding, Inc.
230 Archdale Drive
Charlotte, NC 28210
Subject NPDES Permit No. NC0079898
Needmore Road Landfill
Rowan County, NC
Dear Mr. Olp:
•
Our records indicate that NPDES Permit No. NC0079898 was issued on April 16, 2004 for
the discharge of wastewater to the surface waters of the State from your facility. The purpose of this
letter is to advise you of the importance of the Permit and the liabilities in the event of failure to
comply with the terms and conditions of the Permit. If you have not already done so, it is suggested
that you thoroughly read the Permit. Of particular importance are Pages 4 and 5.
Pages 4 and 5 set forth the effluent limitations and monitoring requirements for your
discharge. Your discharge must not exceed any of the limitations set forth. The section headed
"Monitoring Requirements" describes the measurement frequencies, sample types and sampling
locations. Upon commencement of your discharge (or operation), you must initiate the required
monitoring. The monitoring results must be entered on reporting forms furnished or approved by
this Agency. If you have not received these forms, they should be arriving shortly. If you fail to
receive the forms, please contact this Office as quickly as possible. I have enclosed a sample of the
"Effluent" reporting form (DWQ Form MR-1), plus instructions for completing the form. It is
imperative that all applicable parts be completed, and the original and one copy be submitted as
required.
Please be advised that an annual administering and compliance monitoring fee may be
required for your facility. You will soon be receiving a statement from our Raleigh Office. It is
imperative that the fee be paid in a timely manner so as to prevent enforcement action or poccible
MooresvilleRegional i e, 919 North Main Street,Mooresville, NC 28115 NCDENR
PHONE [phone]
Customer Service
FAX [phone] 1 800
623-7748

revocation of your permit.
The remaining parts of the Permit set forth definitions, general conditions and special
conditions applicable to the operation of wastewater treatment facilities and/or discharge(s). The
conditions include special reporting requirements in the event of noncompliance, bypasses, treatment
unit/process failures, etc. Also addressed are requirements for a certified wastewater treatment plant
operator if you are operating wastewater treatment facilities. Any changes in operation of
wastewater treatment facilities, quantity and type of wastewater being treated or discharged,
expansions and/or upgrading of wastewater treatment facilities must be permitted or_approved by
this Agency.
Failure to comply with the terms and conditions of an NPDES Permit subjects the Permittee
to enforcement action pursuant to Section 143-215.6 of the North Carolina General Statutes. A civil
penalty of up to $25,000 per violation (and/or criminal penalties) may be assessed for such
violations. If you find at any time that you are unable to comply with the terms and conditions of
the Permit, you should contact this Office immediately. A Special Order by Consent (SOC) may be
necessary while pursuing action to obtain compliance.
As a final note, an NPDES Permit is normally issued for a five-year period. Permits are not
automatically renewed. Renewal requests must be submitted to this Agency no later than 180 days
prior to expiration. Please make note of the expiration date of your Permit. This date is set forth on
Page 1 of the Permit. Also note that NPDES Permits are not automatically transferable. If you, as
the Permittee, cease to need this Permit, then you should request that the Division of Water Quality
rescind the Permit or request that DWQ reissue the Permit to another party, if necessary.
As mentioned previously, the purpose of this letter is to advise you of the importance of your
NPDES Permit. Please read the Permit and contact this Office at 704/663-1699 in Mooresville if
you have any questions or need clarification. We look forward to providing any assistance.
Sincerely,
D. , P.E.
WaterRex QualityGleason Regional Supervisor
Enclosure
A:INPDESLTR.WQ

O�V�Aj Michael F. Easley
Q �
Governor
�o G Li%
rNCDENR William G.Ross, Jr., Secretary
7 North Carolina Department of Environment and Natural Resources
O Alan W. Klimek, P.E., Director
Division of Water Quality
April 16, 2004
Mr. Steve Olp
Site Manager
CNA Holding, Inc.
230 Archdale Drive
Charlotte,North Carolina 28210
Subject: Issuance of NPDES Permit NC0079898
Needmore Road Landfill
Rowan County
Dear Mr. Olp:
Division personnel have reviewed and approved your application for renewal of the subject permit.
Accordingly,we are forwarding the attached NPDES discharge permit. This permit is issued pursuant to the
requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North
Carolina and the U.S. Environmental Protection Agency dated May 9, 1994(or as subsequently amended).
This final permit includes no major changes from the draft permit sent to you on February 18, 2004.
If any parts,measurement frequencies or sampling requirements contained in this permit are unacceptable to
you,you have the right to an adjudicatory hearing upon written request within thirty(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 (6714 Mail Service Center,Raleigh,North
Carolina 27699-6714). Unless such demand is made, this decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division may require
modification or revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain
other permits which may be required by the Division of Water Quality or permits required by the Division of Land
Resources, the Coastal Area Management Act or any other Federal or Local governmental permit that may be
required. If you have any questions concerning this permit, please contact Sergei Chernikov at telephone number
[phone],extension 594.
Sincerely, Ifietei.OF ENVIRONMENT
l;ig'11as Signed BY AND NM!t?IGI RESOURCES
NOORESV... � 4L OFFICE'
-javid A.
Alan W. Klimek, P.E.
APR 1 9 2004
cc: Central File.
Mooresville Regional Office/Water Quality Section
NPDES Unit
Dltl WAT Qiiitil ' I.CN,:d .
N.C.Division of Water Quality/NPDES Unit Phone:[phone]
1617 Mail Service Center,Raleigh,NC 27699-1617 fax:[phone]
Internet:h2o.enr.state.nc.us DENR Customer Service Center: 1 800 623-7748

Permit NC0079898
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WAFER 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.
CNA Holdings, Inc.
is hereby authorized to discharge wastewater from a facility located at the
Needmore Road Landfill
Needmore Road north of Woodleaf
Rowan County
to receiving waters designated as South Yadkin River in the Yadkin-Pee Dee River Basin in accordance
with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, IIl and IV
hereof.
This permit shall become effective June 1,2004.
This permit and authorization to discharge shall expire at midnight on March 31, 2009.
Signed this day April 16, 2004.
imal Signed BY
l,
� p.Good
Alan Klimek,P.E.,Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NC0079898
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility,whether for operation or discharge are hereby revoked.As of this
permit issuance,any previously issued permit bearing this number is no longer effective.Therefore, the exclusive
authority to operate and discharge from this facility arises under the permit conditions, requirements,terms,and
provisions included herein.
CNA Holdings, Inc.,is hereby authorized to:
1. Continue to operate an existing wastewater treatment facility with the following components:
• Equalization tank
• Six-train UV/hydrogen peroxide oxidation system
• Chemical feed systems for pH adjustments
• Hydrogen peroxide addition system
• Effluent holding tank
• Parshall flume
• Effluent diffuser
• Leachate collection system
The facility is located at Needmore Road Landfill off Needmore Road north of Woodleaf in Rowan
County.
2. Discharge from said treatment works at the location specified on the attached map into the South
Yadkin River, currently classified WS-IV waters in the Yadkin-Pee Dee River Basin.

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Su 03 07 OB North Permitted Flow:0.288 MGD Landfill not to scale

Permit NC0079898
A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is
authorized to discharge from outfall 001 [remediated groundwater]. Such discharges shall be limited and monitored
by the Permittee as specified below:
PARAMETER DISCHARGE LIMITATIONS MONITORING REQUIREMENTS
Monthly Average Daily Maximum Measurement Sample Type Sample
Frequency Location t
Flow (MGD) 0.288 Continuous Recording Effluent
BOD,5-Day. 20°C 30.0 mg/L 45.0 mg/L Quarterly Composite Effluent
Total Suspended Solids 30.0 mg/L 45.0 mg/L Quarterly Composite Effluent
Oil and Grease 30.0 mg/L 60.0 mg/L Quarterly Grab Effluent
Phenols Quarterly Grab Effluent
Total Barium Quarterly Composite Effluent
1.4_Dioxane Quarterly Grab Effluent
Total Copper Quarterly Composite Effluent
Total Iron Quarterly Composite Effluent
Total Nickel Quarterly Composite Effluent
Total Manganese Quarterly Composite Effluent
Conductivity Quarterly Grab U,D
Dissolved Oxygen Quarterly Grab U,D
Temperature Quarterly Grab U,D
Total Nitrogen Monthly Composite Effluent
(NO2+NO3+TKN)
Total Phosphorus Monthly Composite Effluent
Chronic Toxicity2 Quarterly Composite Effluent
pH3 Quarterly Grab Effluent
NOTES:
1. U: upstream at least 50 feet from the outfall_ D:downstream at the entrance of Cooleemee's water plant intake flume.
2. Chronic Toxicity(Ceriodaphnia) @ 0.42%;January, April,July and October;see condition A. (2)of this permit.
3. The pH shall not be less than 6.0 standard units or greater than 9.0 standard units.
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN TRACE AMOUNTS.
MONITORING FOR ALL PARAMETERS SAMPLED QUARTERLY MUST COINCIDE WITH TOXICITY TESTING.

Permit NC0079898
SUPPLEMENT TO EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS
A. (2) CHRONIC TOXICITY PERMIT LIMIT (Quarterly)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodaphnia dubia at
an effluent concentration of 0.42%.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the "North Carolina
Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or "North Carolina Phase II
Chronic Whole Effluent Toxicity Test Procedure"(Revised-February 1998)or subsequent versions.The tests will be performed during
the months of January,April,July,and October. Effluent sampling for this testing shall be performed at the NPDES permitted final
effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit limit,then multiple-
concentration testing shall be performed at a minimum,in each of the two following months as described in"North Carolina Phase II
Chronic Whole Effluent Toxicity Test Procedure" (Revised-February 1998)or subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the highest concentration having no
detectable impairment of reproduction or survival and the lowest concentration that does have a detectable impairment of reproduction
or survival.The definition of"detectable impairment,"collection methods,exposure regimes,and further statistical methods are
specified in the"North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"(Revised-February 1998)or subsequent
versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form(MR-1)
for the months in which tests were performed,using the parameter code TGP3B for the pass/fail results and THP3B for the Chronic
Value. Additionally,DWQ Form AT-3 (original) is to be sent to the following address:
Attention: Environmental Sciences Branch
North Carolina Division of
Water Quality
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30 days after the end of
the reporting period for which the report is made.
Test data shall be complete,accurate,include all supporting chemical/physical measurements and all concentration/response data,and
be certified by laboratory supervisor and ORC or approved designate signature.Total residual chlorine of the effluent toxicity sample
must be measured and reported if chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required,the permittee will
complete the information located at the top of the aquatic toxicity(AT)test form indicating the facility name,permit number,pipe
number,county, and the month/year of the report with the notation of"No Flow" in the comment area of the form.The report shall be
submitted to the Environmental Sciences Branch at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required,monitoring will be required during the
following month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water Quality indicate
potential impacts to the receiving stream,this permit may be re-opened and modified to include alternate monitoring requirements or
limits.
NOTE: Failure to achieve test conditions as specified in the cited document,such as minimum control organism survival,minimum
control organism reproduction,and appropriate environmental controls,shall constitute an invalid test and will require immediate
follow-up testing to be completed no later than the last day of the month following the month of the initial monitoring.

NPDES Permit Requirements
Page 1 of 16
PART II
STANDARD CONDITIONS FOR NPDES PERMITS
Section A. Definitions
2/Month
Samples are collected twice per month with at least ten calendar days between sampling events
3/Week
Samples are collected three times per week on three separate calendar days.
Act or"the Act"
The Federal Water Pollution Control Act,also known as the Clean Water Act,as amended,33 USC 1251,et. seq.
Annual Average
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar year. In the case of fecal
coliform,the geometric mean of such discharges.
Arithmetic Mean
The summation of the individual values divided by the number of individual values.
Bypass
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.
Calendar Day
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.
Calendar Quarter
One of the following distinct periods: January through March, April through June, July through September, arid
October through December.
Composite Sample
A sample collected over a 24-hour period by continuous sampling or combining grab samples of at least 100 ml in
such a manner as to result in a total sample representative of the wastewater discharge during the sample period. The
Director may designate the most appropriate method (specific number and size of aliquots necessary, the time
interval between grab samples, etc.) on a case-by-case basis. Samples may be collected manually or automatically.
Composite samples may be obtained by the following methods:
(1) Continuous: a single, continuous sample collected over a 24-hour period proportional to the rate of flow.
(2) Constant time/variable volume: 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
(3) Variable time/constant volume: 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 preset gallon interval between sample collection fixed at no greater than 1/24 of the
expected total daily flow at the treatment system, or
(4) Constant time/constant volume: a series of grab samples of equal volume collected over a 24-hour period at
a constant time interval. This method may only be used in situations where effluent flow rates vary
less than 15 percent. The grab samples shall be taken at intervals of no greater than 20 minutes apart
during any 24-hour period and must be of equal size and of no less than 100 milliliters. Use of this method
requires prior approval by the Director.
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NPDES Permit Requirements
Page 2 of 16
In accordance with (4) above,influent grab samples shall not be collected more than once per hour.
Effluent grab samples shall not be collected more 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
intervals evenly spaced over the 24-hour period that are equal in number of hours to the detention time of the
system in number of days. However, the interval between effluent grab samples may not exceed six hours nor
the number of samples less than four during a 24-hour sampling period.
Continuous flow measurement
Flow monitoring that occurs 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.
Daily Discharge
The discharge of a pollutant measured during a calendar day or any 24-hour period that reasonably represents the
calendar day for purposes of sampling. For pollutants measured in units of mass, the "daily discharge" is calculated as
the total mass of the pollutant discharged over the day. The "daily discharge" concentration comprises the mean
concentration for a 24-hour sampling period as either a composite sample concentration or the arithmetic mean of all
grab samples collected during that period. (40 CFR 122.3)
Daily Maximum
The highest"daily discharge" during the calendar month.
Daily Sampling
Parameters requiring daily sampling shall be sampled 5 out of every 7 days per week unless otherwise specified in the
permit. The Division expects that sampling shall be conducted on weekdays except where holidays or other
disruptions of normal operations prevent weekday sampling. If sampling is required for all seven days of the week
for any permit parameter(s), that requirement will be so noted on the Effluent Limitations and Monitoring Page(s).
DWQ or"the Division"
The Division of Water Quality,Department of Environment and Natural Resources.
EMC
The North Carolina Environmental Management Commission.
Facility Closure
The cessation of wastewater treatment at a permitted facility,or the cessation of all activities that require coverage
under the NPDES. Completion of facility closure will allow this permit to be rescinded.
Geometric Mean
The Nth root of the product of the individual values where N = the number of individual values. For purposes of
calculating the geometric mean,values of"0" (or"< [detection level]") shall be considered = 1.
Grab Sample
Individual samples of at least 100 ml collected over a period of time not exceeding 15 minutes. Grab samples can be
collected manually. Grab samples must be representative of the discharge (or the receiving stream, for instream
samples).
Hazardous Substance
Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the Clean Water Act.
Instantaneous flow measurement
A measure of flow taken at the time of sampling, when both the sample and flow will be representative of the total
discharge.
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NPDES Permit Requirements
Page 3 of 16
Monthly Average (concentration limit)
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar month. In the case of fecal
coliform, the geometric mean of such discharges.
Permit Issuing Authority
The Director of the Division of Water Quality.
Quarterly Average (concentration limit)
The average of all samples taken over a calendar quarter.
Severe property damage
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 excludes economic loss caused by delays in production.
Toxic Pollutant:
Any pollutant listed as toxic under Section 307(a)(1) of the Clean Water Act.
Upset
An incident beyond the reasonable control of the Permittee causing unintentional and temporary noncompliance with
permit effluent limitations and/or monitoring requirements. An upset does not include noncompliance caused by
operational error, improperly designed treatment facilities, inadequate treatment facilities, lack of preventive
maintenance,or careless or improper operation.
Weekly Average (concentration limit)
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar week. In the case of fecal
coliform, the geometric mean of such discharges.
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 [40 CFR 122.41].
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 section 301,302,306, 307, 308,318 or 405 of the
Act, or any permit condition or limitation implementing any such sections in a permit issued under section
402, or any requirement imposed in a pretreatment program approved under sections 402(a)(3) or 402(b)(8)
of the Act, is subject to a civil penalty not to exceed $25,000 per day for each violation. [40 CFR 122.41 (a)
(2)]
c. The Clean Water Act provides that any person who negligently violates sections 301, 302,306, 307, 308, 318, or
405 of the Act, or any condition or limitation implementing any of such sections in a permit issued under
section 402 of the Act, or any requirement imposed in a pretreatment program approved under section
402(a)(3) or 402(b)(8) of the Act, is subject to criminal penalties of$2,500 to $25,000 per day of violation, or
imprisonment of not more than 1 year, or both. In the case of a second or subsequent conviction for a
negligent violation, a person shall be subject to criminal penalties of not more than $50,000 per day of
violation, or by imprisonment of not more than 2 years,or both. [40 CFR 122.41 (a) (2)]
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NPDES Permit Requirements
Page 4 of 16
d. Any person who knowing violates such sections, or such conditions or limitations 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. In
the case of a second or subsequent conviction for a knowing violation, a person shall be subject to criminal
penalties of not more than $100,000 per day of violation, or imprisonment of not more than 6 years, or both.
[40 CFR 122.41 (a) (2)]
e. Any person who knowingly violates section 301,302, 303, 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,
and who knows at that time that he thereby places another person in imminent danger of death or serious
bodily injury, shall, upon conviction, be subject to a fine of not more than $250,000 or imprisonment of not
more than 15 years, or both. In the case of a second or subsequent conviction for a knowing endangerment
violation,a person shall be subject to a fine of not more than $500,000 or by imprisonment of not more than
30 years, or both. An organization, as defined in section 309(c)(3)(B)(iii) of the CWA, shall, upon conviction
of violating the imminent danger provision, be subject to a fine of not more than$1,000,000 and can be fined
up to$2,000,000 for second or subsequent convictions. [40 CFR 122.41 (a) (2)]
f. Under state law, a civil penalty of not more than $25,000 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. [North
Carolina General Statutes g 143-215.6A]
g. Any person may be assessed an administrative penalty by the Administrator for violating section 301, 302,
306, 307, 308, 318 or 405 of this Act, or any permit condition or limitation implementing any of such
sections in a permit issued under section 402 of this 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. [40 CFR
122.41 (a) (3)]
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
[40 CFR 122.41 (d)]. -
3. Civil and Criminal Liability
Except as provided in permit conditions on "Bypassing" (Part II. C. 4), "Upsets" (Part II. C. 5) and "Power
Failures" (Part II. C. 7), nothing in this permit shall be construed to relieve the Permittee from any
responsibilities, liabilities, or penalties for noncompliance pursuant to NCGS 143-215.3, 143-215.6 or Section 309
of the Federal Act, 33 USC 1319. Furthermore, the Permittee is responsible for consequential damages, such as
fish kills, even though the responsibility for effective compliance may be temporarily suspended.
4. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the Permittee
from any responsibilities, liabilities, or penalties to which the Permitter is or may be subject to under NCGS 143-
215.75 et seq. or Section 311 of the Federal Act, 33 USG 1321. Furthermore, the Permittee is responsible for
consequential damages, such as fish kills, even though the responsibility for effective compliance may be
temporarily suspended.
5. Property Rights
The issuance of this permit does not convey any property rights in either real or personal property, or any
exclusive privileges, nor does it authorize any injury to private property or any invasion of personal rights, nor
any infringement of Federal, State or local laws or regulations [40 CFR 122.41 (g)].
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.
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7. Severability
The provisions of this permit are severable. 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 [NCGS 150B-23].
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 by this permit [40 CFR 122.41 (h)].
9. Duty to Reapply
If the Permittee wishes to continue an activity regulated by this permit after the expiration date of this permit, the
Permittee must apply for and obtain a new permit [40 CFR 122.41 (b)].
10. Expiration of Permit
The Permittee is not authorized to discharge after the expiration date. In order to receive automatic
authorization to discharge beyond the expiration date, the Permittee shall submit such information, forms, and
fees as are required by the agency authorized to issue permits no later than 180 days prior to the expiration date.
Any Permittee that has not requested renewal at least 180 days prior to expiration, or any Permittee that does not
have a permit after the expiration and has not requested renewal at least 180 days prior to expiration, will subject
the Permittee to enforcement procedures as provided in NCGS 143-215.6 and 33 USC 1251 et. seq.
11. Signatory Requirements
All applications, reports, or information submitted to the Permit Issuing Authority shall be signed and certified
[40 CFR 122.41 (k)].
•
a. All permit applications shall be signed as follows:
(I) 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,provided, the manager is authorized to make management decisions which govern the
operation of the regulated facility including having the explicit or implicit duty of making major capital
investment recommendations, and initiating and directing other comprehensive measures to assure long
term environmental compliance with environmental laws and regulations; the manager can ensure that
the necessary systems are established or actions taken to gather complete and accurate information for
permit application requirements; and where 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 [40 CFR 122.22].
b. All reports required by the permit and other information requested by the Permit Issuing Authority shall be
signed by a person described in paragraph a. 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 [40 CFR 122.22]
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c. Changes to authorization: If an authorization under paragraph (b) of this section is no longer accurate
because a different individual or position has responsibility for the overall operation of the facility, a new
authorization satisfying the requirements of paragraph (b) of this section must be submitted to the Director
prior to or together with any reports, information, or applications to be signed by an authorized
representative [40 CFR 122.22]
d. Certification. Any person signing a document under paragraphs a. or b. of this section shall make the
following certification [40 CFR 122.221:
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate
the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons
directly responsible for gathering the information, the information submitted is, to the best of my knowledge and
belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations."
12. Permit Actions
This permit may be modified, revoked and reissued, or terminated for cause. The filing of a request by the
Permittee for a permit modification, revocation and reissuance, or termination, or a notification of planned
changes or anticipated noncompliance does not stay any permit condition [40 CFR 122.41 (f)].
13. Permit Modification.Revocation and Reissuance.or Termination
The issuance of this permit does not prohibit the permit issuing authority from reopening and modifying the
permit,revoking and reissuing the permit, or terminating the permit as allowed by the laws, rules, and regulations
contained in Title 40, Code of Federal Regulations, Parts 122 and 123; Title 15A of the North Carolina
Administrative Code,Subchapter 2H .0100;and North Carolina General Statute 143-215.1 et. at
14. Annual Administering and Compliance Monitoring Fee Requirements
The Permittee must pay the annual administering and compliance monitoring fee within thirty days after being
billed by the Division. Failure to pay the fee in a timely manner in accordance with 15A NCAC 2H.0105 (b) (4)
may cause this Division to initiate action to revoke the permit.
Section C. Operation and Maintenance of Pollution Controls
1. Certified Operator
Upon classification of the permitted facility by the Certification Commission, the Permittee shall employ a
certified water pollution control treatment system operator in responsible charge (ORC) of the water pollution
control treatment system. Such operator must hold a certification of the grade equivalent to or greater than the
classification assigned to the water pollution control treatment system by the Certification Commission. The
Permittee must also employ one or more certified Back-up ORCs who possess a currently valid certificate of the
type of the system. Back-up ORCs must possess a grade equal to (or no more than one grade less.than) the grade
of the system [15A NCAC 8G.0201].
The ORC of each Class I facility must:
> Visit the facility at least weekly
> Comply with all other conditions of 15A NCAC 8G.0204.
The ORC of each Class II,III and TV facility must:
> Visit the facility at least daily,excluding weekends and holidays
➢ Properly manage and document daily operation and maintenance of the facility
➢ Comply with all other conditions of 15A NCAC 8G.0204.
Once the facility is classified, the Permittee shall submit a letter to the Certification Commission designating the
operator in responsible charge:
a. Within 60 calendar days prior to wastewater being introduced into a new system
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• b. Within 120 calendar days of:
➢ Receiving notification of a change in the classification of the system requiring the designation of a
new ORC and back-up ORC
➢ A vacancy in the position of ORC or back-up ORC.
2. Proper Operation and Maintenance
The Permittee shall at all times provide the operation and maintenance resources necessary to operate the existing
facilities at optimum efficiency. 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 Permittee to install
and operate backup or auxiliary facilities only when necessary to achieve compliance with the conditions of the
permit [40 CFR 122.41 (e)].
3. Need to Halt or Reduce not a Defense
It shall not be a defense for a Permittee in an enforcement action that it would have been necessary to halt or
reduce the permitted activity in order to maintain compliance with the condition of this permit [40 CFR 122.41
(c)].
4. Bypassing of Treatment Facilities
a. Bypass not exceeding limitations [40 CFR 122.41 (m) (2)]
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 b. and c. of this section.
b. Notice [40 CFR 122.41 (m) (3)1
(I) Anticipated bypass. If the Permittee knows in advance of the need for a bypass, it shall submit prior
notice, if possible at least ten days before the date of the bypass; including an evaluation of the
anticipated quality and effect of the bypass.
(2) Unanticipated bypass. The Permittee shall submit notice of an unanticipated bypass as required in Part
II. E. 6. (24-hour notice).
c. Prohibition of Bypass
(1) Bypass from the treatment facility is prohibited and the Permit Issuing Authority may take enforcement
action against a Permittee for bypass,unless:
(A) Bypass was unavoidable to prevent loss of life,personal injury or severe property damage;
(B) There were no feasible alternatives to the bypass, such as the use of auxiliary treatment facilities,
retention of untreated wastes or maintenance during normal periods of equipment downtime. This
condition is not satisfied if adequate backup equipment should have been installed in the exercise of
reasonable engineering judgment to prevent a bypass which occurred during normal periods of
equipment downtime or preventive maintenance;and
(C) The Permittee submitted notices as required under Paragraph b. of this section.
(2) Bypass from the collection system is prohibited and the Permit Issuing Authority may take enforcement
action against a Permittee for a bypass as provided in any current or future system-wide collection system
permit associated with the treatment facility.
(3) The Permit Issuing Authority may approve an anticipated bypass, after considering its adverse effects, if
the Permit Issuing Authority determines that it will meet the three conditions listed above in Paragraph c.
(1) of this section.
5. Upsets
a. Effect of an upset [40 CFR 122.41 (n) (2)1: An upset constitutes an affirmative defense to an action
brought for noncompliance with such technology based permit effluent limitations if the requirements of
paragraph b. of this condition are met. No determination made during administrative review of claims that
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noncompliance was caused by upset, and before an action for noncompliance, is final administrative action
subject to judicial review.
b. Conditions necessary for a demonstration of upset: A Permittee who wishes to establish the
affirmative defense of upset shall demonstrate, through properly signed, contemporaneous operating logs,or
other relevant evidence that:
(1) An upset occurred and that the Permittee can identify the cause(s) of the upset;
(2) The Permittee facility was at the time being properly operated;and
(3) The Permittee submitted notice of the upset as required in Part II.E. 6. (b) (B) of this permit.
(4) The Permittee complied with any remedial measures required under Part II. B. 2. of this permit.
d. Burden of proof[40 CFR 122.41 (n) (4)]: The Permittee seeking to establish the occurrence of an
upset has the burden of proof in any enforcement proceeding.
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 143-215.1 and in a manner such as to prevent any pollutant
from such materials from entering waters of the State or navigable waters of the United States. The Permittee
shall comply with all existing Federal 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 503. The
Permittee shall comply with applicable 40 CFR 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 15A NCAC 2H.0124 —
Reliability) to prevent the discharge of untreated or inadequately treated wastes during electrical power failures
either by means of alternate power sources, standby generators or retention of inadequately treated effluent.
Section D. Monitoring and Records
1. Representative Sampling
Samples collected and measurements taken, as required herein, shall be characteristic of the volume and nature of
the permitted discharge. Samples collected at a frequency less than daily shall be taken on a day and time that is
characteristic of the discharge over the entire period 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 [40 CFR 122.41 (j)].
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 (MR 1, 1.1, 2, 3) or alternative forms approved by the
Director,postmarked no later than the 28th 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:
NC DENR / Division of Water Quality/ Water Quality Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
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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 is 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. Flow measurement devices shall be accurately calibrated at a minimum of once per year and maintained
to ensure that the accuracy of the measurements is consistent with the accepted capability of that type of device.
The Director shall approve the flow measurement device and monitoring location prior to installation.
Once-through condenser cooling water flow 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 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 [40 CFR 122.41].
To meet the intent of the monitoring required by this permit, all test procedures must produce minimum
detection and reporting levels that are below the permit discharge requirements and all data generated must be
reported down to the minimum detection or lower reporting level of the procedure. If no approved methods are
determined capable of achieving minimum detection and reporting levels below permit discharge requirements,
then the most sensitive (method with the lowest possible detection and reporting level) approved method must
be used.
5. Penalties for Tampering
The Clean Water Act provides that any person who falsifies, tampers with, or knowingly renders inaccurate, any
monitoring device or method required to be maintained under this permit shall, upon conviction, be punished by
a fine of not more than $10,000 per violation, or by imprisonment for not more than two years per violation, or
by both. If a conviction of a person is for a violation committed after a first conviction of such person under this
paragraph, punishment is a fine of not more than $20,000 per day of violation, or by imprisonment of not more
than 4 years,or both [40 CFR 122.41].
6. Records Retention
Except for records of monitoring information required by this permit related to the Permittee's sewage sludge
use and disposal activities, which shall be retained for a period of at least five years (or longer as required by 40
CFR 503), the Permittee shall retain records of all monitoring information,including
➢ all calibration and maintenance records
➢ all original strip chart recordings for continuous monitoring instrumentation
➢ copies of all reports required by this permit
➢ copies of all data used to complete the application for this permit
These records or copies shall be maintained for a period of at Ieast 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 [40 CFR
122.41].
7. Recording Results
For each measurement or sample taken pursuant to the requirements of this permit, the Permittee shall record
the following information [40 CFR 122.41]:
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;
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e. The analytical techniques or methods used;and ,
£ The results of such analyses.
8. Inspection and Entry
The Permittee shall allow the Director, or an authorized representative (including an authorized contractor acting
as a representative of the Director),upon 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 activity is located or conducted, or where
records must be kept under the conditions of this permit;
b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of this
permit;
c. Inspect at reasonable times any facilities, equipment (including monitoring and control equipment), practices,
or operations regulated or required under this permit;and
d. Sample or monitor at reasonable times, for the purposes of assuring permit compliance or as otherwise
authorized by the Clean Water Act, any substances or parameters at any location [40 CFR 122.41 (i)].
Section E Reporting Requirements
1. Change in Discharge
All discharges authorized herein shall be consistent with the terms and conditions of this permit. The discharge
of any pollutant identified in this permit more frequently than or at a level in excess of that authorized shall
constitute a violation of the permit.
2. Planned Changes
The Permittee shall give notice to the Director as soon as possible of any planned physical alterations or
additions to the permitted facility [40 CFR 122.41 (1)]. Notice is required only when:
a. The alteration or addition to a permitted facility may meet one of the criteria for new sources at 40 CFR
122.29 (b);or
b_ The alteration or addition could significantly change the nature or increase the quantity of pollutants
discharged. This notification applies to pollutants subject neither to effluent limitations in the permit, nor to
notification requirements under 40 CFR 122.42 (a) (1). •
c. The alteration or addition results in a significant change in the Permittee's sludge use or disposal practices,
and such alternation, addition or change may justify the application of permit conditions that are different
from or absent in the existing permit, including notification of additional use or disposal sites not reported
during the permit application process or not reported pursuant to an approved land application plan.
3. Anticipated Noncompliance
The Permittee shall give advance notice to the Director of any planned changes to the permitted facility or other
activities that might result in noncompliance with the permit [40 CFR 122.41 (1) (2)].
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 permit to document the change of ownership. Any such action
may incorporate other requirements as may be necessary under the Clean Water Act [40 CFR 122.41 (I) (3)].
5. Monitoring Reports
Monitoring results shall be reported at the intervals specified elsewhere in this permit [40 CFR 122.41 (1) (4)].
a. Monitoringresults must be reported on a Discharge Monitoring Report (DMR) (See Part II. D. 2) or forms
provided by the Director for reporting results of monitoring of sludge use or disposal practices.
b. If the Permittee monitors any pollutant more frequently than required by this permit, the results of such
monitoring shall be included in the calculation and reporting of the data submitted on the DMR.
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6. Twenty-four Flour Reporting
a. The Permittee shall report to the Director or the appropriate Regional Office any noncompliance that
potentially threatens public health or the environment. Any information shall be provided orally within 24
hours from the time the Permittee became aware of the circumstances. A written submission shall also be
provided within 5 days of the time the Permittee becomes aware of the circumstances. The written
submission shall contain a description of the noncompliance, and its cause; the period of noncompliance,
including exact dates and times, and if the noncompliance has not been corrected, the anticipated time it is
expected to continue; and steps taken or planned to reduce, eliminate, and prevent reoccurrence of the
noncompliance [40 CFR 122.41 (I) (6)].
b. The Director may waive the written report on a case-by-case basis for reports under this section if the oral
report has been received within 24 hours.
c. Occurrences outside normal business hours may also be reported to the Division's Emergency Response
personnel at [phone], [phone] or [phone].
7. Other Noncompliance
The Permittee shall report all instances of noncompliance not reported under Part II. E. 5 and 6. of this permit at
the time monitoring reports are submitted. The reports shall contain the information listed in Part II. E. 6. of
this permit [40 CFR 122.41 (1) (7)].
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 [40 CFR 122.41 (1) (8)].
9. Noncompliance Notification
The Permittee shall report by telephone to either the central office or the appropriate regional office of the
Division as soon as possible, but in no case more than 24 hours or on the next working day following the
occurrence or first knowledge of the occurrence of any of the following
a. Any occurrence at the water pollution control facility which results in the discharge of significant amounts of
wastes which are abnormal in quantity or characteristic, such as the dumping of the contents of a sludge
digester; the known passage of a slug of hazardous substance through the facility; or any other unusual
circumstances.
b. Any process unit failure, due to known or unknown reasons, that render the facility incapable of adequate
wastewater treatment such as mechanical or electrical failures of pumps,aerators,compressors,etc.
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass directly to receiving
waters without treatment of all or any portion of the influent to such station or facility.
Persons reporting such occurrences by telephone shall also file a written report within 5 days following first
knowledge of the occurrence.
10. Availability of Reports
Except for data determined to be confidential under NCGS 143-215.3 (a)(2) or Section 308 of the Federal Act, 33
USC 1318, all reports prepared in accordance with the terms shall be available for public inspection at the offices
of the Division of Water Quality. As required by the Act, effluent data shall not be considered confidential.
Knowingly making any false statement on any such report may result in the imposition of criminal penalties as
provided for in NCGS 143-215.1 (b)(2) or in Section 309 of the Federal Act.
11. Penalties for Falsification of Reports
The Clean Water Act provides that any person who knowingly makes any false statement, representation, or
certification in any record or other document submitted or required to be maintained under this permit,including
monitoring reports or reports of compliance or noncompliance shall, upon conviction, be punished by a fine of
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not more than $25,000 per violation, or by imprisonment for not more than two years per violation, or by both
[40 CFR 122.41].
12. Annual Performance Reports
Permittees who own or operate facilities that collect or treat municipal or domestic waste shall provide an annual
report to the Permit Issuing Authority and to the users/customers served by the Permittee (NCGS 143-215.1C).
The report shall summarize the performance of the collection or treatment system, as well as the extent to which
the facility was compliant with applicable Federal or State laws, regulations and rules pertaining to water quality.
The report shall be provided no later than sixty days after the end of the calendar or fiscal year, depending upon
which annual period is used for evaluation.
PART III
OTHER REQUIREMENTS
Section A. Construction
The Permittee shall not commence construction of wastewater treatment facilities,nor add to the plant's treatment
capacity,nor change the treatment process(es) utilized at the treatment plant unless the Division has issued an
Authorization to Construct(AtC)permit. Issuance of an AtC will not occur until Final Plans and Specifications for
the proposed construction have been submitted by the Permittee and approved by the Division.
Section B. 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.
Section C. Changes in Discharges of Toxic Substances
The Permittee shall notify the Permit Issuing Authority as soon as it knows or has reason to believe (40 CFR 122.42):
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 l.t.g/L);
(2) Two hundred micrograms per liter (200 pg/L) for acrolein and acrylonitrile; five hundred micrograms
per liter (500 µg/L) for 2.4-dinitrophenol and for 2-methyl-4.6-dinitrophenol; and one milligram per liter
(1 mg/L) for antimony;
(3) Five 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 thepermit, if that discharge will exceed the g
highest of the following "notification levels";
(1) Five hundred micrograms per liter (500 ig/L);
(2) One milligram per liter(1 mg/L) for antimony;
(3) Ten times the maximum concentration value reported for that pollutant in the permit application.
Section D. Evaluation of Wastewater Discharge Alternatives
The Permittee shall evaluate all wastewater disposal alternatives and pursue the most environmentally sound
alternative of the reasonably cost effective alternatives. If the facility is in substantial non-compliance with the terms
and conditions of the NPDES permit or governing rules, regulations or laws, the Permittee shall submit a report in
such form and detail as required by the Division evaluating these alternatives and a plan of action within 60 days of
notification by the Division.
Section E. Facility Closure Requirements
The Permittee must notify the Division at least 90 days prior to the closure of any wastewater treatment system
covered by this permit. The Division may require specific measures during deactivation of the system to prevent
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adverse impacts to waters of the State. This permit cannot be rescinded while any activities requiring this permit
continue at the permitted facility.
PART IV
SPECIAL CONDITIONS FOR MUNCIPAL FACILITIES
Section A. Publicly Owned Treatment Works (POTWs)
All POTWs must provide adequate notice to the Director of the following:
1. Any new introduction of pollutants into the POTW from an indirect discharger which would be subject to
section 301 or 306 of CWA if it were directly discharging those pollutants;and
2. Any substantial change in the volume or character of pollutants being introduced by an indirect discharger
as influent to that POTW at the time of issuance of the permit.
3. For purposes of this paragraph, adequate notice shall include information on (1) the quality and quantity of
effluent introduced into the POTW, and (2) any anticipated impact of the change on the quantity or quality
of effluent to be discharged from the POTW.
Section B. Municipal Control of Pollutants from Industrial Users.
1. Effluent limitations are listed in Part I of this permit. Other pollutants attributable to inputs from
industries using the municipal system may be present in the Permittee's discharge. At such time as
sufficient information becomes available to establish limitations for such pollutants, this permit may be
revised to specify effluent limitations for any or all of such other pollutants in accordance with best
practicable technology or water quality standards.
2. Under no circumstances shall the Permittee allow introduction of the following wastes in the waste
treatment system:
a. Pollutants which create a fire or explosion hazard in the POTW, including, but not limited to,
wastestreams with a closed cup flashpoint of less than 140 degrees Fahrenheit or 60 degrees
Centigrade using the test methods specified in 40 CFR 261.21;
b. Pollutants which will cause corrosive structural damage to the POTW, but in no case Discharges
with pH lower than 5.0,unless the works is specifically designed to accommodate such Discharges;
c. Solid or viscous pollutants in amounts which will cause obstruction to the flow in the POTW
resulting in Interference;
d. Any pollutant, including oxygen demanding pollutants (BOD, etc.) released in a Discharge at a flow
rate and/or pollutant concentration which will cause Interference with the POTW;
e. Heat in amounts which will inhibit biological activity in the POTW resulting in Interference, but in
no case heat in such quantities that the temperature at the POTW Treatment Plant exceeds 40°C
(104°F) unless the Division,upon request of the POTW,approves alternate temperature limits;
f. Petroleum oil, nonbiodegradable cutting oil, or products of mineral oil origin in amounts that will
cause interference or pass through;
g. Pollutants which result in the presence of toxic gases, vapors, or fumes within the POTW in a
quantity that may cause acute worker health and safety problems;
h. Any trucked or hauled pollutants, except at discharge points designated by the POTW.
With regard to the effluent requirements listed in Part I of this permit, it may be necessary for the
Permittee to supplement the requirements of the Federal Pretreatment Standards (40 CFR, Part 403) to
ensure compliance by the Permitter with all applicable effluent limitations. Such actions by the Permittee
may be necessary regarding some or all of the industries discharging to the municipal system.
4. The Permittee shall require any industrial discharges sending influent to the permitted system to meet
Federal Pretreatment Standards promulgated in response to Section 307(b) of the Act. Prior to accepting
wastewater from any significant industrial user, the Permittee shall either develop and submit to the
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NPDES Permit Requirements
Page 14of16
Division a Pretreatment Program for approval per I5A NCAC 2H .0907(a) or modify an existing •
Pretreatment Program per 15A NCAC 2H .0907(b).
5. This permit shall be modified, or alternatively,revoked and reissued, to incorporate or modify an approved
POTW Pretreatment Program or to include a compliance schedule for the development of a POTW
Pretreatment Program as required under Section 402(b)(8) of the Clean Water Act and implementing
regulations or by the requirements of the approved State pretreatment program,as appropriate.
Section C. Pretreatment Programs
Under authority of sections 307(b) and (c) and 402(b)(8) of the Clean Water Act and implementing regulations 40
CFR Part 403, North Carolina General Statute 143-215.3 (14) and implementing regulations 15A NCAC 2H
.0900, and in accordance with the approved pretreatment program, all provisions and regulations contained and
referenced in the Pretreatment Program Submittal are an enforceable part of this permit.
The Permittee shall operate its approved pretreatment program in accordance with Section 402(b)(8) of the Clean
Water Act, the Federal Pretreatment Regulations 40 CFR Part 403, the State Pretreatment Regulations 15A
NCAC 2H .0900, and the legal authorities, policies, procedures, and financial provisions contained in its
pretreatment program submission and Division approved modifications there of. Such operation shall include
but is not limited to the implementation of the following conditions and requirements:
1. Sewer Use Ordinance (SUO)
The Permittee shall maintain adequate legal authority to implement its approved pretreatment program.
2. Industrial Waste Survey(IWS)
The Permittee shall update its Industrial Waste Survey (IWS) to include all users of the sewer collection
system at least once every five years.
3. Monitoring Plan
The Permittee shall implement a Division approved Monitoring Plan for the collection of facility specific
data to be used in a was tewater treatment plant Headworks Analysis (HWA) for the development of
specific pretreatment local limits. Effluent data from the Plan shall be reported on the DMRs (as required
by Part II,Section D,and Section E.5.). -
4. Headworks Analysis (HWA) and Local Limits
The Permittee shall obtain Division approval of a Headworks Analysis (HWA) at least once every five
years, and as required by the Division. Within 180 days of the effective date of this permit (or any
•subsequent permit modification) the Permittee shall submit to the Division a written technical evaluation
of the need to revise local limits (i.e., an updated HWA or documentation of why one is not needed) [40
CFR 122.42]. The Permittee shall develop,in accordance with 40 CFR 403.5(c) and 15A NCAC 2H .0909,
specific Local Limits to implement the prohibitions listed in 40 CFR 403.5(a) and (b) and 15A NCAC 2H
.0909.
5. Industrial User Pretreatment Permits (IUP) &Allocation Tables
In accordance with NCGS 143-215.1, the Permittee shall issue to all significant industrial users, permits for
operation of pretreatment equipment and discharge to the Permittee's treatment works. These permits
shall contain limitations, sampling protocols, reporting requirements, appropriate standard and special
conditions, and compliance schedules as necessary for the installation of treatment and control
technologies to assure that their wastewater discharge will meet all applicable pretreatment standards and
requirements. The Permittee shall maintain a current Allocation Table (AT) which summarizes the results
of the Headworks Analysis (HWA) and the limits from all Industrial User Pretreatment Permits (IUP).
Permitted IUP loadings for each parameter cannot exceed the treatment capacity of the POTW as
determined by the HWA.
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NPDES Permit Requirements
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6. Authorization to Construct (A to C)
The Permittee shall ensure that an Authorization to Construct permit (AtC) is issued to all applicable
industrial users for the construction or modification of any pretreatment facility. Prior to the issuance of
an AtC, the proposed pretreatment facility and treatment process must be evaluated for its capacity to
comply with all Industrial User Pretreatment Permit (IUP) limitations.
7. POTW Inspection& Monitoring of their SIUs
The Permittee shall conduct inspection, surveillance, and monitoring activities as described in its Division
approved pretreatment program in order to determine, independent of information supplied by industrial
users,compliance with applicable pretreatment standards. The Permitter must:
a. Inspect all Significant Industrial Users (SIUs) at least once per calendar year;and
b. Sample all Significant Industrial Users (SIUs) at least twice per calendar year for all permit-
limited pollutants, once during the period from January 1 through June 30 and once during the
period from July 1 through December 31, except for organic compounds which shall be sampled
once per calendar year;
8. SIU Self Monitoring and Reporting
The Permittee shall require all industrial users to comply with the applicable monitoring and reporting
requirements outlined in the Division approved pretreatment program, the industry's pretreatment permit,
or in 15A NCAC 2H .0908.
9. Enforcement Response Plan (ERP)
The Permittee shall enforce and obtain.appropriate remedies for violations of all pretreatment standards
promulgated pursuant to section 307(b) and (c) of the Clean Water Act (40 CFR 405 et. seq.), prohibitive
discharge standards as set forth in 40 CFR 403.5 and 15A NCAC 2H .0909, and specific local limitations.
All enforcement actions shall be consistent with the Enforcement Response Plan (ERP) approved by the
Division.
10. Pretreatment Annual Reports (PAR)
The Permittee shall report to the Division in accordance with 15A NCAC 2H .0908. In lieu of submitting
annual reports, Modified Pretreatment Programs developed under 15A NCAC 2H .0904 (b) may be
required to meet with Division personnel periodically to discuss enforcement of pretreatment requirements
and other pretreatment implementation issues.
For all other active pretreatment programs, the Permittee shall submit two copies of a Pretreatment Annual
Report (PAR) describing its pretreatment activities over the previous twelve months to the Division at the
following address:
NC DENR/ DWQ / Pretreatment Unit
1617 Mail Service Center
Raleigh,NC 27699-1617 •
These reports shall be submitted according to a schedule established by the Director and shall contain the
following
• a.) Narrative
A brief discussion of reasons for, status of, and actions taken for all Significant Industrial
Users (SIUs) in Significant Non-Compliance (SNC);
b.) Pretreatment Program Summary (PPS)
A pretreatment program summary (PPS) on specific forms approved by the Division;
c.) Significant Non-Compliance Report (SNCR)
The nature of the violations and the actions taken or proposed to correct the violations on
specific forms approved by the Division;
d.) Industrial Data Summary Forms (IDSF)
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•1
NPDES Permit Requirements
Page 16 of 16
Monitoring data from samples collected by both the POTW and the Significant Industrial
User (SIU). These analytical results must be reported on Industrial Data Summary Forms
(IDSF) or other specific format approved by the Division;
e.) Other Information
Copies of the POTW's allocation table, new or modified enforcement compliance schedules,
public notice of SIUs in SNC, and any other information, upon request, which in the
opinion of the Director is needed to determine compliance with the pretreatment
implementation requirements of this permit;
11. Public Notice
The Permittee shall publish annually a list of Significant Industrial Users (SIUs) that were in Significant
Non-Compliance (SNC) as defined in the Permittee's Division approved Sewer Use Ordinance with
applicable pretreatment requirements and standards during the previous twelve month period. This list
shall be published within four months of the applicable twelve-month period.
12. Record Keeping •
The Permittee shall retain for a minimum of three years records of monitoring activities and results, along
with support information including general records,water quality records, and records of industrial impact
on the POTW.
13. Funding and Financial Report
The Permittee shall maintain adequate funding and staffing levels to accomplish the objectives of its
approved pretreatment program.
14. Modification to Pretreatment Programs
Modifications to the approved pretreatment program including but not limited to local limits
modifications, POTW monitoring of their Significant Industrial Users (SIUs), and Monitoring Plan
modifications, shall be considered a permit modification and shall be governed by 15 NCAC 2H .0114 and
15A NCAC 2H .0907.
•
Version 6/20/2003

