NC0079227_Fact Sheet_20210423

Fact Sheet
NPDES Permit No. NC0079227
Permit Writer/Email Contact: Derek Denard [[e-mail]]
Date:23Apr2021
Division/Branch: NC Division of Water Resources/Water Quality Permitting Section
Compliance & Expediated Permitting Branch
Permitting Action:
❑X Renewal
❑ Renewal with Expansion
❑ New Discharge
❑ Modification (Fact Sheet should be tailored to mod request)
See Permit Application Attachment A:
Complete applicable sections below. If not applicable, enter NA.
1. Basic Facility Information
Facility Information
Applicant/Facility Name:
Schlage Lock Company LLC/ Former Schlage Lock Plant
Applicant Address:
11819 N. Pennsylvania St, Carmel, IN 46032
Facility Address:
213 Red Iron Road, Rocky Mount, NC 27804
Permitted Flow:
0.124 MGD
Facility Type/Waste:
100% Industrial Groundwater Remediation Discharge
Facility Class:
Grade I Physical Chemical Water Pollution Control System
Treatment Units:
collection wells, product separator, equalization tank with transfer
pump, air stripper with blower, discharge tank with effluent pump, bag
filters, effluent flow meter with totalizer
Pretreatment Program (Y/N)
No
County:
Nash
Region
Raleigh
Briefly describe the proposed permitting action and facility background: Schlage Lock Company LLC
has applied to renew NPDES Permit which is an industrial facility (flow <1 MGD) with groundwater
remediation discharge. The design capacity of the treatment system is 0.124 MGD. No significant
changes have been made to this facility since the last permit renewal with the exception of the average
daily flow rate increasing from 30,000 gpd to 35,000 gpd. [See Permit Application Attachment A]
Page 1 of 9

2. Receiving Waterbodv Information:
Receiving Waterbody Information
Outfalls/Receiving Stream(s):
Outfall 001 / UT to Beech Branch
Stream Segment:
28-75-(2)
Stream Classification:
C; NSW
Drainage Area (mi2):
Not Available
Summer 7Q10 (cfs)
0
Winter 7Q10 (cfs):
0
30Q2 (cfs):
0
Average Flow (cfs):
0
IWC (% effluent):
100%
303(d) listed/parameter:
Not listed
Subject to TMDL/parameter:
Yes / Nitrogen, Phosphorus
Basin/Sub-basin/HUC:
Tar -Pamlico / 03-03-02 / 030201010902
USGS Topo Quad:
Drake, NC
3. Effluent Data Summary
Effluent data for Outfall 001 is summarized below for the period of Nov2015 through Apr2020.
Table. Effluent Data Summary Outfall 001 (Compete table below or insert Excel Pivot Table.)
Parameter -I Max Min Average PQL MA DM UoM
1,1-dichloroethylene 1 1 1 1 ug/I
Chloroform 5 1 1.4 1 ug/I
Flow, in conduit or thru treatment plant 0.04 0.0030 0.028 mgd
Oil & Grease 9.2 0.624 4.92 30 60 mg/I
pH 8.23 7.5 7.77 6-9 su
Solids, Total Suspended - Concentration 16.3 2.5 2.77 2.5 30 60 mg/I
Tetrachloroethene 1 1 1 1 ug/I
Toluene 4.8 1 1.2 1 ug/I
Trichloroethene 1 1 1 1 ug/I
Vinyl Chloride 1 1 1 1 ug/I
PQL - Practical Quantitation Limit, MA - Monthly Average, DM - Daily Max, UoM -
Units of Measurement
Page 2 of 9

4. Instream Data Summary
Instream monitoring may be required in certain situations, for example: 1) to verify model predictions
when model results for instream DO are within 1 mg/1 of instream standard at full permitted flow; 2) to
verify model predictions for outfall diffuser; 3) to provide data for future TMDL; 4) based on other
instream concerns. Instream monitoring may be conducted by the Permittee, and there are also
Monitoring Coalitions established in several basins that conduct instream sampling for the Permittee (in
which case instream monitoring is waived in the permit as long as coalition membership is maintained).
If applicable, summarize any instream data and what instream monitoring will be proposed for this
permit action: Not Applicable.
Is this facility a member of a Monitoring Coalition with waived instream monitoring (Y/N): Not
Applicable.
Name of Monitoring Coalition: Not Applicable.
5. Compliance Summary
Summarize the compliance record with permit effluent limits (past 5 years): No violations were noted.
[See Attachment B]
Summarize the compliance record with aquatic toxicity test limits and any second species test results
(past 5 years): No failures in the last 5 years. [See Attachment C]
Summarize the results from the most recent compliance inspection: A December 9, 2019 compliance
evaluation inspection indicated compliance. [See Attachment D]
6. Water Quality -Based Effluent Limitations (WQBELs)
Dilution and Mixing Zones
In accordance with 15A NCAC 2B.0206, the following streamflows are used for dilution considerations
for development of WQBELs: 1Q10 streamflow (acute Aquatic Life); 7Q10 streamflow (chronic Aquatic
Life; non -carcinogen HH); 30Q2 streamflow (aesthetics); annual average flow (carcinogen, HH).
If applicable, describe any other dilution factors considered (e.g., based on CORMIX model results): Not
Applicable.
If applicable, describe any mixing zones established in accordance with 15A NCAC 2B. 0204(b): Not
Applicable.
Oxygen -Consuming Waste Limitations
Limitations for oxygen -consuming waste (e.g., BOD) are generally based on water quality modeling to
ensure protection of the instream dissolved oxygen (DO) water quality standard. Secondary TBEL limits
(e.g., BOD= 30 mg/1 for Municipals) may be appropriate if deemed more stringent based on dilution and
model results.
If permit limits are more stringent than TBELs, describe how limits were developed: Not Applicable.
Page 3 of 9

Ammonia and Total Residual Chlorine Limitations
Limitations for ammonia are based on protection of aquatic life utilizing an ammonia chronic criterion of
1.0 mg/1 (summer) and 1.8 mg/1 (winter). Acute ammonia limits are derived from chronic criteria,
utilizing a multiplication factor of 3 for Municipals and a multiplication factor of 5 for Non -Municipals.
Limitations for Total Residual Chlorine (TRC) are based on the NC water quality standard for protection
of aquatic life (17 ug/1) and capped at 28 ug/1 (acute impacts). Due to analytical issues, all TRC values
reported below 50 ug/1 are considered compliant with their permit limit.
Describe any proposed changes to ammonia and/or TRC limits for this permit renewal: Not Applicable.
Reasonable Potential Analysis (RPA) for Toxicants
If applicable, conduct RPA analysis and complete information below.
The need for toxicant limits is based upon a demonstration of reasonable potential to exceed water quality
standards, a statistical evaluation that is conducted during every permit renewal utilizing the most recent
effluent data for each outfall. The RPA is conducted in accordance with 40 CFR 122.44 (d) (i). The NC
RPA procedure utilizes the following: 1) 95% Confidence Level/95% Probability; 2) assumption of zero
background; 3) use of Y2 detection limit for "less than" values; and 4) streamflows used for dilution
consideration based on 15A NCAC 2B.0206. Effective April 6, 2016, NC began implementation of
dissolved metals criteria in the RPA process in accordance with guidance titled NPDES Implementation of
Instream Dissolved Metals Standards, dated June 10, 2016.
A reasonable potential analysis was conducted on effluent toxicant data collected between Nov2015-
Apr2020. Pollutants of concern included toxicants with positive detections and associated water quality
standards/criteria. Based on this analysis, the following permitting actions are proposed for this permit:
• Effluent Limit with Monitoring. The following parameters will receive a water quality -based
effluent limit (WQBEL) since they demonstrated a reasonable potential to exceed applicable
water quality standards/criteria: None.
• Monitoring Only. The following parameters will receive a monitor -only requirement since they
did not demonstrate reasonable potential to exceed applicable water quality standards/criteria, but
the maximum predicted concentration was >50% of the allowable concentration: Toluene.
• No Limit or Monitoring: The following parameters will not receive a limit or monitoring, since
they did not demonstrate reasonable potential to exceed applicable water quality standards/criteria
and the maximum predicted concentration was <50% of the allowable concentration: None.
• POTW Effluent Pollutant Scan Review: Three effluent pollutant scans were evaluated for
additional pollutants of concern.
o The following parameter(s) will receive a water quality -based effluent limit (WQBEL)
with monitoring, since as part of a limited data set, two samples exceeded the allowable
discharge concentration: NA.
o The following parameter(s) will receive a monitor -only requirement, since as part of a
limited data set, one sample exceeded the allowable discharge concentration: NA.
• Other: The following parameters of concern that showed no detection will receive a quarterly
monitor -only requirement since they are present in groundwater that is being remediated.
• Summary of new limits added based on RPA: NA.
• Summary of existing limits deleted based on RPA: NA.
Page 4 of 9

If applicable, attach a spreadsheet of the RPA results [See Attachment D] as well as a copy of the
Dissolved Metals Implementation Fact Sheet for freshwater/saltwater [Not applicable] to this Fact Sheet.
Include a printout of the RPA Dissolved to Total Metal Calculator sheet if this is a Municipality with a
Pretreatment Program.
Toxicity Testing Limitations
Permit limits and monitoring requirements for Whole Effluent Toxicity (WET) have been established in
accordance with Division guidance (per WET Memo, 8/2/1999). Per WET guidance, all NPDES permits
issued to Major facilities or any facility discharging "complex" wastewater (contains anything other than
domestic waste) will contain appropriate WET limits and monitoring requirements, with several
exceptions. The State has received prior EPA approval to use an Alternative WET Test Procedure in
NPDES permits, using single concentration screening tests, with multiple dilution follow-up upon a test
failure.
Describe proposed toxicity test requirement: Chronic Toxicity (Ceriodaphnia) P/F, limited, at 90%:
February, May, August, and November [See A. (2.)]. Sampling and testing for volatile organic
compounds shall be concurrent with whole -effluent toxicity sampling and testing.
Mercury Statewide TMDL Evaluation
There is a statewide TMDL for mercury approved by EPA in 2012. The TMDL target was to comply with
EPA's mercury fish tissue criteria (0.3 mg/kg) for human health protection. The TMDL established a
wasteload allocation for point sources of 37 kg/year (81 lb/year), and is applicable to municipals and
industrial facilities with known mercury discharges. Given the small contribution of mercury from point
sources (-2% of total load), the TMDL emphasizes mercury minimization plans (MMPs) for point source
control. Municipal facilities > 2 MGD and discharging quantifiable levels of mercury (>1 ng/1) will
receive an MMP requirement. Industrials are evaluated on a case -by -case basis, depending if mercury is a
pollutant of concern. Effluent limits may also be added if annual average effluent concentrations exceed
the WQBEL value (based on the NC WQS of 12 ng/1) and/or if any individual value exceeds a TBEL
value of 47 ng/1
Describe proposed permit actions based on mercury evaluation: Not Applicable.
Other TMDL/Nutrient Management Strategy Considerations
If applicable, describe any other TMDLs/Nutrient Management Strategies and their implementation
within this permit: Not Applicable.
Other WQBEL Considerations
If applicable, describe any other parameters of concern evaluated for WQBELs: Not Applicable.
If applicable, describe any special actions (HQW or ORW) this receiving stream and classification shall
comply with in order to protect the designated waterbody: Not Applicable.
Page 5 of 9

If applicable, describe any compliance schedules proposed for this permit renewal in accordance with
15A NCAC 2H.0107(c)(2)(B), 40CFR 122.47, and EPA May 2007 Memo: Not Applicable.
If applicable, describe any water quality standards variances proposed in accordance with NCGS 143-
215.3(e) and 15A NCAC 2B. 0226 for this permit renewal: Not Applicable.
7. Technology -Based Effluent Limitations (TBELs)
Not applicable. See fact sheet section 12 for discussion of Oil and Grease and Total Suspended Solids.
8. Antidegradation Review (New/Expanding Discharge):
The objective of an antidegradation review is to ensure that a new or increased pollutant loading will not
degrade water quality. Permitting actions for new or expanding discharges require an antidegradation
review in accordance with 15A NCAC 2B.0201. Each applicant for a new/expanding NPDES permit
must document an effort to consider non -discharge alternatives per 15A NCAC 2H.0105( c)(2). In all
cases, existing instream water uses and the level of water quality necessary to protect the existing use is
maintained and protected.
If applicable, describe the results of the antidegradation review, including the Engineering Alternatives
Analysis (EAA) and any water quality modeling results: Not Applicable.
9. Antibacksliding Review:
Sections 402(o)(2) and 303(d)(4) of the CWA and federal regulations at 40 CFR 122.44(1) prohibit
backsliding of effluent limitations in NPDES permits. These provisions require effluent limitations in a
reissued permit to be as stringent as those in the previous permit, with some exceptions where limitations
may be relaxed (e.g., based on new information, increases in production may warrant less stringent TBEL
limits, or WQBELs may be less stringent based on updated RPA or dilution).
Are any effluent limitations less stringent than previous permit (YES/NO): No.
If YES, confirm that antibacksliding provisions are not violated: Not Applicable.
10. Monitoring Requirements
Monitoring frequencies for NPDES permitting are established in accordance with the following
regulations and guidance: 1) State Regulation for Surface Water Monitoring, 15A NCAC 2B.0500; 2)
NPDES Guidance, Monitoring Frequency for Toxic Substances (7/15/2010 Memo); 3) NPDES Guidance,
Reduced Monitoring Frequencies for Facilities with Superior Compliance (10/22/2012 Memo); 4) Best
Professional Judgement (BPJ). Per US EPA (Interim Guidance, 1996), monitoring requirements are not
considered effluent limitations under Section 402(o) of the Clean Water Act, and therefore anti -
backsliding prohibitions would not be triggered by reductions in monitoring frequencies.
For instream monitoring, refer to Section 4.
Page 6 of 9

11. Electronic Reporting Requirements
The US EPA NPDES Electronic Reporting Rule was finalized on December 21, 2015. Effective
December 21, 2016, NPDES regulated facilities are required to submit Discharge Monitoring Reports
(DMRs) electronically. Effective December 21, 2020, NPDES regulated facilities will be required to
submit additional NPDES reports electronically. This permit contains the requirements for electronic
reporting, consistent with Federal requirements.
12. Summary of Proposed Permitting Actions:
A. Table. Current Permit Conditions and Proposed Changes — Outfall 001
Parameter
Current Permit
Proposed
Change
Basis for Condition/Change
Flow (MGD)
MA 0.124
No change
WQBEL. State WQ standard,15A NCAC 02B .0505
Oil and Grease
(mg/L)
MA 30 mg/1
DM 60 mg/1
No change
BPJ
WQBEL. State WQ narrative standard,15A NCAC
02B .0211 (12); EPA QCW 1976
TBEL. Metal Products & Machinery Effluent
Guidelines 40 CFR 438 DM 45 mg/1; Metal
Finishing 40 CFR 433 MA 21 mg/ and DM 52 mg/1)
Total
Suspended
Solids (mg/L)
MA 30 mg/1
DM 60 mg/1
No change
BPJ
TBEL. Secondary treatment standards/40 CFR 133 /
15A NCAC 2B .0406
(Metal Products & Machinery Effluent Guidelines
40 CFR 438: DM 62 mg/1;
Metal Finishing Effluent Guidelines 40 CFR 433:
MA 31 mg/ and DM 60 mg/1)
pH (su)
6 — 9 SU
No change
WQBEL. State WQ standard, 15A NCAC 2B .0200
(14)
Temperature
(°C)
Not required
Added
monitoring
WQBEL. State WQ narrative standard, 15A NCAC
02B .0208 (b), .0211 (14)
Vinyl Chloride
(µg/L)
Monitor &
Report
No change
WQBEL. State WQ standard, 15A NCAC 02B
.0208 (a)
Trichloroethene
(TCE) (µg/L)
Monitor &
Report
No change
WQBEL. State WQ standard, 15A NCAC 02B
.0208 (a)
Tetrachloroethe
ne (PCE) (µg/L)
Monitor &
Report
No change
WQBEL. State WQ standard, 15A NCAC 02B
.0208 (a)
Page 7 of 9

1,1
Dichloroethene
(DCE) (µg/L)
Monitor &
Report
No change
EPA National Recommended Water Quality Criteria
for Human Health (Fish Consumption)
Toluene (µg/L)
Monitor &
Report
No change
WQBEL. State WQ standard, 15A NCAC 02B
.0208 (a)
Chloroform
(µg/L)
Monitor &
Report
No change
EPA National Recommended Water Quality Criteria
for Human Health (Fish Consumption)
Chronic
Toxicity
P/F, limited, at
90%
Update Condition
page
WQBEL. No toxics in toxic amounts. 15A NCAC
2B.0200 and 15A NCAC 2B.0500
Electronic
Reporting
Required
Update
Electronic
Reporting Special
Condition page
In accordance with EPA Electronic Reporting Rule
2015.
MGD — Million gallons per day, MA - Monthly Average, WA — Weekly Average, DM — Daily Max
The draft permit includes the following significant changes from the existing permit:
1. The permit map was updated.
2. Temperature monitoring was added with a frequency of twice per month.
3. The facility classification Grade I Physical Chemical Water Pollution Control System (WPCS)
was added to the effluent page.
13. Public Notice Schedule:
Permit to Public Notice: 07/10/2020 [See Attachment F]
Per 15A NCAC 2H .0109 & .0111, The Division will receive comments for a period of 30 days following
the publication date of the public notice. Any request for a public hearing shall be submitted to the
Director within the 30 days comment period indicating the interest of the party filing such request and the
reasons why a hearing is warranted.
14. Fact Sheet Addendum (if applicable):
Were there any changes made since the Draft Permit was public noticed (Yes/No): Yes.
If Yes, list changes and their basis below:
1. For Temperature monitoring the following footnote was added:
Temperature: This requirement applies only when thermal groundwater treatment is in use.
2. Permit Condition A. (2.) for Chronic Toxicity Permit Limit was updated.
3. Permit Condition A. (3.) for electronic reporting was updated.
15. Fact Sheet Attachments (list in order of reference):
Page 8 of 9

A. NC0079227 Renewal (Application)_20190619_55p
B. NC0079227 MR VIOLATIONS 03-2015 03-2020lp.
C. Whole Effluent Toxicity Testing and Self -Monitoring Summary _HQ February 2020 45
D. NC0079227 Compliance Evaluation Inspection _20191209_7p
E. NC0079227 RPA Spreadsheet Summary_5p
F. North Carolina Press Association _NCNotices_com_20200710_lp
G. Regional Office Staff Report_joshua brigham_20200624_2p
H. Peer Review Emily Phillips_email _20200625_lp
I. Approval of Electronic Transmittals_20200630
J. Draft Permit Transmittal_ Response_20200706
K. Permittee Comments 202007146p
L. 1. ATB_Hannah Headrick_Comments _20200708_3p
2. Comments on Draft NPDES Permit NC0079227_lp
M. NC0079227 Review Checklist_lp
N. Electronic Transmittal Receipt _20210423_2p
O. QAQC20210423_2p
Page 9 of 9

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Russell Eller
Schlage Lock Company
11819 N Pennsylvania St
Carmel, IN 46032
Subject: Permit Renewal
Application No. NC0079227
Nash remediation site
Nash County
NOR.Tk CAROLINA
Environmental Quality
June 19, 2019
Dear Applicant:
The Water Quality Permitting Section acknowledges the June 7, 2019 receipt of your permit renewal application and
supporting documentation. Your application will be assigned to a permit writer within the Section's NPDES WW permitting
branch. Per G.S. 150B-3 your current permit does not expire until permit decision on the application is made.
Continuation of the current permit is contingent on timely and sufficient application for renewal of the current permit. The
permit writer will contact you if additional information is required to complete your permit renewal. Please respond in a
timely manner to requests for additional information necessary to allow a complete review of the application and renewal
of the permit.
Information regarding the status of your renewal application can be found online using the Department of Environmental
Quality's Environmental Application Tracker at:
https://deq.nc.gov/permits-regulations/permit-guidance/environmental-application-tracker
If you have any additional questions about the permit, please contact the primary reviewer of the application using the
links available within the Application Tracker.
ec: WQPS Laserfiche File w/application
DE
Wren Thedford
Administrative Assistant
Water Quality Permitting Section
North Carolina Department of Environmental Qualty I Divisnn of Water Resources
Raleigh Regional Office 13300 Barrett Drive I Raleigh, North Carolina 27609
919-791-4200