te of North Carolinarb '�partment of Environment �d Natural Resources r, . 11iFillA
ision of Water Quality ,��' ��-�
wili ,
Michael F. Easley, Governor (' NCDENR
William G. Ross, Jr., Secretary _o� NORTH CAROLINA DEPARTMENT OE
Alan W. Klimek, P.E., Director �V ENVIRONMENT AND NATURAL RESOURCES
. February 18, 2004
Mr. Steve Olp
Site Manager
CNA Holding, Inc.
230 Archdale Drive
Charlotte,North Carolina 28210
Subject: Draft NPDES Permit
Permit NC0079898
Needmore Road Landfill
Rowan County
Dear Mr. Olp:
Enclosed with this letter is a copy of the draft permit for your facility. Please review the draft very carefully
to ensure thorough understanding of the conditions and requirements it contains.
The draft permit contains no significant changes from your current permit.
Please submit any comments to me no later than thirty days following your receipt of the draft. Comments
should be sent to the address listed at the bottom of this page. If no adverse comments are received from
the public or from you, this permit will likely be issued in early April,with an effective date of May 1,2004.
If you have any questions or comments concerning this draft permit, contact me at the telephone number or
e-mail address listed below.
Since ly, z::/x/
NC DEPT.'lr PsIIIIRONMENT
D NATL. RESOURCES
Se ei Chernikov, !;•,ESVIL1 AL OFFICE
DES Unit ri
cc: NPDES Unit E E B 2 0 2004
Mooresville Regional Office / Water Quality Section
DEH
�r T
1617 Mail Service Center,Raleigh,North Carolina 27699-1617 919 733-5083,extension 5 4 l I SEC I IQ
An Equal Opportunity Affirmative Action Employer sergei.chemikov@ ncmail.net

4
Permit NC007986.8
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
Draft 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.
CNA Holdings, Inc.
is hereby authorized to discharge wastewater from a facility located at
Needmore Road Landfill
Needmore Road
North of Woodleaf
Rowan County
to receiving waters designated as South Yadkin River in the Yadkin-Pee Dee River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts
I, II, III and IV hereof.
This permit shall become effective
This permit and authorization to discharge shall expire at midnight on March 31, 2009.
Signed this day
DRAFT
Alan Klimek,P.E.,Director
Division of Water Quality
By Authority of the Environmental Management Commission

# Permit NC0079898
SUPPLEMENT TO PERMIT COVER SHEET
CNA Holdings, Inc_, is hereby authorized to:
1. Continue to operate an existing wastewater treatment facility with the following components:
• Equalization tank
• Six-train UV/hydrogen peroxide oxidation system
• Chemical feed systems for pH adjustments
• Hydrogen peroxide addition system
• Effluent holding tank
• Parshall flume
• Effluent diffuser
• Leachate collection system
The facility is located at Needmore Road Landfill in Rowan County.
2. Discharge from said treatment works at the location specified on the attached map into South Yadkin
River, classified WS-IV waters in the Yadkin-Pee Dee River Basin.

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Latitude:35°49'06" Facility ,�
Longitude:80°34'35" N C 0 0 7 9 8 9 8
Quad# D16SE Location
Receiving Stream:South Yadkin
River CNA Holdings, Inc.
Stream Class:WS-1V Needmore Road
F �'
Permittednitted Flaw:0.288 MGD Landfill d f i I f Noah
not to scale

Permit No. NC0079898
A (1). EFI~LUENT LIMITATIONS AND MONITORING REQUIREMENTS -Draft
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is
authorized to discharge from outfall(s) serial number 001 - Remediated Groundwater. Such discharges shall be
limited and monitored by the Permittee as specified below:
EFFLUENT DISCHARGE LIMITATIONS MONITORING REQUIREMENTS
CHARACTERISTICS
Monthly Weekly Daily Effluent Measurement Sample Type Sample
Average Average Maximum Frequency Locations
Flow (MGD) _ 0.288 Continuous Recording E
BOD,5-Day,20°C 30.0 mg/L_ 45.0 mg/L Quarterly Composite E
Total Suspended Solids 30.0 mg/L i 45.0 mg/L Quarterly Composite E
OHI and Grease , 30.0 mg/L 60.0 mg/L Quarterly Grab E
Phenols Quarterly Grab E
Total Barium Quarterly Composite E
1,4—Dioxane Quarterly Grab E
Total Copper Quarterly Composite E
Total Iron Quarterly Composite E
Total Nickel Quarterly Composite E
Total Manganese Quarterly Composite E
Conductivity Quarterly Grab U,D
Dissolved Oxygen Quarterly Grab U,D
Temperature Quarterly Grab U,D
Total Nitrogen Monthly Composite E
(NO,+NO,+TKN) -
Total Phosphorus Monthly Composite E
Chronic Toxicity' Quarterly Composite E
pH' Quarterly Grab E
NOTES:
1. Sample Locations: E -- Effluent, U — Upstream 50 feet above the outfall, D — Downstream at entrance of
Cooleemee's water plan intake flume.
2. Chronic Toxicity (Ceriodaphnia) @ 0.42%; January, April, July and October; see condition A(2) of this
permit.
3. The pH shall not be less than 6.0 standard units or greater than 9.0 standard units.
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN TRACE AMOUNTS.
MONITORING FOR ALL PARAMETERS WITH THE EXCEPTION OF FLOW MUST COINCIDE WITH TOXICITY
TESTING.

Permit No. NC0079898
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS
A (2). CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia dubia at an effluent concentration of 0.42%.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the "North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or "North
Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised-February 1998) or subsequent versions.
The tests will be performed during the months of January, April,July,and October. Effluent sampling for this testing
shall be performed at the NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit
limit, then multiple-concentration testing shall be performed at a minimum, in each of the two following months
as described in "North Carolina Phase H Chronic Whole Effluent Toxicity Test Procedure" (Revised-February
1998) or subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the highest
concentration having no detectable impairment of reproduction or survival and the lowest concentration that
does have a detectable impairment of reproduction or survival.The definition of"detectable impairment,"
collection methods, exposure regimes, and further statistical methods are specified in the "North Carolina Phase
II Chronic Whole Effluent Toxicity Test Procedure" (Revised-February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the months in which tests were performed, using the parameter code TGP3B for
the pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3 (original)is to be sent to
the following address:
Attention: Environmental Sciences Branch
North Carolina Division of
Water Quality
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30
days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required,
the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating
the facility name, permit number, pipe number, county, and the month/year of the report with the notation of
"No Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences
Branch at the address cited above.

a
r
Permit No. NC0079898
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS
A(2). Continued...
Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be
required during the following month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of
Water Quality indicate potential impacts to the receiving stream, this permit may be re-opened and modified to
include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival, minimum control organism reproduction, and appropriate environmental controls, shall
constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day
of the month following the month of the initial monitoring.

' DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC0079898
Facility Information
Applicant/Facility Name: CNA Holdings, Incorporated _
Applicant Address: 2300 Archdale Drive/IZIP 811,Charlotte,NC 28210
Facility Address: Needmore Road, North of Woodleaf _
Permitted Flow 0.288 MGD
Type of Waste: 100% Industrial
Facility/Permit Status: Renewal
County: Rowan
Miscellaneous
Receiving Stream: South Yadkin River Regional Office: Mooresville
Stream Classification: WS-IV USGS Topo Quad: DI6SE _
303(d) Listed?: NO Permit Writer: Sergei Chernikov
Subbasin: 03-07-06 Date: January 30,2004
Drainage Area (mi2): 559
Summer 7910 (cfs) 106
Winter 7910 (cfs): 179 _
Average Flow (cfs): 229
IWC (%) (Dilution): 0.42(238)
Primary SIC Code:
SUMMARY
CNA Holdings (formerly known as HNA Holdings) operates a groundwater remediation system at their closed
Needmore Road Landfill. Originally permitted in 1991, the discharge is from the remediation of landfill leachate
which has migrated into groundwater.
The remediation system consists of a 275,000 gallon equalization tank, a six-train UV/hydrogen peroxide oxidation
system, chemical feed systems for pH adjustment, effluent holding tank, Parshall flume, effluent diffuser, 10
extraction wells, and a leachate collection system. The system is designed to operate at a minimum of 50 gpm.
Groundwater is currently recovered at a rate less than 50 gpm (72,000 gpd) because organic levels in some of the
wells are too high for treatment in the current UV system. As a result,recovered groundwater is stored until enough
is collected for treatment. The facility has been shut down since August 2002 due to on-going drought conditions.
A reasonable potential analysis was conducted for phenol, 1.4 dioxane,manganese,and barium. Results indicated no
potential to exceed existing standards.Regional office recommends renewal of the permit.
TOXICITY TESTING:
Current Requirement: Chronic P/F @ 0.42%
Recommended Requirement: Chronic P/F @ 0.42%
A review of testing results indicates that only one failure have occurred during previous permit cycle.
COMPLIANCE SUMMARY:
A review of compliance data indicates that this facility has been in compliance with all effluent limitations on a
consistent basis.
INSTREAM MONITORING:
This facility measures temperature, conductivity, and dissolved oxygen upstream and downstream of the discharge.
A review of upstream and downstream data suggests that the facility's discharge is not contributing to elevated
instream levels of the aforementioned parameters. In light of the type of discharge and the water supply classification
of the receiving stream,instream monitoring for these parameters will remain in place.
PROPOSED CHANGES:
None.
HNA N,edrni we Landfill Fact Shcet
NPDES Renewal
Page

•
741‘1
PROPOSED SCHEDULE FOR PERMIT ISSUANCE:
Draft Permit to Public Notice: February 18,2004(est.)
Permit Scheduled to Issue: April 10,2004(est.)
STATE CONTACT:
If you have any questions on any of the above information or on the attached permit, please contact Sergei
Chernikov at(919)733-5038 ext.594.
REGIONAL OFFICE COMMENT:
No adverse comments from MRO in staff report(10/17/2003).
NAME: DATE:
•
EfNA I1oI llllre.N c+lmurr Landfill Fau Shed
NPI)ES R'ne'W':ll
Page 2

SOC PRIORITY PROJECT: No
To: Permits and Engineering Unit
Water Quality Section
Attention: Charles Weaver
Date: October 7, 2003
NPDES STAFF REPORT AND RECOMMENDATION
MRO No.: 03-072
County: Rowan
Permit No. NC0079898
PART I - GENERAL INFORMATION
1. Facility and Address: Needmore Road Landfill Site
Groundwater Remediation Facility
CNA Holdings, Inc.
2300 Archdale Drive
Charlotte, North Carolina 28210
2. Date of Investigation: N/A
3. Report Prepared By: Michael L. Parker, Environmental Engineer II
4. Persons Contracted and Telephone Number: Mr. Steve Olp; [phone]
5. Directions to Site: From the junction of Highway 801 and SR 1984 (Needmore Road) in
northwestern Rowan County, travel west on SR 1984 approximately 2.30 miles to the
junction with a gravel road on the right where a sign is marked "Hoechst Celanese 2110
Needmore Road, %2 mile". The remediation facility is located approximately 0.5 mile north
of this junction at the end of the gravel road.
6. Discharge Point(s). List for all discharge points:
Latitude: 35° 49' 06" Longitude: 80° 34' 35"
USGS Quad No.: D 16 SE USGS Name: Cooleemee,NC
7. Site size and expansion are consistent with application? Sufficient area exist for
expansion, if necessary.

Page Two
8. Topography (relationship to flood plain included): Rolling, with slopes of 3-8%toward
South Yadkin River. The WWT facility does not appear to be located in a flood plain.
9. Location of nearest dwelling: No dwelling within 500 feet of the WWT facility.
10. Receiving stream or affected surface waters: South Yadkin River
a. Classification: WS-IV
b. River Basin and Subbasin No.: Yadkin and 03-07-06
c. Describe receiving stream features and pertinent downstream uses: The receiving
stream is about 80 to 100 feet wide with a significant amount of flow. Davie County
has a drinking water intake approximately 1.8 miles downstream.
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
a. Volume of wastewater to be permitted: 0.288 MGD (Ultimate Design Capacity)
b. What is the current permitted capacity of the wastewater treatment facility? No flow
limit given in the existing permit.
c. Actual treatment capacity of the current facility (current design capacity)? 0.288
MGD.
d. Date(s) and construction activities allowed by previous Authorizations to Construct
issued in the previous two years: None.
e. Please provide a description of existing or substantially constructed wastewater
treatment facilities: The existing groundwater remediation facility consists of a
275,000 gallon equalization tank, a six-train UV/Hydrogen Peroxide Oxidation of
Organics system (manufactured by Solarchem), chemical feed systems for pH
adjustment(30%- Sulfuric Acid/30%-Sodium Hydroxide), Hydrogen Peroxide (50%)
addition system, effluent holding tank, Parshall Flume unit for effluent flow
measurement, 10 extraction wells, and a leachate collection system.
f. Please provide a description of proposed wastewater treatment facilities: There are
no proposed WWT facilities at this time.
g. Possible toxic impacts to surface waters: The current permit requires an acute
toxicity test with an LC50 greater than 42% effluent. Changes in the Division's
toxicity testing requirements may warrant a change to chronic testing.

Page Three
2. Residuals handling and utilization/disposal scheme: No solids disposal scheme is available
at this time since solids generation is not expected.
3. Treatment plant classification: Unknown*.
*The main treatment unit of this facility is a six-train UV/Hydrogen Peroxide Oxidation
unit, which is not listed in the current rating sheet.
4. SIC Code(s): 9999 Wastewater Code(s): 66 Main Treatment Unit Code: unknown
PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grant Funds or are any public monies
involved (municipals only)?There were no public monies involved in the construction of
this facility.
2. Special monitoring or limitations (including toxicity) requests: None at this time.
3. Important SOC, 3OC or Compliance Schedule dates: N/A.
4. Alternative Analysis Evaluation: There is no known alternative other than a surface
discharge available to this facility at the present time.
5. Air Quality and/or Groundwater concerns or hazardous waste utilized at this facility that
may impact water quality, air quality or groundwater? No hazardous waste is used at this
facility. Organic contaminants in the contaminated groundwater are oxidized by Hydrogen
Peroxide (50%) and Ultra Violet light to form carbon dioxide and water.
PART IV - EVALUATION AND RECOMMENDATIONS
CNA Holdings, Inc. requests the subject NPDES Discharge Permit(No. NC0079898) be
renewed. The GW remediation facilities authorized by the permit have been shut down since
August 2002 due to on-going drought conditions at that time, low levels of contaminants detected in
the GW and the receiving stream, and the presence of a drinking water intake downstream. CNA
has proposed leaving the GW remediation system shut down unless directed to resume pumping by
the State.

FiFrPr
Page Four
Pending a final review and approval by the NPDES Unit, we recommend that the permit be
renewed as requested. There are no other changes proposed to the permit and/or the existing
remediation facilities at this time.
7/7(/'
a�-l�f�t r� /'--7—,K3
Signature of Report Preparer Date
/D. R--(4/6;1E -s, L// °-Water QualitySupervisor Date
h:ldsrldsr431needmore.dsr

6 -77
11.
State of North Carolina V
Department of Environment
and Natural ResourcesAdig•
Division of Water Quality V
•
Michael F. Easley, Governor / .*.� 1
William G. Ross, Jr., Secretary c -
Alan W. Klimek: F.E., Director P. !�
y � NORTH CARO ` ' --r -Al4T/ OF
ENVIRONMENT AND NATURAL FL
URCE5
June 20, 2003
JUN 2 5 2003
Mr. Steve Olp
CNA Holding, Inc.
2300 Archdale Drive W
Charlotte, North Carolina 28210 WI4 QUALITY
Subject: NPDES Permit Renewal Application SECTION
Permit NC0079898
Needmore Road Landfill
Rowan County
Dear Mr. Olp:
The NPDES Unit received your permit renewal application on June 16, 2003. Thank you for
submitting this package.
The permit renewal for this facility has been assigned to a staff member. This staff member will
contact you if further information is needed to complete the permit renewal. Please note that the
NPDES Unit has several vacant positions. This staff shortage has lasted for over 4 years and is
delaying all permit renewals. Our remaining permit writers are currently reviewing Authorizations
to Construct, speculative limit requests, major permit modifications and 201 plan updates ahead of
permit renewals. This is necessary due to a variety of factors, including mandatory deadlines in
the statutes which govern our program.
If this staff shortage delays reissuance of NC0079898 the existing requirements in your permit
will remain in effect until the permit is renewed (or the Division takes other action). We
appreciate your patience and understanding while we operate with a severely depleted staff. If
you have any additional questions concerning renewal of the subject permit, please contact
Charles Weaver at [phone], extension 511.
Sincerely,
L)CALLA-1
C` '
Valery Stephens
Point Source Unit
cc: Mooresville Regional Office, Water Quality Section
NPDES File
Central Files
1617 Mail Service Center,Raleigh,North Carolina 27699-1617 919 733-5083,extension 520 (fax)919 733-0719
VISO-US ON THE INTERNET @ http:Uh20.enr state.nc.usINPOES Valery.Stephens@ncmail,net

•
l Celanese
_ _ ` ------Ste olp Celanese Americas Corp.
[ Ll \fl r. Hager 2300 Archdale Drive
1 l 1 Remediatian Charlotte,NC 28210
i
r1IE1 USA
V�+� �� Phone: [phone]
LTelefax: 704-554-2407
DENR-WATER QUALITY [e-mail]
POINT SOURCE BRANCH
June 12, 2003
N.C. Department of Environment and Natural Resources
Division of Water Quality/NPDES Unit
1617 Mail Service Center
Raleigh,NC 27699-1617
Dear Sir or Madam:
Please find enclosed the NPDES Permit renewal application for the Needmore Road Landfill
Groundwater Treatment System (existing permit NC007 9898). This treatment system only processes
groundwater. Therefore, as recommended by North Carolina Department of Environment and Natural
Resources(NCDENR) application form C-GW was used.
Under an agreement with NCDENR,the system is currently not operating. However, it is expected that
operations could resume for this facility. If restarted,the operating conditions for this system are
expected to have not changed significantly from the conditions presented in the initial permit application.
Concentrations of contaminants in groundwater at the site have generally declined,reducing the potential
load to the outfall. Analytical data from the most recent groundwater sampling at the site are attached. In
addition, a summary of the results from the most recent outfall sampling is attached.
A topographic map showing the location of the outfall is also attached. The outfall location has not
changed during operation to date.
Because this is an application for renewal of an existing permit, a report of alternatives to surface water
discharge was not included. This exclusion was made on the recommendation of NCDENR. The
treatment system conditions have not changed and the option of disposal to POTW or other alternatives to
surface water remain infeasible.
If you have any questions,please feel free to contact me at 704-554-3892.
Sincerely,
,.....‘7--....7---•
Steve Olp
Sr. Manager
Attachments

NPDES PERMIT APPLICATION - SHORT FORM C-GW
To be filed by persons engaged in groundwater rernediation projects
N. C. Department of Environment and Natural Resources
Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-16t7
NPDES Permit NCO() 7 9898
Please print or type
1. Applicant and facility producing discharge
A. Name CNA Holdings, Inc.
B. Mailing address of applicant:
1. Street address 2300 Archdale Drive
2. City Charlotte 3. County Mecklenburg
4. State NC 5. Zip Code 28210
Telephone Number ( 7O4 ) 554-3892
Fax Number ( 704 ) 554-2407
e-mail address: [e-mail]
C. Location of facility:
1. Street 345 Messick Farm Road
2. City Salisbury 3. County Rowan
4. State NC 5. Zip Code 28144
Telephone Number ( NA )
Fax Number ( NA )
2. Standard Industrial Classification (SIC) code(s) (if known): NA- Groundwater Only
3. This application is for a: n New Permit [ Permit Renewal , Permit Modification
4. Product(s) recovered (circle all that apply): Gasoline Diesel fuel Solvents
Other(describe) None - Groundwater only (see attached data)
5. (a) Check here if discharge occurs all year X , or
(b) Circle the month(s) in which discharge occurs: January February March April
May June July August September October November December
(c) Days per week discharge occurs:
6. Volume of wastewater discharged to receiving stream(s): 288,000 (monthly average) GPD*
*Gallons per operating day
7. Check here if wastewater is discharged directly to the receiving stream(s) X
If not, state the specific discharge location:
Mark the path taken by the wastewater to the receiving stream(s) on the site map. If a storm sewer is
the only viable means of discharge,trace the route of the storm sewer to its discharge point(s).
Short Form C-GW Vers.en 9.99

NPDES PERMIT APPLICATION - SHORT FORM C-GW
To be filed by persons engaged in groundwater remediation projects
8. Number of separate discharge points: One
NOTE: If the facility has separate discharge points (outfalls), include a schematic diagram of
wastewater flow at the facility.
South Yadkin
9. Name of receiving water(s):
This application package must include the items listed below. This application will be returned if the
required items are not included.
❑ A USGS topographical map(or copy of the relevant portion)which shows all outfalls
❑ A report of alternatives to surface water discharge as outlined by the Division's"Guidance for Evaluation of Wastewater Disposal
Alternatives"(required by 15A NCAC 2H.0105(c))
a A summary of the most recent analytical results containing the maximum values for each chemical detected
Applications for new (un-permitted) discharges must also include the items listed below. This
application will be returned if the required items are not included.
• An engineering proposal describing the remediation project in detail(required by 15A NCAC 2H.0105 (c))
❑ If the treatment system will discharge to a storm sewer,attach written approval from the municipality responsible for the sewer.
❑ A list of any chemicals found in detectable amounts at the site,with the maximum observed concentration reported for each chemical
(the most recent sample must be collected less than one year prior to the date of this application)
❑ A summary of analytical results containing the maximum values for each chemical detected
❑ The removal efficiency of each compound detected(if known)
For fuel remediation projects, analyses for volatile organic compounds(VOCs)should be performed. Analyses for any fuel additives likely
to be present at the site should also be performed. At minimum,analyses should be performed for the following compounds:
benzene' toluene" ethylbenzene' xylene' lead methyl tert-butylether(MTBE) dibromoethane(EDB)
1,2-dichloroethane isopropyl ether napthalene phenol
('an EPA-approved method capable of detection levels to 1 ppb should be used to detect these compounds).
For solvents or unidentified projects,an EPA Method 624/625 analysis should be performed. The data submitted with this application
should include the ten largest peaks not identified as targeted compounds and not present in the procedural blank. These peaks should be
identified and approximately quantitated(as per the same restrictions found on the NC DENWDWQ Annual Pollutant Analysis
Monitoring(APAM)Requirement-Reporting Form A).
If metals or pesticides are suspected to be present, these compounds should be analyzed to the same detection level as presented in the
NC APAM.
I certify that I am familiar with the information contained in the application and that to the best of
my knowledge and belief such information is true, complete, and accurate.
Steve Olp Site Manager
Printed name of Person Signing Title
c.9)
6/ /2/.23
Signature of Applicant Date
North Carolina General Statute 143-215.6(b)(2)provides that: Any person who knowingly makes any false statement representation,or certification in
any application,record,report,plan,or other document files or required to be maintained under Article 21 or regulations of the Environmental Management
Commission implementing that Article,or who falsifies,tampers with,or knowingly renders inaccurate any recording or monitoring device or method
required to be operated or maintained under Article 21 or regulations of the Envsronmental Management Commission implementing that Article,shall be
guilty of a misdemeanor punishable by a fine not to exceed S10,000,or by imprisonment not to exceed six months,or by both.
(1 B U.S.C.Section 1001 provides a punishment by a fine of not more than S10,000 or imprisonment for not more than 5 years,or both,for a similar
offense,)
Short Form C-GW Version 9-99

V2rIrnent
t f North Carolina PLC DWI. •
e i
b NATURAL RESOLD RCE&kii 7 u I/ mand Natural Resources _ _ _
Division of Water Quality MAY 31 2000
James B. Hunt, Jr., Governor man of 1111101110101 11111110F1 IICDEI' IR
Bill Holman, Secretary mow#w =MK IMPA
NORTH CAROLINA DEPARTMENT OF
Kerr T. Stevens, Director ENVIRONMENT AND NATURAL RESOURCES
May 20, 2000
Mr. Richard Ramirez
CNA Holdings, Inc.
P.O. Box 32414
Charlotte. North Carolina 28232
Subject: NPDES Permit Modification - Name Change
Permit NC0079898
CNA Holdings, Inc.
(Formerly HNA Holdings, Inc.)
Rowan County
Dear Mr. Ramirez:
In accordance with your request received May 12. 2000, the Division is forwarding the subject permit
modification. This modification documents the change in ownership at the subject facility. All other terms and
conditions in the original permit remain unchanged and in full effect. This permit modification is issued under
the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between
North Carolina and the U. S. Environmental Protection Agency dated December 6, 1983.
If any parts, measurement frequencies or sampling requirements contained in this permit modification
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 a written petition conforming to Chapter 150B of the
North Carolina General Statutes, filed with the Office of Administrative Hearings, Post Office Drawer 27447,
Raleigh, North Carolina 276 1 1-7447. Unless such demand is made, this decision shall be final and binding.
This permit does not affect the legal requirement to obtain other permits which may be required by the
Division of Water Quality, the Division of Land Resources, Coastal Area Management Act, or any other Federal or
Local government permit that may be required. If you have any questions concerning this permit, please contact
Christie Jackson at the telephone number or address listed below.
Sincerely, 1
Zii/tit-1,-* 741. Cita7741e,1"
err T. Stevens
cc: Central Files
Mooresville Regional Office, Water Quality Section
NPDES Unit •
Point Source Compliance Enforcement Unit
1617 Mail Service Center,Raleigh,North Carolina 27699.1617 919 733-5083,extension 538 (fax)919 733-0719
VISIT us ON THE INTERNET @ htip://h2o.enr.state.nc.us/NPDES Ch rislie.Jackson @ ncmai I.net