Geosyntec °
consultants
Geosyntec Consultants of NC, PC
2501 Blue Ridge Road, Suite 430
Raleigh, North Carolina 27607
PH 919.870.0576
www.geosyntec.com
May 31, 2019
Ms. Wren Thedford
NPDES Complex Permitting
North Carolina DEQ/Division of Water Resources/Water Quality Permitting
1617 Mail Service Center RECEIVED/NCDEQ/DWR
Raleigh, North Carolina 27699-1617
JUN 0 7 2019
Subject: Renewal Request for NPDES Permit NC0079227
Former Schlage Lock Facility Water quality
Permitting Section
213 Red Iron Rd.
Rocky Mount, Nash County, NC
Dear Ms. Thedford:
On behalf of Schlage Lock Company LLC (Schlage), Geosyntec Consultants of NC, PC
(Geosyntec) is pleased to submit the NPDES permit renewal application for the referenced site in
Rocky Mount, North Carolina. In accordance with permit renewal requirements, the following
information is provided:
• This cover letter requesting the renewal;
• A copy of the December 4, 2014 documentation designating Geosyntec to serve as
Schlage's Authorized Representative;
• A copy of the February 22, 2018 modification request submitted to Ms. Julie Grzyb to
incorporate liquid effluent from a proposed in situ thermal remediation (ISTR) system
into the process flow of the existing pump and treat system;
• A copy of the June 13, 2018 correspondence from Ms. Linda Culpepper indicating that
the NPDES permit would not require modification;
• Signed Short Form NPDES Permit Application (C-GW, version 6/17);
• Topographic and aerial maps that shows the location of the site and its discharge outfall
(note that these figures were prepared by Schlage's previous consultant for the 2015
permit renewal);
Former Schlage Lock Facility, Rocky Mount, NC
engineers I scientists I innovators

Ms. Wren Thedford
31 May 2019
Page 2
• The most recent analytical results for the effluent (VOCs — February 2019, Chronic
Toxicity- February 2019, total suspended solids and oil & grease — February 2019); and
• The Sludge Management Plan for the facility.
Please call me if you have any questions regarding this NPDES permit renewal application.
Sincerely,
Wayne Amber, Ph.D.
Project Manager
Attachments: 1 — Authorized Representative Documentation
2 — February 2018 Modification Request
3 — June 2018 NCDEQ Response to Modification Request
4 — Short Form C-GW
5 — Figures
6 — Effluent Analytical Data
7 — Sludge Management Plan
Copies to: Mr. Russ Eiler - Schlage
Former Schlage Lock Facility, Rocky Mount, NC
engineers I scientists I innovators

Attachment 1 — Authorized Representative
Documentation

MUM
December 4, 2014
NC DENR / DWR / NPDES Unit
Attention: Wren Thedford
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Appointment of Authorized Representative
NPDES Permit No. NC0079227
Former Schlage Lock Plant
Rocky Mount, North Carolina
Dear Ms. Thedford:
Delaware Limited Liability Company
11819 North Pennsylvania Street
Carmel. IN
46032
As required by Part II.B.11.b of the referenced NPDES Permit, Schlage Lock Company LLC hereby
designates the person or persons occupying the following position as authorized representatives with
permission to prepare the NPDES reporting:
• Geosyntec Consultants Inc. Project Manager assigned to the project.
If you should have any questions or require additional information, please contact me at your
convenience.
II
'Ruse E er, CEF,RIWP-M,CHMM
Global EHS Compliance, Sustainability,
Remediation, and Audit Manager
Allegion plc
c/0 Schlage Lock Company LLC
11819 N. Pennsylvania Street
Carmel, Indiana 46032 USA
Office +1.317.810.3874
Ce11 +1.317.557.0016
Fax [phone]
Email: [e-mail]
cc: Beau Hodge, Geosyntec Consultants Inc.

Attachment 2 — February 2018 Modification
Request

Geosyntec °
consultants
Geosyntec Consultants of NC, PC
2501 Blue Ridge Road, Suite 430
Raleigh, North Carolina 27607
PH 919.870.0576
www geosyntec com
February 22, 2018
Ms. Julie A. Grzyb
Supervisor
NPDES Complex Permitting
North Carolina DEQ/Division of Water Resources/Water Quality Permitting
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: Modification Request for NPDES Permit NC0079227
Former Schlage Lock Facility
213 Red Iron Rd.
Rocky Mount, Nash County, NC
Dear Ms. Grzyb:
Geosyntec Consultants of NC, PC (Geosyntec) is working on behalf of Schlage Lock Company
LLC (Schlage) to conduct environmental remediation activities at the Former Schlage Lock
Facility located at 213 Red Iron Road in Rocky Mount, North Carolina (Site). Environmental
activities at the Site are being conducted in accordance with a North Carolina Department of
Environmental Quality (NCDEQ) issued Administrative Order (AO) in Lieu of a Post -Closure
Permit, which initially became effective in December 2011 and was updated in December 2016
(Docket Number AA2011-084). Currently, remedial activities at the Site include the operation of
a groundwater extraction and treatment system, which treats chlorinated volatile organic
compound (CVOC) impacted groundwater prior to discharge under an existing National Pollutant
Discharge Elimination System (NPDES) Permit NC0079227 (Attachment 1). As we have
discussed with you in a phone conversation on 02 February 2018, and as presented in this
correspondence, Geosyntec is requesting a modification to NPDES Permit NC0079227, to
implement additional remedial actions at the Site using in situ thermal remediation (ISTR), which
is proposed to discharge its treated effluent into the existing groundwater extraction and treatment
system prior to discharge in the existing NPDES Outfall 001. The NPDES permit modification
request form (NPDES Permit Application - Short Form C — GW) is provided as Attachment 2.
Purpose of Modification Request
A groundwater extraction and treatment system has been in operation at the Site since 1992 to
address CVOCs in groundwater. While the groundwater distribution of CVOCs has been relatively
Former Schlage Lock Facility, Rocky Mount, NC
engineers I scientists I innovators

Ms. Julie A. Grzyb
22 February 2018
Page 2
stable in recent years, a more aggressive source zone remedial strategy has been approved by
NCDEQ as part of an NCDEQ-approved Site Closure Strategy. An evaluation of targeted source
zone remedial technologies led to the concurrent decision by Geosyntec, Schlage, and NCDEQ to
reduce CVOC mass via ISTR, as documented in an Interim Measures Work Plan (June 2017). The
proposed ISTR system will utilize Electrical Resistive Heating (ERH) to heat up the subsurface
beyond the boiling point of the CVOCs and remove contaminants with vapor recovery wells. The
extracted steam and vapors will be separated into liquid and vapor streams, cooled, and treated
above -grade in a modular treatment system operated at the Site by the ISTR contractor. After pre-
treatment by the ISTR contractor, the liquid -phase effluent is proposed to be discharged to the
existing on -Site groundwater extraction treatment system, where it will combine with extracted
groundwater from operating recovery wells. The groundwater extraction and treatment system will
serve as secondary treatment and the combined treated groundwater will discharge to the existing
Outfall 001.
The ISTR system construction and operation process is anticipated to take approximately one year
to complete (we anticipate construction to begin in Spring 2018), and the modular equipment will
be removed following ISTR operations, at which point the groundwater extraction and treatment
system operations are anticipated to continue. Please note that the groundwater extraction and
treatment system will continue to operate during ISTR construction and operation; however, some
pumping wells located within the footprint of the ISTR treatment zone will be abandoned.
Description of Existing Groundwater Extraction and Treatment System and Permitted
Discharge
The existing groundwater extraction and treatment system currently consists of sixteen recovery
wells (nine in the Middle Aquifer and seven in the Lower Aquifer). Prior to implementation of the
ISTR system, three Middle Aquifer recovery wells (RW-2, RW-3 and RW-7, which have a
combined average extraction rate of approximately 2 gallons per minute [gpm]), will be
abandoned. Extracted groundwater is piped to the treatment building where it passes through an
equalization tank, an air stripper, and bag filers prior to discharge via permitted Outfall 001 to an
Unnamed Tributary of Beech Branch. A USGS map showing the location of the permitted Outfall
001 is provided as within the existing NPDES permit, included as Attachment 1.
Between 2003 and 2017, the average pumping rate of the system was 18.9 gpm (equivalent to
0.027 million gallons per day [MGD]). The effluent from the treatment system is monitored in
Former Schlage Lock Facility, Rocky Mount, NC
engineers I scientists I innovators

Ms. Julie A. Grzyb
22 February 2018
Page 3
accordance with NPDES permit NC0079227 (effective June 1, 2015 through October 31, 2019)
(Attachment 1). The system's average flow rate (monitored continuously) between 2003 and 2017
was less than 22 percent of the 0.124 MGD permit limit.
Pursuant to the existing NPDES permit, groundwater extraction and treatment system effluent
samples are analyzed twice per month for Oil and Grease, Total Suspended Solids, pH, and
temperature; and quarterly for select VOCs and chronic toxicity. Oil and Grease, Total Suspended
Solids, and pH in the effluent are consistently within permit limits. VOC concentrations in the
effluent have remained consistently below laboratory detection limits (i.e. less than 1 µg/L). In the
treatment system influent, the average concentration of the primary VOC of concern,
tetrachloroethylene (PCE), was 4,035 micrograms per liter (µg/L) between 2003 and 2017. The
reduction in tetrachloroethylene concentration demonstrates that the removal efficiency of the
treatment system is greater than 99.9%. The most recent monthly and quarterly sampling results
are provided as Attachment 3.
Proposed In Situ Thermal Remediation System
The proposed ISTR system will achieve a significant removal of CVOCs (estimates of source area
CVOC mass removal of approximately 12,000 lbs) through heating of the subsurface and
subsequent recovery of volatilized CVOCs and steam. Vapor recovery (VR) wells will convey the
extracted steam and vapors to modular treatment components, including a process to separate
liquids and vapors, a steam condenser system, a vapor treatment system, and a condensate
treatment system. The condensate treatment system includes both a cooling process and an
adsorption process to remove CVOCs in the condensed liquid. The vapor treatment system will be
subject to its own air permit process, which is being addressed separately with NCDEQ. TRS
Group, Inc. (TRS) has been selected as the ISTR contractor. A process flow diagram and detailed
process and instrumentation diagrams (P&IDs) for the liquid -phase treatment components of the
ISTR system, provided by TRS, are included as Attachment 4.
The average condensate production rate produced by the ISTR system is expected to be
approximately 1.8 gpm and is expected to contain approximately 1,000 µg/L PCE prior to
treatment. The water treatment system for the condensate will consist of tanks for sedimentation,
bag filters to capture remaining suspended solids, liquid granular activated carbon (LGAC) vessels
to provide 99% reduction in CVOC concentrations via adsorption, and a heat exchanger to reduce
Former Schlage Lock Facility, Rocky Mount, NC
engineers I scientists I innovators