STATE OF NORTH CAROLINA Permit NC0079898
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended,
CNA Holdings, Inc.
is hereby authorized to discharge wastewater from a facility located at
Needmore Road Landfill
Needmore Road
North of Woodleaf
Rowan County
to receiving waters designated as South Yadkin River in the Yadkin-Pee Dee River
Basin
in accordance with effluent limitations, monitoring requirements, and other
conditions set forth in Parts I, II, III and IV hereof.
This permit shall become effective May 20, 2000.
This permit and authorization to discharge shall expire at midnight on April 30, 2004.
Signed this day May 20, 2000.
•
rr-T. Stevens, irector
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NC0079898
SUPPLEMENT TO PERMIT COVER SHEET
CNA Holdings, Inc., is hereby authorized to:
1. Continue to operate an existing wastewater treatment facility with the following
components:
♦ Equalization tank
• Six-train UV/hydrogen peroxide oxidation system
• Chemical feed systems for pH adjustments
♦ Hydrogen peroxide addition system
♦ Effluent holding tank
• Parshall flume
• Effluent diffuser
• Leachate collection system
The facility is located at Needmore Road Landfill in Rowan County.
2. Discharge from said treatment works at the location specified on the attached map
into South Yadkin River, classified WS-IV waters in the Yadkin-Pee Dee River
Basin.

r��
,Vl
NORTH CAROLINA DEPARTMENT OF
AT& ENVIRONMENT AND NATURAL RESOURCES
NCDENRDIVISION OF WATER QUALITY
MOORESVILLE REGIONAL OFFICE
December 16, 1999
JAMES B. HUNT JR. Y
GOVERNOR
David A. Jenkins, President
HNA Holdings, Inc.
BILL HOLMAN
SECRETARY 2300 Archdale Drive, IZIP 811
Charlotte, North Carolina 28210
KERR T. STEVENS
DIRECTOR
NPDES Permit No. NC0079898
Needmore Road Remediation
Rowan, NC
Dear Mr. Jenkins:
Our records indicate that NPDES Permit No. NC0079898 was issued on
November 29, 1999 for the discharge of wastewater to the surface waters of the State
from your facility. The purpose of this letter is to advise you of the importance of the
Permit and the liabilities in the event of failure to comply with the terms and conditions
of the Permit. If you have not already done so, it is suggested that you thoroughly read
the Permit. Of particular importance are Pages 4 and 5.
Pages 4 and 5 set forth the effluent limitations and monitoring requirements for
your discharge. Your discharge must not exceed any of the limitations set forth. The
section headed "Monitoring Requirements" describes the measurement frequencies,
sample types and sampling locations. Upon commencement of your discharge (or
operation), you must initiate the required monitoring. The monitoring results must be
•- entered on reporting forms furnished or approved by this Agency. If you have not
received these forms, they should be arriving shortly. If you fail to receive the forms,
please contact this Office as quickly as possible. I have enclosed a sample of the
"Effluent" reporting form (DEM Form MR-1), plus instructions for completing the form.
It is imperative that all applicable parts be completed, and the original and one copy be
submitted as required.
Please be advised that an annual administering and compliance monitoring fee
may be required for your facility. You will soon be receiving a statement from our
Raleigh Office. It is imperative that the fee be paid in a timely manner so as to prevent
enforcement action or possible revocation of your permit.
IMBECIUMM
919 NORTH MAIN STREET. MOORESVILLE, NORTH CAROLINA ,2,81 15
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10% POST-CONSU MAR PAPER

111.r7
David A. Jenkins
December 16, 1999
The remaining parts of the Permit set forth definitions, general conditions and
special conditions applicable to the operation of wastewater treatment facilities and/or
discharge(s). The conditions include special reporting requirements in the event of
noncompliance, bypasses, treatment unit/process failures, etc. Also addressed are
requirements for a certified wastewater treatment plant operator if you are operating
wastewater treatment facilities. Any changes in operation of wastewater treatment
facilities, quantity and type of wastewater being treated or discharged, expansion and/or
upgrading of wastewater treatment facilities must be permitted or approved by this
Agency.
Failure to comply with the terms and conditions of an NPDES Permit subjects
the Permittee to enforcement action pursuant to Section 143-215.6 of the North Carolina
General Statutes. A civil penalty of up to $25,000 per violation (and/or criminal
penalties) may be assessed for such violations. If you find at any time that you are
unable to comply with the terms and conditions of the Permit, you should contact this
Office immediately. A Special Order by Consent (SOC) may be necessary while
pursuing action to obtain compliance.
As a final note, an NPDES Permit is normally issued for a five-year period.
Permits are not automatically renewed. Renewal requests must be submitted to this
Agency no later than 180 days prior to expiration. Please make note of the expiration
date of your Permit. This date is set forth on Page 1 of the Permit. Also note that
NPDES Permits are not automatically transferable. If you, as the Permittee, cease to
need this Permit, then you should request that the Division of Water Quality rescind the
Permit or request that the Division of Water Quality reissue the Permit to another party,
if necessary.
As mentioned previously, the purpose of this letter is to advise you of the
importance of your NPDES Permit. Please read the Permit and contact this Office at
704/663-1699 in Mooresville of you have any questions or need clarification. We look
forward to providing any assistance.
Sincerely,
E/d,
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Enclosure
DRG:de

•
State of North Carolina
Department of EnvironmentA7;1111:iirli
�
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Bill Holman, Secretary NORTH CANIIZPENR
PEP TM4Eh1T OF
Kerr T. Stevens, Director ENVIRONMENT AND NATURAL RESOURCES
DEC
November 29, 1999 /999
e
Sf9;j Of fYyr
Mr. David A. Jenkins, President 41/04s;;1I Ili if d qd
HNA Holdings, Inc. arr
2300 Archdale Drive, IZIP 811 f'10E
Charlotte, North Carolina 28210
Subject: NPDES Permit Issuance
Permit Number NC0079898
Needmore Road Remediation
Rowan County
Dear Mr. Jenkins:
In accordance with the application for discharge permit received January 29, 1999, the
Division is forwarding herewith the subject state - NPDES permit. This permit is issued pursuant to
the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement
between North Carolina and the U.S. Environmental Protection Agency dated December 6, 1983.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty
(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 a demand is made, this permit shall be final and binding.
This permit does not affect the legal requirements to obtain other permits which may be
required by the Division of Water Quality or permits required by the Division of Land Resources,
Coastal Area Management Act, or any other Federal or Local governmental permits which may be
required.
If you have any questions or comments regarding these speculative limitations, please do not
hesitate to contact Mark McIntire at telephone number [phone], extension 553.
Sincerely
Original Signed By
David A. Goodrich
Kerr T. Stevens
Cc: Central Files
NPDES Permit File
Mooresville Regional Office, Water Quality
Technical Assistance and Certification Unit
1617 MAIL SERVICE CENTER,RALEIGH,NORTH CAROLINA 27699-1617-TELEPHONE [phone]/FAX [phone]
AN EQUAL OPPORTUNITY AFFIRMATIVE ACTION EMPLOYER-S0%RECYCLED/109E POST-CONSUMER PAPER
VISIT US ON THE INTERNET AT http://h2o.enr.state.nc.us/NPDE5

Permit No. NC0079898
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
HNA Holdings, Incorporated
is hereby authorized to discharge wastewater from a facility located at
Needmore Road Landfill
Needmore Road
North of Woodleaf
Rowan County
to receiving waters designated as the South Yadkin River in the Yadkin-Pee Dee River Basin in
accordance with effluent limitations, monitoring requirements, and other conditions set forth in
• Parts I, II, III and IV hereof.
This permit shall become effective January 1, 2000.
This permit and authorization to discharge shall expire at midnight on April 30, 2004.
Signed this day November 29, 1999.
Original Signed By
David A. Goodrich
Kerr T. Stevens, Director
Division of Water Quality
By Authority of the Environmental Management Commission

r r
Permit No. NC0079898
SUPPLEMENT TO PERMIT COVER SHEET
HNA Holdings, Incorporated
is hereby authorized to:
1. Continue operation of an existing wastewater treatment system consisting of an equalization tank, a
six-train UV/hydrogen peroxide oxidation system, chemical feed systems for pH adjustment, hydrogen
peroxide addition system. effluent holding tank. Parshall flume, an effluent diffuser and leachate
collection system located at Needmore Road Landfill in Rowan County; and
2. Discharge from said treatment works at the location specified on the attached map into the South
Yadkin River, a class WS-IV water in the Yadkin•Pee bee River Basin.

A (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL Permit No. NC0079898
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from outfall(s) serial number 001 -
Remediated Groundwater. Such discharges shall be limited and monitored by the Permittee as specified below:
EFFLUENT CHARACTERISTICS DISCHARGE LIMITATIONS r MONITORING REQUIREMENTS
Monthly F Effluent Measurement Sample Sample
Average , Weekly Average Daily Maximum Frequency _ _ Type r Location'
Flow (MGD) 0.288 - Continuous Recording L
BOD, 5-Day, 20°C 30.0 mg/L 45.0 mg/L Quarterly Composite E
Total Suspended Solids 30.0 mg/L 45.0 mg/L Quarterly Composite E
Oil and Grease 30.0 mg/L _ 60.0 mg/L Quarterly Grab E
Phenols Quarterly Grab E
Barium Quarterly Composite E
1.4 - Dioxane Quarterly Grab E
Copper _ Quarterly Composite E
iron Quarterly Composite E
Nickel Quarterly Composite E
Manganese Quarterly Composite E
Conductivity Quarterly Grab U, D
Dissolved Oxygen Quarterly Grab U, D
Temperature Quarterly Grab U, D
Total Nitrogen (NOz+NO3+TKN) Monthly Composite E
Total Phosphorus Monthly Composite E
Chronic Toxicity2 Quarterly Composite E
pH5 Quarterly Grab E
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN TRACE AMOUNTS.
MONITORING FOR ALL PARAMETERS WITH THE EXCEPTION OF FLOW MUST COINCIDE WITH TOXICITY TESTING.
NOTES:
I Sample Locations: E-Effluent, U-Upstream 50 feet above the outfall,D-Downstream at entrance of Cooleemee's water plan intake flume.
2 Chronic Toxicity(Ceriodaphnia) @ 0.42%; January,April, July and October; see condition A(2) of this permit.
5 The pH shall not be less than 6.0 standard units or greater than 9.0 standard units. -

Permit No. NC0079898
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS
A (2). CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia dubia at an effluent concentration of 0.42%.
The permit holder shall perform at a minimum. quarterly monitoring using test procedures outlined in the
"North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent
versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised-February
1998) or subsequent versions. The tests will be performed during the months of January, April, July, and
October. Effluent sampling for this testing shall be performed at the NPDES permitted final effluent
discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the
permit limit, then multiple-concentration testing shall be performed at a minimum. in each of the two following
months as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised-
February 1998) or subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the highest
concentration having no detectable impairment of reproduction or survival and the lowest concentration that
does have a detectable impairment of reproduction or survival. The definition of "detectable impairment."
collection methods, exposure regimes, and further statistical methods are specified in the "North Carolina
Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised-February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the months in which tests were performed, using the parameter code TGP3B for
the pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent
to the following address:
Attention: Environmental Sciences Branch
North Carolina Division of
Water Quality
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30
days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate
signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is
employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required,
the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating
the facility name, permit number, pipe number, county, and the month/year of the report with the notation of
"No Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences
Branch at the address cited above.

Permit No. NC0079898
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS
A(2). Continued...
Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will
be required during the following month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of
Water Quality indicate potential impacts to the receiving stream, this permit may be re-opened and modified to
include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document. such as minimum control
organism survival, minimum control organism reproduction. and appropriate environmental controls, shall
constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day
of the month following the month of the initial monitoring.

PART I
Section B. Schedule of Compliance
1. 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.
3. No later than 14 calendar days following a date identified in the above schedule of compliance,
the permittee shall submit either a report of progress or, in the case of specific actions being
required by identified dates, a written notice of compliance or noncompliance. In the latter case,
the notice shall include the cause of noncompliance,any remedial actions taken,and the
probability of meeting the next schedule requirements.

Part II
Page 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 Commission.
4. Act or "the Act"
The Federal Water Pollution Control Act, also known as the Clean Water Act, as amended, 33 USC
1251,et. seq.
5. Mass/Day Measurements
a. The "monthly average discharge" is defined as the total mass of all daily discharges sampled
and/or measured during a calendar month on which daily discharges are sampled and
measured, divided by the number of daily discharges sampled and/or 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 I of the permit.

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

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

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Part 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 pollutant listed as toxic under Section 307(a)(I) 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)]
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§ 143-215.6A1
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.

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2. Duty to Mitigate
The permittee shall take all reasonable steps to minimize or prevent any discharge or sludge use or
disposal in violation of this permit which has a reasonable likelihood of adversely affecting
human health or the environment.
3. Civil and Criminal Liability
Except as provided in permit conditions on "Bypassing" (Part II, C-4) and "Power Failures" (Part II,
C-7), nothing in this permit shall be construed to relieve the permittee from any responsibilities,
liabilities, or penalties for noncompliance pursuant to NCGS 143-215.3, 143-215.6 or Section 309 of
the Federal Act, 33 USC 1319. Furthermore, the permittee is responsible for consequential damages,
such as fish kills, even though the responsibility for effective compliance may be temporarily
suspended.
4. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve
the permittee from any responsibilities, liabilities, or penalties to which the permittee is or may
be subject to under NCGS 143-215.75 et seq. or Section 31] 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.
9. Duty to Reapply
If the permittee wishes to continue an activity regulated by this permit after the expiration date of
this permit, the permittee must apply for and obtain a new permit.

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Part II
Page 6 of 14
10. Expiration of Permit
The permittee is riot authorized to discharge after the expiration date. In order to receive
automatic authorization to discharge beyond the expiration date, the permittee shall submit such
information, forms, and fees as are required by the agency authorized to issue permits no later than
180 days prior to the expiration date. Any permittee that has not requested renewal at least 180
days prior to expiration, or any permittee that does not have a permit after the expiration and has
not requested renewal at least 180 days prior to expiration, will subject the permittee to enforcement
procedures as provided in NCGS 143-215.6 and 33 USC 1251 et. seq.
11. Signatory Requirements
All applications, reports, or information submitted to the Permit Issuing Authority shall be signed
and certified.
a. All permit applications shall be signed as follows:
(I) 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. I am aware that there are significant penalties for submitting false
information, including the possibility of fines and imprisonment for knowing violations."

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12. Permit Actions
This permit may be modified,revoked and reissued,or terminated for cause. The filing of a request
by the permittee for a permit modification, revocation and reissuance, or termination, or a
notification of planned changes or anticipated noncompliance does not stay any permit condition.
13. Permit Modification.Revocation and Reissuance.or Termination
The issuance of this permit does not prohibit the permit issuing authority from reopening and
modifying the permit,revoking and reissuing the permit,or terminating the permit as allowed by
the laws, rules, and regulations contained in Title 40, Code of Federal Regulations, Parts 122 and
123; Title 15A of the North Carolina Administrative Code, Subchapter 21-I .0100; and North
Carolina General Statute 143-215.1 et. al.
14. Previous Permits
All previous National Pollutant Discharge Elimination System Permits issued to this facility,
whether for operation or discharge, are hereby revoked by issuance of this permit. 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 MAINTENANCE OF POLLUTION CONTROLS
1. Certified Operator
Pursuant to Chapter 90A-44 of North Carolina General Statutes, and upon classification of the
facility by the Certification Commission, the permittee shall employ a certified wastewater
treatment plant operator in responsible charge (ORC) of the wastewater treatment facilities. Such
operator must hold a certification of the grade equivalent to or greater than the classification
assigned to the wastewater treatment facilities by the Certification Commission. The permittee
must also employ a certified back-up operator of the appropriate type and any grade to comply
with the conditions of Title 15A, Chapter 8A .0202. The ORC of the facility must visit each Class I
facility at least weekly and each Class II, III, and IV facility at least daily, excluding weekends
and holidays, and must properly manage and document daily operation and maintenance of the
facility and must comply with all other conditions of Title 15A, Chapter 8A .0202. Once the
facility is classified, the permittee shall submit a letter to the Certification Commission which
designates the operator in responsible charge within thirty days after the wastewater treatment
facilities are 50% complete.
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.

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

Part II
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5. Upsets
a. Definition.
Upset means an exceptional incident in which there is unintentional and temporary
noncompliance with technology based permit effluent limitations because of factors beyond the
reasonable control of the permittee. An upset does not include noncompliance to the extent
caused by operational error, improperly designed treatment facilities, inadequate treatment
facilities,lack of preventive maintenance, or careless or improper operation.
b. Effect of an upset.
An upset constitutes an affirmative defense to an action brought for noncompliance with such
technology based permit effluent limitations if the requirements of paragraph c. of this
condition are met. No determination made during administrative review of claims that
noncompliance was caused by upset, and before an action for noncompliance, is final
administrative action subject to judicial review.
c. Conditions necessary for a demonstration of upset.
A permittee who wishes to establish the affirmative defense of upset shall demonstrate,
through properly signed,contemporaneous operating logs,or other relevant evidence that:
(1) An upset occurred and that the permittee can identify the cause(s)of the upset;
(2) The permittee facility was at the time being properly operated; and
(3)The permittee submitted notice of the upset as required in Part II, E.6. (b) (B) of this permit.
(4) The permittee complied with any remedial measures required under Part II, B. 2. of this
permit.
d. Burden of proof.
In any enforcement proceeding the permittee seeking to establish the occurrence of an upset has
the burden of proof.
6. Removed 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 143-215.1 and in a manner such
as to prevent any pollutant from such materials from entering waters of the State or navigable
waters of the United States. The permittee shall comply with all existing federal 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.

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Part II
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SECTION D. MONITORING AND RECORDS
I. Representative Sampling
Samples collected and measurements taken, as required herein, shall be characteristic of the
volume and nature of the permitted discharge. Samples collected at a frequency less than daily
shall be taken on a day and time that is characteristic of the discharge over the entire period
which the sample represents. All samples shall be taken at the monitoring points specified in this
permit and, unless otherwise specified, before the effluent joins or is diluted by any other
wastestream, body of water, or substance. Monitoring points shall not be changed without
notification to and the approval of the Permit Issuing Authority.
2. Reporting
Monitoring results obtained during the previous month(s) shall be summarized for each month and
reported on a monthly Discharge Monitoring Report (DMR) Form (DEM No. 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 all
data generated must be reported down to the minimum detection or lower reporting level of the
procedure. If no approved methods are determined capable of achieving minimum detection and

Part 1I
Page 1I 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.
S. Penalties for Tampering
The Clean Water Act provides that any person who falsifies, tampers with, or knowingly renders
inaccurate, any monitoring device or method required to be maintained under this permit shall,
upon conviction,be punished by a fine of not more than$10,000 per violation,or by imprisonment for
not more than two years per violation, or by both. If a conviction of a person is for a violation
committed after a first conviction of such person under this paragraph, punishment is a fine of not
more than$20,000 per day of violation,or by imprisonment of not more than 4 years,or both.
6. Records Retention
Except for records of monitoring information required by this permit related to the permittee's
sewage sludge use and disposal activities, which shall be retained for a period of at least five
years (or longer as required by 40 CFR 503), the permittee shall retain records of all monitoring
information, including all calibration and maintenance records and all original strip chart
recordings for continuous monitoring instrumentation, copies of all reports required by this permit,
for a period of at least 3 years from the date of the sample, measurement, report or application.
This period may be extended by request of the Director at any time.
7. Recording Results
For each measurement or sample taken pursuant to the requirements of this permit, the permittee
shall record the following information:
a. The date,exact place,and time of sampling or measurements;
b. The individual(s) who performed the sampling or measurements;
c. The date(s) analyses were performed;
d. The individual(s) who performed the analyses;
e. The analytical techniques or methods used;and
f. The results of such analyses.
8. Inspection and Entry
The permittee shall allow the Director, or an authorized representative (including an authorized
contractor acting as a representative of the Director), upon the presentation of credentials and other
documents as may be required by law,to;
a. Enter upon the permittee's premises where a regulated facility or activity is located or
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.

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SECTION E. REPORTING REQUIREMENTS
1. Change in Discharge
All discharges authorized herein shall be consistent with the terms and conditions of this permit.
The discharge of any pollutant identified in this permit more frequently than or at a level in excess
of that authorized shall constitute a violation of the permit.
2. Planned Changes
The permittee shall give notice to the Director as soon as possible of any planned physical
alterations or additions to the permitted facility. Notice is required only when:
a. The alteration or addition to a permitted facility may meet one of the criteria for determining
whether a facility is a new source in 40 CFR Part 122.29 (b);or
b. The alteration or addition could significantly change the nature or increase the quantity of
pollutants discharged. This notification applies to pollutants which are subject neither to
effluent limitations in the permit, nor to notification requirements under 4() CFR Part 122.42 (a)
(I).
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) (See Part II. D. 2
of this permit)or forms provided by the Director for reporting results of monitoring of sludge use
or disposal practices.
b. If the permittee monitors any pollutant more frequently than required by the permit, using test
procedures specified in Part II, D. 4. of this permit or in the case of sludge use or disposal,
approved under 40 CFR 503,or as specified in this permit, the results of this monitoring shall be
included in the calculation and reporting of the data submitted in the DMR.
c. Calculations for all limitations which require averaging of measurements shall utilize an
arithmetic mean unless otherwise specified by the Director in the permit.

Part II
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6. Twenty-four Hour Reporting
a. The permittee shall report to the central office or the appropriate regional office any
noncompliance which may endanger health or the environment. Any information shall be
provided orally within 24 hours from the time the permittee became aware of the
circumstances. A written submission shall also be provided within 5 days of the time the
permittee becomes aware of the circumstances. The written submission shall contain a
description of the noncompliance, and its cause; the period of noncompliance, including exact
dates and times, and if the noncompliance has not been corrected, the anticipated time it is
expected to continue; and steps taken or planned to reduce, eliminate, and prevent reoccurrence
of the noncompliance.
b. The following shall be included as information which must be reported within 24 hours under
this paragraph:
(1) Any unanticipated bypass which exceeds any effluent limitation in the permit.
(2) Any upset which exceeds any effluent limitation in the permit.
(3) Violation of a maximum daily discharge limitation for any of the pollutants listed by the
Director in the permit to be reported within 24 hours.
c. The Director may waive the written report on a case-by-case basis for reports under paragraph
b. above of this condition if the oral report has been received within 24 hours.
7. Other Noncompliance
The permittee shall report all instances of noncompliance not reported under Part Il. E. 5 and 6. of
this permit at the time monitoring reports are submitted. The reports shall contain the information
listed in Part II. E. 6. of this permit.
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 II
Page 14 of 14
Persons reporting such occurrences by telephone shall also file a written report in letter form within
5 days following first knowledge of the occurrence.
10. Availability of Reports
Except for data determined to be confidential under NCGS 143-215.3(a)(2) or Section 308 of the
Federal Act, 33 USC 1318, all reports prepared in accordance with the terms shall be available for
public inspection at the offices of the Division of Water Quality. As required by the Act, effluent
data shall not be considered confidential. Knowingly making any false statement on any such
report may result in the imposition of criminal penalties as provided for in NCGS 143-215.1(b)(2) or
in Section 309 of the Federal Act.
11. Penalties for Falsification of Reports
The Clean Water Act provides that any person who knowingly makes any false statement,
representation, or certification in any record or other document submitted or required to be
maintained under this permit, including monitoring reports or reports of compliance or
noncompliance shall, upon conviction,be punished by a fine of not more than $10,000 per violation,
or by imprisonment for not more than two years per violation,or by both.

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

PART IV
ANNUAL ADMINISTERING AND COMPLIANCE MONITORING FEE
REQUIREMENTS
A. The permittee must pay the annual administering and compliance monitoring fee
within 30 (thirty) days after being billed by the Division. Failure to pay the fee in
a timely manner in accordance with 15A NCAC 2H .0105(b)(4) may cause this
Division to initiate action to revoke the permit.

SOC PRIORITY PROJECT: No
To: Permits and Engineering Unit
Water Quality Section
Attention: Charles Weaver
Date: March 5, 1999
NPDES STAFF REPORT AND RECOMMENDATION
MRO No.: 99-24
County: Rowan
Permit No. NC0079898
PART I - GENERAL INFORMATION
1. Facility and Address: Needmore Road Landfill Site
Groundwater Remediation Facility
HNA Holdings, Inc.
2300 Archdale Drive/IZIP 811
Charlotte, North Carolina 28210
2. Date of Investigation: March 4, 1999
3. Report Prepared By: Michael L. Parker, Environmental Engineer II
4. Persons Contracted and Telephone Number: Mr. Rick Ramirez; [phone]
5. Directions to Site: From the junction of Highway 801 and SR 1984 (Needmore Road) in
northwestern Rowan County, travel west on SR 1984 approximately 2.30 miles to the
junction with a gravel road on the right where a sign is marked "Hoechst Celanese 2110
Needmore Road, '/2 mile". The remediation facility is located approximately 0.5 mile
north of this junction at the end of the gravel road.
6. Discharge Point(s). List for all discharge points:
Latitude: 35' 49' 06" Longitude: 80° 34' 35"
Attach a U.S.G.S. map extract and indicate treatment facility site and discharge point on
map.
USGS Quad No.: D 16 SE USGS Name: Cooleemee,NC
7. Site size and expansion are consistent with application? Sufficient area exist for
expansion, if necessary.

Page Two
8. Topography (relationship to flood plain included): Rolling, with slopes of 3-8%toward
South Yadkin River. The WWT facility does not appear to be located in a flood plain.
9. Location of nearest dwelling: No dwelling within 500 feet of the WWT facility.
10. Receiving stream or affected surface waters: South Yadkin River
a. Classification: WS-IV
b. River Basin and Subbasin No.: Yadkin and 03-07-06
c. Describe receiving stream features and pertinent downstream uses: The receiving
stream is about 80 to 100 feet wide with a significant amount of flow. The Town
of Cooleemee's water intake is approximately three (3)miles downstream.
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. a. Volume of wastewater to be permitted: 0.288 MGD (Ultimate Design Capacity)
b. What is the current permitted capacity of the wastewater treatment facility? No
flow limit given in the existing permit.
c. Actual treatment capacity of the current facility (current design capacity)? 0.288
MGD.
d. Date(s) and construction activities allowed by previous Authorizations to
Construct issued in the previous two years: None.
e. Please provide a description of existing or substantially constructed wastewater
treatment facilities: The existing groundwater remediation facility consists of a
275,000 gallon equalization tank, a six-train UV/Hydrogen Peroxide Oxidation of
Organics system (manufactured by Solarchem), chemical feed systems for pH
adjustment (30%- Sulfuric Acid/30%-Sodium Hydroxide), Hydrogen Peroxide
(50%) addition system, effluent holding tank, Parshall Flume unit for effluent
flow measurement, 10 extraction wells, and a leachate collection system.
f. Please provide a description of proposed wastewater treatment facilities: There are
no proposed WWT facilities
g. Possible toxic impacts to surface waters: The current permit requires an acute
toxicity test with an LCsa greater than 42% effluent. Changes in the Division's
toxicity testing requirements may warrant a change to chronic testing.

T ''T.
Page Three
2. Residuals handling and utilization/disposal scheme: No solids disposal scheme is
available at this time. The applicant will need to submit a solid waste management plant
to DWQ for approval if and when solids generation is expected.
3. Treatment plant classification: Unknown*.
*The main treatment unit of this facility is a six-train UV/Hydrogen Peroxide Oxidation
unit, which is not listed in the current rating sheet.
4. SIC Code(s): 9999
Wastewater Code(s): 66
Main Treatment Unit Code: unknown
PART III - OTHER PERTINENT INFORMATION
l. Is this facility being constructed with Construction Grant Funds or are any public monies
involved (municipals only)?There were no public monies involved in the construction of
this facility.
2. Special monitoring or limitations (including toxicity) requests: The permittee has
requested that effluent testing for Cr, Cu, Pb, Oil & Grease, 1-2 Dichloroethane,
Chlorobenzene, and Methylene Chloride be removed from the Permit since they have not
been detected in the effluent for the past three (3) years.
3. Important SOC, JOC or Compliance Schedule dates: N/A.
4. Alternative Analysis Evaluation: There is no known alternative other than a surface
discharge available to this facility at the present time.
5. Air Quality and/or Groundwater concerns or hazardous waste utilized at this facility that
may impact water quality, air quality or groundwater? No hazardous waste is used at this
facility. Organic contaminants in the recovered groundwater are oxidized by Hydrogen
Peroxide (50%) and Ultra Violet light to form carbon dioxide and water.

•
Page Four
PART IV - EVALUATION AND RECOMMENDATIONS
Hoechst Celanese Corporation requests its NPDES Discharge Permit (No. NC0079898)
be renewed. In addition, the Company also requests that the specific parameters identified in Part
III, No. 2 above be removed from the permit since testing for the past three years has not shown
them to be present in the effluent. Pending concurrence by the P&E Group,we have no objection
to the approval of this request. It is also anticipated that toxicity testing will be changed from
acute to chronic at the renewal of this permit. There are no other changes proposed to the permit
at this time.
It is recommended that the NPDES Discharge Permit be renewed as requested by the
applicant.
.a/ 2-4 -f=-P7
ignature of ort Preparer Date
4a. .1 5 -
Water Quality egional Superv' Date
h:ldsr\dsr99\needmore.dsr

•
State of North Carolina 1 h 4)1 19111;111r4 •A
Department of Environment Gil ��S
and Natural Resources
Division of Water Quality OS( r
James B. Hunt, Jr., Governor � �y
Wayne McDevitt, Secretary Si
1CDEI1R
A. Preston Howard, Jr., P.E., Director NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
February 4, 1999
Mr. Rick Ramirez
HNA Holdings, Inc.
2300 Archdale Drive / IZIP 811 ; ir'
Charlotte, North Carolina 28210 , az tiDa
Subject: NPDES Permit Renewal Applications
Permit NC0079898
Needmore Road Landfill
Rowan County
Dear Mr. Ramirez:
The Division received your permit renewal application and a check for $200.00
(check # 91005552) on January 29, 1999. Thank you for submitting this package in a
timely fashion.
Changes in the permitting fees for NPDES facilities took effect on January 1,
1999. Among those changes was the elimination of renewal fees for existing NPDES
permits. I am returning the check you submitted with the permit application, along with
a revised fee schedule.
The permit renewal for this facility will be assigned to a member of the NPDES
Unit staff. That staff member will contact you if further information is needed to
complete the permit renewal.
If you have any additional questions concerning renewal of the subject permit,
please contact me at [phone], extension 511.
Sincerely,
getZ1 W. Wiwi
Charles H. Weaver, Jr.
NPDES Unit
cc: Central Files
Mooresville Regional Office, Water Quality Section
NPDES File
P.O.Box 29535,Raleigh,North Carolina 27626-0535 919 733-5083,extension 511 (fax)919 733-0719
An Equal Opportunity Affirmative Action Employer [e-mail]

•
Hoechst
Hoechst Corporation
P.O.Box 4915
Warren,N.J.07060-4915
January 25, 1999
142188
Mr. David Goodrich
NPDES Permits Supervisor
Division of Water Quality
P.O. Box 29535
512 N. Salisbury Street
Raleigh,NC 27626
Subject: HNA Holdings, Inc.
Salisbury, North Carolina
Needmore Road Landfill -
NPDES Permit Renewal (Permit Number NC0079898)
Dear Mr. Goodrich:
HNA Holdings Inc. (formerly Hoechst Celanese Corporation), a subsidiary of Hoechst
Corporation, owns a closed landfill site north of WoodIeaf,North Carolina. Groundwater is
recovered and treated prior to discharge to the South Yadkin River in accordance with
National Pollutant Discharge Elimination System (NPDES) Permit number NC0079898,
which expires July 31, 1999. Three copies of this letter and the attached permit application
are being submitted for renewal of the NPDES permit. Also enclosed is a check in the
amount of S250.00 for a timely permit renewal without modification.
Facility Location
The 1-HNA Needmore Road Landfill (NRL) facility is located north of the town of Woodleaf
in Rowan County. The facility's location is presented on Figure 1, which also shows nearby
transportation routes and surface waters.
Facility Overview
Recovered groundwater is equalized and treated using ultraviolet light and hydrogen
peroxide. Treated groundwater is discharged through a Parshall flume at Outfall 001 to the
South Yadkin River (Class WS-IV waters) through a diffuser.

•
! .'. . '' .
Mr. David Goodrich
Page 2
January 25, 1999
142188
Proposed Permit Conditions
Table 1 presents a summary of a statistical analysis for discharge data for the previous three
years for the NRL facility.
Table 1
Summary of NRL Facility Monitoring Data for the Period of September 1995 through August 1998
(Values in mg/L unless noted)
Monthly
Maximum Average/ NC Water
lnstream Daily Max Quality
of Average Standard Concentration Permit Standard/
Parameter Count Detects (b) Maximum Deviation cap Limit Action Level
Row(mgd) 324 324 0.0572 0.604 0.0431 - 0.288/- -
BOD 12 12 8.1 14 3 - 30/45 -
TSS 12 12 15.5 36 7.5 - 30/45 -
Oil and Grease 12 0 - - - - 30/60 -
Phenols 12 3 0.0014 0.008 0.0027 - - -
Barium 12 12 0.165 0.84 0.213 0.0035 - 1.0i-
Chromium 12 0 - - - - - -
Copper 12 0 - - - - - -
Iron 12 12 7.27 14 4.1 0.059 - -/1
Lead 12 0 - - - - - -
Mercury 12 1 0.0001 0.0012 0.00035 0.000005 - 0.000012/-
Nickel 12 7 0.0107 0.035 0.011 0.00015 - 0.0251-
1,2 12 0 - - - - - -
Dichloroethene
1,4 Dioxane 12 6 36.3 139 47.5 0.58 - -
Chiorobenzene 12 0 - - - - - -
Methylene 12 0 - - - - - -
Chloride
(a) Assumes an instream waste concentration of 0.42°0
(b) Average of all values, using zero for non-detects

Mr. David Goodrich
Page 3
January 25, 1999
142188
The facility currently is required to monitor quarterly for the parameters presented in
Table 1. The NC water quality standard or action level also is presented in Table 1 where
applicable. Accounting for the Instream Waste Concentration (IWC) of 0.42 percent, the
maximum instream concentration for each of the parameters listed in Table 1 is less than the
NC Water Quality Standard or Action Level. The following parameters have not been
detected in the effluent in the previous three years, and HNA requests that monitoring for
these parameters be discontinued:
• Chromium
• Copper
• Lead
• Oil and Grease
• 1-2 Dichloroethene
• ChIorobenzene
• Methylene Chloride
Toxicity Testing
The current NPDES permit requires an acute toxicity test with an LC50 greater than 42
percent effluent. The IWC for the NRL outfall is 0.42 percent based on a permitted effluent
flow of 0.288 MGD and a receiving stream 7Q10 of 68.5 MGD. Since discharge and river
flows are essentially unchanged, HNA would prefer that the toxicity testing requirement
remain unchanged with the permit renewal. However, we understand that DWQ's policy
regarding toxicity testing has changed since issuance of the current permit, and chronic
testing at the IWC may he required.
Flow
Effluent flow rates for September 1995 through August 1998 from the NRL facility are
presented on Figure 2. The groundwater treatment system operates at a minimum flow rate
of 50 gpm. Groundwater is recovered at a rate less than 50 gpm. Therefore, recovered
groundwater is stored until a sufficient volume is available for treatment. The system was
designed to treat larger volumes of groundwater. However, organic levels in some of the
wells are too high for treatment in the current UV system. HNA Holdings, Inc. is
investigating alternative treatment methods for these wells. In the future, if additional
treatment is installed, groundwater may be recovered at design flow rates. Therefore, 1-LN A
would like the current monthly average flow rate limit of 0.288 mgd to remain the same
with the renewed permit.
A North Carolina Short Form C for groundwater remediation systems is included in
Attachment B.

r•
Mr. David Goodrich
Page 4
January 25, 1999
142188
Please feel free to contact me at(704)554-2711 or our consultant, Kristen Jenkins,with
CH2M HILL, at(704) 329— 0073, extension 228 if you have any questions or require
additional information.
Sincerely,
Hoechst Corporation
a‘-) 4-666 /
Rick R ez /` •
Vice President and Site Manager
\P:\HCC\SALISBUR\PERMIT\nrllet3.doc
Enclosure
C: Kristen Jenkins/CH2M HILL

I
•
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i ':1 -',~' Treatment Facility
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USGS Cooleemee Quadrangle Figure 1
HNA Holdings, Inc.
Needmore Road Landfill Facility
CH2M HILL NPDES Permit No. NC0079898

Figure 2
Needmore Road Landfill Discharge Flow Rates
0.7000
0.6000
0.5000
� l
E. 0.4000
o Flow (mgd)
o
67 0.3000 — — .... —•30 per. Mov.
Avg. (Flow
(mgd))
0.2000
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0.0000 °oa— ,ns2+- °n o c' °o 0 0 o A
4/11/95 10/28/95 5/15/96 12/1/96 6/19/97 1/5/98 7/24/98 2/9/99
Nedtol2.xls Flow 12/18/98

r
North Carolina Dept. of Environment, Health, and Natural Resources
Division of Environmental Management, P.O. Box 29535, Raleigh, NC 27626-0535
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM APPLICATION NUMBER
APPLICATION FOR PERMIT DISCHARGE SHORT FORM C-GW
Date Received
To be filed by persons engaged in groundwater
remediation projects. Year Month Day
Do not attempt to complete this form before reading accompanying instructions.
(Please print or type)
1 . Name, address, location, and telephone number of facility producing discharge
A. Name HNA Holdings, Inc.
B. Mailing Address
1 . Street address 2300 Archdale Drive, IZIP 811
2. City Charlotte 3. State North Carolina
4. ZIP 28210
C. Location: •
1 . Street Needmore Road
2. City Woodleaf 3. State North Carolina
4. County Rowan
D. Telephone No. 704-554-2711
E. Nature of business Closed Landfill Site — Groundwater Remediation
2. Facility contact
A. Name Rick Ramirez
B. Title Vice President and Site Manager C. Telephone No. 704-554-2711
3. The application is for ❑ a new i► permit renewal, ❑permit modification.
permit,
SIC j (if known). If application is for renewal or modification, please
indicate permit number: NC0079898
4. Product(s) recovered There is no free product recovery at the site. Dissolved
organic contaminants in groundwater are primarily ethylene glycol and 1 .4 dioxane.
[Diesel fuel, leaded or unleaded fuel, solvents, etc.]
This application must also include the following:
A) A report of alternatives to surface water discharge as outline by N.C. Permit and
Engineering Unit's
"Guidance for Evaluation of Wastewater Disposal Alternatives." [Required by 15A
NCAC 2H.0105 (c)].
This report was submitted for the initial NPDES permit for this discharge and prior to
startup of the groundwater remediation system.
B) An engineering proposal detailing the remediation project. [Required by 15A NCAC 2H
.0105 (c)].
This proposal was submitted for the initial NPDES permit for this discharge and prior
to startup of the groundwater remediation system.
C) A listing of any chemicals found in detectable amounts with the maximum observed
concentration reported. The summary of analytical results containing this maximum
value should also be submitted (i.e. the listing, not the graphical scan). The most
recent sample must be no older than one year previous to the date of this application.
For fuel remediation projects, volatile organic compounds should be scanned along
with any suspected fuel additives. The following compounds should be included:
benzene', toluene`, ethylbenzene., xyiene', lead, methyl tert-butylether (MTBE),
dibromoethane (EDB), 1 ,2-dichloroethane, isopropylether, naphthalene, phenol.
. An EPA approved method capable of detection levels to 1 ppb should be used to
detect these compounds

For solvents or unidentified products, an EPA Method 624/625 analysis should be provided,
with the 10 largest peaks. not identified as one of the targeted compounds and not present in
the procedural blank, identified and approximately quantitated. [As per the same guidance
stipulated on NCDEM's "Annual Pollutant Analysis Monitoring (APAM) Requirement -
Reporting Form A." Revised June 1990].
If metals or pesticides are suspected to be present, these should be analyzed to the same
detection level as presented in the NC APAM.
Remediation at this site is not being conducted as a result of fuel, solvents, unidentified
product, metals or pesticide contamination. Therefore, only analytical data collected in
accordance with the current NPDES permit is presented.
D) The removal efficiency of each compound detected for the proposed project should be
provided if known.
1 , 4 dioxane - approximately 98 percent
5. Name of receiving water South Yadkin River
Attach a USGS topographical map with all discharge points clearly marked.
6. Is potential discharge directly to the receiving water? If not, state specifically the
discharge point.
Wastewater is piped directly into the S. Yadkin River with discharge to river through a
diffuser
Mark clearly the pathway to the potential receiving water on the site map. [This includes
tracing the pathway of the storm sewer to its discharge point, if a storm sewer is the
only viable means of discharge.]
7. Amount of treated groundwater to be discharged in gallons per operating day:
200 GPM: 0.288 MGD
8. Describe the duration and frequency of the discharge (continuous, intermittent,
seasonal) Including the moths of discharge. number of days per week of discharge,
volume treated (monthly average flow in gallons per day).
Groundwater is discharged intermittently. The groundwater treatment system is sized
for 50 gpm. However, groundwater is recovered at a rate less than 50 gpm. Therefore,
recovered groundwater is stored prior to treatment. The maximum monthly average
flow is 0. 15 mgd.
I certify that I am familiar with the familiar with the information contained in the
application and that to the best of my knowledge and belief such information is true,
complete, and accurate.
David A. Jenkins President, HNA Holdings, Inc.
PRINTED fame of Person Signing Title
6F
21.
SIGItURE of Applicant Date Application Signed
North Carolina General Statute 143-215.6 (b) (2) provides that:
Any person who knowingly makes any false statement, representation, or certification in any
application, record, report. plan or other document files or required to be maintained under
Article 21 or regulations of the Environmental Management Commission implementing that
Article, or who falsifies, tampers with or knowingly renders inaccurate any recording or
monitoring device or method required to be operated or maintained under Article 21 or
regulations of the Environmental Management Commission implementing that Article. shall be
guilty of a misdemeanor punishable by a fine not to exceed 310,000, or by imprisonment not
tc exceed six months, or by both. (18 U.S.C. Section 1001 provides a punishment by a fine
of not more than $10,000 or imprisonment not more than 5 years, or both, for a similar
offense.)