Ms. Julie A. Grzyb
22 February 2018
Page 4
water temperature to that of the extracted groundwater. Sampling ports are included in the influent
line to each LGAC vessel and at the effluent of the heat exchanger.
The heat exchanger in the steam condenser system is water-cooled by recirculating potable water
within two cooling towers. The cooling water will not come into contact with the steam from the
subsurface. The cooling water will periodically blowdown to control mineral buildup at an
anticipated average rate of 0.3 gpm.
The treated condensate stream will join the potable water blowdown stream for an expected
combined flowrate of 2.1 gpm (0.0030 MGD) and an approximate PCE concentration of 9 Kg/L.
The treated effluent will then enter the existing on -Site treatment system where it will join
extracted groundwater and pass through the settling, air stripping, and filtration processes prior to
discharge via existing Outfall 001. A process flow diagram for the existing pump -and -treat system,
annotated with the proposed thermal effluent insertion point, is provided as Attachment 5.
In summary, the thermal system will add approximately 2.1 gpm of treated water into the existing
treatment system, which is currently only processing less than 22 percent of its 0.124 MGD limit
at an average flowrate of 18.9 gpm. Additionally, it is noted that the abandonment of three recovery
wells will result in a reduction of approximately 2 gpm from the groundwater extraction and
treatment system. The thermal effluent will be treated by LGAC adsorption, cooled to the same
temperature as the extracted groundwater, and then combined with extracted groundwater for
secondary treatment by air stripping. The water quality of the effluent in Outfall 001 is expected
to be comparable to existing conditions and to meet permit limits.
Per discussion with you by telephone on 02 February 2018, Geosyntec understands that the
existing NPDES permit will need to be modified to include an explicit temperature requirement,
in consideration of the new remedial process that has been proposed. No other modifications (e.g.,
flow rate, CVOC limits, etc.) are anticipated to be required. The thermal treatment system is
scheduled to be installed between April 2018 and July 2018. Thermal operations are planned to
begin in July 2018 and end in the second quarter of 2019, which is within the dates of the current
NPDES permit authorization. Geosyntec greatly appreciates your attention to this requested
modification in order to facilitate a timely installation of the remedy and path to closure.
Former Schlage Lock Facility, Rocky Mount, NC
engineers I scientists 1 innovators

Ms. Julie A. Grzyb
22 February 2018
Page 5
Should you have any questions regarding this submittal, please contact the undersigned at (704)
227-0850.
Sincerely,
f Ahrens, P.E. Wayne Amber, Ph.D.
Principal Engineer
Project Manager
Attachments: 1 — Existing NPDES Permit NC0079227
2 - NC Form C-GW
3 - Recent monthly and quarterly sampling results
4 - Proposed Thermal Process Diagrams
5 - Existing System Process Diagram
Copies to: Mr. Russ Eiler - Schlage
Former Schlage Lock Facility, Rocky Mount, NC
engineers I scientists I innovators

ATTACHMENT 1

NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
Mr. Russell E. Eiler
Schlage Lock Company LLC
11819 N. Pennsylvania St
Carmel, IN 46032
Dear Mr. Eiler:
Donald R. van der Vaart
Secretary
May 6, 2015
Subject: Issuance of NPDES Permit NC0079227
Former Schlage Lock Plant
213 Red Iron Road, Rocky Mount 27804
Nash County
The Division of Water Resources (the Division) hereby issues the attached NPDES permit for the subject
facility. 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 October 15, 2007, or as subsequently amended.
The Division understands that you have made no significant changes to your facility the last permit
renewal with the exception of the average daily flow rate increasing from 30,000 gpd to 35,000 gpd. We
have made the following updates to your previous permit:
• added updates to facility map and parameter codes.
Proposed federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and
specify that, if a state does not establish a system to receive such submittals, then permittees must submit
DMRs electronically to the Environmental Protection Agency (EPA). The Division anticipates that these
regulations will be adopted and is beginning implementation.
The requirement to begin reporting discharge monitoring data electronically using the NC DWR's
Electronic Discharge Monitoring Report (eDMR) interne application has been added to your NPDES
permit. [See Special Condition A. (3.)] For information on eDMR, registering for eDMR and obtaining
an eDMR user account, please visit the following web page:
http://portal.ncdenr.org/web/wq/admin/bog/ipu/edmr.
For information on EPA's proposed NPDES Electronic Reporting Rule, please visit the following web
site:
http://www2.epa.gov/compliance/proposed-npdes-electronic-reporting-rule.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] Fax: [phone]/Customer Service: 1-877-623-6748
Internet:: www.ncwater.orq
An Equal Opportunity\ffirmative Action Employer

Mr. Eiler
May 6,2015
Page 2 of 2
If any parts, measurement frequencies, or sampling requirements contained in this permit are
unacceptable, you have the right to an adjudicatory hearing, upon written request submitted within thirty
(30) days after receiving this letter. Your request must take the form of a written petition conforming to
Chapter 150B of North Carolina General Statutes, and you must file it with the Office of Administrative
Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699-6714. Unless such a demand is
made, this permit shall remain 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 Resources or any
other Federal, State, or Local governmental permits that may be required.
If you have questions, or if we can be of further service, please contact Derek Denard at
[[e-mail] or call [phone].
espec fully,
%'t... r✓
S. Jay Zimmerman, Dire
Division of Water Resfsfirces, NCDENR
Enclosure: NPDES Permit NC0079227 (Issuance Final)
hc: Central Files
NPDES Program Files
RRO Files/ Attn: Danny Smith
ec: Aquatic Toxicology Unit, Susan Meadows [susan.meado‘[e-mail] ncdenr.gov

NPDES Permit NC0079227
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER RESOURCES
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
(NPDES)
In compliance with the provisions 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, the
Schlage Lock Company LLC
is hereby authorized to discharge treated wastewater from a facility known as
Former Schlage Lock Plant (GW-REM)
213 Red Iron Road, Rocky Mount 27804
Nash County
to receiving waters designated as an unnamed tributary to Beech Branch, within the Tar -Pamlico River
Basin, in accordance with effluent limitations, monitoring requirements, and other applicable conditions
set forth in Parts I, II, III, and IV hereof.
The permit shall become effective June 1, 2015.
This permit and the authorization to discharge shall expire at midnight on October 31, 2019.
Signed this day May 6, 2015.
S . Zimmerman, Director
Division of Water Resources
By Authority of the Environmental Management Commission
Page 1 of 6

NPDES Permit NC0079227
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked, and as of this 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 described herein.
Schlage Lock Company LLC
is hereby authorized to:
1. continue operating a 0.124 MGD groundwater remediation system that includes the following
components;
• collection wells
• product separator
• equalization tank with transfer pump
• air stripper with blower
• discharge tank with effluent pump
• bag filters
• effluent flow meter with totalizer
located at the Schlage Lock Company remediation site , 213 Red Iron Road, Rocky Mount, in Nash
County; and
3. discharge from said treatment works via Outfall 001 at a location specified on the attached map,
into an unnamed tributary to Beech Branch [Stream Segment 28-75-(2)], currently a Class C;
NSW waterbody within Subbasin 03-03-02 of the Tar -Pamlico River Basin.
Page 2 of 6

NPDES Permit NC0079227
PART I
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of this permit and Iasting until expiration, the Permittee is
authorized to discharge via Outfall 001. Such discharges shall be limited, monitored and reported' by the
Permittee as specified below:
EFFLUENT
CHARACTERISTIC
[Parameter Codes]
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Location
Flow (MGD)
50050
0.124
Continuous 2
Recording
Effluent
Oil and Grease (mg/L)
00556
30 mg/L
60 mg/L
2/Month
Grab
Effluent
Total Suspended Solids (mg/L)
C0530
30 mg/L
60 mg/L
2/Month
Grab
Effluent
pH (su)
00400
Not < b.0 or > 9.0
standard units
2/Month
Grab
Effluent
Vinyl Chloride 3 (mg/L)
39175
Quarterly
Grab
Effluent
Trichloroethene 3 (TCE) (µg/L)
78391
Quarterly
Grab
Effluent
Tetrachloroethene 3 (PCE) (pg/L)
78389
Quarterly
Grab
Effluent
1,1 Dichloroethene 3 (DCE) (µg/L)
34501
Quarterly
Grab
Effluent
Toluene 3 (y.g/L)
34010
Quarterly
Grab
Effluent
Chloroform 3 (µg/L)
32106
Quarterly
Grab
Effluent
Chronic Toxicity 4
TGP3B
Quarterly
Grab
Effluent
Footnotes:
1. No later than 270 days from the effective date of this permit, the permittee shall begin submitting discharge
monitoring reports electronically using the Division's eDMR application system
[see A. (3)].
2. All discharges Ieaving the treatment facility shall be monitored via a calibrated flow meter system preferably
with an automatic totalizer function. If an automatic totalized flow monitoring is unavailable, the permittee
shall record the approximate time that discharge began and ended, and the instantaneous flow rate so a total
flow event can be calculated.
3. Methods used to evaluate this parameter must produce data with a Practical Quantitation Limit (PQL)
sufficiently sensitive to evaluate compliance with surface water quality standards [see permit Standard
Conditions, Monitoring and Records, Part II Section D. 4.]
4. Chronic Toxicity (Ceriodaphnia) P/F at 90%: February, May, August, and November [See A. (2.)].
Sampling and testing for volatile organic compounds shall be concurrent with whole -effluent toxicity
sampling and testing.
Discharge shall not contain floating solids or foam visible in other than trace amounts.
Discharge shall show no evidence as a source for oily film or sheen on the receiving stream..
Page 3 of 6