State of North Carolina
Department of Environment . � ,'t %and Natural Resources s iaTIAAL IMOUR`'llS `
Division of Water Qualify A I ►)
JAN 8 .1999 - - iv
James B. Hunt, Jr., Governor OtI
kilkiatina _ NC DENR
Wayne McDevitt, Secretary saw = oliwy
` '�� �
A. Preston Howard, Jr., P.E., Director
December 21, 1998
A.J.Branecky
HNA Holdings,Inc.
P.O. Box 4
Salisbury, NC 28144
Subject:Renewal of NPDES Permit NC0079898
Needmore Road Landfill
Rowan County
Dear Permittee:
The subject permit expires on July 31, 1999. North Carolina General Stature 143.215.1(c) requires that an
application for permit renewal be filed at least 180 days prior to the expiration date.
To satisfy this requirement, your renewal package must be sent to the Division postmarked no later than February 1,
1999. Failure to request renewal by February 1, 1999 will result in a civil assessment of at least $250.00. Larger
penalties may be assessed depending upon the delinquency of the request.
If any wastewater discharge will occur after July 31, 1999 (or if continuation of the permit is desired), the permit must
not be allowed to expire. Operation of waste treatment works or continuation of a discharge after July 31, 1999
would violate NCGS 143-215.1 and could result in assessment of civil penalties of up to $10,000 per day.
If all wastewater discharge has ceased at the subject facility and you wish to rescind this permit, contact Robert
Farmer of the Division's Compliance Enforcement Unit at [phone], extension 531_ You may also contact the
Mooresville Regional Office at [phone] to begin the rescission process.
Use the enclosed checklist to complete your renewal package. The checklist identifies the items which you must
submit when applying for renewal of the subject permit.
If you have any questions, please contact me. My telephone number, fax number and e-mail address are listed below.
Sincerely,
141/67(/
Uharles H. Weaver, Jr.
NPDES Unit
cc: Central Files
Mooresville Regional Office, Water Quality Section
NPDES Unit
P.O. Box 29535, Raleigh, North Carolina 27626-0535 919 733-5083, extension 511 (fax) 919 733-0719
An Equal Opportunity Affirmative Action Employer [e-mail]

NC DENR/DWQ 1 NPDES
Permit Renewal Applications
Renewal Package Checklist
NPDES Permit NC0079898
HNA Holdings, Inc.
Rowan County
The following items are REQUIRED for all renewal packages:
A cover letter requesting the renewal and documenting any changes at the facility
since issuance of the last permit. Submit one signed original and two copies.
flThe completed application form (copy attached), signed by the permittee or an
Authorized Representative. Submit one signed original and two copies.
— If an Authorized Representative is preparing the renewal package, documentation
must be provided from the permittee defining the person or company preparing the
renewal package as an Authorized Representative (see Part II.B.11.b. of the
NPDES permit).
A narrative description of the sludge management plan at the subject facility. If
your facility has no sludge management plan, explain the reason for this in your
cover letter. Submit one original and two copies.
The following requirement does NOT apply to municipal or non-industrial facilities.
The following item applies to Industrial facilities only:
Industrial facilities classified as Primary Industries (listed in Appendix A of Title 40 of
the Code of Federal Regulations, Part 122) must submit a Priority Pollutant Analysis
in accordance with 40 CFR Part 122.21.
Send the completed renewal package and appropriate fee to:
Mr. Charles H. Weaver, Jr.
NC DENR/DWQ /NPDES
P.O. Box 29535
Raleigh, North Carolina 27626-0535

State of North Carolina
Department of Environment AATICIriA
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor — — 'r
Wayne McDevitt, Secretary C ri F
A. Preston Howard, Jr., P.E., Director
December 30, 1997
Mr. A. J. Branecky
FKAT, LLC
PO Box 4
Salisbury NC 28145
Subject: Permit Modification -Name Change
FKAT, LLC
(formerly Hoechst Celanese Corporation)
Permit No. NC0079898
Rowan County
Dear Mr. Branecky:
In accordance with your completed name/ownership change application dated November 7,
1997, we are forwarding herewith the modified Certificate of Coverage page for the subject facility. The
only changes in this permit are in regard to name and ownership. All other terms and conditions in the
original permit remain unchanged and in full effect. This Certificate of Coverage is issued pursuant to
the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement
between North Carolina and the U. S. Environmental Protection Agency dated December 6, 1983.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to request an individual permit by submitting an individual
permit application. Unless such request is made, this certificate of coverage shall be final and binding.
Please take notice that this certificate of coverage is not transferable except after notice to the
Division of Water Quality. The Division of Water Quality may require modification or revocation and
reissuance of the certificate of coverage.
This permit does not affect the legal requirements to obtain other permits which may be
required by the Division of Water Quality or permits required by the Division of Land Resources,
Coastal Area Management Act or any other Federal or Local governmental permit that may be required.
If you have any questions concerning this change, please contact Steve Coerper at 919/ 733-5083,
extension 361.
Sincerely,
A. Preston Ho d, Jr., P.E.
cc: Mooresville Regional Office,Water Quality Section
Central Files
Permits and Engineering
•
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

Permit No. NC0079898
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
FKAT, LLC
is hereby authorized to discharge wastewater from a facility located at
Needmore Road Landfill
Needmore Road
north of Woodleaf
Rowan County
to receiving waters designated as South Yadkin River in the Yadkin-Pee Dee River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in
Parts I, IL and III hereof.
This permit shall become effective January 1, 1998.
This permit and authorization to discharge shall expire at midnight on July 31, 1999.
Signed this 30th day of December, 1997.
bull:k
A. Preston Howard, Jr., P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit No. NC0079898
SUPPLEMENT TO PERMIT COVER SHEET
FKAT, LLC
is hereby authorized to:
1. Continue to operate the existing wastewater treatment facility consisting of an equalization tank,
a six-train UV/Hydrogen Peroxide Oxidation of Organics system(manufactured by Solarchem),
chemical feed systems for pH adjustment, Hydrogen jPeroxide addition system, effluent
holding tank, Parshall Flume, and leachate collection system located at Needmore Road
Landfill, Needmore Road, north of Woodleaf, Rowan County (See Part III of this Permit), and
2. Discharge from said treatment works at the location specified on the attached map into
South Yadkin River which is classified Class WS-IV waters in the Yadkin-Pee Dee River
Basin.

r
c4—\\. 0 - ,„, „„, ,________-,-
\ - -;--- -
!IF11:11:::::\ \, , ,,
, \, ' - r'00 A
.,i ' ' /f/ YADK/N i% � � �� 1 = o fi
15 ` c '✓C// / ~` ' " Cooleemee'Junctii r
-,-„,,,, ,.
, , t
„..,._ ___ . ____ _ ,,seb.... , , .
„, ,, _
_ _
- ___ . / -_/ <r
--.\ \\ .1"
•
__,__ `^U 755 �� - `1 d i-` L7 ,.---, 2_- -
__.,___-_—__,-t/-,C------..!-.1
• ~ • • (
�, /1' 1 •
t1762
tN - \ _ _ , ._______ y , . _____________ _
ROAD CLASSIFICATION SCALE 1:24 000
PRIMARY HIGHWAY LIGHT-DUTY ROAD.HARD OR
HARD SURFACE IMPROVED SURFACE -_--_ _... _—..1 MILE
SECONDARY HIGHWAY 0 7000 FEET
.HARD SURFACE rj =UNIMPROVED ROAD = = . ..— 'MOW, ;;—..' `.....
1 0 1 KILOMETER
Latitude 35°49'06" Longitude 80°34`35" —i
Map # D16SE Sub-basin 030706 CONTOUR INTERVAL 10 FEET
Stream Class WS-IV
QUAD LOCATION
Discharge Codes 66 FKAT, LLC
Receiving Stream South Yadkin River NC0079898
Design QQ.2880 MOO Permit expires 07/31/99 Rowan County

State of North Carolina
j)\ Department of Environment
and Natural Resources AW, • •
Division of Water Quality
James B. Hunt. Jr., Governor Amememw
Wayne McDevitt, Secretary DENR
A. Preston Howard, Jr., P.E., Director
• February 3, 1998
Ftd 4 118
Mr.A.J. Branecky
HNA Holdings. Inc
P.O. Box 4
Salisbury, North Carolina 28144
Subject: NPDES Permit Correctiontion
Name and Ownership Change
HNA Holdings, Inc-
Permit No. NC0079898
(formerly Hoechst Celanese Corporation}
Rowan County
Dear Mr. Branecky:
In accordance with your request received via fax on January 20, 1998, the Division is forwarding the subject permit
correction. The only changes in this permit regard name and ownership, which were not correctly identified in the previous
permit modification sent to you on December 30, 1997.
All other terms and conditions in the original permit remain unchanged and in full effect. This permit modification is
issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement
between North Carolina and the U. S. Environmental Protection Agency dated December 6, 1983.
This permit does not affect the legal requirement to obtain other permits which may be required by the Division of Water
Quality, the Division of Land Resources, Coastal Area Management Act, or any other Federal or Local government permit that
may be required.
If you have any questions concerning this permit, please contact Charles Weaver at the telephone number listed
below.
Sincerely,
Original Signed By
David A. Goodrich
A. Preston Howard,Jr.,P.E.
cc: Central Files
Mooresville Regional Office, Water Quality Section
NPDES Unit
Compliance Enforcement Unit
P.O. Box 29535, Raleigh, North Carolina 27626-0535 919 733-5083, extension 511 (fax)919 733-0719
An Equal Opportunity Affirmative Action Employer Charles_Weaver@ dem.ehnr.state.nc.us

Permit No. NC0079898
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission,
and the Federal Water Pollution Control Act, as amended,
HNA Holdings, Inc.
is hereby authorized to discharge wastewater from a facility located at
Needmore Road Landfill
Needmore Road
north of Woodleaf
Rowan County
to receiving waters designated as the South Yadkin River in the Yadkin-Pee Dee River
Basin
in accordance with effluent limitations, monitoring requirements, and other conditions
set forth in Parts I, !I, Ill and IV hereof.
This permit shall become effective February 3, 1998.
This permit and authorization to discharge shall expire at midnight on July 31 , 1999.
Signed this 3rd day of February, 1998.
Original Signed By
David A. Goodrich-
A. Preston Howard, Jr., P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit No. NC0079898
SUPPLEMENT TO PERMIT COVER SHEET
HNA Holdings, Inc.
is hereby authorized to:
1. Continue to operate the existing wastewater treatment facility consisting of:
• an equalization tank,
• a six-train UV/Hydrogen Peroxide Oxidation of Organics system
(manufactured by Solarchem),
• chemical feed systems for pH adjustment,
• Hydrogen Peroxide addition system,
• effluent holding tank,
• Parshall Flume and leachate collection system
located at the Needmore Road Landfill, Needmore Road, north of Woodleaf,
Rowan County (see Part III of htis permit), and
2. Discharge from said treatment works at the location specified on the attached
map into the South Yadkin River which is classified Class WS-IV waters in the
Yadkin-Pee Dee River Basin.

State of North Carolina g
Department of Environment,
SLI Health and Natural Resources A7;7A
Division of Environmental Management
so ft,RE NOsevi•ft wooll r
James B. Hunt, Jr., Governor
415 Jonathan B. Howes, Secretary Q H Ni Ft
A. Preston Howard, Jr., P.E., Director
N.C. DEPT. OP
July 29, 1994 ENVIRONMENT, HEALTH,
& NATURAL RESOURCES
Mr. Keith E. Darnell AUG g 1994
Technical Fibers Group
Hoechst Celanese Corporation DIVISION Of ENVIRONMENTAL MANAGEMENT
PO Box 4 MOORESVILLE REO101jAL OFFICE
Salisbury NC 28145-0004
Subject Permit Issuance
Permit No. NC0079898
Needmore Road Landfill
Rowan County
Dear Mr. Darnell
In accordance with your application for discharge permit received on January 31, 1994, we are
forwarding herewith the subject State - NPDES permit. This permit is issued pursuant to the
requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement
between North Carolina and the US Environmental Protection Agency dated December 6, 1983.
In response to comments in your letter of June 23, 1994, regarding the draft permit, the following
modifications/comments are offered:
• Supplement to Permit Cover Sheet- The reference to the number of extraction wells has
been deleted from the facilities description as requested.
•Effluent limitations and monitoring - Requirements for NH3 and total phosphorus have been
deleted based on their low concentations at the wells. The Acute Toxicity parameter has been
added to the list on the effluent sheet.
• Downstream monitoring point- This has been modified to Cooleemee's water plant intake
based on comments from the Division of Environmental Health.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicative hearing upon written request within thirty
(30) days following receipt of this letter. This request must be in the form of a written petition,
conforming to Chapter 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.
Please take notice this permit is not transferable. Part II,E.4. addresses the requirements to be
followed in case of change in ownership or control of this discharge.
This permit does not affect the legal requirements to obtain other permits which may be required by
the Division of Environmental Management or permits required by the Division of Land Resources,
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

4
Coastal Area Management Act or any other Federal or Local governmental permit that may be
required.
If you have any questions concerning this permit, please contact Mr. Greg Nizich at telephone
number 919/733-5083.
Sincerely,
Original Signed By
David A. Goodrich
A. Preston Howard, Jr., P.E.
cc: Mr. Jim Patrick, EPA
Mooresville Regional Office
Compliance
Central Files

1 Permit No. NC0079898
•
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT N.C. OF
ENVIRONMENT, HEALTH.
PERMIT & NATURAL RESOURCES
TO DISCHARGE WASTEWATER UNDER THE AUG 3 1994
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
DIVISION OF ENVIRONMENTAL MANAGEMENT
MOORESVILLE REGIONAL OFFICE
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,
Hoechst Celanese Corporation
is hereby authorized to discharge wastewater from a facility located at
Needmore Road Landfill
Needmore Road
north of Woodleaf
Rowan County
to receiving waters designated as South Yadkin River in the Yadkin-Pee Dee River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in
Parts I, II, and III hereof.
This permit shall become effective September 1, 1994
This permit and the authorization to discharge shall expire at midnight on July 31, 1999
Signed this day July 29, 1994
Original Signed Ey
David A. Goodrich
A. Preston Howard, Jr., P.E., Director
Division of Environmental Management
By Authority of the Environmental Management Commission

1
Permit No. NC0079898
SUPPLEMENT TO PERMIT COVER SHEET
Hoechst Celanese Corporation
is hereby authorized to:
1. Continue to operate the existing wastewater treatment facility consisting of an equalization tank,
a six-train UV/Hydrogen Peroxide Oxidation of Organics system (manufactured by Solarchem),
chemical feed systems for pH adjustment, Hydrogen Peroxide addition system, effluent holding
tank, Parshall Flume, and leachate collection system located at Needmore Road Landfill,
Needmore Road, north of Woodleaf, Rowan County (See Part III of this Permit), and
2. Discharge from said treatment works at the location specified on the attached map into South
Yadkin River which is classified Class WS-IV waters in the Yadkin-Pee Dee River Basin.
I

a
A. ( ). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL Permit No. NC0079898 , .
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from outfall
serial number 001. Such discharges shall be limited and monitored by the permitter as specified below:
Effluent Characteristic Discharge Limitation: Monitoring Requirements
Lbs/day Units (specify Measurement Sample *Sample
Mon. Avg. Daily Max Mon, Avq. Daily Max. Frequency Type Location
Flow 0.288 MGD Continuous Recording E
BOD, 5 Day, 20 °C 30.0 mg/I 45.0 mg/I Quarterly Composite E
TSS 30.0 mg/I 45.0 mg/I Quarterly Composite E
Oil and Grease 30.0 mg/I 60.0 mg/1 Quarterly Grab E
Phenols Quarterly Grab E
Barium Quarterly Composite E
1,2 - Dichloroethene^cis/trans Quarterly Grab E
1,4 Dioxane Quarterly Grab E
Chlorobenzene Quarterly Grab E
Chromium Quarterly Composite E
Copper Quarterly Composite E
* Sample locations: E- Effluent, U - Upstream 50' above discharge, D - Downstream at entrance of Cooleemee's water plant intake flume.
** Acute Toxicity (Daphnid 48 hr)LC50 @ 42%; January, April,July and October; See Part III,Condition E.
Monitoring for all parameters except flow shall coincide with toxicity testing.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored quarterly by grab sample at the
effluent.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
i

A. ( ). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL Permit No. NC0079898
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from outfall
serial number 0(11. (Continued) .
effluent Characteristic Discharge Limitations Monitoring Requirements
Lbs/day Other Units (specify) Measurement Sample `Sample
Mon. Avq. Daily Max Mon. Avq. Daily Max. Frequency Type Location
Iron Quarterly Composite E
Lead Quarterly Composite E
Mercury Quarterly Composite E
Nickel Quarterly Composite E
Methylene Chloride Quarterly Grab E
Manganese Quarterly Composite E
Conductivity Quarterly Grab U,D
Dissolved Oxygen Quarterly Grab U,D
Temperature Quarterly Grab U,D
Acute Toxicity** Quarterly Composite E

PARTI
4
1 Section B. Schedule of Compli&nce
a4
I. The permittee shall comply with Final Effluent Limitations specified for discharges in
accordance with the following schedule:
Perrn.inee 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.
•
3. No later than 14 cale,,dar days following a date identified in the above schedule of compliance,
the permittee shall submit either a report of progress or, in the case of specific actions being
required by identified dates. a written notice of compliance or noncompliance. In the latter
case, the notice shall include the cause of noncompliance, any remedial actions taken, and the
probability of meeting the next schedule requirements.

Part II
Pagelofl4
PART II
STANDARD CONDITIONS FOR NPDES PER. ZITS •
SECTION A. DEFINITIONS
I. permit Issuing Authority
The Director of the Division of Environmental Management.
2. DEM or Division
Means the Division of Environmental Management, Department of Environment, Health and
Natural Resources.
3. \IC
Used herein means the North Carolina Environmental Management Commission.
4. Act or "the Act"
The Federal Water Pollution Control Act, also known as the Clean Water Act, as amended. 33
CSC 1251, et. seq.
5. ,'\Sasc Dav Measurements
a. The "monthly average discharge" is defined as the total mass of all daily discharges
sampled and.or measured during a calendar month on which daily discharges are sampled
and measured, divided by the number of daily discharges sampled and/or measured during
such month. It is therefore, an arithmetic mean found by adding the weights of the
pollutant found each day of the month and then dividing this sum by the number of days
the tests were reported. The limitation is identified as "Monthly Average" in Part I of the
permit.
b. The "weekly average discharge" is defined as the total mass of all daily discharges sampled
and/or measured during the calendar week (Sunday - Saturday) on which daily discharges
are sampled and measured, divided by the number of daily discharges sampled and/or
measured during such week. It is, therefore, an arithmetic mean found by adding the
eights 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 diischarges sampled and/or measured during such
year. It is, therefore, an arithmetic mean found by adding the weights of pollutants found
each day of the year and then dividing this sum by the number of days the tests were
reported. This limitation is defined as "Annual Average" in Part I of the permit.

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

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

y Part II
Page4of14
c. Weighted by Flow Value: Weighted by flow value means the summation of each
concentration times its respective flow divided by the summation of the respective flows.
10. Calendar 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.
1 1. 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 pollutant listed as toxic under Section 307(a)(1) of the Clean Water Act.
SECT1O< B GEs`ER.AL. CONDITIONS
1. p''n. to Comply
The permittee must comply with al] conditions of this permit. Any permit noncompliance
constitutes a violation of the Clean Water Act and is grounds for enforcement action; for permit
termination, re%ocation and reissuance, or modification; or denial of a permit renewal
ar rlication.
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 525,000 per day for each violation. Any person who
negligently violates any permit condition is subject to criminal penalties of 52,500 to
525,000 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 55,000
to 550,000 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 510,000 per violation with the maximum amount not to exceed 5125,000, [Ref:
Section 309 of the Federal Act 33 U.S.C. 1319 and 40 CFR 122,41 (a))
c. Under state law, a civil penalty of not more than ten thousand dollars (510,000) per
violation may be assessed against any person who violates or fails to act in accordance with
the terms, conditions, or requirements of a permit. [Ref: North Carolina General Statutes
§ 143-215.6A]
d. Any person may be assessed an administrative penalty by the Administrator for violating
section 301, 302, 306, 307, 308, 318, or 405 of the Act, or any permit condition or
limitation implementing any of such sections in a permit issued under section 402 of the
Act Administrative penalties for Class I violations are not to exceed $10,000 per violation,
ith the maximum 2rocunt of any Class I penalty assessed not to exceed S25,000.

Part II
Page 5 of 14
Penalties for Class 11 violations are not to exceed 5I0,000 per day for each day during •.�
which the violation continues, with the maximum amount of any Class II penalty not to
exceed S125,000.
2. ]Du t to Mitigate
The permirtee shall take all reasonable steps to minimize or prevent any discharge or sludge use
or disposal in violation of this permit which has a reasonable likelihood of adversely affecting
human health or the environment.
3. Civil and Criminal Liability
Except as provided in permit conditions on "Bypassing" (Part II, C-4) and "Power Failures"
(Part 1I. C-7), nothing in this permit shall be construed to relieve the permittee from any
responsibilities, liabilities, or penalties for noncompliance pursuant to NCGS 143-215.3, 143-
215.6 or Section 309 of the Federal Act, 33 USC 1319. Furthermore, the permittee is
responsible for consequential damages, such as fish kills, even though the responsibility for
effective compliance may be temporarily suspended.
4. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve
the perminee from any responsibilities, liabilities. or penalties to which the permittee is or may
be subject to under NCGS 143-215.75 et seq. or Section 311 of the Federal Act, 33 USG 1321.
Furthermore, the perrrunee is responsible for consequential damages, such as fish kills. even
though the responsibility for effective compliance may be temporarily suspended.
5. propem Ri;hts
The issuance of this permit does not convey any property rights in either real or personal
properry. 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. $everabiliry
The provisions of this permit are severable, and if any provision of this permit, or the
application of any provision of this permit to any circumstances, is held invalid,the application
of such provision to other circumstances, and the remainder of this permit, shall not be affected
thereby. •
8. Duty to Provide Information
The permittee shall furnish to the Permit Issuing Authority, within a reasonable time, any
information which the Permit Issuing Authority may request to determine whether cause exists
for modifying. revoking and reissuing, or terminating this permit or to determine compliance
with this permit. The permittee shall also furnish to the Permit Issuing Authority upon
request. copies of records required to be kept by this permit.

Part Il
Page 6 of 14
9. Duty to Reapply_
If the permittee wishes to continue an activity regulated by this permit after the expiration date
of this permit, the perminee must apply for and obtain a new permit.
10. Expirain of Permit
The permittee is not authorized to discharge after the expiration date. In order to receive
automatic authorization to discharge beyond the expirat;on date, the permittee shall submit such
information, forms, and fees as arc required by the agency authorized to issue permits no later
than 180 days prior to the expiration date. Any perrnittee 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. 5ignatory 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:
(I) 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 vk ho 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:
(I) The authorization is made in writing by a person described above;
(2) The authorization specified either an individual or a position having responsibility for
the overall operation of the regulated facility or activity, such as the position of plant
manager, operator of a well or well field, superintendent, a position of equivalent
responsibility, or an individual or position having overall responsibility for
environmental matters for the company. (A duly authorized representative may thus be
either a named individual or any individual occupying a named position.); and
(3) The written authorization is submitted to the Permit Issuing Authority.

- Part II
Page 7 of 14
c. Certification. Any person signing a document under paragraphs a. or b. of this section
shall make the following certification: r k
"I certify, under penalty of law,that this document and all attachments were prepared under
my direction or supervision in accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information submitted. Based on my inquiry of
the person or persons who manage the system, or those persons directly responsible for
gathering the information, the information submitted is, to the best of my knowledge and
belief, true, accurate, and complete. I am aware that there are significant penalties for
submitting false information, including the possibility of fines and imprisonment for
knowing violations."
12. permit Actions
This permit may be modified, revoked and reissued, or terminated for cause. The filing of a
request by the permittee for a permit modification, revocation and reissuance, or termination,
or a notification of planned changes or anticipated noncompliance does not stay any permit
condition.
13. permit Modification. Revocation and Reissuaacl,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
I22 and 123; Title 15A of the North Carolina Administrative Code, Subchapter 2H .0100; and
North Carolina General Statute 143-215.1 et. al.
14. Previous Permits
All previous National Pollutant Discharge Elimination System Permits issued to this facility,
v�hether for operation or discharge, are hereby revoked by issuance of this permit. [The
exclusive authority to operate this facility arises under this permit. The authority to operate the
facility under previously issued permits bearing this number is no longer effective. ) The
conditions, requirements, terms, and provisions of this permit authorizing discharge under the
National Pollutant Discharge Elimination System govern discharges from this facility.
SECTION C. OPERATION AND MAINTENANCE OF POLLUTION CONTROLS
1. Certified Operator
Pursuant to Chapter 90A-44 of North Carolina General Statutes, and upon classification of the
facility by the Certification Commission, the permittee shall employ a certified wastewater
treatment plant operator in responsible charge (ORC) of the wastewater treatment facilities.
Such operator must hold a certification of the grade equivalent to or greater than the
classification assigned to the wastewater treatment facilities by the Certification Commission.
The permittee must also employ a certified back-up operator of the appropriate type and any
grade to comply with the conditions of Title 15A, Chapter 8A .0202. The ORC of the facility
must visit each Class I facility at least weekly and each Class II, III, and IV facility at least
daily, excluding weekends and holidays, and must properly manage and document daily
operation and maintenance of the facility and must comply with all other conditions of Title
I 5A, 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 509k complete.

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

Part II
Page 9 of 14
periods of equipment downtime. This condition is not satisfied if adequate backup
equipment should have been installed in the exercise of reasonable engineering
judgment to prevent a bypass which occurred during normal periods of equipment
downtime or preventive maintenance;and
(C)The permittee submitted notices as required under Paragraph c. of this section.
(2) The Permit Issuing Authority may approve an anticipated bypass, after considering its
adverse affects, if the Permit Issuing Authority determines that it will meet the three
conditions listed above in Paragraph d. (1) of this section.
S. 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 ccnstitutes 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 arc 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 perrnittee submitted notice of the upset as required in Part II, E. 6. (b) (B) of this
permit.
(4) The permittee complied with any remedial measures required under Part II, B. 2. of this
permit.
•
d. Burden of proof.
In any enforcement proceeding the perrnittee seeking to establish the occurrence of an upset
has the burden of proof.
6. Removed Substances
Solids. sludges, filter backwash, or other pollutants removed in the course of treatment or
control of\wastewaters shall be utilized/disposed of in accordance with NCGS 143.215.1 and in
a manner such as to prevent any pollutant from such materials from entering waters of the State.
or navigable waters of the United States. The permittee shall comply with all existing federal

Pan II
Page 10 of 14
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 Pan 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 perminee
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.
SECTION D MONITORING ANp RECORDS
I. Representative Sampling
Samples collected and measurements taken, as required herein, shall be characteristic of the
volume and nature of the permitted discharge. Samples collected at a frequency less than daily
shall be taken on a day and time that is characteristic of the discharge over the entire period
which the sample represents: All samples shall be taken at the monitoring points specified in
this permit and, unless otherwise specified, before the effluent joins or is diluted by any other
wastestream, body of water, or substance. Monitoring points shall not be changed without
notification to and the approval of the Permit Issuing Authority.
2. Reporting
Monitoring results obtained during the previous month(s) shall be summarized for each month
and reported on a monthly Discharge Monitoring Report (DMR) Form (DEM No. MR 1, 1.1, 2,
3) or alternative forms approved by the Director, DEM. postmarked no later than the 30th day
following the completed reporting period.
The first DMR is due on the last day of the month following the issuance of the permit or in the
case of a new facility, on the last day of the month following the commencement of discharge.
Duplicate signed copies of these, and all other reports required herein, shall be submitted to the
following address:
Division of Environmental Management
Water Quality Section
ATTENTION: Central Files
Post Office Box 29535
Raleigh, North Carolina 27626-0535
3. Flow Measurements
Appropriate flow measurement devices and methods consistent with accepted scientific
practices shall be selected and used to ensure the accuracy and reliability of measurements of
the volume of monitored discharges. The devices shall be installed, calibrated and maintained
to ensure that the accuracy of the measurements are consistent with the accepted capability of
that type of device. Devices selected shall be capable of measuring flows with a maximum
deviation of less than + 107c from the true discli .rge rates throughout the range of expected
l

ran ii
Page 11 of 14
s `
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 I;CGS 143-215.63 et. seq, the Water and Air Quality Reporting Acts, and to
regulations published pursuant to Section 304(g), 33 USC 1314, of the Federal Water
Pollution Control Act, as Amended, and Regulation 40 CFR 136; or in the case of sludge use or
disposal, approved under 40 CFR 136, unless otherwise specified in 40 CFR 503, unless
other test procedures have been specified in this permit.
To meet the intent of the monitoring required by this permit, all test procedures must produce
minimum detection and reporting levels that are below the permit discharge requirements and
all data generated must be reported down to the minimum detection or lower reporting level of
the procedure. If no approved methods are determined capable of achieving minimum
detection and reporting levels below permit discharge requirements, then the most sensitive
(method with the lowest possible detection and reporting level) approved method must be used.
5. Penalties for Tampering
The Clean Water Act provides that any person who falsifies, tampers with, or knowingly
renders inaccurate, any monitoring device or method required to be maintained under this
permit shall, upon conviction, be punished by a fine of not more than S10,000 per violation, or
b} 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 S20,000 per day of violation, or by imprisonment of not
more than 4 years, or both.
6. Records Retention
Except for records of monitoring information required by this permit related to the permittee's
seat age 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
pennittee shall record the following information:
a. The date. exact place, and time of sampling or measurements;
b. The individuals) 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.

Part11
Page 12 of 14
8. Inspection and Erin
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 activity is located or
conducted, or where records must be kept under the conditions of this permit;
b. Have access to and copy, at reasonable times, any records that must be kept under the
conditions of this permit;
c. Inspect at reasonable times any facilities, equipment (including monitoring and control
equipment), practices, or operations regulated or required under this permit; and
d. Sample or monitor at reasonable times, for the purposes of assuring permit compliance or
as otherwise authorized by the Clean Water Act, any substances or parameters at any
location.
SECTIQN E REPORTING REOU1P,EI`1ENTS
I. 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 per7nittee shall give notice to the Director as soon as possible of any planned physical
alterations or additions to the permitted facility. Notice is required only when:
a. The alteration or addition to a permitted facility may meet one of the criteria for determining
whether a facility is a new source in 40 CFR Part 122.29 (b); or
b. The alteration or addition could significantly change the nature or increase the quantity of
pollutants discharged. This notification applies to pollutants which are subject neither to
effluent limitations in the permit. nor to notification requirements under 40 CFR Pan 122.42
(a) (1).
c. The alteration or addition results in a significant change in the permittee's sludge use or
disposal practices, and such alternation, addition or change may justify the application of
permit conditions that are different from or absent in the existing permit, including
notification of additional use or disposal sites not reported during the permit application
process or not reported pursuant to an approved land application plan.
3. Anticipated Noncompliance
The permince 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.

rail II
Page 13 of 14
•
4. Trans fez
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. Nonitoring Reams
Monitoring results shall be reported at the intervals specified elsewhere in this permit.
a. Monitoring results must be reported on a Discharge Monitoring Report (DMR)(See Part II.
D. 2 of this permit) or forms provided by the Director for reporting results of monitoring of
sludge use or disposal practices.
b. If the permittee monitors any pollutant more frequently than required by the permit, using
test procedures specified in Part II, D. 4. of this permit or in the case of sludge use or
disposal, approved under 40 CFR 503, or as specified in this permit, the results of this
monitoring shall be included in the calculation and reporting of the data submitted in the
DMR.
c. Calculations for all limitations which require averaging of measurements shall utilize an
arithmetic mean unless otherwise specified by the Director in the permit.
6. Tw enty=four Hour Repotting
a. The permittee shall report to the central office or the appropriate regional office any
noncompliance which may endanger health or the environment. Any information shall be
provided orally within 24 hours from the time the permittee became aware of the
circumstances. A written submission shall also be provided within 5 days of the time the
permittee becomes aware of the circumstances. The written submission shall contain a
description of the noncompliance, and its cause; the period of noncompliance, including
exact dates and times, and if the noncompliance has no been corrected, the anticipated time
it is expected to continue; and steps taken or planned to reduce, eliminate, and prevent
reoccurrence of the noncompliance.
b. The following shall be included as information which must be reported within 24 hours
under this paragraph:
(1) Any unanticipated bypass which exceeds any effluent limitation in the permit.
(2) Any upset which exceeds any effluent limitation in the permit.
(3) Violation of a maximum daily discharge limitation for any of the pollutants listed by the
Director in the permit to be reported within 24 hours.
c. The Director may waive the written report on a case-by-case basis for reports under
paragraph b. above of this condition if the oral report has been received within 24 hours.
7. Other Noncompliance
The permittee shall report all instances of noncompliance not reported under Part 11. E. 5 and 6.
of this permit at the time monitoring reports are submitted. The reports shall contain the
information listed in Part II. E. 6. of this permit.

Pan 1I
Page 14 of 14
8. Other lnformadog
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 Noi.if cation
The permittee shall report by telephone to either the central office or the appropriate regional
office of the Division as soon as possible, but in no case more than 24 hours or on the next
working day following the occurrence or first knowledge of the occurrence of any of the
following:
a. Any occurrence at the water pollution control facility which results in the discharge of
significant amounts of wastes which are abnormal in quantity or characteristic, such as the
dumping of the contents of a sludge digester; the known passage of a slug of hazardous
substance through the facility; or any other unusual circumstances.
b. Any process unit failure, due to known or unknown reasons, that render the facility
incapable of adequate wastewater treatment such as mechanical or electrical failures of
pumps, aerators, compressors, etc.
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass
directly to receiving waters without treatment of all or any portion of the influent to such
station-or facility.
Persons reporting such occurrences by telephone shall also file a written report in letter form
within 5 days following first knowledge of the occurrence.
10. ,Availability of Reports
Except for data determined to be confidential under NCGS 143-215.3(a)(2) or Section 308 of
the Federal Act, 33 USC 1318, all reports prepared in accordance with the terms shall be
available for public inspection at the offices of the Division of Environmental ?Management. As
required b\ the Act, effluent data shall not be considered confidential. Knowingly making any
false statement on any such report may result in the imposition of criminal penalties as provided
for in NCGS 143-215.1(b)(2) or in Section 309 of the Federal Act.
11. penalties for Falsification of Reports
The Clean Water Act provides that any person who knowingly makes any false statement,
representation, or certification in any record or other document submitted or required to be
maintained under this permit, including monitoring reports or reports of compliance or
noncompliance shall, upon conviction, be punished by a fine of not more than 510,000 per
violation, or by imprisonment for not more than two years per violation, or by both.

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

Part III Permit No. NC0079898
E. ACUTE TOXICITY PERMIT LIMIT(QRTRLY)
The permittee shall conduct acute toxicity tests on a quarterly basis using protocols defined as
definitive in E.P.A. Document 600/4-85/013 entitled "The Acute Toxicity of Effluents to
Freshwater and Marine Organisms." The monitoring shall be performed as a Daphnia pulex or
Ceriodaphnia 48 hour static test,using effluent collected as a 24 hour composite. The LC50 of this
effluent using the previously stated methodology may at no time in any toxicity test be less than
42%. Effluent samples for self-monitoring purposes must be obtained during representative
effluent discharge below all waste treatment. The first test will be performed after thirty days from
the effective date of this permit during the months of January,April,July and October.
The parameter code for this test if using Daphnia pulex is TAA3D. The parameter code for this test
if using Ceriodaphnia is TAA3B. 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 appropriate parameter code. Additionally, DEM Form AT-1
(original)is to be sent to the following address:
Attention:
Environmental Sciences Branch
North Carolina Division of
Environmental Management
4401 Reedy Creek Road
Raleigh, N.C. 27607
Test data shall be complete and accurate and include all supporting chemical/physical measurements
performed in association with the toxicity tests, as well as all dose/response data. Total residual
chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly
monitoring 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 either these monitoring requirements or tests performed by the North
Carolina Division of Environmental Management indicate potential impacts to the receiving stream,
this permit may be re-opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival 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.

.
PART IV
ANNUAL ADMINISTERING AND COMPLIANCE MONITORING FEE REQUIREMENTS
A. The permittee must pay the annual administering and compliance monitoring fee within 30
(thirty) days after being billed by the Division. Failure to pay the fee in a timely manner in
accordance with 15A NCAC 2H .0105(b)(4) may cause this Division to initiate action to
revoke the permit.
•

State of North Carolina
Department of Environment,
Health and Natural Resources A14,7,Aii7/017. Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary DO C H
A. Preston Howard, Jr., P.E., Director iv.c 1 �, .
ENVIRONMENT, HEALTH,.
/
l & NATURAL RESOURCES
'\1 July 2b, 1995 JUL 3 1 1995
7D4rPit V"z- Keith E. Darnell Environmental Superintendent ENSIGN OF fHYIR3HfiiEtdlA[ MANAGEMENTHoechst Celanese - Rowan Site MOORESVILLE REGIONAL OFFICE
P. O. Box 4
Salisbury, NC 28145
Subject: Acknowledgment of Permit Rescission Request
Hoechst Celanese- Rowan Site
NPDES General Permit No. NCG120041
Rowan County
Dear Mr.Darnell:
This is to acknowledge receipt of your request that NPDES General Permit No.
NCG 120041 be rescinded. Your request indicated that this facility has ceased all landfill
activities, and have established a vegetative cover and that this permit is no longer needed.
By copy of this letter, 1 am requesting confirmation from our Mooresville Regional
Office that this permit is no longer needed. After verification by the regional office that the
permit is no longer needed, NPDES General Permit No. NCG120041 will be rescinded.
If there is a need for any additional information or clarification, please do not hesitate
to contact Robert Farmer at(919) 733-5083, ext. 531.
Sincerely,
4Li oe f 4t
Robert L. Sledge, Supervisor
Compliance/Enforcement Group
cc: Water Quality Regional Supervisor- w/attachments
Permits &Engineering Unit - Dave Goodrich- w/attachments
Compliance/Rescission Files - w/attachments
Central Files- w/attachments
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
L

Hoechst Celanese
„�1� Technical Fibers Group
4{'� Hoechst Celanese Corporation
/ Highway 70 West, Po Box 4
(�vieclif)
Salisbury, NC 28145-0004
1704-636-6000
KED_017.L95
FEDERAL EXPRESS =
c:
Q Lr-) t
Colleen Sullins - DEM -42
512 North Salisbury Street za;q cr.
Raleigh, North Carolina 27626-0535 June 30. 19
Lu
o
Subject: General Permit No. NCG120000
Needmore Road Landfill - COC NCG120041
Hoechst Celanese Corporation - Rowan County
Dear Ms. Sullins:
By this letter, Hoechst Celanese Corporation is requesting rescission of Certificate of
Coverage NCG120041 issued under General Permit NCG120000. The Needmore Road
Landfill facility is closed with no exposed waste, has an established vegetative cover, and
is not expected to produce stormwater runoff that would adversely impact surrounding
surface waters.
This facility was inspected by Rick Doby, Sr. or the Mooresville Regional Office on August
18, 1994 and the final compacted cover was confirmed as meeting state closure
requirements. A copy of Mr. Doby's letter is attached.
The Needmore Road Landfill facility is also covered under General Permit No. NCG010000
(COC NCG010505) for land disturbance activities related to closure and final cover.
Hoechst Celanese Corporation would like to retain this Certificate of Coverage to
accommodate land disturbance activities likely to occur during installation of a proposed
synthetic cap. These land disturbance activities will occur on top of the existing cover and
will not result in any waste being exposed. An approved Sedimentation and Erosion
Control Plan would be obtained from the Rowan County Environmental Services
Department prior to the start of any construction activity.
1 discussed both the recession of COC NCG120041 and retention of COC NCG010505
with Mike Parker of the Mooresville Regional Office earlier this year and it is based on his
guidance that this letter is submitted.
Hoechst

If you have any questions or require additional information, please contact me.
Sincerely,
Hoechst Celanese Corporation
Keith E. Darnell
Environmental Superintendent
cc: Mike Freeze
George Glover
Jerry Replogle
Ron Caldwell
Mike Parker - MRO
QHoechst

State of North Carolina
Department of Environment,
Health and Natural Resources AggwiA
Mooresville Regional Office
James B. Hunt, Jr„ Governor [ e u F
Jonathan B. Howes, Secretary r �i
Vivian H. Burke, Regional Manager
DIVISION OF SOLID WASTE MANAGEMENT
August 18 , 1994
MEMORANDUM TO: Julian Foscue
FROM: Rick Doby, Sr. Q33) k"(
Waste Management Specialist
SUBJECT: Hoechst/Celanese Fibers Industrial Landfill
Permit No. 80-02
Rowan County, N. C.
On Tuesday, August 9 , 1994 , I conducted a final inspection for
closure and stability of the Hoechst Celanese Landfill on SR 1984
in Rowan County. The inspection was accompanied by Jerry F.
Replogle, P. E. , Project Engineer for Rust Engineering Company, and
Mike Freeze, S.R. Utilities Engineer with Hoechst Celanese,
Salisbury, North Carolina Plant.
A total of 31 pre-bored inspection holes were observed at a
frequency of one per acre (see attachment) . Each hole was at least
24 inches deep and no waste was observed in any of the holes;
therefore, it appears that the site has received at least 24 inches
of final compacted cover. The entire site also appears to be
stabilized with native vegetation. A final approval and inspection
for sedimentation and erosion control was recently made by the
Rowan County Environmental Services Department.
If you have any questions, please feel free to contact me.
cc: Keith Darnell - Hoechst Celanese Corp.
CRD/kr
919 North Main Street,Mooresville,North Carolina 28115 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50%recycled/ 10%post-consumer paper

IllrFIF'
NPDES FACILITY AND PERMIT DATA 07/25/95 13 : 16 : 31
UPDATE OPTION TRXID 5NU KEY NCG120041
PERSONAL DATA FACILITY APPLYING FOR PERMIT REGION
FACILITY NAME> HOECHST CELANESE-ROWAN SITE*** COUNTY> ROWAN 03
ADDRESS : MAILING (REQUIRED) LOCATION (REQUIRED)
STREET: PO BOX 4 HWY 70 WEST STREET : RT 1 NEEDMORE ROAD
CITY: SALISBURY ST NC ZIP 28144 CITY: WOODLEAF ST NC ZIP 27054
TELEPHONE 704 636 6000 DATE FEE PAID: 09/25/92 AMOUNT : 400 . 00
STATE CONTACT> ULMER PERSON IN CHARGE STEVEN M SIMPSON
1=PROPOSED, 2=EXIST, 3=CLOSED 1 1=MAJOR, 2=MINOR 2 1=MUN, 2=NON-MUN 2
LAT: LONG: N=NEW, M=MODIFICATION, R=REISSUE> N
DATE APP RCVD 09/25/92 WASTELOAD REQS / /
;PATE STAFF REP REQS / / WASTELOAD RCVD / /
DATE STAFF REP RCVD / / SCH TO ISSUE / /
RATE TO P NOTICE / / DATE DRAFT PREPARED 06/30/93
PATE OT AG COM REQS / / DATE DENIED / /
DATE OT AG COM RCVD / / DATE RETURNED / /
DATE TO EPA / / DATE ISSUED 07/09/93 ASSIGN/CHANGE PERMIT
PATE FROM EPA / / EXPIRATION DATE 08/31/97
SEE CODE ( 0 ) 1=( >10MGD) , 2=( >1MGD) , 3=( >0 . 1MGD) , 4=( <O . 1MGD) , 5=SF, 6=(GP25 , 64, 79 ) ,
7=(GP49, 73 )8=(GP76)9=(GP13 , 34, 30, 52 )0=(NOFEE) DIS/C 73 CONBILL ( )
COMMENTS : REQUESTED RESCISSION 6/30/95-RF
MESSAGE : LATITUDE/LONTITUDE MUST BE ALL NUMERIC

•
SOG PRIORITY PROJECT: No
To: Permits and Engineering Unit
Water Quality Section
Attention: Greg Nizich
Date : September 6 , 1994
AUTHORIZATION TO CONSTRUCT
NPDES PERMIT
REPORT AND RECOMMENDATIONS
County : Rowan
MRO No . : 94-187
Permit No . N00079998
PART I - GENERAL INFORMATION
1 . Facility and Address : Hoechst Celanese Corporation
Needmore Road Landfill
Post Office 4
Salisbury, N . C . 28144
2 . Date of On-Site Investigation ( if conducted) : November 30 ,
1994
3 . Report Prepared By : Michael L . Parker , Environ . Engr . II
4 . Persons Contacted and Telephone Number : Keith Darnell ,
(704 ) 636-6000 , ext . 4267 .
5 . Verified Discharge Point (s) , List for All Discharge Points :
Latitude : 35 ' 49 ' 06" Longitude : 80 ' 34 ' 35"
Attach a USGS map extract and indicate treatment facility
site and discharge point on map . Ensure discharge point(s)
correspond to NPDES permitted discharge points .
USGS Quad No . : D 16 SE
6 . Site size and expansion area consistent with application?
Yes .
7 . Topography (relationship to flood plain included) : Rolling,
3-8% slopes . The WWTP site is not located in a flood plain .
8 . Location of Nearest Dwelling: None within 500 feet of the
WWTP site.

r
Page Two
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS .
1 . Existing Treatment Facility
a . Current permitted capacity : 0 . 288 MCD .
b . Date(s) and construction activities allowed by previous
ATCs issued in the previous two ( 2 ) years : Last ATC
was i sued on January 31 , 1992 .
r_ . Actual treatment capacity of the current facility
(design volume) : 0 . 288 MCD .
d . Description of existing or substantially constructed
WWT facilities : The existing facilities consist of
equalization followed by a magnetic flow meter , static
mixers with chemical addition , a lamella type clarifier
with polymer addition, a sand filter , a 12 , 000 gallon
sludge holding tank , a plate and frame filter press , a
3000 gallon storage tank , an organic destruct system
consisting of oxidation and chemical addition, a 1500
gallon effluent tank with chemical addition , and a
parshall flume .
2 . Type of Proposed Treatment Facility : The applicant proposes
to construct an Enox feed system into the existing GW
remediation system.
3 . Residuals Handling and Utilization/Disposal Scheme :
Residuals generation is not expected .
4 . Treatment Plant Classification ( attached completed rating
sheet ) : Unknown . The main treatment process utilized at
this facility is not listed on the current rating form.
SIC Code(s ) : 9999
Wastewater Code(s) : 66
Main Treatment Unit Code : 51102
6 . Important SOC/JOC or Compliance Schedule Dates : N/A

r T
Page Three
PART III - EVALUATION AND RECOMMENDATIONS
Hoechst Celanese Corporation proposes to add an Enox feed
system to their existing GW remediation treatment system to
enhance the oxidation of organics and improve effluent toxicity
characteristics .
Pending a review and approval of this request by the SERG,
it is recommended that an ATC be issued .
A'.1141CA-6.1‹. f-4
Signature of Report Preparer Date
4/16
Water Quality Re i nal Supervisor Date

e of North Carolina
•d
apartment of Environment,
Health and Natural Resources 4 • •
Division of Environmental Management S
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary ,, + p E H N R
A. Preston Howard, Jr., P.E., Director
August 3, 1993 ENVN.C. DEPT. OE
gIRONMENT, HEr\LTH.
pp & NATURAL RESOURCES
V
u i 6
rn Mr. Keith E. Daell AAUGQ RESOURCES
Rit
Technical Fibers Group �O IIRVU/
Hoechst Celanese Corporation flIY1S40h OF ENVIRONMENTAL HA11aGEt4Ehi
PO Box 4 MOORESVILLE REG11;hAL OFFICE
Salisbury NC 28145-0004
Subject: Authorization to Construct Request
Permit AC0079898
Needmore Road Landfill
Rowan County
Dear Mr. Darnell
The Division of Environmental Management, Permits and Engineering Unit, hereby acknowledges
receipt of your request for an Authorization to Construct wastewater treatment facilities in accordance with
NPDES Permit Number NC0079898. This application has been assigned the number shown above.
Please refer to the application number when making any inquiries about this application.
Your request has been assigned to Greg Nizich for a detailed engineering review. Should any
additional information be required you will be contacted in the near future.
Please be aware that the Division's regional office, copied below, must provide recommendations
from the Regional Supervisor prior to final action by the Division.
If you have any questions, please contact the review engineer at [phone].
Sincerely,
ti-LColeeW H. Sullins, P.E.
Supervisor, Permits and Engineering Unit
cc: Mooresville Regional Office
File
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

CJ
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0
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PROPOSED ENOX 910 SYSTEM FOR NEEDMORE ROAD
LOW LEVEL CONCENTRATION TREATMENT PLANT z A Oni
THE PROPOSED ENOX 910 SYSTEM CONSISTS OF A TRUCK UNLOAD7*NG
STATION, STORAGE TANK, RECIRCULATING PUMP AND METERING PUMP .
REFERENCE DRAWINGS : SFY-01-5659001 REV-2 , SFY-09-5659001ul
--- �x-
REV 2 & SFY-10-5659005 REV-1 . �PV
TANK TRUCKS WILL UNLOAD AT THE EXISTING STATION. A NEW -,,. ;n
PIPELINE WILL BE INSTALLED TO TRANSFER THE ENOX FROM THE _
TRUCK TO A NEW 6000 GALLON STORAGE TANK. TANK TRUCKS WILL
DELIVER UP TO 5000 GALLON OF ENOX PER SHIPMENT. THE
PIPELINE WILL BE PURGED WITH COMPRESSED AIR TO AVOID ANY
SPILL IN THE CONTAINED TRUCK UNLOADING STATION. THE
UNLOADING PIPELINE WILL BE A 2 INCH CPVC PIPE .
THE 6000 GALLON FIBERGLASS STORAGE TANK WILL BE HEAT TRACED
AND INSULATED TO MAINTAIN THE TEMPERATURE OF ENOX ABOVE 85
DEGREES F . THIS TANK WILL BE LOCATED ON AN ELEVATED
CONCRETE PAD INSIDE THE EQUALIZATION TANK CONTAINMENT AREA.
CONTROLS ON THE TANK WILL CONSIST OF A LEVEL TRANSMITTER FOR
MONITORING BY THE PLC AND A REDUNDANT HIGH LEVEL ALARM WHICH
WILL ALARM THE PLC MONITOR AND A HORN AND FLASHING LIGHT AT
THE TRUCK UNLOADING STATION.
THE CPVC PIPELINE FROM THE STORAGE TANK WILL BE HEAT TRACED
AND INSULATED. A RECIRCULATING PUMP WILL BE LOCATED INSIDE
THE TREATMENT BUILDING AND WILL CIRCULATE ENOX THAT IS NOT
PICKED UP BY THE METERING PUMP BACK TO THE STORAGE TANK.
CIRCULATION OF ENOX BACK TO THE TANK WILL PREVENT ANY
CRYSTALLIZATION OF MATERIAL IN THE PIPELINE . THIS
RECIRCULATION PUMP AS WELL AS THE METERING PUMP WILL BE
INSTALLED WHERE THE EXISTING AIR COMPRESSOR IS LOCATED. THE
AIR COMPRESSOR IS TO BE RELOCATED OUTSIDE THE BUILDING.
A METERING PUMP WILL FEED ENOX THROUGH A 1/4 INCH STAINLESS
STEEL TUBE TO THE INFLUENT PIPELINE FROM THE EQUALIZATION
TANK. THE ENOX WILL BE INJECTED INTO THE PIPELINE AFTER THE
PH PROBES AND PRIOR TO THE HYDROGEN PEROXIDE INJECTION POINT
AND STATIC MIXER. THE METERING PUMP FLOW RATE WILL BE
CONTROLLED BY THE PLC AND WILL FEED BETWEEN 50 AND 350
ml/man DEPENDING ON THE INFLUENT FLOW AND NUMBER OF UV
REACTORS IN OPERATION.
A NEW HYDROGEN PEROXIDE METERING PUMP WILL BE INSTALLED IN
THE EXISTING SYSTEM. THE PRESENT METERING PUMPS ARE ABOVE
THE RANGE OF THAT REQUIRED AFTER INJECTION OF ENOX. THIS
WILL INSURE THAT THE PEROXIDE IN THE EFFLUENT IS LESS THAN 5
PPM.
THIS ENOX SYSTEM CAN BE INSTALLED IN APPROXIMATELY 3 MONTHS
AFTER APPROVAL TO PROCEED.

ti
i
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ee„...--9
SOC PRIORITY PROJECT : Yes No X
If Yes , SOC No .
To: Permits and Engineering Unit
Water Quality Section
Attention: Susan Robson
Date : February 21 , 1994
NPDES STAFF REPORT AND RECOMMENDATION
County : Rowan
Permit No . NC0079898
PART I - GENERAL INFORMATION
1 . Facility and Address : Needmore Road Landfill Site
Groundwater Remediation Facility
Hoechst Celanese Corporation
Post Office Box 4
Salisbury , North Carolina 28145
2 . Date of Investigation : 02-16-94
3 . Report Prepared By : G . T . Chen
4 . Persons Contracted and Telephone Number : Mr . Mike Freeze ;
( 704 ) 636-6000
5 . Directions to Site : From the junction of Highway 801 and SR
1984 (Needmore Road) in northwestern Rowan County , travel west
on SR 1984 approximately 2 . 30 miles to the junction with a
gravel road on the right where a sign is marked "Hoechst
Celanese 2110 Needmore Road , 1/2 mile" . The remediation
facility is located approximately 0 . 5 mile north of this
junction at the end of the gravel road .
6 . Discharge Point (s ) . List for all discharge points :
Latitude : 35 ° 49 ' 06" Longitude : 80 ° 34 ' 35"
Attach a U . S . G . S . map extract and indicate treatment facility
site and discharge point on map .
USGS Quad No . : D 16 SE USGS Name: Cooleemee , NC
7 . Site size and expansion are consistent with application?
Yes No X If No , explain :
8 . Topography ( relationship to flood plain included) : Rolling ,
with slopes of 3-8% toward South Yadkin River . The facility

•
•
is not in a flood plain .
9 . Location of nearest dwelling : No dwelling within 500 feet of
the facility .
10 . Receiving stream or affected surface waters : South Yadkin
River
a . Classification : WS-IV
b . River Basin and Subbasin No . : Yadkin and 03-07-06
c . Describe receiving stream features and pertinent
downstream uses : The receiving stream, a segment of the
South Yadkin River , is about 80 to 100 feet wide with a
significant amount of flow . The water appeared to be
muddy on the day of the inspection . The Town of
Cooleemee ' s water intake is approximately three ( 3 ) miles
downstream.
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1 . a . Volume of wastewater to be permitted : 0 . 288 MGD
(Ultimate Design Capacity)
b . What is the current permitted capacity of the wastewater
treatment facility? No flow limit given in the existing
permit .
c . Actual treatment capacity of the current facility
(current design capacity )? 0 . 288 MCD .
d . Date(s ) and construction activities allowed by previous
Authorizations to Construct issued in the previous two
years : None .
e . Please provide a description of existing or substantially
constructed wastewater treatment facilities : The
existing groundwater remediation facility consists of a
275 , 000 gallon equalization tank , a six-train UV/Hydrogen
Peroxide Oxidation of Organics system (manufactured by
Solarchem) , chemical feed systems for pH adjustment ( 30%-
Sulfuric Acid/30%-Sodium Hydroxide) , Hydrogen Peroxide
( 50%) addition system, effluent holding tank , Parshall
Flume unit for effluent flow measurement , 10 extraction
wells , and a leachate collection system.
f . Please provide a description of proposed wastewater
treatment facilities : N/A .
NPDES Permit Staff Report
Version 10/92
Page 2

g . Possible toxic impacts to surface waters : None .
h . Pretreatment Program (POTWs only) : N/A.
in development : approved :
should be required : not needed :
2 . Residuals handling and utilization/disposal scheme : No solids
disposal scheme is available at this time . The applicant
needs to submit a solid waste management plant to DEM for
approval , if solids generation is expected .
a . If residuals are being land applied , please specify DEM
Permit No . :
Residuals Contractor :
Telephone No . :
b . Residuals stabilization : PSRP :
RFRP :
Other :
c . Landfill :
d . Other disposal /utilization scheme ( specify ) :
3 . Treatment plant classification (attach completed rating
sheet) : N/A* . *The main treatment unit of this facility is
a six-train UV/Hydrogen Peroxide Oxidation unit , which is not
listed in the current rating sheet .
4 . SIC Code(s ) : 9999
Wastewater Code(s) of actual wastewater , not particular
facilities , i . e . , non-contact cooling water discharge from a
metal plating company would be 14 , not 56 ,
Primary : 66 Secondary :
Main Treatment Unit Code : 00000
PART III - OTHER PERTINENT INFORMATION
1 . Is this facility being constructed with Construction Grant
Funds or are any public monies involved (municipals only) ?
N/A.
2 . Special monitoring or limitations ( including toxicity)
requests : None .
NPDES Permit Staff Report
Version 10/92
Page 3

A .
3 . Important SOC , JOC or Compliance Schedule dates : ( please
indicate ) N/A.
Date
Submission of Plans and Specifications
Begin Construction
Complete Construction
4 . Alternative Analysis Evaluation: Has the facility evaluated
all of the non-discharge options available . Please provide
regional perspective for each option evaluated . The treated
groundwater is discharged to Second Creek , which has a stream-
flow of 632 CFS , therefore , an alternative analysis evaluation
may not be necessary .
Spray Irrigation :
Connection to Regional Sewer System:
Subsurface :
Other Disposal Options :
5 . Air Quality and/or Groundwater concerns or hazardous waste
utilized at this facility that may impact water quality , air
quality or groundwater? No hazardous waste is used at this
facility . Organic contaminants in the recovered groundwater
are oxidized by Hydrogen Peroxide ( 50% ) and Ultra Violet light
to carbon dioxide and water . No adverse impact on the
environment is expected .
6 . Other Special Items : None .
PART IV - EVALUATION AND RECOMMENDATIONS
Hoechst Celanese Corporation requests its NPDES Discharge
Permit (No . NC0079898 ) be renewed with modifications to include
three ( 3 ) additional extraction wells and an increase in flow from
35 GPM (0 . 050 MGD) to about 64 GPM (0 . 092 MGD) . It should be
pointed out that there is no flow limitation in the existing
permit . In addition , the Company requests that only monitoring
requirements (but not limitations) be set forth for Phenols ,
Barium, and 1 , 1-Dichlorethene in the renewed NPDES Permit . The
Company also requests that Acute Toxicity Testing requirement be
changed to a Chronic Toxicity Testing requirement . The Company
advises that a six-train UV/Hydrogen Peroxide Oxidation unit has
been installed in lieu of a Pero-Pure Organic Destruction Process
NPDFS Permit Staff Report
Version 10/92
Page 4

/11111r-
unit as the main treatment facility of the groundwater remediation
system.
In view of the projected increase of wastef l ow with new waste
sources , and other request for modifications , a new wasteload
allocation may be necessary .
It is recommended that the NPDES Discharge Permit be renewed
as requested by the applicant .
x . e(4 4
Signature of Report Preparer
Water Quality Reg nal Supervisor
2/2 //5�
Date
NPDES Permit Staff Report
Versi on 10/92
Page 5

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itetti z — - A9e
State`of North Carolina j
Department of Environment, (9f
Health and Natural Resources 46117A
Division of Environmental Management
JamesnahaB. Hunt, Jrw„ , rnor
EJ C I F{
Jonathan B. Howes, SecretaryC
A. Preston Howard, Jr., P,E.6.pirec or
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' 144
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101
tot S bru aty 3, 1994fl
Keith E. Darnell R Subject : NPDES Permit Application
Hoechst Celanese Corporation NPDES Permit No.NC0079898
P. 0. Box 4
Salisbury, NC 28145 Needmore Road Landfill
Dear Mr. Darnell Rowan County
This is to acknowledge receipt of the following documents on January 31, 1994:
q Application Form
Engineering Proposal (for proposed control facilities) ,
Request for permit renewal,
Application Processing Fee of $300.00,
, Engineering Economics Alternatives Analysis,
Local Government Signoff,
Source Reduction and Recycling,
, Interbasin Transfer,
Other ,
The items checked below are needed before review can begin :
Application Form
- Engineering proposal (see attachment) ,
- Application Processing Fee of
- Delegation of Authority (see attached)
- Biocide Sheet (see attached)
- Engineering Economics Alternatives Analysis,
, Local Government Signoff,
Source Reduction and Recycling,
Interbasin Transfer,
Other
P.O. Box 29535,Raleigh,North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50%recycled/ T 0%post-consumer paper

If the application is not made complete within thirty (30) days, it will be
returned to you and may be resubmitted when complete .
This application has been assigned to Susan Robson
( 919/733-5083) of our Permits Unit for review. You will be advised of any
comments recommendations, questions or other information necessary for the
review of the application .
I am, by copy of this letter, requesting that our Regional Office
Supervisor prepare a staff report and recommendations regarding this
discharge . If you have any questions regarding this applications,
please contact the review person listed above .
Sincerely,
jigfroan-,
Coleen H. Sullins, P . E .
CC: Mooresville Regional Office

HOECHST CELANESE CORPORATION
NEEDMORE ROAD LANDFILL SITE
TREATMENT FACILITY
ROWAN COUNTY, NORTH CAROLINA
RENEWAL APPLICATION FOR NPDES PERMIT NO. NC0079898
FOR
TREATMENT FACILITY DISCHARGE
JANUARY 1994
i0
-ems
ss
RUST ENVIRONMENT & INFRASTRUCTURE
PROJECT NO. 87805.000
PREPARED BY :
RUST ENVIRONMENT & INFRASTRUCTURE
GREENVILLE, SOUTH CAROLINA

TABLE OF CONTENTS
1.0 PROJECT DESCRIPTION
2.0 WASTESTREAM CHARACTERIZATION
3.0 NPDES PERMIT APPLICATION FORM
4.0 NPDES PERMIT APPLICATION FORM COMMENTS

LIST OF FIGURES
FIGURE 1-1 SITE LOCATION MAP
FIGURE 1-2 SITE MAP
•

•
LIST OF TABLES
TABLE 2-1 WASTESTREAM CHARACTERIZATIONS
TABLE 2-2 DISCHARGE MONITORING RESULTS FOR EXISTING
TREATMENT FACILITY
I

1.0 PROJECT DESCRIPTION
This National Pollutant Discharge Elimination System (NPDES) Permit application is being
submitted by the Hoechst Celanese Corporation (HCC) located at Salisbury, North Carolina
for renewal of existing NPDES Permit No. NC0079898 for the discharge from the Needmore
Road Landfill Site treatment facility located in Rowan County. A USGS topographical map
showing the location of the site and discharge point is presented in Figure 1-1. Existing
NPDES Permit NC0079898 for the discharge from the treatment facility to the South
Yadkin River in the Yadkin-Pee Dee River Basin became effective on November 1, 1991
and is scheduled to expire on July 31, 1994. The North Carolina Department of
Environment, Health, and Natural Resources (NC DEHNR) requires an application for a
NPDES Permit renewal to be submitted at least 180 days in advance of the expiration date
of the NPDES Permit. Therefore, this application for renewal of the permit for the
Needmore Road Landfill Site treatment facility discharge is being submitted on or before
January 31, 1994 to meet the 180 day requirement.
HCC will also begin pumping groundwater from additional extraction wells as a result of
ongoing remediation activities at the Needmore Road Landfill Site. At this time,
groundwater from three additional extraction wells (EW) (EW 8, 9, and 10) will be pumped
to the facility for treatment prior to being discharged to the South Yadkin River in
accordance with effluent limitations of NPDES Permit No. NC0079898. Therefore, this
application is also being submitted to inform the NC DEHNR of the new groundwater
sources that will be included in the discharge and to reflect changes, if any, in the
characteristics of the discharge as a result of the pumping of the groundwater from these
three additional wells. It should be noted, however, that the average daily flow requested
in this NPDES Permit renewal application will remain at 200 GPM (0.288 MGD) which is
the flow on which the current NPDES Permit is based.
The HCC manufacturing facility located at Salisbury, North Carolina owned and operated
a landfill off of Needmore Road in northern Rowan County. This landfill is no longer an
1

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NPOES Permit NC0079898 Application
mils ENVIRONMENT& Hoechst Celanese Corporation
INFRASTRUCTURE Needmore Road Landfill Site
Rowan County, NC

active landfill and has been out of service since April of 1990. As a result of landfilling
activities at the site, some contamination of groundwater occurred. HCC has conducted and
continues to conduct remediation activities at the site to address this groundwater
contamination.
A treatment facility with a capacity of 200 GPM was constructed at the site to treat
groundwater from various extraction wells and a small quantity of landfill leachate. This
facility was constructed in 1992 and in accordance with NC DEHNR Authorization To
Construct ACA079898 dated January 31, 1992. The facility includes the following treatment
processes.
• Equalization for both hydraulic and pollutant loading
• UV/Hydrogen Peroxide oxidation of organics (system manufactured by
Solarchem)
The facility was placed into operation in November 1992 and has been treating groundwater
from a total of seven (7) extraction wells and a small quantity of landfill leachate or
seepage. The seven wells are identified as extraction wells 1, 2, 3, 4, 5, 6, and 7. A map
showing the location of the treatment facility on the site along with the discharge location
is presented in Figure 1-2.
HCC also submitted an application for a NPDES Permit for the discharge from this
treatment facility. The NC DEHNR issued NPDES Permit NC0079898 for this discharge
which became effective on November 1, 1991 and which expires on July 31, 1994.
Due to the design of the Solarchem system, as described in the aforementioned
authorization to construct and a subsequent revision issued on October 19, 1992, there is no
sludge generated from this facility. A sludge management plan is therefore not applicable
and has not been included in this application.
3

3 N
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/ y
\Q (
NPDES Outfall
001
NEEDMORE ROAD LANDFILL SITE
1
1
1
` 1
•
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0 600 1200 1800
l , 1 1
FIGURE 1-2
SITE MAP
ENVIRONMENT & NPDES PERMIT NC0079898 APPLICATION
NEEDIyQR RUcr HOECHST CELANESE CORPORATION
E ROAD INFRASTRUCTURE RU E RNEEDMORE OWAN COUNTYROAD LANDFILL SITE
JANUARY 1994

2.0 WASTESTREAM CHARACTERIZATION
In Table 2-1, characterization data are provided for the existing influent to the treatment
facility. The influent consists of groundwater from Extraction Wells 1, 2, 3, 4, 5, 6, and 7
and landfill leachate and is identified in Table 2-1 as the Existing Needmore Road
Treatment Facility Influent. This is the only wastestream currently being pumped to the
existing treatment facility. This characterization is based on a sample of this combined
wastestream collected on December 21, 1993 from the existing equalization tank prior to
any treatment. For those months the facility was in operation in 1993, the average discharge
flow rate to and from the facility based on discharge monitoring data provided in Table 2-2
was approximately 35 GPM or 0.050 MGD.
Also provided in Table 2-1 are characterization data for groundwater collected from the new
Extraction Wells 8, 9, and 10. These characterization data include projected flow rates
based on actual pumping tests. At present, these three wells are the only new sources of
groundwater that HCC plans to pump to the existing treatment facility for treatment prior
to a discharge at Outfa11001 of NPDES Permit NC0079898. The characterization of these
three wells is based on samples collected on December 7 and 8, 1993. It should be noted
the groundwater characterization data summarized in Table 2-1 are based on groundwater
conditions at the time this NPDES Permit application was prepared, and it is possible that
the contaminant concentrations may change over the life cycle of the on-site remediation
activity.
Based on the projected flows and contaminant concentrations from the additional three
wells, flow rates and contaminant concentrations of the existing influent to the treatment
facility, the projected characteristics of the new influent to the treatment facility were
calculated and are presented in Table 2-1.
A comparison of the existing influent to the treatment facility and the projected new influent
5