NPDES Permit NC0079227
A. (2.) CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY)
[15A NCAC 02B .0500 et seq.]
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia dubia at an effluent concentration of 90%.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the "North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised December 2010, or subsequent versions
or '`North Carolina Phase 1I Chronic Whole Effluent Toxicity Test Procedure" (Revised- December 2010) or
subsequent versions. The tests will be performed during the months of February, May, August and
November. These months signify the first month of each three-month toxicity testing quarter assigned to the
facility. Effluent sampling for this testing must be obtained during representative effluent discharge and 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 -December 2010) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (DMR-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, DWR Form AT-3 (original) is to be sent to
the following address:
Attention: North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section 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 Water Sciences Section 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. Assessment of toxicity compliance is based on the toxicity testing quarter,
which is the three month time interval that begins on the first day of the month in which toxicity testing is
required by this permit and continues until the final day of the third month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of
Water Resources indicate potential impacts to the receiving stream, this permit may be re -opened and modified to
include alternate monitoring requirements or Iimits.
Page 4 of 6

NPDES Permit NC0079227
NOTE: Failure to achieve test con ditions 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.
A. (3.) ELECTRONIC REPORTING OF DISCHARGE MONITORING
REPORTS [G.S. 143-215.1(b)]
Proposed federal regulations require electronic submittal of all discharge monitoring reports (DMRs)
and specify that, if a state does not establish a system to receive such submittals, then permittees must
submit DMRs electronically to the Environmental Protection Agency (EPA). The Division anticipates
that these regulations will be adopted and is beginning implementation in late 2013.
NOTE: This special condition supplements or supersedes the following sections within Part II of this
permit (Standard Conditions for NPDES Permits):
• Section B. (11.) Signatory Requirements
• Section D. (2.) Reporting
• Section D. (6.) Records Retention
• Section E. (5.) Monitoring Reports
1. Reportinz [Supersedes Section D. (2.) and Section E. (5.) (a)]
Beginning no later than 270 days from the effective date of this permit, the pennittee shall begin
reporting discharge monitoring data electronically using the NC DWR's Electronic Discharge
Monitoring Report (eDMR) internet application.
Monitoring results obtained during the previous month(s) shall be summarized for each month and
submitted electronically using eDMR. The eDMR system allows permitted facilities to enter
monitoring data and submit DMRs electronically using the internet. Until such time that the state's
eDMR application is compliant with EPA's Cross -Media Electronic Reporting Regulation
(CROMERR), permittees will be required to submit all discharge monitoring data to the state
electronically using eDMR and will be required to complete the eDMR submission by printing,
signing, and submitting one signed original and a copy of the computer printed eDMR to the
following address:
NC DENR / DWR / Information Processing Unit
ATTENTION: Central Files / eDMR
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility
being physically located in an area where less than 10 percent of the households have broadband
access, then a temporary waiver from the NPDES electronic reporting requirements may be granted
and discharge monitoring data may be submitted on paper DMR forms (MR 1, 1.1, 2, 3) or
alternative forms approved by the Director. Duplicate signed copies shall be submitted to the
mailing address above.
Page 5 of 6

NPDES Permit NC0079227
Requests for temporary waivers from the NPDES electronic reporting requirements must be
submitted in writing to the Division for written approval at least sixty (60) days prior to the date the
facility would be required under this permit to begin using eDMR. Temporary waivers shall be valid
for twelve (12) months and shall thereupon expire. At such time, DMRs shall be submitted
electronically to the Division unless the permittee re -applies for and is granted a new temporary
waiver by the Division.
Information on eDMR and application for a temporary waiver from the NPDES electronic reporting
requirements is found on the following web page:
http://portal.ncdenr.org/web/wq/admin/bog/ipu/edmr
Regardless of the submission method, 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.
2. Signatory Requirements [Supplements Section B. (11.) (b) and supersedes Section B. (11.) (d)1
All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part II,
Section B. (11.)(a) or by a duly authorized representative of that person as described in Part II,
Section B. (11.)(b). A person, and not a position, must be delegated signatory authority for eDMR
reporting purposes.
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user
account and login credentials to access the eDMR system. For more information on North
Carolina's eDMR system, registering for eDMR and obtaining an eDMR user account, please visit
the following web page:
http://portal.ncdenr.org/web/wq/admin/bog/ipu/edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system shall make
the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION
WILL BE ACCEPTED:
"I certify, under penalty of law, that this document and all cattachnients 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 offines and imprisonment for knowing violations."
3. Records Retention [Supplements Section D. (6.)I
The permittee shall retain records of all Discharge Monitoring Reports, including eDMR submissions. These
records or copies shall be maintained for a period of at least 3 years from the date of the report. This period
may be extended by request of the Director at any time [40 CFR 122.41].
Page 6 of 6

Outfall 001
(flows northeast)
Approximate
Facility Boundary
St Ptktr •
Former Schlage Lock Plant
Groundwater Remediation
213 Red Iron Road, Rocky Mount 27804
Receiving Scream:
Drainage Basin:
Latitude:
Stream Class:
State Grid/USCS Quad:
UT to Beech Branch
Tar -Pamlico River Basin
36°01'26"
C; NSW
C27SE / Drake, NC
Stream Segment:
Suh-Basin:
Lonaitudc:
DUC:
23-75-(2)
03-03-02
77° 45' 56"
03020101
Facility
Location
Scale 1:24,000
North
UT toBeech Branch
[flows northeast]
Red Iron Rd
NPDES Permit NC0079227
Nash County

NPDES Permit Standard Conditions
Page 1 of 18
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. These samples shall be
representative of the wastewater discharged during the sample period.
3/Week
Samples are collected three times per week on three separate calendar days. These samples shall be representative of
the wastewater discharged during the sample period.
Act or "the Act"
The Federal Water Pollution Control Act, also known as the Clean Water Act (CWA), as amended, 33 USC 1251, et.
seq.
Annual Average
The aritlunetic mean of all "daily discharges" of a pollutant measured during the calendar year. In the case of fecal
conform, the geometric mean of such discharges.
Arithmetic Mean
The summation of the individual values divided by the number of individual values.
Bvpass
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 Week
The period from Sunday through the following Saturday.
Calendar Quarter
One of the following distinct periods: January through March, April through June, July through September, and
October through December.
Composite Sample
A satnple 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
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
(3)
Version 11/09/2011.1

NPDES Permit Standard Conditions
Page 2 of 18
(4) Constant time/constant volume: a series of grab samples of equal volume collected over a 24-hour period at a
constant time interval. Use of this method requires prior approval by the Director. This method may only be
used in situations where effluent flow rates vary less than 15 percent. The following restrictions also apply:
• Influent and effluent grab samples shall be of equal size and of no less than 100 milliliters
s Influent samples shall not be collected more than once per hour.
➢ Permittees with wastewater treatment systems whose detention time < 24 hours shall collect effluent grab
samples at intervals of no greater than 20 minutes apart during any 24-hour period.
➢ Permittees with wastewater treatment systems whose detention time exceeds 24 hours shall collect effluent
grab samples at least every six hours; there must be a minimum of four samples 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. For pollutants expressed in other units of measurement, the
"daily discharge" is calculated as the average measurement of the pollutant over the day. (40 CFR 122.2; see also
"Composite Sample," above.)
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. 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).
DWR or "the Division"
The Division of Water Resources, Department of Environment and Natural Resources.
Effluent
Wastewater discharged following all treatment processes from a water pollution control facility or other point source
whether treated or untreated.
EMC
The North Carolina Environmental Management Commission
EPA
The United States Environmental Protection Agency
Facility Closure
Cessation of all activities that require coverage under this NPDES permit. 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).
Version 11/09/2011.1

NPDES Permit Standard Conditions
Page 3 of 18
Hazardous Substance
Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the CWA.
Instantaneous flow measurement
The flow measured during the minimum time required for the flow measuring device or method to produce a result in
that instance. To the extent practical, instantaneous flow measurements coincide with the collection of any grab
samples required for the same sampling period so that together the samples and flow are representative of the discharge
during that sampling period.
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 or other bacterial parameters or indicators, the geometric mean of such discharges.
Permit Issuing Authority
The Director of the Division of Water Resources.
Quarterly Average (concentration limit)
The arithmetic mean 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 CWA.
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 or other bacterial parameters or indicators, 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 CWA and is grounds for enforcement action; for permit termination, revocation and reissuance, or
modification; or denial of a pennit renewal application [40 CFR 122.41].
a. The Permittee shall comply with effluent standards or prohibitions established under section 307(a) of the
CWA for toxic pollutants and with standards for sewage sludge use or disposal established under section
405(d) of the CWA 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 CWA provides that any person who violates section[s] 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 $37,500 per day for each violation. [33 USC 1319(d) and 40 CFR
122.41(a)(2)]
c. The CWA 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
Version 11/09/2011.1

NPDES Permit Standard Conditions
Page 4 of 18
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. [33 USC 1319(c)(1) and 40 CFR 122.41(a)(2)]
d. Any person who knowingly 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.
[33 USC 1319(c)(2) and 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 § 143-215.6A]
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 $16,000 per violation, with the maximum amount of any Class I penalty assessed not to exceed
$37,500. Penalties for Class Il violations are not to exceed $16,000 per day for each day during which the
violation continues, with the maximum amount of any Class II penalty not to exceed $177,500. [33 USC
1319(g)(2) and 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 with 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 I1.C.7), nothing in this permit shall be construed to relieve the Permittee from any responsibilities, liabilities,
or penalties for noncompliance pursuant to NCGS 143-215.3, 143-215.6 or Section 309 of the Federal Act, 33 USC
1319. Furthermore, the Permittee is responsible for consequential damages, such as fish kills, even though the
responsibility for effective compliance may be temporarily suspended.
4. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the Permittee
from any responsibilities, liabilities, or penalties to which the Permittee is or may be subject to under NCGS 143-
215.75 et seq. or Section 311 of the Federal Act, 33 USG 1321. Furthermore, the Permittee is responsible for
consequential damages, such as fish kills, even though the responsibility for effective compliance may be
temporarily suspended.
5. Property Rights
The issuance of this permit does not convey any property rights in either real or personal property, or any exclusive
privileges, nor does it authorize any injury to private property or any invasion of personal rights, nor any
infringement of Federal, State or local laws or regulations [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.
g-
Version 11/09/2011.1