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TABLE 2-1
NOECHST CELANESE CORPORATION
NEEDMORE ROAD tANDF1LL SITE TREATMENT FACILITY
ROWAN COUNTY.NORTH CANOL1NA
NPDES PERMIT NC0070606
WASTESTREAM CHARACTERIZATION
RUST Eli PROJECT NO.Mot ow
6Imam&CeramI WSIIMALrSo E06STINO NEEDMORE ROAD NEW 7W50 D`NEEOMDR!ROAD PROJECTED NEEDUOAE ROAD WATER QUALITY C1111Ym1Y1 WATER OUALETY CRITERIA
Pr amlor UMI EWE EW.5 EVA10 TREATMENT FACILITY I Nh.UENT TREATMENT FACI.T(Y INFLUENT TREATMENT FACILITY EFRUEMT 1MTMEMi CONDEN RATON EASED EFFLUENT LN4IrATIDN
Cobol hqA 0,020 0.020 <-020 0.031 0.022 40.150 ND CRITERA NO CRITERIA
C011p9r In9A 0.064 <0.020 0.051 0.072 0.057 <0.100 9007 1.673(4)
Aron me 33.00 9.20 35.40 12.00 20.14 425 1.00 230(4)
11.4 H51 0.0110 40.0050 0.0204 0.0337 0.0257 40.05 0,0250 5.575(1)
MRIP•WA• `. m0A 34.70 r _ 135.00 17.70 30.60 47.61 a0 NC NC
U•n9r1•*F m04 1.02 0.91 1.61 4.00 A.53 <5 0.20 47.150(3)
MATerY m0A 40.00020 0.00039 000032 40.00320 0.00014 <0-0002 0.000012 0.00297(A)
(1044 m0A 0-247 <0.020 0.031 0.060 0.055 0/100 0.025 5075(3)
PoYrhon m0A <2,0 <2-0 <2,0 2.35 1.20 <5 NC NC
54440500 me 40.0000 <0.0050 <0.0050 <0.010 <0.040 <0.010 NC NC
*kw my1 <0.010 <0,010 <0.010 <0.010 <0.010 <0.010 NC NC
Sodium PEA 12.20 1960 021 30.50 27,31 c000 NC NC
Th•S1•n NW <0.10 <0,0050 <0.0050 <0.020 <6.02 <0.02 NC NC
V•nNh•• me <0.020 <0,020 1 <0,020 <0.020 40.02 4002 NC NC
7300 PIS 0.060 00-020 0_120 0.637 _-_ 0.220 40.350 0.050 1195 Id)
WADI•BELOW METHOD DETECTION LIMIT FOR HOIITTPICAL VOLATILES AND SEMIVOLATILES,TENTATIVELY IDENTIFIED AND DETECTED AT SMDL
NA•NOT ANALYZED
ND•NOT DETECTED
NC•NOT CALCULATED
(1)•CALCULATED USIND 3002 PLOW WITH DILUTION FACTOR•516(AESTHETIC!)
(2)•CALCULATED USING MEAN ANNUAL FLOW WITI1 DILUTION FACTOR•1410(TOXIC SUBSTANCES•CARCINOGEN)
(3)•CALCULATED USIA 7010 FLOW WITH DILUTION FACTOR•23S(TOXIC SUBSTANCES-NONCARCIN00EN7
(II•CALCULATED USING 7010 FLOW WITH DILUTION FACTOR•236(PROtECTION OF AQUATIC LIFE)
(I)•ANTICIPATED CRITERIA.NOT PRESENT NC DONNA WATER QUALITY CRITERIA
(51•DRINKING WATER STANDARD CRITERIA.NOT PRESENT NC DONNA WATER QUALITY CRITERIA
NEEDMR8,WK4 125194

TABLE 2-2
HOECHST CELANESE COPORATION
NEEDMORE ROAD LANDFILL SITE TREATMENT FACILITY
ROWAN COUNTY, NORTH CAROLINA
NPOES PERMIT NC0079898
DISCHARGE MONITORING RESULTS 1993
RUST PROJECT NO.87805.000
MONTH
PARAMETER ;. UNITS JULY AUGUST SEPTEMBER OCTOBER NOVEMBER
Flow
Min MGD 0.024 0.025 0.023 0.011 0.002
Ave MGD 0.066 0.055 0.051 0.041 0.038
Max MOD 0.092 0.089 0.073 0.081 0.086
Conventional
TOC mg/I 17 NA NA 7.3 NA
Phenols mg/ <0.05 <0.05 <0.05 <0.05 <0.028
Oil&Grease mg/I <5 <5 <5 <5 <5
pH units 7.6 7,6-7.8 7.8 7,3-7.4 7.0-7.9
Metals
Antimony mg/l <0.50 NA NA <0.03 NA
Barium mg/I <0.32 <0.293 <0.315 0.13 0.125
Cobalt W mg/I <0.05 NA NA 0.037 NA
Lead mg/I <0.20 NA NA <0.05 NA
Magnesium mg/I 41 NA NA 37 NA
Zinc mg/I 0.059 NA NA 0.041 NA
ValatIle&Semlvolatlle
Acetone ugh 240 NA NA <100 NA
Benzene ug/I <5 NA NA <5 NA
Butylbenzylphthatate ugh <10 NA NA <10 NA
Chlorobenzene ug/I <5 NA NA <5 NA
DMR.WK4 1/25/94

TABLE 2-2
HOECHST CELANESE COPORATION
NEEDMORE ROAD LANDFILL SITE TREATMENT FACILITY
ROWAN COUNTY, NORTH CAROLINA
NPDES PERMIT NC0079898
DISCHARGE MONITORING RESULTS 1993
RUST PROJECT NO. 87805.000
-- MONTH 1
PARAMETER UNITS JULY AUGUST SEPTEMBER OCTOBER NOVEMBER 1
1,2 Dichlorobenzene ugh <10 NA NA <10 NA
1,1 Dichloroethane ugh <5 NA NA <5 NA
1,1 Dichloroethene ugh <5 NA NA <5 NA
1,2 Dichloroethene ugh <5 NA NA <5 NA
1,4 Dioxane _ ugh 230 NA NA <10 NA
Ethylbenzene ugh <5 NA NA <5 NA
Methylene Chloride ugh <5 NA NA <5 NA
4-Methyl Phenol ugh <10 NA NA <10 NA
1,1,1,2-Telrachioroethane ugh <5 NA NA <5 NA
1,1,1 Trichloroethane ug/1 <5 NA NA <5 NA
Trichtoroethene ugh <5 NA NA <5 NA
Trichlorolluoromethane ugh <5 NA NA <5 NA
Toluene ugh <5 NA NA <5 NA
Vinyl Chloride ugh <10 NA NA <10 NA
NA-NOT ANALYZED. ONLY QUARTERLY REPORTING REQUIRED.
DMR.WK4 1/25/94

to the treatment facility reveals no significant differences in the characteristics of the two
wastestreams.
The projected characteristics of the effluent from the treatment facility which will be
discharged at Outfall 001 of NPDES Permit NC0079898 are also provided in Table 2-1 .
These characteristics were estimated based on the projected characteristics of the new
influent to the treatment facility and anticipated removal efficiencies across the existing
treatment facility. Removal efficiencies were estimated from information provided by the
treatment equipment vendor and were also based on actual discharge monitoring results
from the existing treatment facility provided in Table 2-2.
Even though HCC has provided in this application the projected characteristics of the
effluent from the treatment facility which will be discharged at Outfall 001, HCC is not
proposing that these projected charactersitics of the discharge be specified as actual NPDES
effluent limitations. As noted in comments in Section 4.0 of this application, any NPDES
effluent limitations, if necessary, should be based on water quality criteria.
Data provided for the various wastestreams included conventional pollutants, volatile
organics,semi-volatile organics,metals,and other miscellaneous pollutants typically required
by EPA NPDES Permit Application Form 2C. Analytical data for the following
contaminants was not provided because it was believed that they are not present in the
groundwater:
Bromide Total Residual Chlorine
Color Fecal Coliform
Fluoride Radioactivity
Surfactants Boron
Molybdenum Tin
Titanium Dioxin
Pesticides/PCBs
12

The data presented in Table 2-1 include data for some (ten largest peaks not identified as
targeted compounds) tentatively identified volatile and semi-volatile organics which were
detected but at below method detection limit (BMDL). These tentatively identified
compounds are not typically considered to be priority pollutant organics.
With the additional Extraction Wells 8, 9, and 10, discharge flow rates will increase from
the existing average of about 35 GPM (0.050 MGD) to about 64 GPM (0.092 MGD).
However, in this application, HCC is requesting a discharge flow rate of 200 GPM (0.288
MGD) which is identical to the flow on which the existing NPDES Permit is based. A flow
of 200 GPM is requested since the existing treatment facility has a capacity of 200 GPM and
the pumping of groundwater from additional wells may be necessary during the effective
period of the renewed NPDES Permit.
If the addition of wells other than the ones listed in this application (EW 8, 9, and 10) is
expected to result in new treatment requirements, additional hydraulic capacity needs
beyond 200 GPM, or a significantly different discharge profile, HCC will request the
appropriate permit modifications and potential authorization to construct at that time.
13

3.0 NPDES PERMIT APPLICATION FORM
A completed NPDES APPLICATION FOR PERMIT DISCHARGE SHORT FORM C-
GW, as requested by the NC DEHNR, is provided in this section of this application.
'4

. North Carolina Dept. of Environment, Health, and Natural Resources
Division of Environmental Management, P.O. Box 29535, Raleigh, NC 27626-0535
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM APPL[CATION NUMBER
APPLICATION FOR PERMIT DISCHARGE SHORT FORM C-GW Ell 0 ERNIE
rate Received
To be filed by persons engaged in groundwater qi di / 1 i /
remediation projects. rear month pay
(DEM USE ONLY)
Do not attempt to complete this form before reading accompanying instructions.
(Please print or type) $` °d a
1 . Name, address, location, and telephone number of facility producing discharge
A. Name Hoechst Celanese Corporation
6. Mailing address
I. Street address Hicihway 70 West; P.O. Box 4
2. City Salisbury 3. State North Carolina
4. ZiP 28145-0004
C. Location: 1
1 . Street Needmore Road
2. City Wood'eaf 3.5tate North Carolina
4. County Rowan
•
D. Telephone No. ( 704)- 636-6000 r
E. Nature of business Closed Landfill Site - Groundwater Remediationr�
2. Facility contact
A. Name Mr. Keith Darnell rn
B. Title Envi ronmental Superintendent C. Telephone No. ( 704) -636-6000 .a-
3. The application is for ❑a new permit,
permit renewal, ['permit modification. �
SIC IMMO (if known). If application is for renewal or modification, please indicate permit
number: NC00 79898
4. Product(s) recovered There is no free product recovery at the site. Dissolved
contaminants in groundwater are primarily the result of ethylene glycol .
[Diesel fuel, leaded or unleaded fuel, solvents, etc.]
This application must also Include the following:
A) A report of alternatives to surface water discharge as outlined by N.C. Permit and Engineering Unit's
'Guidance for Evaluation of Wastewater Disposal Alternatives: [Required by 15A NCAC 2H .0105 (c)].
6) An engineering proposal detailing the remediation project. [Required by 15A NCAC 2H .0105 (c)].
C) A listing of any chemicals found in detectable amounts with the maximum observed concentration
reported. The summary of analytical results containing this maximum value should also be
submitted (i.e. the listing, not the graphical scan). The most recent sample must be no older than
one year previous to the date of this application.
For fuel remediation projects, volatile organic compounds should be scanned along with any
suspected fuel additives. The following compounds should be included: benzene*, toluene*,
•ethylbenzene*, xylene*, lead , methyl tert-butylether (MTBE), dibromoethane (EDB),
1,2-dtchloroethane, isopropyl ether, naphthalene, phenol.
* An EPA approved method capable of detection levels to 1 ppb should be used to detect these
compounds

For solvents or unidentified products, an EPA Method 624/625 analysis should be provided,
with the 10 largest peaks, not identified as one of the targeted compounds and not present in
the procedural blank, identified and approximately quantitated. f As per the same guidance
stipulated on NCDEM's "Annual Pollutant Analysis Monitoring (APAM) Requirement - Reporting
Form A," Revised June 1990].
If metals or pesticides are suspected to be present, these should be analyzed to the same detection
level as presented in the NC APAM.
D) The removal efficiency of each compound detected for the proposed project should be provided,
if known.
5. Name of receiving water South Yadkin River
Attach a USGS topographical map with all discharge points clearly marked.
6. Is potential discharge directly to the receiving water? If not, state peci jcally the discharge point.
Wastewater is piped directly into the S. Yadkin River with discharge to river through
Mark clearly the pathway to the potential receiving water on the site map. [This includes tracing diffuser
the pathway of the storm sewer to its discharge point, if a storm sewer is the only viable means of
discharge.]
7. Amount of treated groundwater to be discharged in gallons per operating day:
200 GPM; 0.239 MGD
8. Describe the duration and frequency of the discharge (continuous, intermittent, seasonal)
including the months of discharge, number of days per week of discharge, volume treated
(monthly average flow in gallons per day).
This discharge will be a continuous discharge. On very infrequent occasions (i .e. ,
low rainfall ), water levels in extraction wells may drop to such levels that
intermittent discharges are necessary.
i certify that I am familiar with the information contained in the application and that to the best
of my knowledge and belief such information is true, complete, and accurate.
Richard A. Mickel son Plant Manager
PRINTED Name of Person Signi Title
GNATURE of Applicant Date Application Signed
North Carolina General Statute 143-215.6 (b) (2) provides that:
Any person who knowingly makes any false statement representation, or certification in any application,
record, report, plan or other document files or required to be maintained under Article 21 or regulations
of the Environmental Management Commission implementing that Article, or who falsifies, tampers with
or knowingly renders inaccurate any recording or monitoring device or method required to be operated
or maintained under Article 21 or regulations of the Environmental Management Commission implementing
that Article, shall be guilty of a misdemeanor punishable by a fine not to exceed $10,000, or by imprison-
ment not to exceed six months, or by both. (18 U.S.C. Section 1001 provides a punishment by a fine of not
more than $10,000 or imprisonment not more than 5 years, or both, for a similar offense.)

4.0 NPDES PERMIT APPLICATION FORM COMMENTS
The following additional comments are offered as part of this NPDES Permit Application.
• In Table 2-1, HCC provided the projected characteristics of the discharge at
Outfall 001. As stated in Section 2.0, it was not HCC's intent that these
projected characteristics be specified as actual NPDES effluent limitations.
HCC has calculated and presented in Table 2-1 effluent limitations that could
not be exceeded based on NC DEHNR water quality criteria specified in
Section .0200 (Classifications and Water Quality Standards Applicable to
Surface Waters of North Carolina)of the North Carolina Administrative Code
15A NCAC 2B. These effluent limitations were calculated using the
allowable instream concentration for the contaminants and the appropriate
dilution factor using the annual average, the 30Q2, or 7Q10 stream flow. As
noted in Table 2-1, the concentrations of all the pollutants in the projected
influent to and effluent from the treatment facility are well below any water
quality based effluent limitations. Therefore, HCC is requesting that no
actual effluent limitations be specified for these contaminants in the renewed
NPDES Permit with only monitoring required. If the NC DEHNR feels that
it is necessary to specify actual effluent limitations for these contaminants, the
effluent limitations should be based on appropriate water quality criteria. In
Table 2-1, water quality based limitations have only been presented for those
specific organics and metals which have been detected in the existing influent
to the treatment facility or the three proposed extraction wells ( EW - 8, 9,
10).
• The existing effluent limitation of 0.001 pounds/day for Total Phenols is
overly stringent. Due to the analytical detection Iimit for Total Phenols of
50 ug/l, it would be impossible to determine if the discharge was in
compliance with the existing limit of 0.001 pounds/day at the requested flow
17

rate of 0.288 MGD. The Total Phenol concentration would have to be equal
to or less than 0.4 ugh1 for the discharge to be in compliance with the existing
permit limit which is well below the analytical capability for the contaminant.
Secondly, the South Yadkin River is classified as Class WS-III waters. The
instream concentration for Total Phenols in a Class WS-III water should not
exceed 1.0 ug/1 according to Section .0200 (Classifications and Water Quality
Standards Applicable to Surface Waters of North Carolina) of the North
Carolina Administrative Code 15A NCAC 2B to protect water supplies from
taste and odor problems. According to these same regulations, aesthetic
quality (i.e. taste and odor) is to be protected at the 30Q2 flow of the
receiving stream. The proposed discharge flow rate is 0.288 MGD. The 30Q2
of the receiving stream at the discharge point is 229 CFS or 148 MGD. The
dilution factor, which should be used in calculating the water quality based
effluent limitation, using the 30Q2 flow would be 515. Therefore, the effluent
limitation would be 515 times 1.0 ug/1 or 515 ug/1. Based on discharge flow
rate of 0.288 MGD, the pounds/day limit would be 1.24. Total phenol
concentrations in the existing discharge at Outfall 001, as noted in Table 2-2,
have been well less than 515 ug/1. HCC, therefore, requests that the
NPDES Permit effluent limitation for Total Phenols be deleted when the new
permit is issued. If the NC DEHNR deems it necessary to specify an actual
permit for Total Phenols, the limit should be based on water quality criteria.
• The existing effluent limitation for Barium of 238 ug/1 is too stringent based
on consideration of water quality criteria. The instream concentration for
Barium in a Class WS-III water should not exceed 1.0 mg/1 according to
SECTION .0200 (Classifications and Water Quality Standards Applicable to
Surface Waters of North Carolina) of the North Carolina Administrative Code
15A NCAC 2B to protect human health. Using the same rationale as noted
above for Total Phenols, with the exception of using the 7010 flow of 106
CFS (68.5 MGD) (protection of human health for noncarcinogens) instead of
18

the 30Q2 flow, the water quality effluent limitation would be 239 times 1.0
mg/1 or 239 mg/1. Barium concentrations in the existing discharge at Outfall
001, as noted in Table 2-2, have been well less than 239 mg/1. HCC therefore
requests that the effluent limitation for Barium be deleted upon issuance of
the new permit. If the NC DEHNR deems it necessary to specify an actual
permit for Barium, the limit should be based on water quality criteria.
• Part III, Item F of the existing NPDES Permit states that HCC shall install
the Perox-Pure Organic Destruction Process for the treatment of the
contaminated groundwater. It should be noted that HCC installed a similar
treatment process manufactured by Solarchem Environmental Systems. The
reasons for this change and the concurrence from NC DEHNR are outlined
in the revised authorization to construct issued on October 19, 1992. The new
NPDES Permit wording should reflect that the treatment technology is the
Solarchem Environmental Systems process.
• Part III, Item D of the existing NPDES Permit requires HCC to perform
Acute Toxicity Testing of the discharge on a quarterly basis. During the start-
up of the treatment system in December of 1992, the discharge did not pass
this acute toxicity test. Subsequent analytical investigation discovered the
source of this failure to be the treatment technology itself. Excess residual
hydrogen peroxide is required for the UV/peroxide system to effectively
destroy organics at high flow rates. This residual peroxide was the cause of
the acute toxicity. HCC worked around this problem during 1993 by
operating the treatment system well below its maximum hydraulic capacity
and by maintaining a low residual peroxide (about 3 mg/1) in the effluent.
This has allowed the system to successfully destroy the targeted organics and
pass subsequent acute toxicity tests, but it has limited the hydraulic capacity
of the system to only about 18 % of original design. This has created a delay
19

in implementing the overall groundwater remediation strategy for the
Needmore Road Landfill Site.
In reviewing the toxicity testing requirements for this permit, HCC believes
there are several mitigating factors that should be considered. First, at the
7010 flow of the receiving stream (106 CFS or 68.5 MGD), the instream
concentration of the HCC discharge is less than 1%. Secondly, the effluent
from the system is discharged through a multiport diffuser which allows for
rapid attenuation of the effluent into the South Yadkin River. Thirdly, the
environmental fate of hydrogen peroxide is generally benign as it does not
bio-accumulate and degrades into water and oxygen. In consideration of these
factors, HCC proposes that a chronic toxicity limit be specified in the new
permit in lieu of the current acute toxicity limit. A chronic toxicity limit based
on the instream concentration of 0.42%would be sufficient to protect aquatic
life and would allow HCC to effectively implement its groundwater
remediation at the site. HCC would also like to note that this is consistent
with requirements of other states in the southeast as illustrated by South
Carolina's rules that do not require toxicity testing for instream concentrations
below 1% that are discharged through a diffuser, and require only chronic
testing for instream concentrations between 1% and 10% that are discharged
through a diffuser.
20

4104 -
artDEFT. OF N vrt u
� RESOURCES Ai4iSOM1,40
1KUNI1Y JAN 3 1 1992
State of North Carolina in" J1 i }'fRarw!'
Department of Environment, Health and Natt� '"d`r �`a' Ueri„c
Division of Environmental Management
512 North Salisbury Street• Raleigh, North Carolina 27611
James G.Martin,Governor
William W. Cobey,Jr., Secretary George T. Everett,Ph
January 31, 1992 Director
Mr. Steven M. Simpson, Environmental Engineer
Hoechst Celanese
Post Office Box 4
Salisbury, N. C. 28144
Subject: Permit No. NC0079898
Authorization to Construct
Hoechst Celanese Corporation
Needmore Road Landfill
Groundwater Remediation Facility
Rowan County
Dear Mr. Simpson:
A letter of request for an Authorization to Construct was received on September 18, 1991, by the
Division and final plans and specifications for the subject project have been reviewed and found to be
satisfactory. Authorization is hereby granted for the construction of a 0.288 MGD groundwater
remediation facility, which consists of extraction wells and a seepage collection sump, a 275,000 gallon
equalization tank with a floating mixer and high level alarm, secondary containment around the
equalization tank, 200 GPM duplex centrifugal pumps, a magnetic flow meter and pneumatically
positioned pinch valve, an iron removal system which consists of two in-line static mixers for chemical
additions of hydrogen peroxide (to oxidize soluble iron not oxidized in the equalization tank) and either
sulfuric acid or sodium hydroxide (to maintain desired pH of 7 to 8 to optimize downstream clarification),
a lamella type clarifier with integral flash mix for adding aluminum chloride and polymer(to improve floc
formation) and flocculation chambers, a continuous backwash, upflow, deep bed sand filter, a 12,000
gallon sludge holding tank, a five cubic foot plate and frame filter press, a 3000 gallon storage tank with
200 GPM duplex centrifugal pumps, a magnetic flow meter and pneumatically controlled pinch valve, a
static mixer for the addition of sulfuric acid to lower the pH to approximately 5.5, an organic destruct
system which consists of an oxidation chamber where hydrogen peroxide is added to the water and
subjected to ultraviolet light, which converts the organics to carbon dioxide and water, a 1500 gallon
effluent tank and mixer whereby sodium hydroxide is added to raise the pH to 6 to 9, a Parshall flume for
flow measurement, effluent discharge piping with effluent diffuser, and all other appurtenances, and the
discharge of treated wastewater into the South Yadkin River in the Yadkin-Pee Dee River Basin.
Regional Offices
Asheville Fayetteville Mooresville Raleigh Washington Wilmington Winston-Salem
704/251-6208 919/486-1541 704/663-1699 919/733-2314 919/946-6481 919/395-3900 919/896-7007
Pollution Prevention Pays
P.O.Box 29535,Raleigh,North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

This Authorization to Construct is issued in accordance with Part III paragraph A of NPDES
Permit No. NC0079898, which was issued on September 16, 1991, and became effective on November
1, 1991, and shall be subject to revocation unless the wastewater treatment facilities are constructed in
accordance with the conditions and limitations specified in Permit No. NC0079898.
The sludge generated from these treatment facilities must be disposed of in accordance with G.S.
143-215.1 and in a manner approved by the North Carolina Division of Environmental Management.
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 treatment or disposal facilities.
The Mooresville Regional Office, phone no. 704/663-1699, shall be notified at least forty-eight
(48) hours in advance of operation of the installed facilities so that an in-place inspection can be made.
Such notification to the regional supervisor shall be made during the normal office hours from 8:00 a.m.
until 5:00 p.m. on Monday through Friday, excluding State Holidays.
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 the NPDES Permit, this Authorization to Construct, and the approved plans and
specifications. Mail the Certification to the Permits and Engineering Unit, P.O. Box 29535, Raleigh, NC
27626-0535.
The subject wastewater treatment and disposal facilities shall be connected to an operational
publicly owned wastewater collection system within 180 days of its availability to the subject facilities, if
the subject wastewater treatment or disposal facilities are in noncompliance with the terms and conditions
of the NPDES permit, the Authorization to Construct, or the governing statutes or regulations. Prior to the
initiation of these connection activities, appropriate approval must be received from this Division.
Upon classification of the facility by the Certification Commission, the Permittee shall employ a
certified wastewater treatment plant operator to be in responsible charge of the wastewater treatment
facilities. The operator must hold a certificate of the type and grade at least equivalent to the classification
assigned to the wastewater treatment facilities by the Certification Commission. Once the facility is
classified, the Permittee must 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.
A copy of the approved plans and specifications shall be maintained on file by the Permittee for the
life of the facility.
Failure to abide by the requirements contained in this Authorization to Construct may subject the
Permittee to an enforcement action by the Division of Environmental Management in accordance with
North Carolina General Statute 143-215.6A to 143-215.6C.
The issuance of this Authorization to Construct 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.

One (1) set of approved plans and specifications is being forwarded to you. If you have any
questions or need additional information, please contact Mr. Randy Jones at telephone number 919/733-
5083.
Sin rely,
eorge T. Eve tt
cc: Rowan County Health Department
Mooresville Regional Office,Water Quality
Training and Certification Unit
Mooresville Regional Office,Groundwater
Groundwater Section, Jack Floyd
Davis and Floyd (PO Drawer 428, Greenwood, SC 29648)

Permit No. NC0079898
Authorization to Construct
January 31, 1992
Engineer's Certification
I, , 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, for the
Project Name Location
Permittee 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 the approved plans and specifications.
Signature Registration No.
Date

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NPDES WASTE LOAD ALLOCATION /
PERMIT NO.: NC0079898 Modeler Date Rec. - # / '
m'Aw 2_H RI 'fig s
PERM ITEE NAME: Hoechst Celanese Corporation 2
FACILITY NAME: Needmore Road Landfill Drainage Area(mi ) 5 5`) Avg. Streamflow (cfs): (,�,5
Facility Status: Existing 7Q10 (cfs) /(1 Winter 7Q10 (cfs) / 30Q2 (cfs) C Z2 I
Permit Status: Renewal Toxicity Limits: IWC D,4) % Acu hronic P/k' (r 1/L
J - "Tc
Major Minor �.Instream Monitoring:
Pipe No.: 001 +c011,. Parameters 7 ' ( 1 L ,�
Design Capacity: 0.288 MGD 4 u was decided to monitor only for Temperature.Conducdvi(y.artd DO ��i. "
Domestic (% of Flow): � �q Upstream: —50 feet above discharge a.+ r1n I e pit
) oa ' q°�' ��ti Downstream: downstream from discharge(mad R� t upstream from r t
Industrial (% of Flow): 100 % '� .�` Cooleemee
' I` �ti�� ;. Effluent '
4l� ti� ° Summer Winter
Comments: Characteristics
r'C' BOD5 (mg/i)
., T55 (m8//) 30 30
STREAM INDEX: 12-108-(1)
RECEIVING STREAM:South Yadkin River P (S'U�
%f/
} M7ot;fit/ A .477!.-i7/' 75,
Class: WS-III ��I �G re e. (14//I ( ,.;
Sub-Basin: 03-07-06 Parameter Requirement
Total phenols monitor
Reference USGS Quad: D16SE,Cooleemee (please attach) Total Phosphorus monitor ,
County: Rowan ' 'd-Grease monitor
1,4 Dioxane monitor
Chlorobenzene monitor
Regional Office: Mooresville Regional Office Barium monitor
Previous Exp. Date: 7/31/94 Treatment Plant Class: I Chromium monitor
Copper monitor
Classification changes within three miles: Iron Lead monitor
onitor
Reverts to Class C at Cooleemee Dam Mercury monitor
Nickel monitor _
1,2 Dichloroethene^cis/trans monitor
_ Methylene Chloride monitor
Manganese monitor
Requested by: Gre 7 Nizich&? J Date: 2/17/94 Ammonia Nitrogen monitor
Prepared by: �� -, Date: 2 y Comments: he no( ti 4 f2o -�-,`�ryr Sr`N-t.�
Reviewed by: � Date: 0°7 ,C q Al/e uab(i ib An Aki ik.7
,A. Effluent tnotvtoringof all parameters except wasteflow
1 ...y UP Irnntinlinlic ninnitnnnn ctSnl!1lt hP rinnr/T„n- '- .to mint-irT . voi11- f1-,.. a�,it, tr vsr+* .toct (A, 1,,1

FACT SHEET FOR WASTELOAD ALLOCATION
Request# 7748
� 7 N.G. DEPT, O
FacilityName: Needmore Road Landfill IR NAT o\r.\!ENi. HEALTH
NPDES No.: NC0079898 URAL RESOURCES'
Type of Waste: Industrial - 100% APR 14 Facility Status: Existing 1994
Permit Status: Renewal
Receiving Stream: South Yadkin River DIVISIEN OF ENVfRONVERTAI E4ANAOEI ENT
Stream Classification: WS-III MOORESYfttE RE&IONAj Off1GE
Subbasin: 030706
County: Rowan $tarn Characteristic:
Regional Office: Mooresville '( USGS # 0211893501
Requestor: Greg Nizich Date: 11/90
Date of Request: 2/17/94 Drainage Area(mi2) 559
Topo Quad: D16SE Summer 7Q10 (cfs): 106
Winter 7Q10(cfs): 179
Average Flow (cfs): 632
30Q2 (cfs): 229
IWC (%): 0.42
Wasteload Allocation Summary
(approach taken,correspondence with region, EPA,etc.)
Limits for Phenols, Barium, and 1,1 Dichloroethene were dropped: however, monitoring is
required for Phenols and Barium. I reviewed DMR data and RUST (Hoechst Celanese Corp
consultant) wastestream characterization data. The maximum concentrations for each parameter
/f 4E p qG
above detection level were used to calculate the maximum discharge effluent concentrations.re, � rc i e
Monitoring only is required for all parameters with concentrations above detection levels. The
monitoring requirements are based on Public Health concerns; because,Davie County's Water
Supply intake is only 2.5 miles downstream from Needmorefirmre Road Landfill's effluent. Acute
toxicity test Daphnid 48 hour LC50 test @ 42% Qrtly (Apr, Jul, Oct, Jan) will be required. SOP
states: "If IWC is less than 1% and greater than 0.25%, apply an acute toxicity testing requirement
to the NPDES permit" IWC=0.42% Flow limit of 0.288 MGD should be added to permit.
Limit for BOD5 and TSS of 30/30. Instream Monitoring recommended.
Special Schedule Requirements and additional comments from Reviewers
st,ch /,v,! 1GI/C, {�f/I fl ,K' Tf(tn iY/r1)tn'Y/ki, .5/i' 7%n (- •
3-05-r Cl^-�t K4.1A 5; c.r2 w� ,,c51 AIbZJ W i e Lb-rq /ev, i4U0 r 5
0Vr / E,
c a- tvl I,h,Je&k) yeaA o4f /t0/q.- /-42"-Q.Lati, p/-6/064-ns,
Recommended by: 1 4 4Date:
Reviewed by
z
Instream Assessment: ��� ,L 4A, tt,V Date: l�� 1/(;
Regional Supervisor: P/? tiGi. j7J Date: ,/z/f.
Permits & Engineering: /J Date: 00171'
oR`r'
RETURN TO TECHNICAL BY:
1

2
TOXICS/CONVENTIONAL PARAMETERS
Type of Toxicity Test: Acute Daphnid 48 hour
Existing Limit: 42%
Recommended Limit: 42%
Monitoring Schedule: APR, JUL, OCT,JAN
Existing Limits
Mon. Avg. Daily Max.
Barium (ug/l): 238
Phenols (lbs/day): 0.001
1,1-Dichloroethene (ug/l): 81
pH (SU): 6-9
Oil &Grease (mg/1): 30 60
Recommended Limits
Monthly Average Daily Max. Mon. Freq. WQ or EL
pH (SU): 6-9 2Jmonth WQ
Oil & tease-cm--gB): 30 60 2Jmonth WQ
Summer Winter
BOD5(mg/1): 30 3g VL#
(.lw`t--t3 291k/col r 0 0. fi g`
(See page three for special monitoring requirements.)
fLlt,Cc07fit{i'ZGt Ce)21, �iUiS c i'l)L-jvc rif;-;rl-✓ /y.
zc
Limits Changes Due To: Parameter(s) Affected
Error in previous WLA
limit should not have been given Phenols and Barium
DMR data and new wastestream chararcterization
show levels below detection 1,1-Dichloroethene
X Parameter(s) are water quality limited. For some parameters, the available load capacity of
the immediate receiving water will be consumed. This may affect future water quality based
effluent limitations for additional dischargers within this portion of the watershed.
OR
No parameters are water quality limited, but this discharge may affect future allocations_
f'1 fi1 St� Y �fc�;5'�2.fC )z j �Za- ToY rcf co 1' (/ 7tci-P

3
SPECIAL MONITORING REQUIREMENTS
The following is a list of parameters to monitor based on maximum observed concentrations found
in monitoring wells and/or DMR data. Effluent monitoringof all parameters except wasteflow
(continuous monitoring) should be done quarterly to coincide with the acute toxicity test. (Apr, Jul,
Oct, Jan).
Monitoring Wells
Parameter Requirement Maximum Observed Cone. (ug/11
Total phenols monitor 40.2 -
Total Phosphorus monitor 32
O' monitor- 5200
1,4 Dioxane monitor 2300 ,�,
Chlorobenzene monitor 18 �: 1��y t Y
Barium monitor 206' ? L� ��6,t'- Uti
Chromium monitor 4 ��. re,C ' �
Copper monitor 64 0, (n.,�t C
Iron monitor 39400 . Q,ii
Lead monitor 26.4 k 4 �,
Mercury monitor 0.39 / 1 � ,UC �-�,
Nickel monitor 247 -�'� • ) ),,1"-
�ti lel
1,2 Dichloroethene^cis/trans monitor 14 �,
Methylene Chloride monitor 60 UN qIJ-
Manga.nese monitor 8910 ' J GL1
Ammonia Nitrogen monitor 100
*Ethylene Glycol monitor 16000
*Acetone monitor 2400
*TKN monitor 430
*Benzoic Acid monitor 251 �D
*4 Methylphenol monitor 11
*Calcium monitor 248,000
*Cobalt monitor 5100
*Magnesium monitor 370,000
*Sodium monitor 19,600
*TOC monitor 43,400
*TOX monitor 70
r`COD monitor- 122,000
BODS monitor 85,000
TSS- monitor— 92,000
Conductivity monitor 2060 (mmhoslcm)
Flow- mon - continuously -042-9-MGD
*No standard. Should we still monitor since discharge is 2.5 miles upstream from Cooleemee's
Water Supply. e 6.•,0-rL 0of ni ALt/C 13 ,2 A)o.
c
'31P / �S
**Recommend instream monitoring fo -mperatur: ondu , D.0., d B 5
cie mD t r�./ t;-x 0a, '' .

42.
Adequacy of Existing Treatment
Has the facility demonstrated the ability to meet the proposed new limits with existing treatment
facilities? Yes X No
If no,which parameters cannot be met?
Would a "phasing in" of the new limits be appropriate?Yes No_X
If yes, please provide a schedule (and basis for that schedule) with the regional
office recommendations:
If no, why not?
,special Instructions or Conditions
BTEX parameters should be monitored using an EPA-approved method to a detection level of I
ppb. Permit must contain flow monitoring requirement such that all volumes of wastewater
leaving the facility are monitored. Recommend continuous flow monitoring. Recommend
quarterly monitoring for those chemical parameters to be limited or monitored. This monitoring
should coincide with all whole-effluent toxicity monitoring.
A reopener clause should be placed in the permit to allow for additional limits on these or other
toxicants should the whole-effluent toxicity testing results indicate toxic effects.
Explain exact pathway of discharge ( i.e. storm sewer to tributary, etc.)
Additional Information attached? (Y or N) If yes, explain with attachments.