NPDES Permit Standard Conditions
Page 5 of 18
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, fonns, and fees as are required
by the agency authorized to issue permits no later than 180 days prior to the expiration date unless permission for a
later date has been granted by the Director. (The Director shall not grant permission for applications to be
submitted later than the expiration date of the existing permit.) [40 CFR 122.21(d)] 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:
(1) For a corporation: by a responsible corporate officer. For the purpose of this Section, a responsible
corporate officer means: (a) a president, secretary, treasurer or vice president of the corporation in charge
of a principal business function, or any other person who performs similar policy or decision making
functions for the corporation, or (b) the manager of one or more manufacturing, production, or operating
facilities, 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]
Version 11/09/2011.1

NPDES Permit Standard Conditions
Page 6 of l3
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 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE ACCEPTED:
"1 certifii, 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 fbr
submitting false information, including the possibility of funs 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 riisuance, or termination, or a notification of planned changes
or anticipated noncompliance does not stay any permit condition [40 CFR 122.41(0].
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 pennit, or terminating the pernit 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, Subchaptcr 02H .0100; and North Carolina General Statute 143.215.1 et. al.
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 02H .0105(b)(2)
may cause this Division to initiate action to revoke the permit.
Section C. Operation and Maintenance of Pollution Controls
I. Certified Operator
Owners of classified water pollution control systems trust designate operators, certified by the Water Pollution
Control System Operators Certification Commission (WPCSOCC), of the appropriate type and grade for the
system, and, for each classification must [T15A NCAC 08G .0201]:
a. designate one Operator In Responsible Charge (ORC) who possesses a valid certificate of the type and grade at
least equivalent to the type and grade of the system;
b. designate one or more Back-up Operator(s) in Responsible Charge (Back-up ORCs) who possesses a valid
certificate of the type of the system and no more than one grade less than the grade of the system, with the
exception of no backup operator in responsible charge is required for systems whose minimum visitation
requirements are twice per year; and
c. submit a signed completed "Water Pollution Control System Operator Designation Form" to the Commission
(or to the local health department for owners of subsurface systems) countersigned by the designated certified
operators, designating the Operator in Responsible Charge (ORC) and the Back-up Operator in Responsible
Charge (Back-up ORC):
(1) 60 calendar days prior to wastewater or residuals being introduced into a new system; or
(2) within 120 calendar days following:
> receiving notification of a change in the classification of the system requiring the designation of a new
Operator in Responsible Charge (ORC) and Back-up Operator in Responsible Charge (Back-up ORC)
of the proper type and grade; or
➢ a vacancy in the position of Operator in Responsible Charge (ORC) or Back-up Operator in
Responsible Charge (Back-up ORC).
Version 11/09/2011.1

NPDES Pen -nit Standard Conditions
Page 7 of 18
(3) within seven calendar days of vacancies in both ORC and Back-up ORC positions replacing or designating
at least one of the responsibilities.
The ORC of each Class 1 facility (or the Back-up ORC, when acting as surrogate for the ORC) must:
➢ Visit the facility as often as is necessary to insure proper operation of the treatment system; the treatment
facility must be visited at least weekly
➢ Comply with all other conditions of 15A NCAC 08G .0204.
The ORC of each Class 1I, III and IV facility (or the Back-up ORC, when acting as surrogate for the ORC) must:
> Visit the facility as often as is necessary to insure proper operation of the treatment system; the treatment
facility must be visited at least five days per week, excluding holidays
> Properly manage and document daily operation and maintenance of the facility
> Comply with all other conditions of 15A NCAC 08G .0204.
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 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)].
NOTE: Properly and officially designated operators are fully responsible for all proper operation and maintenance
of the facility, and all documentation required thereof, whether acting as a contract operator [subcontractor] or a
member of the Permittee's staff.
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 I22A1(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) 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 judgement 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.
Version 11/09/2011.1

D FENCE
DRIP LOO
TO/FROM AOI-2
VR PIPING
FROM AOI-2
BAG FILTERS
POLY TANKS
MAKEUP WA ET R�
POTABLE SOURCE)
BLOWER
40 HP
x
x
RIP LOOP
TO/FROM AOI-1
,_�� V R PIPING
FROM AOI-1
200 LB LIQUID
GAC VESSELS
5,000 lb VAPOR
GAC VESSELS
NOTES
1. STACK HEIGHT WILL BE 15 FT, UNLESS OTHERWISE
REQUIRED BY THE AIR PERMIT.
2. PIPING TO/FROM THE VGAC VESSELS CAN BE CPVC OR
FLEX HOSE.
LEGEND
d 11 T p-
3/4" PEX
GRASS
TACK (SEE NOTE 1)
SEE NOTE 2
ERH SYSTEM DISCHARGE T
GEOSYNTEC WATER TREAMENT
SYSTEM PRIOR TO NPDES
DISCHARGE (OUTFALL 001)
OFFICE
TRAILER
BROKEN CONCRETE
k x
x x
x x
x x
x
x
TO GEOSYNTEC WATER
TREAMENT SYSTEM
K1
L14
x
M14
x
WATER
TREATMENT
SYSTEM
BLDG
x
x
x
x
ROM CONDENSER
N'
H28
° H29c H30
s
N
i
1" SCH 80 PVC
2" SCH 40 PVC
6" SCH 40 CPVC
SECONDARY CONTAINMENT
SECURITY FENCE
0 10 20
40
SCALE IN FEET
TRS
Accelerating Value
TRS GROUP, INC. 338 COMMERCE AVE., SUITE 304, LONGVIEW, WA 98632
CONFIDENTIAL: INFORMATION CONTAINED IN THIS DOCUMENT 15 CONFIDENTIAL AND THE
PROPERTY OF TRS GROUP, INC NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED, USED OR
DISTRIBUTED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP INC LONGVIEW. WA
DESIGNED BY
M. NANISTA
DRAWN BY
A. PEABODY
CHECKED BY
D. OBERLE
PROJECT MANAGER
D. SMALL
QSAT REVIEW
2018-01-02
SITE
LOCATION
CLIENT
FORMER SCHLAGE LOCK FACILITY
ROCKY MOUNT, NORTH CAROLINA
GEOSYNTEC CONSULTANTS, INC.
EQUIPMENT PIPING PLAN
APPROVED FOR CONSTRUCTION
BY
DATE
DATE
2018-02-08
PROJECTNC.ROM.2046
SHEET
Y-4

LEGEND
PLID LINE COLORS
PROCESS LINE LABELING
SEE SHEET P-2 FOR DESCRIPTION
SOLENOID
BALL VALVE
BUTTERFLY VALVE
ANTI -SIPHON VALVE
PVC TRUE UNION BALL VALVE
SAMPLE PORT
CHECK VALVE
SELF-CONTAINED
PRESSURE REGULATOR
SPIGOT
BACKFLOW PREVENTER
FLANGE
VACUUM RELEASE VALVE
XX PIPING SPEC. :CHANGE
PUMP
BLOWER
ciaD
NOTES
ROTARY LOBE BLOWER
TANK
HEAT EXCHANGER
FILTER/SILENCER
BAG FILTER HOUSING
SUBMERSIBLE PUMP
PI
COMPUTER OPERATED MONITORING,
DATA COLLECTION AND CONTROLS
HARDWIRE CONTROLS
PRESSURE INDICATOR
PCV PRESSURE CONTROL VALVE
PSL PRESSURE SWITCH LOW
FE FLOW ELEMENT
Fl FLOW INDICATOR
FQI FLOW QUANTITY INDICATOR
FT FLOW TRANSMITTER
FQI FLOW QUANTITY INDICATOR
U LEVEL INDICATOR
LSH LEVEL SWITCH HIGH
LSHH LEVEL SWITCH HIGH -HIGH
LSL LEVEL SWITCH LOW
LSLL LEVEL SWITCH LOW -LOW
TAH TEMPERATURE ALARM HIGH
TE TEMPERATURE ELEMENT
TSL TEMPERATURE SWITCH LOW
11 TEMPERATURE INDICATOR
TSH TEMPERATURE SWITCH HIGH
YC CONTROLLER
T TEMPERATURE SENSOR
CS CARBON STEEL
CPVC SCH 40. CPVC PIPE
pp( PEX TUBING
FCV FLOW CONTROL VALVE
PSH PRESSURE SWITCH HIGH
TSH TEMPERATURE SWITCH HIGH
SOFTENED/POTABLE/CLEAN WATER
PROCESS WATER
AIR
AIR/STEAM MIX
BLOWDOWN
COMPUTER OPERATED CONTROLS
HARDWIRE CONTROLS
ELECTRICAL CABLE
•
TRS
Accelerating Value
DESIGNED BY SITE FORMER SCHLAGE LOCK FACILITY
M. NANISTA LOCATION ROCKY MOUNT, NORTH CAROLINA
CLIENT GEOSYNTEC CONSULTANTS, INC
DRAWN BY
A. PEABODY PROCESS AND INSTRUMENTATION DIAGRAM
CHECKED BY
D. OBERLE LEGEND
PROJECT MANAGER
D. SMALL APPROVED FOR CONSTRUCTION DATE 2018-02-05 PROJECTNC.ROM.2046
OSAT REVIEW BY 'v
1. THIS IS AN ALL INCLUSIVE LEGEND SHEET. NOT ALL
SYMBOLS WILL APPEAR ON EACH SHEET.
TRS GROUP, INC. 338 COMMERCE AVE., SUITE 304, LONGVIEW, WA 98632
CONFIDENTIAL: INFORMATION CONTAINED IN THIS DOCUMENT IS CONFIDENTIAL AND THE
PROPERTY OF TRS GROUP, INC NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED. USED OR
DISTRIBUTED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP, INC LONGVIEW WA
SHEET P_ 1
2018-01-02
DATE