� r
Facility Name iv C e( �► %�'r 4 d ��q n d Y1 / Permit# Ne 60 7 9 4`/e Pipe# 06/.
ACUTE TOXICITY PERMIT LIMIT (QRTRLY)
The permittee shall conduct acute toxicity tests on a quarterly basis using protocols defined as definitive in E.P.A.
Document 600/4-85/013 entitled "The Acute Toxicity of Effluents to Freshwater and Marine Organisms." The
monitoring shall be performed as a Daphnia pulex.or Ceriodaphni; 48 hour static test, using effluent collected as a
24 hour composite. The LC50 of this effluent using the previously stated methodology may at no time in any
toxicity test be less than 4.2 %. Effluent samples for self-monitoring purposes must be obtained during
representative effluent discharge below all waste treatment. The first test will be performed after thirty days from
the effective date of this permit during the months of fiflr �r.f, Sri if) .
The parameter code for this test if using Daphnia pax is TAA3D. The parameter code for this test if using
Ceriodaphni,is TAA3B. 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 appropriate
parameter code. Additionally, DEM Form AT-1 (original)is to be sent to the following address:
Attention: Environmental Sciences Branch
North Carolina Division of
Environmental Management
4401 Reedy Creek Road
Raleigh, N.C. 27607
Test data shall be complete and accurate and include all supporting chemical/physical measurements performed in
association with the toxicity tests, as well as all dose/response data. Total residual chlorine of the effluent toxicity
sample must be measured and reported if chlorine is employed for disinfection of the waste stream.
Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly monitoring 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 either these monitoring requirements or tests performed by the North Carolina Division
of Environmental Management indicate potential impacts to the receiving stream, this permit may be re-opened and
modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism
survival 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.
7Q10 /0 cfs
Permitted Flow ,, ig ' MGD Recommended by:
IWC d, 4,)
9b Basin & Sub-basin Ya d7/Z-4<---t'
Receiving Stream Cn Ya d
County KoiAv h Date
QAL Daphnid 48 Version 10/91

4„..1 in 1
ST
' NPDES WASTE LOAD ALLOCATION
Modeler Date Rec. #
PERMIT NO.: NC0079898 SN LAD t't5 �a 5csA
PERMI I 1 EE NAME: Hoechst Celanese Corporation/ Needmore 2 1
icopD z ,' z Drainage Area (mi ) 559 Avg. Streamflow (cfs): 632
Facility Status: Proposed
Permit Status: New 7Q10 (cfs) too Winter 7Q10 (cfs) j"7' 30Q2 (cfs) 221
Iv. te r, o Toxicity Limits: I Cr 4Z % Acut- Chronic
Major , Minor An ,t, �' ivt item q tc60 427e
Pipe No.: 001 � 411vll F. a £l ND
i Instream Monitoring:
Design Capacity: 0.288 MGD MAR 2 c, Parameters
199i Upstream Location
{% of Flow): It so or to
Industrial (% of Flow): 100% NOORE.SvgiF s, RE „,, �.t.gri` Downstream Location
REEFi- Ott1ei
Comments: Effluent hour}m:M4. DA 3-1 N1fix
Groundwater Remediation Mike Scoville has copy of Engineering_ Characteristics s %wlN Aim/wI0 , Fes''
Report BOD5 (mg/I)
NH3-N (mg/1) '
RECEIVING STREAM: South Yadkin River D.O. (mg/1)
Class: WS-III TSS (mg/1)
Sub-Basin: 03-07-06
Reference USGS Quad: D16SE,Cooleemee (please attach) F. Col. (/100 ml)
County: Rowan pH (SU) - 6 —9 z7,,,a4
Regional Office: Mooresville Regional Office
Previous Exp. Date: 00/00/00 Treatment Plant Class: _ Unknown q 4 * 4 () Ca o Z/A utJ
Classification changes within three miles: Pur�olrs(tbs/�Ry) O. 001 c�,K+-7
Reverts to Class Cat Cooleemee Dam
9 r1YPt y
,l,i•Teslto¢a 0We �f1
Slwum(, ,c) 2,3ci kllu-Y
Requested by: j Jeffrey A. Curka Date: 10/31/90
Prepared by: coa4..C• (J(J . Date:
Comments: i cs n i-ra2ii'1 tt.titt J4 TA Anp►titeD Asr) Skala-PP
Reviewed by: 201-tii.,-, 5,g a..,,Lem2.0--, Date:' r i f I K Fes-kervio oni A 011,4 61W1 6A515 IV caaaeLpavp LAilli1 IkliC E .0 r
N� -buts- �EcTirt4. A REI,P614Erc eu USG SFtoul.b 6V ilAa-l) INS MiT 70
�° *mow fa. ill A4-, !Afar* eN 'rn14cA�ITS SKou1.D 1I FAULTY cAu. ITS
%0 A I Y'•I - /0 Q . / w N 4uf,NT Tax-t a ri 'f:93. 'f a+t- suPPbicr Pkoothter405 Adz,,ttu AA6R A+valoR
•ailMwl 47,S,,rPTinrJ ,4y AAMPFM„M 172F-o0roview --

-2-
PARAMETERS TO BE MONITORED
(Monitor on a quarterly basis to correspond with toxicity testing)
Other (The following is a list of parameters to monitor based on maximum
observed concentrations found in monitoring wells)
Parameter Requirement
Methylene Chloride Monitor
Acetone Monitor
Trichlorofluoromethane Monitor
Antimony Monitor
Vinyl Chloride Monitor
1, 1-Dichloroethane Monitor
1,2-Dichloroethene Monitor
Ethylbenzene Monitor
1, 4-Dioxane Monitor
Chlorobenzene Monitor
1,2-Dichlorobenzene Monitor
1, 1, 1-Trichloroethane Monitor
Toluene Monitor
Butylbenzylphthalate Monitor
Tetrachloroethane Monitor
Benzene Monitor
4-Methylphenol Monitor
Trichloroethene Monitor
Cobalt Monitor
Zinc Monitor
Lead Monitor
TOC Monitor
Magnesium Monitor
++ These parameters should be monitored on a quarterly basis.

-1-
Request #5939
Facility Name :Hoechst Celanese/Needmore Road Landfill
NPDES No. :NC0079898
Type of Waste :100% Industrial
Facility Status :Proposed
Permit Status :New
Receiving Stream :South Yadkin River
Stream Classification:WS-III
Subbasin :030706
County :Rowan
Stream Characteristics:
Regional Office :MROJ'Y USGS # 0211893501 Date 11/90
Requestor. :J.C. Drainage Area: 559 sq.mi.
Date of Request :10/31/90 Summer 7410: 106 cfs
Topo Quad :D16NE Winter 7Q10 : 179 cfs
Average Flow: 632 cfs
3042 : 229 cfs
Wasteload Allocation Summary
(approach taken, correspondence with region, EPA, etc. )
This project is a proposed groundwater remediation of a landfill
currently leaching into the groundwater. The proposed discharge point
is approximately 2.5 miles from Davie Co. W.S. Due to the proximity of
the W.S. , Tech Support recommends monitoring all parameters found in
detectable amounts in initial scans. (Those parameters are listed on
page two of this form) . Technical Support also recommends air stripper
and/or carbon adsorption as minimum treatment .
This Wasteload Form will be forwarded to Health Services for comments .
Toxics monitoring (including the list of parameters on page two) should 7
be performed on a quarterly basis to correspond with whole effluent /
toxicity testing.
** A reopener clause should be placed in the permit to allow for + hi .�R«�1
additional limits on toxicants should the facility fail its whole a
effluent toxicity tests. cd,,rI
Special Scheduled Requirements and additional comments from Reviewers: ( } ,�' 1+1L$ro!
Recommended by: /44,,,4 61(I.4trm4 , Date: (/30/ I
Reviewed by
Instream Assessment : Date: y/,,3 0
Regional Supervisor:A9Cr .YD-11, 1 Date: 51 ' 1
Permits & Engineering: )}� Date: L`'�4
RETURN TO TECHNICAL SERVICES BY:

-2-
CONVENTIONAL PARAMETERS
Existing Limitq NO EXISTING LIMITS
Recommended Limits
Monthly Average Daily Maximum Freq.
Summer/Winter
Wasteflow (MGD) : 0 .288
pH (SU) : 6-9 2/mon
Oil & Grease (mg/1) : 30 60 2/mon
Phenols (lbs/day) : 0 .001 qtrly
1, 1 Dichloroethene (ug/1) : 81 qtrly
Barium (ug/l) : 238 qtrly
Toxicity: Acute Qtrly 48hr Daphnid, >= 42%
INSTREAM MONITORING REQUIRMENTS: No Requirement
Limits Due To: Parameter(s) Affected
Well Monitoring data Barium, Phenol, 1, 1 Dichloroethene
Other (The following is a list of parameters to monitor based on maximum
observed concentrations found in monitoring wells)
Parameter Requirement Maximum Observed Conc . (uq/1)
Methylene Chloride Monitor 4
Acetone Monitor 11
Trichlorofluoromethane Monitor 4
Antimony Monitor 12
Vinyl Chloride Monitor 2
1, 1-Dichloroethane Monitor 137
1,2-Dichloroethene Monitor 25
Ethylbenzene Monitor 2
1, 4-Dioxane Monitor 6711
Chlorobenzene Monitor 38
1,2-Dichlorobenzene Monitor 9
1, 1, 1-Trichloroethane Monitor 26
Toluene Monitor 6
Butylbenzylphthalate Monitor 30
Tetrachloroethane Monitor 8
Benzene Monitor 15
4-Methylphenol Monitor 64
Trichloroethene Monitor 140
Cobalt Monitor 40
Zinc Monitor 30
Lead Monitor 6
TOC Monitor 726, 000
Magnesium Monitor 24, 600
++ These parameters should be monitored on a quarterly basis.
4,., C onr..k W/ A; `+am.'{"

!PPP.-
Facility Name 1pf4ISr CNA!ii; e/Ni0E,Nts c 14. tAkMD6u-Permit # NC007g8S
ACUTE TOXICITY TESTING REQUIREMENT (QRTRLY)
Daphnid 48 hr- LC50
The permittee shall conduct acute toxicity tests on a quarterly basis using protocols defined as
definitive in E.P.A. Document 600/4-85/013 entitled "The.Acute Toxicity of Effluents to
Freshwater and Marine Organisms". The monitoring shall be performed as a Daphnia pulex or
Ceriodaphnia 48 hour static test, using effluent collected as a 24 hour composite. The LC50 of this
effluent usingthe previouslystated methodologymay at no time in any two consecutive toxicity
must be obtained during
less than 2%. Effluent samples for self-monitoringpurposes
tests be s . 4 p
representative effluent discharge below all waste treatment. The first test will be performed after
thirty days from issuance of this permit during the months of TAN, A . Cf tL. J CCV
The parameter code for this test if using Daphnia pulex is TAA3D. The parameter code for this test
if using Ceriodaphnia is TAA3B. 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 appropriate parameter code. Additionally,DEM Form AT-1
(original)is to be sent to the following address:
Attention: Technical Services Branch
North Carolina Division of
Environmental Management
P.O. Box 27687
Raleigh, N.C. 27611
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 any single quarterly monitoring indicate a failure to meet specified limits, then monthly
monitoring 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 either these monitoring requirements or tests performed by the North
Carolina Division of Environmental Management indicate potential impacts to the receiving stream,
this permit may be re-opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival 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.
7Q10 COG cfs
Permitted Flow 0. Zeg MGD Recommended by:
IWWC% 0. 4I9
Basin & Sub-Basin 0$o7oG 'MDap
Receiving Stream S. VinKau g .
County efkifr,q Date liz3/co
**Acute Toxicity(Daphnid 48 hr) LC50 42- %,3*w RPR �+�e- Ocr , See Part 3 , Condition Cy .

s"`SG�TL o
NATURAL +,
��c ntEP'r'• OF N �
RESOURCES AND ,jC I T „�F
commoirrY DEVELOP v�[ J
.1�
'C CT 2 0 '1992
s 1,1. State of North Carolina
1S1g% OF ROW e • 's •1 'nt of Environment, Health and Natural Resources
wow 1615 '1 " Division of Environmental Management
512 North Salisbury Street• Raleigh, North Carolina 27611
James G.Martin,Governor A.Preston Howard,Jr.,P. E.
William W.Cobey,Jr., Secretary Acting Director
October 19, 1992
Mr. Steven M. Simpson,Environmental Engineer
Hoechst Celanese
Post Office Box 4
Salisbury, N. C. 28144
Subject: Permit No. NC0079898
Authorization to Construct
Hoechst Celanese Corporation
Needmore Road Landfill
Groundwater Remediation Facility
Rowan County
Dear Mr. Simpson:
On January 31, 1992, the Division of Environmental Management issued an Authorization to
Construct to Hoechst Celanese Corporation for the subject groundwater remediation facility to serve the
Needmore Road Landfill. That Authorization to Construct was for the construction of a 0.288 MGD
groundwater remediation facility, which consists of extraction wells and a seepage collection sump, a
275,000 gallon equalization tank with a floating mixer and high level alaun, secondary containment around
the equalization tank, 200 GPM duplex centrifugal pumps, a magnetic flow meter and pneumatically
positioned pinch valve, an iron removal system which consists of two in-line static mixers for chemical
additions of hydrogen peroxide (to oxidize soluble iron not oxidized in the equalization tank) and either
sulfuric acid or sodium hydroxide (to maintain desired pH of 7 to 8 to optimize downstream clarification),
a lamella type clarifier with integral flash mix for adding aluminum chloride and polymer (to improve floc
formation) and flocculation chambers, a continuous backwash, upflow, deep bed sand filter, a 12,000
gallon sludge holding tank, a five cubic foot plate and frame filter press, a 3000 gallon storage tank with
200 GPM duplex centrifugal pumps, a magnetic flow meter and pneumatically controlled pinch valve, a
static mixer for the addition of sulfuric acid to lower the pH to approximately 5.5, an organic destruct
system which consists of an oxidation chamber where hydrogen peroxide is added to the water and
subjected to ultraviolet light, which converts the organics to carbon dioxide and water, a 1500 gallon
effluent tank and mixer whereby sodium hydroxide is added to raise the pH to 6 to 9, a Parshall flume for
flow measurement, effluent discharge piping with effluent diffuser, and all other appurtenances, and the
discharge of treated wastewater into the South Yadkin River in the Yadkin-Pee Dee River Basin.
Regional Offices
Asheville Fayetteville Mooresville Raleigh Washington Wilmington Winston-Salem
704/251-6208 919/486-1541 704/663-1699 919/571-4700 919/946-648I 919/395-3900 919/896-7007
Pollution Prevention Pays
P.O.Box 29535,Raleigh,North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

On August 3, 1992 (with final revised plans received on August 31, 1992), the Division received
revised plans for the subject facility. The revision includes a design modification to delete the originally
approved iron removal system. The purpose of the iron removal system was to prevent the deposition of
iron compounds on the quartz tubes in the ultraviolet oxidation equipment. The deposition of iron
compounds on the tubes reduces the efficiency of the system. The new proposed ultraviolet system has a
continual cleaning system for the tubes. Along with the elimination of the iron removal system, the
following equipment can, therefore, be eliminated: inclined plate clarifier, sand filter, chemical feed
systems for polymer and aluminum chloride, filter press and sludge handling equipment, along with
various tanks,pumps, and other appurtenances associated with the iron removal system.
This Authorization to Construct is issued in accordance with Part III paragraph A of NPDES
Permit No. NC0079898, which was issued on September 16, 1991, and became effective on November
1, 1991, and shall be subject to revocation unless the wastewater treatment facilities are constructed in
accordance with the conditions and limitations specified in Permit No. NC0079898.
The sludge generated from these treatment facilities must be disposed of in accordance with G.S.
143-215.1 and in a manner approved by the North Carolina Division of Environmental Management.
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 treatment or disposal facilities.
The Mooresville Regional Office, phone no. 704/663-1699, shall be notified at least forty-eight
(48) hours in advance of operation of the installed facilities so that an in-place inspection can be made.
Such notification to the regional supervisor shall be made during the normal office hours from 8:00 a.m.
until 5:00 p.m. on Monday through Friday, excluding State Holidays.
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 the NPDES Permit, this Authorization to Construct, and the approved plans and
specifications. Mail the Certification to the Permits and Engineering Unit, P.O. Box 29535, Raleigh, NC
27626-0535.
Upon classification of the facility by the Certification Commission, the Permittee shall employ a
certified wastewater treatment plant operator to be in responsible charge (ORC)of the wastewater treatment
facilities.The operator must hold a certificate of the type and grade at least 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 grade to comply with
the conditions of Title 1SA, Chapter 8A, .0202. The ORC of the facility must visit each Class I facility at
least weekly and each Class II, III, and IV facility at least daily, excluding weekends and holidays, and
must properly manage and document daily operation and maintenance of the facility and must comply with
all other conditions of Title 15A, Chapter 8A, .0202. Once the facility is classified, the Permittee must
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.
A copy of the approved plans and specifications shall be maintained on file by the Permittee for the
life of the facility.
Failure to abide by the requirements contained in this Authorization to Construct may subject the
Permittee to an enforcement action by the Division of Environmental Management in accordance with
North Carolina General Statute 143-215.6A to 143-215.6C.
The issuance of this Authorization to Construct 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.

One (1) set of approved plans and specifications is being forwarded to you. If you have any
questions or need additional information, please contact Mr. Randy Jones at telephone number 919/133-
5083.
Sincerely,
A. Preston How..d, r., P. '
cc: Rowan County Health Department
Mooresville Regional Office,Water Quality
Training and Certification Unit
Mooresville Regional Office, Groundwater
Groundwater Section,Jack Floyd
Davis and Floyd (PO Drawer 428, Greenwood, SC 29648)

Permit No. NC0079898
Authorization to Construct
October 19, 1992
Engineer's Certification
I, , 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, , for the
Project Name Location
Permittee 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 the approved plans and specifications.
Signature Registration No.
Date
•
i

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�.C. DAP 1: OF NATURAL
Qv� RESOURCES AND
pCOMMUNrry DEVELOP'k=r,'-r
d�RA$v
MAR 1 1 1993
4-yka ey)
PIM
"{* UIRL laf Kl:�lu�iAL iE�rrli�E
State of North Carolina
Department of Environment, Health and Natural Resources
7. \)htj -
Division of Environmental Management
512 North Salisbury Street • Raleigh,North Carolina 27604
James B. Hunt,Jr.,Governor Jonathan B.Howes,Secretary.
March 11, 1993
Mr. Carl W. Repsher
Hoechst Celanese Corporation
Post Office Box 4
Salisbury, NC 28144
Subject: NPDES Permit NC0079898
Hoechst Celanese Corporation
Rowan County
Dear Mr. Repsher:
On September 16, 1991, the Division of Environmental Management issued NPDES
Permit No. NC0079898 to Hoechst Celanese Corporation. A review of the permit file has
indicated that an error was inadvertently made in the permit. Accordingly, we are forwarding
herewith modifications to the subject permit to correct the error. The modifications are as follows:
sample type for the Acute Toxicity monitoring requirement has been changed to composite on the
Effluent Limitations page to reflect the requirements of Part III, Condition D.
Please find enclosed the amended Effluent Limitations page which should be inserted into
your permit. The corresponding old sheet should be discarded. All other terms and conditions
contained in the original permit remain unchanged and in full effect. This permit modification is
issued pursuant to the requirements of North Carolina General Statutes 143-215.1 and the
Memorandum of Agreement between North Carolina and the U. S. Environmental Protection
Agency.
If any parts, measurement frequencies or sampling requirements contained in this permit
are unacceptable to you, you have the right to an adjudicatory hearing upon written request within
thirty (30) days following receipt of this letter. This request must be in the form of a written
Regional Offices
Asheville Fayetteville Mooresville Raleigh Washington Wilmington Winston-Salem
704/251-6208 919/486-1541 704/663-1699 919/571-4700 919/946-6481 919/395-3900 919/896-7007
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

Page Two
Mr. Repsher
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.
If you have any questions concerning this permit modification, please contact Charles M. Lowe
at telephone number 919/733-5083.
Sincerely yours,
Preston Howard, Jr., P.E.
Acting Director
cc. Mr. Jim Patrick, EPA
19 oresvifle Regional Office
Permits and Engineering Files
Environmental Sciences Branch
Compliance
Central Files
1

A. ( ). El4NLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL Permit No. NC0079898
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from outfall
serial number 001. Such discharges shall be limited and monitored by the p-iinittee as specified below:
Effluent Characteristic Discharge Limitation: Monitorina Requirements
Lbs/day Units (specify Measurement Sample
'Sarnpl@
Mon. Avg. Daily Max Mon. Avg. Daily Max, Frequency Type L_gcatian
Flow Continuous Recording E
Oil and Grease 30.0 mg/I 60.0 mg/I 2/Month Grab E
Acute Toxicity'" Quarterly Composite E
Organics"' Quarterly Grab E
Phenols 0.001 2/Month Grab E
Barium 238.0 ug/I 2/Month Grab E
1,1 - Dichloroethene 81 .0 ug/1 Quarterly Grab E
* Sample locations: E - Effluent
** Acute Toxicity (Daphnid 48 hr) LCSO 42%; January, April, July and October; See Part HI, Condition D.
*** See Part III, Condition E.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored 2/month by grab sample at the
effluent.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Michael F. Easley, Governor Wiiiiarn G. Ross, Jr., Secretary
Coleen H. Sullins, Director
August 15, 2008
Mr. Steve Olp E
CNA Holdings, Inc. RECLVEL
P.O. Box 819026
Dallas, TX 75381
AUG 1S
Subject: Renewal Notice
NPDES Permit NC00798
Needmore Road Landfill NC DENR MR0
Rowan County DWQ Surface Water Protect�c
Dear Permittee:
Your NPDES permit expires on March 31, 2009. Federal(40 CFR 122.41) and North Carolina(15A
NCAC 2H.0105 (e))regulations state that permit renewal applications must be filed at least 180 days prior
to expiration of the current permit. If you have already mailed your renewal application,you may
disregard this notice.
Your renewal package must be sent to the Division postmarked no later than October 2, 2008.
Failure to request renewal by this date may result in a civil penalty assessment. Larger penalties may be
assessed depending upon the delinquency of the request.
If any wastewater discharge will occur after March 31,2009,the current permit must be renewed.
Discharge of wastewater without a valid permit would violate North Carolina General Statute 143-215.1;
unpermitted discharges of wastewater may be assessed civil penalties of up to $25,000 per day.
Nall wastewater discharge has ceased at your facility and you wish to rescind this permit, contact
me at the telephone number or address listed below.
Use the enclosed checklist to complete your renewal package. The checklist identifies the items you
must submit with the permit renewal application. If you have any questions,please contact me at the
telephone number or e-mail address listed below.
Sincerely,
Vtiviff/7/
Charles H. Weaver,Jr.
NPDES Unit
cc: Central Files
Mooresville Regional Office, Surface Water Protection
NPDES File
1617 Mail Service Center, Raleigh,North Carolina 27699-1617 One
512 North Salisbury Street,Raleigh,North Carolina 27604 North Carolina
Phone: [phone] FAX [phone]/[e-mail] Naturally
An Equal Opportunity/Affirmative Action Employer—50%Recycleci110%Post Consumer Paper

NPDES PERMIT NC0079898
NEEDMORE ROAD LANDFILL
ROWAN COUNTY
The following items are REQUIRED for all renewal packages:
•
➢ A cover letter requesting renewal of the permit and documenting any changes at the facility since
issuance of the last permit. Submit one signed original and two copies.
➢ The completed application form (copy attached), signed by the permittee or an Authorized
Representative. Submit one signed original and two copies.
> If an Authorized Representative (such as a consulting engineer or environmental consultant) prepares
the renewal package, written documentation must be provided showing the authority delegated to any
such Authorized Representative (see Part ILB.11.b of the existing NPDES permit).
> A narrative description of the sludge management plan for the facility. Describe how sludge (or other
solids) generated during wastewater treatment are handled and disposed. If your facility has no such
plan (or the permitted facility does not generate any solids), explain this in writing. Submit one signed
original and two copies.
The following items must be submitted by any Municipal or Industrial facilities discharging
process wastewater:
Industrial facilities classified as Primary Industries (see Appendices A-D to Tide 40 of the Code of Federal
Regulations, Part 122) and ALL Municipal facilities with a permitted flow ? 1.0 MGD must submit a
Priority Pollutant Analysis (PPA) in accordance with 40 CFR Part 122.21.
The above requirement does NOT apply to privately owned facilities treating 100%
domestic wastewater, or facilities which discharge non process wastewater (cooling
water, filter backwash, etc.)
Send the completed renewal package to:
Mrs. Dina Sprinkle
NC DENR / DWQ / Point Source Branch
1617 Mail Service Center
Raleigh, NC 27699-1617

Celanese
Steve Olp Celanese Americas Corp.
Sr.Manager 2848 Cherry Road—St.100
Global Remediation Rock Hill,SC 29730
USA
Phone: [phone]
Telefax: 803-235-6210
[e-mail]
January 24,2005
North Carolina Department of Environment and Natural Resources
Division of Water Quality
1617 Mail Service Center
Raleigh,NC 27699-1617
USPS CERTIFIED MAIL#7002 2030 0001 8158 9693—RETURN RECEIPT REQUESTED
SUBJECT: Monthly Water Quality Monitoring Report December, 2004
NPDES Permit No.NC 007 9898
CNA Holdings,Inc. (formerly HNA Holdings, Inc.)
Needmore Road former Landfill
Dear Sirs:
The December,2004 Water Quality Monitoring Report for the CNA Holdings, Inc.(formerly HNA
Holdings, Inc.)facility located near Salisbury,NC (Needmore Road former Landfill)is enclosed.
This letter is to advise the DWQ that monthly samples for December,2004 were not collected at the above
noted facility. There was no discharge during this reporting period.
I certify under penalty of law that 1 have personally examined and am familiar with the information
submitted in the attached documents;and based on my inquiry of those immediately responsible for
obtaining the information. I believe the submitted information is true,accurate and complete. I am aware
that there are significant penalties for submitting false information including the possibility of fine and
imprisonment.
Very truly yours,
CNA Holdings, Inc./Celanese Americas Corporation
oc4
Steve Olp
Senior Manager
Global Remediation
Enclosures: DEM Form MR-1 (Original and One Copy)
cc: E. W.Glover—Earth Tech-Roswell,GA(Review and File)
Rob Holland—Earth Tech-Raleigh
File: Needmore Road/NPDES/DMRs 2004

EFFLUENT I(NW
JAN 2 7 2005
NPDES Permit No. NC0079898 Discharge No. 1 Month December Year 2004
Facility Name CNA Holdings, Inc. - Needmore Rd Landfill Class NA County Rowan
Operator In Responsible Charge(ORC) Rob Holland Grade I Phone [phone]
Certified Laboratories 1) 2)
Check Box it ORC Has Changed U Person(s) Collecting Samples N/A
Mail ORIGINAL and ONE COPY to:
ATTN_CENTRAL FILES ii
DIVISION OF WATER QUALITY X rW ( Cam- I, .,'r,4 .It ,.7 e?/ / l),V/U`}_
1617 MAIL SERVICE CENTER (SIGNATURE F OPERATOR IN RESPONSIBLE CHARGE} MATE '
RALEIGH,NC 27699-1617 By This Signature.I Certify That This Report Is
Accurate And Complete To The Best Of My Knowledge.
5GG50 00625 00665
'a a1 - .
r. FLOW Fo
o N m N
m E Elf X H O cn �' °c o_ c
m 2
p ¢ ~ o INF Z Z U 0 F O L Q o ° a
mN a o m od a_ no 1 z
a) ',, 0 Daily o 6 L O 2
0 o Rate z g 0
HRS HRS Y,'N MGD MG.L MG'L 042°e MG/1_ Marl mat MOIL MG'._ UG1L MG'L F.1CL M:91_ OGt ru
1 N
2 8'.00 AM 2.00 Y 0.0000 `
3 N
4 N
5 N
6 N
7 N
_8 -. N �.
9 8:00 AM 2.00 Y 0.0000
10 N
11 N
12 N
13 _ N
14 N
15 N E.6 0 7 rn; ^
16 8:00 AM 2.00 Y 0 0000
17 N
18 N
19 N
.
20 N
21 N _
22 N
23 8:00 AM 2.00 Y 0.0000
24 N
25 N w
26 N _
27 N
28 N _ -
29 N
30 8:00 AM 2.00 Y 0.0000
31 N
AVERAGE 0.0000 rya rya rva - Na n'a Na n/a n/a n:'a rYa na n'a Iva _
MAXIMUM 0.0000 We n/a ri/a n/a L. n/a n/a n/a n/a nla n/a ri/a n/a n/a n/a
MINIMUM 0.0000 nla n'a n/a n/a Na n'a rya n?a n-a rya n'a i>a n'a rva
l Comp.(C)/Grab(G) R C C C C C G G C G C C C C G
Monthly Limit 0 288 0.42% 30 .30 30 61.9
DLC For-1 1,29�00

-.4111111111
Facility Status: (Pleases k One of the Following)
All monitoring data and sampling frequencies meet permit requirement: X
Compliance
All monitoring data and sampling frequencies do NOT meet permit requirement:
Non-Compliance
If the facility is noncompliance,please comment on corrective actions being taken in respect to equipment, operation,
maintenance,etc.,and a time table for improvements to be made.
Monthly samples were not collected because there was no discharge during this reporting period.
"I certify, under penalty of law,that this document and all attachments were prepared under my direction or supervision in accordant
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."
CNA Holdings, Inc.
Permittee (Please print or type)
••• I /2—
Signature of Permittee— Date
2848 Cherry Road Ste. 100 Rock Hill SC 29730 803-325-6176 3731/2009
Permittee Address Phone Number Permit Exp. Date
PARAMETER CODES
00010 Temperature 00556 Oil&Grease 00951 Total Fluoride 01092 Zinc 50060 Total Residual
00076 Turbidity 00600 Total Nitrogen 01002 Total Arsenic 01105 Aluminum Chlorine
00080 Color(Pt-Co) 00610 Ammonia Nitrogen 01027 Cadmium
00082 Color(ADMI) 00625 Total K)eldhal 01032 Hexavalent 01147 Total Selenium 71880 Formaldehyde
Nitrogen Chromium
00095 Conductivity 00630 Nitrates!Nitrite 01034 Chromium 32730 Total 31616 Fecal Conform
Phenolics
00300 Dissolved Oxygen 00665 Total Phosphorous 01037 Total Cobalt
00310 BODS 00720 Cyanide 01042 Copper 34235 Benzene 71900 Mercury
00400 pH 00745 Total Sulfide 01045 Iron 34481 Toluene
00530 Total Suspended 00927 Total Magnesium 01051 Lead 38260 MBAS 81551 Xylene
Residue 00929 Total Sodium 01067 Nickel 39516 PCBs
00545 Settleable Matter 00940 Total Chloride 01077 Silver 50050 Flow 00340 COD
Parameter code assistance may be obtained by calling the Water Quality Compliance Group at(919)733-5083,extension 581 or 534
`CRC must visit facility and document visitation of facility as required per 15A NCAC 8A.0202(b)(5)(B).
The monthly average for lecal conform is to be reported as a GEOMETRIC mean.Use only units designated in the reporting facility's
permit for reporting data.
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)
DLC Form-2eace4 1129l00

04/12/2004 11:03 919-733-1330 DEHR 44ATER QUALITY PN. 81/01
NU DEPT.017 ENVIRONMti►11
AND NATI JP ; RESOURCES
Water Pollution Control System ORC Designatioracirm
WPCSOCC
NCAC 15A:08G .0201
MAY 2 C 4
General Information:
Permittee Owner/Officer Name:C- / 1 4 14-kW, ,-'S , N G
Mailing Address: lP- o I `)( 3 2 M 111
City; C r State: NC— Zip: a&23Z -
Telephone Number: (-3-o4 ) 55 )
Signature: Date: 5//cr/'ds
Facility Information:
Facility: CN A 1-Wt i,.se.5 #N c. - pe �Muur t� l j
�C-60 99 �8 Count Y`l�r2w�ti
Permit Number: Y�
SUBMIT A SEPARATE FORM FOR EACH TYPE OF SYSTEM
Mark(X)Type of Facility Class (1 -4) Class
Wastewater Plant Spray Irrigation NA
Physical/Chemical �i! I Land Application N/A
Collection System Subsurface N/A
Operator in Responsible Charge:
Print Name: to,t Social Security#: zqo- F`C
Certificate Type and Grade: Certificate#: 27 /._
Work Telephone: (211J 4.4S Signature: .-
Back-Up Operator in Responsible Charge:
Print Name; .3 6 11 N / (iv It Social Security#: 6 7 G _ 4.0 - 7 7 3 2
Certificate Type and Grade: _ r P1 c1 e l � �� Certificate#: '2'7 4- 4
Work Telephone: 31 '1 ) 8 C4- r; ;/ 3,2_ Signature:
,7
Mail or Fax to: WPCSOCC
161E Mail Service Center
Raleigh,N.C.27699-1618
Fax: [phone]
Revised 10/2000

701 Corporate Center Drive, Suite 475, Raleigh, NC 27607
1111CCEPT.OF EIN1RONIAti
lik
N Ti� ' PEOOURCESItk
1100RES) '
April 6,2004
Mr. D. Rex Gleason, P.E.
Water Quality Regional Supervisor APR L 7 2004
Division of Water Quality •
North Carolina Department of Natural Resources(NCDENR) .:
919 North Main Street
Mooresville,North Carolina 28115 wATE, •.� TY TIAt
to
USPS CERTIFIED MAIL #7002 010 0003 3868 5978-RETURN RECEIPT REQUESTED
Subject: ORC Change Notification
NPDES Permit No. NC 0079898
CNA Holdings,Inc. (formerly HNA Holdings,Inc.)
Needmore Road former Landfill
Telephone
Dear Mr.Gleason:
919.854.6200
The ORC of the above noted site will change effective April 9 2004. Please address future
correspondence to: Facsimile
Robert Holland 919.854.6259
Earth Tech, Inc.
701 Corporate Center Drive, Suite 475
Raleigh,NC 27607
Phone: [phone]
FAX: [phone]
E-Mail: [e-mail]
Please call Rob at 919.854.6241 if you have any questions.
Very truly yours,
Earth Tech, Inc.
--44.1 cA:2-4—
Richard D. Park
Project Manager
cc: Steve Olp(Celanese Americas Corp.)
Everett Glover(Earth Tech—Roswell, Ga)
E A R T H ` 7 ECH
Aiwa INTERNA77QNAL LTD,COMPANY

MAY-03--2004 MON 06 07 AM ENV SCIENCES BRANCH FAX NO. 919 733 9959 P. 01
IL-77G. riG("' 701 Corporate Center Drive, Suite 475, Raleigh, NC 27607
C./VA 1/OA-6. tAl
April 6,2004
Environmental Science firanch
Division of Water Quality
North Carolina Deparinient of Natural Resources(NCDENR)
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
IISPS CERTIFIED MAIL#7002 0510 11003 3RM 5961-RETURN REC'#sIPT REOUE4TED
Subject: OIR.0 Change Nolifcatiort
NPI)HS Permit No. NC 0079898
CNA Holdings,Inc.(formerly DNA Ifoldings,Inc.)
Neecdmore Road former Landfill
Environmental Science Branch: Telephone
The [ RC of the above noted site will change eflcctive April 4 2004. Please address future 919.854.6200
correspondence to:
Facsimile
Robert[Wand
Earth'tech,Inc. 919.854.6259
701 Corporate Center Drive, Suite 475
Raleigh,NC 27607
Phone: [phone]
PAX: 919.854.6259
E?-Mail: )[e-mail]
Please call Rob at 919.854.6241 if you have any questions.
Very truly yours,
Earth`I'cch,Inc.
iZ z (
Richard 1:). Park
Project Manager
cc: Steve O1p(Celanese Americas Corp.)
Everett Clover Mirth Tech--Roswell,Cra) f;.,`
hitt
acji
\jV 7a4-t67Cn3. 6040
ETMVOnm,r,laf Scktrtc s Bratrc?
CZ.. `T le0 e./)s(l f tl lU 6. 1310 Of rt-
7'3 , f331sE A R T H ® r E C 11
l.'t-'- C fijie-tc:G `fYi Ub-G.- f 3160- II#yc01N1�RNAT1Uwt 1rr>,COM1s1NY
7 3,5. O` fq u�•t V.

._ ...�,a.—,.,.... . ..,41E1 X...ev..1.ey.ea:xs.--• 044, f.- ..r w.'.v..*w,a, :.,V4Li w:r..A...tas'w-,..r.w:..!_....:•
JUN-23-2003 MON 07:09 AM FAX NO. P. 01
3.3S2 Waltzer Store Road, Franlclinville, North Carolina 27248
Sits Gt%C---
�J
f p r f`i Ccr" •
.Iulic 19.2003
f'uvirorunental Science Branch
I)ivicion of Water Quality
North Carolina Department of Environment and Natural Resources(NCDENK)
162 I Mail Service Center
Raleigh, North Carolina 27699-1621
•
USPS CERTIFIED MAIL #7002 0510 0003 1628 5848-RETURN RECEIPT REQUESTED
Subject: Scheduled Quarterly Water Quality Monitoring(May 2003) i
NPIIIH:S Permit No. NC 0079898
CNA Holdings,Inc. (formerly UNA ilulclings,Inc.)
Necdniore Road former Landfill '
Telephone
l.;nviiorilnental Science Branch. r
3.36 824.9178
This letter i, to advise the Environmental Science Branch that Chronic Toxicity samples for
May 2003 were not collected at the above Poled facility. Facsimile
33Ci.82'1.9179
Active extraction was suspended during the summer drought as communicated to the State in
August 2002. Surface water monitoring during the low stream flow periods did not detect
site related chemicals of interest. This was communicated to Mr. Mark Poindexter and Ms.
Cheryl Marks of the NC:1)IiNR Division of Waste Management, Solid Waste Section in a
letter clued December 2002_ In this letter, ('NA proposed to leave the groundwater
extraction and treatment system shut down unless directed to resume pumnpiug by the State.
'[his is consistent with Celanese's Phase 11 rentediation proposal consisting of discontinuing
the extraction and treatment of groundwater while continuing to monitor site groundwater
and adjacent surface water. 'the plan to not resume pumping was supported by an
independent review of the technical data by Ms. Natalie Sierra of the NCDLNR Division of
Water Quality, NP1)I.S Unit. Celanese will coulinuc to monitor the silirnitiorr and report as
appropriate.
Please call(336)215-1782 if you have any quesrintt,s.
Very truly yours,
difecr' Gale I r -+ar
:alit),Ted', Jllc. �'f Z�I f� r�RgeS� I
From
y �+ i[7 F.-AD',"1 i S n
Co
lzich,trd Park 1. ...
--� -'nhonc,sr
I'rnject Ma nn ei'
I. -- i
(•C. S l•NT d ra II
cc. Steve Olp(Celanese Americas Corp.) .. . . .. _„T__ - .. —
Everett Everett Glover(Earth Tech— Roswell, GA) .fl ff0) -
Scicitcc,tray,
E A R l iI ��.,/ ( E C R

JUN-04-2003 WED 12:28 PM FAX NO. P. 01
50<- Cc r--
�< 1 it cl'--
338i Walk.'r Store RO.iA, franlclinvillc, Nord, Carolina 2724E
Post-it"Fax Note 7671 Do mot 1
5 pauua
10
May 19, 2003 :.,'°:°:P71-0
��>/e'1J j 1: rrom
Cn
E.nViroliiiient�il Science Branch 1PtrontrrDivision of Water Quality G�3 f� Fax i ^-'
North Carolina Department of Environment and Ni — - - ---
1621 Mail Service Center — _. ... -
Raleigh,North Carolina 27699-1621
USPS CERTIFIED MAIL N7002 0510 0003 1628 5855 - RETURN RECEIPT REQUESTED
• Subject Scheduled Quarterly Water Quality Monitoring(April 2003)
NPDES Permit No. NC 0079898 TelepIto,ie
CNA Holdings, Inc. (formerly HNA Holdings,Inc.)
Needmore Road former Landfill 336.524.9178
Environmental Science Branch: r""rr,itc
•
30.s:.1.gi79
•
This letter is to advise the Environmental Science Branch that Chronic Toxicity samples for
Apiii 2003 were not collected at the above noted facility.
Active extraction was suspended during the summer drought as communicated to the State in •
August 2002 Suilicc water monitoring during the low stream flow periods did not detect
site related chemicals of interest This was communicated to Mr_ Mark Poindexter and Ms.
Cheryl Marks of the NCDENR Division of Waste Management, Solid Waste Section in a
letter dated December 2002. In this Zeller, CNA proposed to leave the groundwater
extraction and treatment system split down unless directed to resume pumping by the State,
This is consistent with Cetanese's Phase II rcmediation proposal consisting of discontinuing
the extraction and treatment of groundwater while continuing to monitor site groundwater
and adjacent surface water. The plan to not resume pumping was supported by an
independent review of the technical data by Ms. Natalie Sierra of the NCDENR Division of
Water Quality, NPDES Unit. Celanese will continue to monitor the situation and report as
appropriate.
Please call [phone] if you have any questions
Very truly yours,
• Earth I'ell, Inc
RECE1V ''LL)
Richard Park
Project Manager MAY 2 1 2003
cc: Steve Olp(Celanese Americas Corp.)
Everett Glover(Earth Tech-Roswell,GA) r,virtroetttal 5ciances Brand',
v/ , • ti{ es5ct- - MA0 w�T F, ¢Jc�
CG . _.�—
vrn sty 1�1LS �r \
E A Et t IC � �r � c H ". A
NCO iNTf,RNA7k)ry/lr t fi7.COWAN!'