REFER TO DRAWING SHEET P-4
3
TYPICAL OF 108
CO -LOCATED VAPOR
RECOVERY WELLS
CIRCULATING DRIP SYSTEM
FOR ELECTRODE WETTING
REFER TO DRAWING SHEET P-7
BLEED AIR
°o O
BLOWER
VAPOR PHASE
CARBON
DISCHARGE
TO
ATMOSPHERE
REFER TO DRAWING SHEET P-5 REFER TO DRAWING SHEET P-6
CONDENSER
P❑ID LINE COLORS
SOFTENED/POTABLE/CLEAN WATER
PROCESS WATER
AIR
AIR/STEAM MIX
BLOWDOWN
AIR IN
10
COOLING
TOWER
J
AIR OUT
MAKE-UP
WATER
- 14 0
LIQUID GRANULAR
ACTIVATED CARBON
REFER TO DRAWING SHEET P-8
WATER TO
GEOSYNTEC WATER
TREATMENT SYSTEM
(SEE ATTACHMENT 5
FOR PUMP AND TREAT
PROCESS DIAGRAM)
TRS
Accelerating Value
TRS GROUP, INC. 338 COMMERCE AVE., SUITE 304, LONGVIEW. WA 98632
CONFIDENTIAL: INFORMATION CONTAINED IN THIS DOCUMENT IS CONFIDENTIAL AND THE
PROPERTY OF TRS GROUP, INC NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED. USED OR
DISTRIBUTED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP. INC LONGVIEW. WA
DESIGNED BY
M. NANISTA
DRAWN BY
A.PEABODY
CHECKED BY
D OBERLE
PROJECT MANAGER
D SMALL
QSAT REVIEW
2018-01-02
SITE
LOCATION
CLIENT
FORMER SCHLAGE LOCK FACILITY
ROCKY MOUNT. NORTH CAROLINA
GEOSYNTEC CONSULTANTS. INC
PROCESS FLOW DIAGRAM
APPROVED FOR CONSTRUCTION
BY
DATE
DATE
2018-02-05 PROJECNJC ROM.2046
SHEET
P-2

Process Stream
Description
Extracted air and steam from vapor recovery system
Discharge air from condenser after steam removal
Condensate discharge from condenser
Bleed air to rotary lobe blower
Discharge air from rotary lobe blower
Discharge from carbon vessels
Cooling air into cooling tower
Air exhaust from cooling tower
Recirculation water from condenser to cooling tower
Recirculation from cooling tower to condenser
Make-up water for cooling tower from potable source
Drip water to electrodes (potable)
Blowdown
Condensate after LGA(
Discharge to Geosyntec water treatment system
NOTES
1 LOCATION INDICATED IN THIS TABLE CORRESPOND TO
THE LOCATION NUMBERS PROVIDED ON SHEET P-2.
Location
6
7
8
9
10
11
Air
(lb/min)
(scfm)
946
946
30,000
30,000
Water Vapor
(lb/min)
0
1.80
1.80
16.94
30
Water
(lb/min) (gpm)
2
15
17
CVOCs
1.5E-05
0 0.039
0 3.9E-04
0.3
1.8
2.1
0
1.5E-07
1.5E-07
100.08
0
0.01
8.8E-03
Temperature
Pressure
(0 from
C F barometric)
69 156 2" Hg Vac
30 86 5" Hg Vac
30
30
30
86
86
86
30 psig
N/A
1 psig
N/A
N/A
N/A
10 psig
12 psig
15 psig
70 psig
12 psig
12 psig
12 psig
TRS GROUP. INC
TRS
Accelerating Value
338 COMMERCE AVE., SUITE 304, LONGVIEW. WA 98632
CONFIDENTIAL: INFORMATION CONTAINED IN THIS DOCUMENT IS CONFIDENTIAL AND THE
PROPERTY OF TRS GROUP. INC. NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED USED OR
DISTRIBUTED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP. INC LONGVIEW WA
DESIGNED BY
M. NANISTA
DRAWN BY
A PEABODY
CHECKED BY
D OBERLE
PROJECT MANAGER
D. SMALL
QSAT REVIEW
2018-01-02
SITE
LOCATION
CLIENT
FORMER SCHLAGE LOCK FACILITY
ROCKY MOUNT. NORTH CAROLINA
GEOSYNTEC CONSULTANTS. INC
PROCESS FLOW MASS BALANCE
APPROVED FOR CONSTRUCTION
BY
DATE
DATE
2018-02-05
PROJECTNC. ROM.2046
SHEET
P-3

REFER TO DRAWING
SHEET P-5
ELECTRODE DRIP
RECIRCULATION LOOP
FROM P-503
DATA ACQUISITION
AND COMPUTER
CONTROLS
ERH POWER
CONTROL UNIT
ELECTRODE CABLES
V)
1/2" PEX
-1
J
0
---------------------------------------------------------
1" HOSE
3/4" PEX
REFER TO DRAWING
SHEET P-5
CPVC
(SIZE VARIES)
REFER TO DRAWING
SHEET P-5
ELEMENT
TYPICAL OF 108 ELECTRODES
WITH CO -LOCATED VAPOR
RECOVERY WELLS
NOTES
1. SEE THE ELECTRODE AND TEMPERATURE MONITORING POINT DETAILS FOR MORE INFORMATION ON THEIR CONSTRUCTION.
2. PSH-401 WILL SHUT DOWN THE PCU IN THE EVENT OF A LOW FIELD VACUUM (LESS THAN 2" H20).
3. DRIP WATER TO ELECTRODES (STREAM 12) WILL BE NON -CONTACT COOLING WATER FROM THE CONDENSER WITH A
POTABLE WATER SOURCE.
ELECTRODE DRIP
RECIRCULATION LOOP
TO P-503
AIR AND STEAM TO
CONDENSER PRIMARY
SEPARATOR
T
T
T
T
T
TYPICAL OF 13
TEMPERATURE MONITORING POINTS
(NUMBER OF SENSORS VARIES BY ZONE)
TRS
Accelerating value
TRS GROUP, INC. 338 COMMERCE AVE., SUITE 304, LONGVIEW, WA 98632
DESIGNED BY SITE FORMER SCHLAGE LOCK FACILITY
M. NANISTA LOCATION ROCKY MOUNT, NORTH CAROLINA
CLIENT GEOSYNTEC CONSULTANTS, INC.
DRAWN BY
A. PEABODY
CHECKED BY FIELD
D.OBERLE PROCESS AND INSTRUMENTATION DIAGRAM
PROJECT MANAGER
D. SMALL APPROVED FOR CONSTRUCTION DATE 2018-02-08 PROJECTNC.ROM.2046
OSAT REVIEW BY
2018-01-02 SHEET P-4
DATE
CONFIDENTIAL: INFORMATION CONTAINED IN THIS DOCUMENT IS CONFIDENTIAL AND THE
PROPERTY OF TRS GROUP, INC NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED. USED OR
DISTRIBUTED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP, INC LONGVIEW. WA

REFER TO DRAWING
SHEET P-4
AIR AND STEAM FROM
VAPOR RECOVERY
J
CPVC6 -8" SS
REFER TO DRAWING
SHEET P-6
COOLING WATER FROM
COOLING TOWER
0
r
STEAM AND
COOLING
WATER OUT
EQUALIZATION LINE
P-501
DRIP LINE
AND BLOWDOWN
N.C.
CONDENSER SKID
AIR AND CONDENSED
STEAM OUT
COOLING
WATER IN
P-503
AUTOMATED
CONTROLS AND
SHUTDOWNS
V-502
SECONDARY
SEPARATOR
DATA ACQUISITION
AND COMPUTER
CONTROLS
-I 6" SS6"CPVC
J
1
P-502
L
NOTESC
1. LSHH-501 WILL SHUT DOWN THE VAPOR RECOVERY BLOWER AND POWER TO THE ELECTRODES.
2. TSH-502 WILL SHUT DOWN THE VAPOR RECOVERY BLOWER. TEMPERATURE SET POINT IS 140°F.
3. PROCESS LINE 9 SPLITS WITH HALF THE TOTAL FLOW (PROCESS LINE 9A) GOING TO EACH COOLING TOWER (SEE P-6).
4. THE HEAT EXCHANGER IS ASME 2 RATED.
O
O
FILTER
O
REFER TO DRAWING
SHEET P-6
REFER TO DRAWING
SHEET P-7
COOLED AIR TO
BLOWER
1
T
COOLING WATER TO
COOLING TOWER
REFER TO DRAWING
SHEET P-8
TO WATER TREATMENT \
SYSTEM /
REFER TO DRAWING
' I SHEET P-4
Q H TO DRIP SYSTEM >
O
REFER TO DRAWING
SHEET P-4
FROM DRIP SYSTEM
REFER TO DRAWING
SHEET P-8
BLOWDOWN
J
TRS
Accelerating Value
TRS GROUP, INC. 338 COMMERCE AVE., SUITE 304, LONGVIEW, WA 98632
CONFIDENTIAL: INFORMATION CONTAINED IN THIS DOCUMENT IS CONFIDENTIAL AND THE
PROPERTY OF TRS GROUP. INC NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED. USED OR
DISTRIBUTED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP, INC LONGVIEW, WA
DESIGNED BY SITE FORMER SCHLAGE LOCK FACILITY
M. NANISTA LOCATION ROCKY MOUNT, NORTH CAROLINA
CLIENT GEOSYNTEC CONSULTANTS, INC.
DRAWN BY
A. PEABODY
CHECKED BY CONDENSER
D. OBERLE PROCESS AND INSTRUMENTATION DIAGRAM
PROJECT MANAGER
D. SMALL APPROVED FOR CONSTRUCTION DATE 2018-02-05 PROJECT.C.ROM.2046
QSAT REVIEW BY
2018-01-02 DATE
SHEET
P-5