\N A rk
C R Michael F.Easley
\-\ QG Governor
/j William G. Ross,Jr.,Secretary
// / Department of Environment and Natural Resources
Q Alan W.Klimek,P.E., Director
Division of Water Quality
March 24,2003
CERTIFIED MAIL
RETURN RECEIPT REQUESTED DEP'-kJ, s+�• tiv.aiasL�k)
NATURAt
Mr.Rick Ramirez RC '
CNA Holdings,Inc. , Mk
P.O.Box 32414 K°
Charlotte,North Carolina 28232
MAP
Subject: NOTICE OF VIOLATION 2 6 2003
Effluent Toxicity Testing
NPDES Permit No.NC0079898
WATER QUALI'v
CNA Holdings,Inc.—Needmore Rd. Landfill •
Rowan County
Dear Mr.Ramirez: SEMI
This is to inform you that the Environmental Sciences Branch has not received your toxicity self-monitoring
report form for the month of January 2003. This is in violation of Title 15A of the North Carolina Administrative Code,
Chapter 2,Subchapter 2B,Section.0506(a)(1)(A)which states that"monthly monitoring reports shall be filed no later
than 30 days after the end of the reporting period for which the report is made."
Information contained on your January 2003 Discharge Monitoring Report(DMR)indicated"groundwater
extraction and treatment system is shut down";however,the Environmental Sciences Branch did not receive the Aquatic
Toxicity Test Form within the 30 day reporting period.
The reporting of toxicity self-monitoring data is a dual requirement. You are required to submit an Aquatic
Toxicity(AT)test form to this office labeled"no flow"during a required toxicity testing month in which the facility does
not discharge. In addition,you are required to submit a monthly DMR to DWQ's Central Files indicating no flow.
Addresses for our office and Central Files are located on the reverse side of this correspondence.
Your NPDES Permit contains the following language:"Should there be no discharge of flow from the facility
during a month in which toxicity monitoring is required,the permittee will complete the information located at the top of
the aquatic toxicity(AT)test form indicating the facility name,permit number,pipe number,county,and the month/year
of the report with the notation of"No Flow"in the comment area of the form. The report shall be submitted to the
Environmental Sciences Branch at the address cited above."
Please be advised that late and/or non-reporting of toxicity self-monitoring data subjects you to the enforcement
authority of the Division.
The reverse side of this Notice contains a summary of important toxicity monitoring and reporting
requirements. Please read this one page summary and if you have any questions concerning this Notice please contact
Mr. Kevin Bowden with the Aquatic Toxicology Unit at(919)733-2136.
Sincerely,
•
imm Overton
Assistant Water Quality Section Chief
For Environmental Sciences
cc: Rex Gleason-Mooresville Regional Office
John Lesley-Mooresville Regional Office
Aquatic Toxicology Unit Files
4, Central Files
NCDENit
Customer Service Environmental Sciences Branch 1621 Mail Service Center Raleigh, NC 27699-1621 [phone]
1-800 623-7748

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
> The following items are provided in an effort to assist you with identifying critical and sometimes overlooked toxicity
testing and reporting information. Please take time to review this information.The items below do not address or include
all the toxicity testing and reporting requirements contained in your NPDES permit. If you should have any questions
about your toxicity testing requirement, please contact Mr. K-evin Bowden with the Aquatic Toxicology Unit at(919) 733-
2136 or another Unit representative at the same number.
> The permittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement and that
toxicity report forms are appropriately tiled.
> The reporting of whole effluent toxicity testing data is a dual requirement. All toxicity test results must be entered(with the
appropriate parameter code)on your monthly Discharge Monitoring Report which is submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh,NC 27699-1617
IN ADDITION
Toxicity test data(original"AT"form)must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
Toxicity test results shall be filed with the Environmental Sciences Branch no later than 30 days after the end of the
reporting period(eg,January test result is due by the end of February).
> Toxicity test condition language contained in your NPDES permit may require use of multiple concentration toxicity testing
upon failure of any single quarterly toxicity test. If the initial pass/fail test fails or if the chronic value is lower than the
permit limit,then at least two multiple concentration toxicity tests(one per month)will be conducted over the following two
months. As many analyses as can be completed will be accepted. If your NPDES permit does not require use of multiple
concentration toxicity testing upon failure of any single quarterly test, you may choose to conduct either single
concentration toxicity testing or multiple concentration toxicity testing per the Division's WET enforcement initiatives
effective July 1, 1999. Follow-up multiple concentration toxicity testing will influence the Division's enforcement response.
> Toxicity testing months are specified by the NPDES Permit, except for NPDES Permits which contain episodic toxicity
monitoring requirements (eg, if the testing months specified in your NPDES permit are March, June, September, and
December,then toxicity testing must be conducted during these months).
> Should the permittee fail to monitor during a month in which toxicity monitoring is required,then monthly monitoring will
begin immediately until such time that a single test is passed. Upon passing this monthly test requirement,the permittee will
revert to the quarterly months specified in the permit. Please note that your permit may or may not contain this language.
> If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January 1-June 30,
then you must provide written notification to the Environmental Sciences Branch by June 30 that a discharge did not occur
during the first six months of the calendar year.
> If you receive notification from your contract laboratory that a test was invalidated, you should immediately notify the
Environmental Sciences Branch at [phone] and provide written documentation indicating why the test was
invalidated and the date when follow-up testing will occur.
> If your facility is required to conduct toxicity testing during a month in which no discharge 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. You should also write"No Flow"on the AT form,sign the form and submit following
normal procedures.
> The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Responsible Charge(ORC)except for facilities
which have not received a facility classification. In these cases,a duly authorized facility representative must sign the AT
form. The AT form must also be signed by the performing lab supervisor.
> To determine if your AT test forms were received on time by the Division of Water Quality,you may consider submitting
your toxicity test results certified mail,return receipt requested to the Environmental Sciences Branch.

Frir ``j .
V 1455 Old Alabama Road, Suite c7o, Roswell, Georgia 30076
f
January 27, 2003 ' RECFR/Frt
Mr. Wes Bell JAN 3 0 2003
Division of Water Quality
North Carolina Department of Environment and Natural Resources liftigEFrt OF tNVtrs1. IN!€MT
919 North Main Street M1RAATURAL RESOURCES
ROBROVRIE Mooresville,North Carolina 28115
REGIONAL F
Subject: Confirmation of Teleconference, Compressor Repair
Groundwater Treatment Facility
NPDES Permit No.NC0079898
CNA Holdings, Inc. (formerly HNA Holdings, Inc.)
Closed Needmore Road Landfill
l).9 9" 1 41)11
Gentlemen:
I ,il l nli3r
This letter is to confirm our telephone conversation on January 13 discussing the repair of the
air compressor associated with the groundwater treatment facility. The compressor wasI .1,}, s,21
damaged, apparently during the ice storm in early December. Examination of the compressor
by a service technician indicated that repairs or replacement would be on the order of$6000.
Since operation of the groundwater extraction and treatment is currently suspended as
discussed in subsequent paragraphs, it was agreed that the compressor repairs did not need to
occur unless the system was restarted. In the event the system is restarted, the compressor
will be repaired or replaced prior to restarting the treatment operation.
CNA Holdings, Inc. owns and maintains the groundwater extraction and treatment system
proximate to and down gradient of their closed solid waste landfill. Operation of the system
was suspended in August 2002 during the severe drought experienced by the area. Prior to
and subsequent to the suspending operations, CNA has been working with the Division of
Waste Management to obtain approval of a revised remediation plan consisting of
termination of active groundwater extraction and treatment. This plan was based on risk
assessment and groundwater modeling that showed that termination of the active remediation
would not adversely affect surface water quality. Routine monitoring and reporting would
continue under the revised remediation plan. During the drought condition, surface waters
were monitored and did not detect site-related compounds. Although formal approval of the
revised remediation plan has not been received, CNA has communicated their intent to not
resume active remediation during the approval process. This is based on conversations with
Mark Poindexter and Cheryl Marks with the Division of Solid Waste, and a review of the
proposed revision to the remedial approach by Natalie Sierra with the Division of Water
Quality-NPDES Unit. In her review, Ms. Sierra states "The proposal [to shut down the
discharge system] does not appear as if it will have a net negative impact on surface water
quality." [Explanation added] (Memo from Sierra to Marks, December 9, 2002).
Li1 EYORK4Projectsl40064IWordProc\nr301241.doc 1/27/2003
sf
E A R 7 H `m T E C ti
A two INTERNATIONAL LTD.COMPANY

1455 Old Alabama Road, Suite 17o, Roswell, Georgia 3ou76
NC DEpT.of rk; teiA''�: irT
\r 1,
L. MIDOR ::4' ,'_wo;'_icFg
August 20, 2002
rr
Mr. Wes Bell 1
Division of Water Quality AUG 2 2 200F 2 ^"f fC
North Carolina Department of Environment and Natural Resources
919 North Main Street
Mooresville,North Carolina 28115 f'-
Mr. Larry Rose
Division of Waste Management
North Carolina Department of Environment and Natural Resources
1646 Mail Service Center
Ione
Raleigh,North Carolina 27699-1646 l ° `ph
Subject: Temporary Suspension of Groundwater Extraction and Treatment € .i I.
NPDES Permit No.NC0079898
CNA Holdings, Inc. (formerly RNA Holdings, Inc.) „ t ,
Closed Needmore Road Landfill
Gentlemen:
This letter is to confirm telephone conversations on August 15 discussing the current and
near-future operation of a groundwater extraction and treatment system at the closed
Needmore Road Landfill near Salisbury, Rowan County, North Carolina. Earth Tech
provides the operator in responsible charge(ORC)and routine reporting for this facility.
CNA Holdings, Inc. operates a groundwater extraction and treatment system proximate to
and down-gradient of their closed solid waste landfill. This system normally operates on a
batch basis as the groundwater extraction wells fill a flow equalization tank. When the
system was to be started in mid-July, it was determined that the system was not operational.
Troubleshooting of the system determined that there had been a failure of one of the
communications cards in the process control system. This was repaired August 15, 2002, and
the system was tested and determined to be operational. Prior to resuming normal treatment,
the outfalI was inspected and the effluent diffuser ports were exposed in the South Yadkin
River due to the drought persisting in central North Carolina. Due to the presence of a
drinking water intake for Davie County located on the South Yadkin River approximately 1.8
miles downstream of the site and the extreme low water conditions in the river, it is planned
to temporarily suspend groundwater extraction and treatment until the flow in the South
Yadkin River returns to a more normal flow condition. During this time, Discharge
Monitoring Reports (DMR form MR-1) and Effluent Toxicity Reports (form AT-1) will
continue to be filed in accordance with the site's NPDES permit. During the subsequent
L:IWORKIProjects140064I WordProc14006496.doc 8/20/2002
sr
E A R T H ` r E C C1
A two INTERNATIONAL LTD COMPANY

Mr. Wes Bell
January 27, 2003
Page 2
As stated in the preceding paragraph, routine monitoring and reporting are an integral part of
the revised remediation plan. This monitoring and reporting will continue throughout the
evaluation period. In the event that the State does not approve the revised remediation
proposal, the air compressor will be replaced or repaired and extraction and treatment
resumed. You will be notified as changes occur.
If you have questions, please contact the writer at 770.990.1410.
Sincerely,
Earth Tech,Inc.
'.-t-(57 ilLki1/-
tb( t)42114.
,9L..
Everett W. Glover, Jr. P.
Project Manager
cc: Steve Olp, CNA Holdings, Inc.
Alan Pinnix, ARCADIS
Richard Park, Earth Tech
L.1 WORKIProjecIs1400641 WordProc1nr301241.doc 1/27/2003
sf
EAR ECH
A ti1CQ INTERNATIONAL LTC COMPANY

Mr. Wes Bell
Mr. Larry Rose
August 20,2002
Page 2
months, the stream flow will be monitored, and CNA will plan to resume extraction and
treatment when reasonable stream flow is re-established.
Thank you for your consideration in this matter. If you have questions, please contact the
writer at 770.990.1410, or Mr. Steve Olp at 704.554.3892.
Sincerely,
Earth Tech,Inc.
W ! '
Everett W. Glover, Jr. P.E.
Project Manager
cc: Cheryl Marks,NCDENR-DWM
Kevin Bowden,NCDENR-DWQ
Steve Olp, CNA Holdings, Inc.
Alan Pinnix, ARCADES
Richard Park, Earth Tech
L:4WORKKProjecis1400641 WordProc14006496.doc 8/10/2002
sr
EAR I H T E C M

3382 Walker Store Road, Franklinville, North Carolina 27248
\ t `T.Cir`ENVIRONMENT
\ / AN NATU AL 1tEGoui cEs
\� ' MOORFS`.ii!. '. '! -,
!•...
/
July 30, 2002 1
•
Mr. D. Rex Gleason, P.E. JUL 3 1 2002
Water Quality Regional Supervisor
Division of Water Quality •
North Carolina Department of Natural Resources(NCDENR)
919 North Main Street °1 T m., "'""n---,A
Mooresville,North Carolina 28115
t
LISPS CERTIFIED MAIL #7002 0510 0003 1628 5640-RETURN RECEIPT REQUESTED
Subject: ORC Change Notification
NPDES Permit No.NC 0079898
CNA Holdings,Inc.(formerly HNA Holdings, Inc.)
Needmore Road former Landfill
Telephone
Dear Mr. Gleason:
336.824.9178
Please note the address change for the ORC of the above noted site. I assumed duties as the
ORC from Eric Lintz on July 15, 2002. Please address future correspondence to me at 3382 Facsimile
Walker Store Road, Franklinville,NC 27248.
336.824.9179
Please call me at 336-215-1782 if you have any questions.
Very truly yours,
Earth Tech, Inc.
&J,a„,.1 .0 721_
Richard D. Park
Project Manager
cc: Steve Olp(Celanese Americas Corp.)
Everett Glover(Earth Tech—Roswell,Ga)
EARTHT E CH
A two INTERNATIONAL LTD.COMPANY

AUG-01-2002 THU 02:27 PM FAX NO. P. 01/01
3392 Walker Store Road. Fr.inklinvitle. North Carolina 27248 '
RECEIv a;
July 30,2002
C:uvironrnental Science Branch JUL 3 1 2002
Division of Water Quality
North Carolina Department of Natural Resources(NCDENR) Envlrn!•vrental SelinC+1513r&neh
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
LISPS CERTIFIED MAIL 07002 OS j0 000 i Z 62R 5664-RETURN RECEIPT REM.;ESTED
Subject; ORC Change Notification
NPDES Permit No.NC 0079898
CNA[Holdings,Inc.(formerly 11111A Holdings,Inc.)
Need more Road former Landfill
•
f:nvirunrnentul Science Branch: Telephone '
,
Picsso nowthe address change for the ORC of iltc alive noted site. T assumed duties as the 335 82 9l78 1
ORC from l;ric lint.on July 15, 2002. Please address future eorrespondencc to me at 3382
Walker Store Road,Frtnklinville,NC 27248. F,cci,nilu
Please call me at 336-215-1782 if you have any questions, 336'8z1'91 79
Very truly yours,
Earth Tech, Inc.
- a-a/4,4j 6 /-:.,.....L.,
Richard D. Park
Project Manager
cc: Steve Olp(Celanese Americas Corp.)
Everett Glover(Earth Tech—Roswell,Oa)
t4-'I o4 Tail IAp it)e- 4, Ce trlrte.a7 'V jot 111A- 4-
,70I A) I,b c 4 bir AtO.o frrr(a )_ v, MK
Post-it'Fak Note 7671 Dan ,al"—
To rlf�ifG2. n�� /
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r3 tr /� f�4ttl r N �owc�c.,tl
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Phone p
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EAR TH TECH
0
A tgco IN(LRNRROML LW.WMPaW

Q✓ William G.Ross Jr., Secretary
co North Carolina Department of Environment and Natural Resaurt es
1 Alan W.KlimeF.,?.E.,Director
� 'C Droision of Water Quality
July 12, 2002
Mr. Eric K. Lintz, P.G.
Earth Tech •
311-J South Westgate Drive
Greensboro, North Carolina 27407
Subject: ORC Change Notification
C.N.A. Holdings, Inc.
NPDES Permit No. NC0079898
Rowan County,NC
Dear Mr. Lintz:
This Office received your correspondence, ORC Change Notification, on July 11, 2002.
Please submit the attached ORC Change Form to the Division's Technical Assistance and
Certification Unit.
Should you have any questions concerning the form please do not hesitate to contact me
at 704-663-1699 ext. 270.
Sincerely,
ohn Lesley
Environmental Specialist II, MRO
•
71 ET:
N.C.Division of Water Quality 919 North Main 5tree:, Mooresville NC 26115 Phone[phone]
FAX [phone]

r 31 -J South Westgate Drive, Greensboro, North Carolina 27407
!\ 11, 1:1C.\11/4
r
IA /
July 9, 2002 RECEIVED
Mr. D. Rex Gleason, P.E.
Water Quality Regional Supervisor Jut- ? 7 1''fl2
Division of Water Quality
NC MPT 4.NWT
North Carolina Department of Natural Resources(NCDENR) 'IK
919 North Main Street IIIS.{g , MICE
Mooresville, North Carolina 28115
USPS CERTIFIED MAIL #7001 0360 0001 1495 2742 - RETURN RECEIPT
REQUESTED
Subject: ORC Change Notification
NPDES Permit No. NC 0079898 Telephone
CNA Holdings,Inc. (formerly HNA Holdings, Inc.)
Needmore Road former Landfill
Dear Mr. Gleason: Facsimile
Please note effective July 15, 2002, I will be leaving Earth Tech, Inc. and will no longer be 3 3 6._9 9.9 6 5 5
the ORC for the above noted site. The new ORC will be Richard Park who is currently with
with Earth Tech and has assisted me with the facility's operation since April 2001.
Please call me at 336-3620-1510 if you have any questions.
Very truly yours,
Earth Tech, Inc.
Eric K. Lintz,PG
Project Manager
cc: Steve Olp(Celanese Americas Corp.)
Everett Glover(Earth Tech—RoswelI, Ga)
Richard Park(Earth Tech—Greensboro,NC)
EARTH @ T E C H
A t14CQ INTERNATIONAL LTD,COMPANY

�� If A��R Michael F.Easley,Governor
Q.0 Q✓ William G.Ross Jr.,Secretary
✓j
North Carolina Department of Environment and Natural Resources
Alan W.Klimek,P.E.,Director
Division of Water Quality
June 6. 2002
ibc)I 510 Ctv5 6a8/ 1rgo
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Steven F. Olp
Senior Corporate Manager, Corporate Remediation
CNA Holdings, Inc./Celanese Americas Corporation
Post Office Box 32414
Charlotte,NC 28232
Subject: Notice of Violation-Effluent Limitations
Needmore Road Landfill WWTP
NPDES Permit No. NC0079898
Rowan County
Dear Mr. Olp:
A review of the January 2002 self-monitoring report for the subject facility revealed a violation of
the following parameter:
Pipe Parameter Reported Value Limit
00I Total Suspended Residue 34 30.0 mg/L FIN
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 the
violations are of a continuing nature, not related to operation and/or maintenance problems, and you
anticipate remedial construction activities,then you may wish to consider applying for a Special Order by
Consent. You may contact Richard Bridgeman of this Office for additional information.
If you have questions concerning this matter, please do not hesitate to contact either Mr.
Bridgeman or me at 704/663-1699.
Sincerely,
D. Rex Gleason, A.E.
Water Quality Regional Supervisor
cc: Point Source Compliance/Enforcment Unit
RMB
4071
N.C.Division of Water Quality 919 North Main Street, Mooresville NC 28115 Phone[phone] NC:DE
FAX [phone]

IPPPPrir- 31 i-J South Westgate Drive. Greensboro, North Carolina 27407
NC 1EP'.C.I3"ri .i •w
ANO I.4,6,TURA RE.u4u1~,,._.
June 19, 2002 JUN 2 0 2002
Mr. D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Division of Water Quality
North Carolina Department of Natural Resources(NCDENR) .,
919 North Main Street
Mooresville,North Carolina 28115
LISPS CERTIFIED MAIL #7001 0360 0001 1495 2728 - RETURN RECEIPT
REQUESTED
Subject: Notice of Violation (NOV)—Effluent Limitations
January 2002 Quarterly Sampling Telephone
NPDES Permit No. NC 0079898
CNA Holdings, Inc. (formerly HNA Holdings, Inc.) 3 r}.x 99 999s
Needmore Road former Landfill
Facsimile
Dear Mr. Gleason:
336.299.o65 5
On behalf of CNA Holdings, Inc., please find attached a copy of the February 27, 2002 non-
compliance notification sent to the central NPDES Branch per your June 6, 2002 NOV. The
letter documents our verbal notification as well as provides a possible explanation for the
January 2002 total suspended solids (TSS) non-compliance. As indicated in the notification,
Earth Tech believes that the January 2002 results were anomalous and not representative of
the typical plant discharge given the site's operational history.
Please note that since the TSS non-compliance was discovered, the effluent mixing tank was
thoroughly cleaned. Subsequently, the April 2002 quarterly sampling reported a TSS
concentration of 6.3 mg/l.
Please call 336-299-9998 (ext.#12) if you have any questions.
Very truly yours,
Earth Tech,Inc.
Eric K. Lintz, PG
Project Manager
cc: Steve Olp (Celanese Americas Corp.)
Everett Glover(Earth Tech—Norcross, Ga)
EARTH ` TECH
A I O INTERNATIONAL LTD.COMPANY

3ii-J South Westgate Drive, Greensboro, North Carolina 27407
Pr.lir'
•
February 27, 2002 •
Mr.Robert Sledge
NPDES Branch
Division of Water Quality •
North Carolina Department of Natural Resources (NCDENR)
1617 Mail Service Center
Raleigh,North Carolina 27699-1617 •
USPS CERTIFIED MAIL #7001 0360 0001 1495 2575 - RETURN RECEIPT
REQUESTED
Subject: Non-Compliance Notification(January 2002 Quarterly Sampling)
NPDES Permit No. NC 0079898 Telephone .
CNA Holdings,Inc. (formerly HNA Holdings,Inc.)
Needmore Road former Landfill 3 3 6-2 9 9.9 9 9 8
Facsimile !
Dear Mr. Sledge:
336.299.0655
On behalf of CNA Holdings, Inc., Earth Tech is providing this written notification of non-
compliance for the above referenced site in accordance with Part II.E.5 and 6 of the NPDES
Permit. The ORC and Permittee verbally notified the Division of Water Quality (DWQ) of
the non-compliance on February 20, 2002. In particular, the January 2002 quarterly Total
Suspended Solids (TSS) was reported at 34 mng/1 which is approximately 13% above the
average monthly limit of 30 mg/1. The TSS sample was composited from a 24-hour batch
operation of the treatment plant between January 21 and January 22, 2002.
The exact cause of the non-compliance remains somewhat unresolved as this was the first
time in the plant's operational history that the TSS was reported above the permitted limit.
There was one incident associated with the plant that may have contributed to the elevated
TSS result. In particular, CNA notified the DWQ on November 28, 2001 of a treatment plant
malfunction which occurred on October 31, 2001. While receiving a delivery of sodium
hydroxide, the holding tank for the noted chemical failed with all the released sodium
hydroxide immediately contained as designed within the facility's containment sump. The
process pumps in the containment sump automatically transferred the sodium hydroxide into,
thefacility's influent equalization tank. The raw water pH in the equalization tank was
subsequently recorded at approximate 12.0 SU. In order to neutralize the raw water, Earth
Tech circulated the contents of the equalization tank through the plant system while slowly
injecting sulfuric acid into the process water. The raw water pH in the equalization tank was
stabilized at approximately 7.0 SU. Though only a theory, it is possible that the elevated raw
water pH caused some mineralization within the equalization tank which was not completely
dissolved during the subsequent sulfuric acid neutralization or acidification prior to treatment.
Most of the impacted raw water noted from the October 2001 incident was batched through
the system in January 2002.
A tgca 1NTERNATIONAL LTD.COMPANY

r.Robert Sledge,Division of Water Quality Page 2 of 2
February 27, 2002
Given the past history of the plant's operation, Earth Tech believes that the January 2002
results were anomalous and not representative of the typical plant discharge. The next
scheduled TSS sampling is scheduled for,April 2002. As suggested by the DWQ during our
February 20th call, Earth Tech will collect the sample in the first part of the month such that
the TSS can be averaged with other samples collected later in the month if necessary to meet
the monthly average limit as required.
Please call 336-299-9998 (ext.#12) if you have any questions.
Very truly yours,
Earth Tech,Inc.
Eric K. Lintz, PG
Project Manager
cc: Steve Olp (Celanese Americas Corp.)
Everett Glover(Earth Tech—Norcross, Ga)
E A R T H ', T ECM
A tgco INTERNATIONAL LTD. COMPANY

Michael F Easley,Governor
' F9 William G. Ross Jr.,Secretary
G North Carolina Department of Environment and Natural Resources
y Gregory J.Thorpe, Ph.D,Acting Director
Division of Water Quality
MAR 1 1 2002 r'
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Rick Ramirez
CNA Holdings, Inc.
PO Box 32414
Charlotte,North Carolina 28232
SUBJECT: Notice of Violation and Assessment of Civil Penalties for Reporting Requirement Violations
NPDES Permit No. NC0079898
Needmore Landfill Treatment Facility
Rowan County
LT 01-004
Dear Mr. Ramirez:
This letter transmits a Notice of Violation and assessment of civil penalty assessed against CNA Holdings, Inc. in
the amount of$ /6109.00 .
This assessment is based upon the following facts: the January 2001 toxicity self-monitoring report form was not
filed with the Environmental Sciences Branch of the Division of Water Quality within the thirty (30)day reporting period
in accordance with the monitoring and reporting requirements contained in your NPDES Permit.
A previous Notice of Violation for failure to report the January,March, April and May 2000 toxicity self-
monitoring data was sent to the facility by certified mail dated September 5,2000. Within the Notice, it was stated,
"Please be advised that reporting violations of your NPDES Permit subjects CNA Holdings, Inc. to the enforcement
authority of the Division." In addition, the facility was assessed a$500.00 civil penalty on November 27,2000,for failing
to timely report the January, March, April and May 2000 toxicity test results.
Based upon the above fact(s), I conclude as a matter of law that CNA Holdings, Inc. violated or failed to act
in accordance with the requirements of G.S. 143-215.65. A civil penalty of not more than $10,000.00 may be
assessed against a person who fails to file,submit or make available any documents, data or reports required by G.S.
143-215.65.
Based upon the above facts(s)and conclusions of law, I hereby assess CNA Holdings, Inc.
a $ 10p°•n0 civil penalty for this fifth violation of G.S. 143-215.65, pursuant to the authority delegated to me
by North Carolina Environmental Management Commission Regulation 15 NCAC 2J .003 and G.S. 143-215.6A(h). Any
continuing violation(s) may subject you to additional penalties.
•
NC DEN
N_ C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1 800 623-6748

Within thirty days receipt of this notice, you must do one of the following:
1. Submit payment of the penalty:
Payment should be made directly to the Department of Environment, Health, and Natural
Resources (do not include waiver form). Payment of the penalty will not foreclose enforcement
action for any continuing or new violation(s). Please submit payment to the attention of:
Ms. Coleen Sullins
Water Quality Section Chief
Division of Water Quality
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
OR
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:
Ms. Coleen Sullins
Water Quality Section Chief
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Please note that all information presented in support of a request for remission must be submitted
in writing. The Director of the Division of Water Quality will review the information during a
bimonthly enforcement conference and inform you of his decision in the matter of the remission
request. His response will provide details regarding case status, directions for payment and
provision for further appeal of the penalty to the Environmental Management Commission's

Committee on Civil Penalty Remissions. Please be advised that the Committee cannot consider
information that was not part of the original remission request considered by the Director and
therefore, it is very important that you prepare a complete and thorough statement in support of
your request for remission.
3. 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)?e petition with the
Office of Administrative Hearings
6714 Mail Service Center
Raleigh,North Carolina 27699-6714
and
Mail or hand-deliver a copy of the petition to
Mr. Dan Oakley
General Counsel
Department of Environment and Natural Resources
1601 Mail Service Center
Raleigh,North Carolina 27699-1601
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
be advised that additional assessments may be levied for future violations which occur after the
review period of this assessment.
If you have any questions, please contact Mr. Matt Matthews, Supervisor of the Aquatic
Toxicology Unit,or Mr. Kevin Bowden at [phone].
Sinc rely,
gory J. Tho e, Ph.D.
3/6/6Z
Date
Attachments
cc: Regional Water Quality Supervisor
Point Source Compliance/Enforcement File
Aquatic Toxicology Unit
Central Files

de.ntursn�rir „,
ti r arau5A4�aisneatysterar(CEMt"r ae
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Track Enforcement Case
A
[G1
_ -ayment i Remission -etbtion 'Collection Settlement 2 Related Cases r Comments r Events
Summary - Related..iolations i PenaltyAssessed r Review
2a• Llr.
Case NumberT-2001-0004 ... NOV: {._.....babe...._
�. —_....1
iti
' Permit 4C0079898 Details.. ! SOC: AD: Monitoring Report i :., .
i :
i Facility NA Holdings Inc1Needmore Details• Region: .Mooresville J County lEowan
r Owner CNA Holdings Int Maintain.-. I Incident j. Inspect Dt j Cat
CentralOfice Login Date 105131/2001 --' comments:�C007�giT§8,CNA Holdings EA for 1/01 late report This is the
IFTH time the fac.has reported late in 12 month window. To
ICI Ce ttralOtbce Contact Sledge,Robert L j :shannon 5125101 CASE CLOSE 4/15.103 DUE TO GREEN CARD '
E i Regional Contact: Bowden,Maurice K. RETURN TO MSC. FAC.NEVER REC D ASST.-KB.coleen
Enforcement Contact teve Olp 1 Salutation for Letter idr.Ramirez
Penalty Assessed Dale: 3fOS120G2 1 Remission Request I EMC Hearing Date.
Letter Date: 310612002 Remission Acknowledged: L i Remission Amount
Penalty Amount. 41000.00 Enf Conf.Date: EMC Results Received:
i Damages 0.00 Remission Amount
Enforcement Cost .i0.00 - } Enf.Cont Letter Date: j _ ] Petition in OAH: i F
Total Case Penalty1000.00 Facility Revd.Enf.Conf.Lir.: r Remission Amount: '
Facility Received F&D: Total Amount Due- 31000-00 Case to Collection: f
Response Due By l Total Amount Paid: 1 j Settlement Requested: L_
Case Closed. /04115,2003 I ..
I
t`
'pack 1 "_iRvl. 7-. __._._cancel g
. P.5q Ready Page 111 SID:ENCS 0..
i
.,start P Alt IS.4101E1
1

State of North Carolina
Department of Environment,
Health and Natural Resources AwrxiA
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary C E H N Fl
A. Preston Howard, Jr., P.E., Director
N.C. DEPT. OF
October la, 1994 ENVIRONMENT, HEALTH,
& NATURAL RESOURCES
Mr. Keith E. Darnell OCT 13 1994
Technical Fibers Group
Hoechst Celanese Corporation DIVISION OF ENVIRONMENTAL MANAGEMENT
P.O. Box 4 IdODA1:SVILLE REGIONAL OFFICE
Salisbury NC 28145-0004
Subject: Authorization to Construct Request
Permit AC0079898
Hoechst Celanese Corporation
Rowan County
Dear Mr. Darnell:
A letter of request for an Authorization to Construct was received August 2, 1994 by the Division
and final plans and specifications have been reviewed and found to be satisfactory. Authorization is
hereby granted for the addition of an ENOX additive system consisting of a 6,000 gallon storage tank, a
recirculating pump, a metering pump, and all associated piping, valves, controls, and appurtenances to
the existing groundwater remediation system, with discharge of treated wastewater into the South Yadkin
River in the Yadkin-Pee Dee River Basin.
This Authorization to Construct is issued in accordance with Part III, Paragraph A, of NPDES
Permit No. NC0079898 issued July 29, 1994, and shall be subject to revocation unless the wastewater
treatment facilities are constructed in accordance with the conditions and limitations specified in Permit
No. NC0079898.
The sludge generated from these treatment facilities must be disposed of in accordance with G.S.
143-215.1 and in a manner approved by the North Carolina Division of Environmental Management.
..
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 treatment or disposal facilities.
The Mooresville Regional Office, telephone number 704-663-1699, shall be notified at least forty-
eight (48) hours in advance of operation of the installed facilities so that an in-place inspection can be
made. Such notification to the regional supervisor shall be made during the normal office hours from 8:00
a.m. until 5:00 p.m. on Monday through Friday, excluding State Holidays.
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 the NPDES Permit, this Authorization to Construct and the approved plans and
specifications. Mail the Certification to the Permits and Engineering Unit, P.O. Box 29535, Raleigh, NC
27626-0535.
Upon classification of the facility by the Certification Commission, the Permittee shall employ a
certified wastewater treatment plant operator to be in responsible charge(ORC) of the wastewater treatment
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

Permit No. NC0079898
Authorization to Construct
Hoechst Celanese Corporation
October 10, 1994
Page 2
facilities. The operator must hold a certificate of the type and grade at least 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 grade to comply with
the conditions of Title 15A,Chapter 8A, .0202. The ORC of the facility must visit each Class I facility at
least weekly and each Class II, III, and IV facility at least daily, excluding weekends and holidays, and
must properly manage and document daily operation and maintenance of the facility and must comply with
all other conditions of Title 15A, Chapter 8A, .0202.g
A copy of the approved plans and specifications shall be maintained on file by the Permittee for the
life of the facility.
Failure to abide by the requirements contained in this Authorization to Construct may subject the
Permittee to an enforcement action by the Division of Environmental Management in accordance with
North Carolina General Statute 143-215.6A to 143-215.6C.
The issuance of this Authorization to Construct 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.
One (1) set of approved plans and specifications is being forwarded to you. If you have any
questions or need additional information, please contact Mr. Greg Nizich, telephone number 919/733-
5083.
Sincerely,
. :_ _ .
estif ward, Jr., P.E.
cc: Rowan County Health Department •
Mooresville Regional Office, Water Quality
Training and Certification Unit
Facilities Assessment Unit
Central Files

Permit No. NC0079898
Authorization to Construct
Hoechst Celanese Corporation
October 10, 1994
Page 3
Engineer's Certification
I, , 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, , for the
Project Name Location
Permittee 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 the approved plans and specifications.
Signature Registration No.
Date
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