CONDENSER SKID
REFER TO DRAWING
SHEET P-5
COOLING WATER FROM
CONDENSER
AIR INTO
COOLING TOWER
BLOWER
(B-601)
COOLING TOWER
CT-1
AIR EXITING
COOLING TOWER
REFER TO DRAWING
SHEET P-5
COOLING WATER TO
< CONDENSER HEAT
EXCHANGER
Trir
REFER TO NOTE 1
7
1
I
L_
NOTES
1. TSL-601 AUTOMATICALLY SHUTS DOWN THE COOLING TOWER FAN AT 45° F. TSL-602 TURNS ON AN IMMERSION HEATER IN THE
COOLING TOWER SUMP.
2. LSHH-601 SHUTS DOWN SYSTEM
3. LSH-601 OPENS BLOWDOWN SOLENOID AT CONDENSER.
4. LSL-601 MUST BE AT LEAST 2 FEET ABOVE PUMP INTAKE.
5. POTABLE MAKEUP WATER IS SUPPLIED TO THE COOLING WATER SUMP TANK, AS NEEDED, AT AN AVERAGE RATE OF 3-5 GPM IN
30 SECOND INCREMENTS.
6. PROCESS LINE 7 SPLITS WITH HALF THE TOTAL FLOW (PROCESS LINE 7A) GOING TO EACH COOLING TOWER (SEE P-2).
7. PROCESS LINE 8 IS THE COMBINATION OF PROCESS LINES 8A (ONE FROM EACH COOLING TOWER, SEE P-2).
8. PROCESS LINE 9 SPLITS WITH HALF THE TOTAL FLOW (PROCESS LINE 9A) GOING TO EACH COOLING TOWER (SEE P-2)
BLOWER
(B-602)
COOLING TOWER
CT-2
DATA ACQUISITION
AND COMPUTER
CONTROLS
COOLING WATER
SUMP TANK
REFER TO NOTE 2
REFER TO NOTE 3
SOLENOID OPENS ON
LOW LEVEL ALARM
1
L
gla
ALARM SHUTS DOWN PUMPS
P-501 AND P-502
REFER TO DRAWING
SHEET P-5
AIR EXITING
COOLING TOWER
REFER TO DRAWING
SHEET P-2
C POTABLE WATER FOR
MAKEUP
J
TRS
Accelerating Value
TRS GROUP, INC. 338 COMMERCE AVE., SUITE 304, LONGVIEW, WA 98632
CONFIDENTIAL: INFORMATION CONTAINED IN THIS DOCUMENT IS CONFIDENTIAL AND THE
PROPERTY OF TRS GROUP, INC. NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED, USED OR
DISTRIBUTED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP INC LONGVIEW, WA
DESIGNED BY SITE FORMER SCHLAGE LOCK FACILITY
M. NANISTA LOCATION ROCKY MOUNT, NORTH CAROLINA
CLIENT GEOSYNTEC CONSULTANTS, INC.
DRAWN BY
A. PEABODY
CHECKED BY COOLING TOWER
D. OBERLE PROCESS AND INSTRUMENTATION DIAGRAM
PROJECT MANAGER
D. SMALL APPROVED FOR CONSTRUCTION DATE 2018-02-05 PROJECT C.ROM.2046
OSAT REVIEW BY ffVV
2018-01-02 SHEET P - 6
DATE

BLEED AIR
L
REFER TO DRAWING
SHEET P-5
AIR FROM CONDENSER
SECONDARY
SEPARATOR
KcV
FILTER
VR BLOWER SKID
Iol
I
6" CPVC-1-.6"
6-
II I
VACUUM
RELEASE
VALVE
FILTER
40 HP ROTARY
LOBE BLOWER
L(B-701) J
T
SILENCER
6" CPVC OR
FLEX HOSE
6" CPVC OR
FLEX HOSE
VAPOR PHASE
CARBON
DATA ACQUISITION
AND COMPUTER
CONTROLS
6" CPVC OR
FLEX HOSE
DISCHARGE TO
ATMOSPHERE
1
J
TRS
Accelerating Value
DESIGNED BY
M. NANISTA
DRAWN BY
A.PEABODY
CHECKED BY
D. OBERLE
PROJECT MANAGER
0. SMALL
SITE FORMER SCHLAGE LOCK FACILITY
LOCATION ROCKY MOUNT, NORTH CAROLINA
CLIENT GEOSYNTEC CONSULTANTS, INC
VAPOR TREATMENT
PROCESS AND INSTRUMENTATION DIAGRAM
TRS GROUP, INC. 338 COMMERCE AVE., SUITE 304, LONGVIEW, WA 98632
CONFIDENTIAL: INFORMATION CONTAINED IN THIS DOCUMENT IS CONFIDENTIAL AND THE
PROPERTY OF TRS GROUP, INC NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED, USED OR
DISTRIBUTED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP INC LONGVIEW WA
QSAT REVIEW
2018-01-02
APPROVED FOR CONSTRUCTION
BY
DATE
DFTE
2018-02-05
PROJECNC ROM 2046
SHEET
P-7

REFER TO DRAWING
SHEET P-5
CONDENSATE FROM
CONDENSER
0
of
AUTOMATED
CONTROLS AND
SHUTDOWNS
7
POLY TANK
FILL PIPE
SUBMERSIBLE
PUMP
(P-801)
POLY TANK
ALL PIPING 2" SCH 40 PVC
NOTESL
1. VESSEL CONNECTIONS MAY VARY.
2. ALL PIPING FOR THE WATER TREATMENT SYSTEM SHOULD BE 2" SCH80 PVC.
3. ALL VALVES TO BE TRUE UNION BALL VALVES.
4. BACKWASH VALVING IS OPTIONAL WHEN NEEDED.
5. VESSELS TO BE FIBERGLASS, EVOQUA PG-200.
6. TRUE UNIONS WILL BE ADDED TO VESSEL INLETS AND OUTLETS OF EACH VESSEL
TO AID IN GAC CHANGE -OUT AND SILT REMOVAL WHEN NEEDED.
7. A HEAT EXCHANGER WILL BE INCORPORATED INTO THE SYSTEM TO MEET NPDES
TEMPERATURE DISCHARGE LIMITS IN THE SYSTEM DISCHARGE, IF NEEDED.
O
SAMPLE PORT
T
LGAC
1
T
IOI
101
1
LGAC
REFER TO DRAWING
SHEET P-5
BLOWDOWN FROM
CONDENSER
HEAT EXCHANGER
(SEE NOTE 7)
REFER TO DRAWING
SHEET P-2
WATER TO GEOSYNTEC
WATER TREATMENT
SYSTEM
•
TRS
Accelerating Value
TRS GROUP, INC. 338 COMMERCE AVE.. SUITE 304, LONGVIEW, WA 98632
CONFIDENTIAL: INFORMATION CONTAINED IN THIS DOCUMENT IS CONFIDENTIAL AND THE
PROPERTY OF TRS GROUP INC. NO INFORMATION CONTAINED HEREIN MAY BE DUPLICATED. USED OR
DISTRIBUTED WITHOUT THE EXPRESSED WRITTEN PERMISSION OF TRS GROUP, INC LONGVIEW, WA
DESIGNED BY
M. NANISTA
DRAWN BY
A. PEABODY
SITE FORMER SCHLAGE LOCK FACILITY
LOCATION ROCKY MOUNT, NORTH CAROLINA
CLIENT GEOSYNTEC CONSULTANTS, INC.
CHECKED BY
D. OBERLE
PROJECT MANAGER
D. SMALL
WATER TREATMENT
PROCESS AND INSTRUMENTATION DIAGRAM
QSAT REVIEW
2018-01-02
APPROVED FOR CONSTRUCTION
BY
DATE
DATE
2018-02-08
PROJECT.
SHEET
P-8

ATTACHMENT 5

15394SYS DIA.DWG 4/20/04 1=1 CH/EH
SOUTH RW
SEPARATION TANK
\T100
PRE-TREATED DISCHARGE
FROM THERMAL SYSTEM
NORTH RW
i
55 GAL DRUM
TO SOUTH RW
EQUILIZATION TANK
T-200
DIAPHRAM PUMP
SUMP
EQ PUMP
P-110
VENT
AIR BLOWER
AIR STRIPPER
(TRAYS, BLOWER
AND PUMP)
N / \ /
EFFLUENT DISCHARGE
AIR COMPRESSOR
CARBON CANISTER #2
CARBON CANISTER 11
P-400
/ N / N
CARBON CANISTERS DEACTIVATED AND REMOVED
OVERFLOW DISCHARGE
DISCHARGE TANK
T-610
CLOSED VALVE
-( *A" .>--
BAG FILTERS
.B.
DISCHARGE PUMP
P-610
Environmental
Resources
ERM Management
GROUNDWATER TREATMENT SYSTEM BLOCK DIAGRAM
FORMER SCHLAGE LOCK FACILITY
NPDES PERMIT #NC0079227
FIGURE
1-2

Attachment 3 — June 2018 NCDEQ Response to
Modification Request

Water Resources
ENVIRONMENTAL QUALITY
June 13, 2018
Russell E. Eiler, Director, Global EHS Compliance
Schlage Lock Company LLC
11819 N. Pennsylvania Street
Carmel, Indiana 46032
Subject:
Dear Mr. Eiler:
ROY COOPER
MICHAEL S. REGAN
LINDA C'ULPEPPER
NPDES Permit NC0079227
Review of Application to Modify Permit for
the Former Schlage Lock Plant
GW-REM — Class PC-1
213 Red Iron Road, Rocky Mount 27804
Nash County
The Division of Water Resources (the Division or DWR) has reviewed your application (received
April 3, 2018) to modify the subject permit. We do not believe the permit needs to be modified for
you to proceed.
We understand you propose to vaporize liquid -phase organic compounds to facilitate contaminant
removal in the subsurface, then condense the vapor back to liquid for treatment prior to discharge.
We have considered the potential impacts to the receiving stream of changes in process
temperature, and have also reconsidered the list of parameters of concern (POCs).
The Division concludes that a permit modification is not required if the condensate effluent is
treated, as is the extracted groundwater, such that all discharges meet existing permit limits and
conditions. Lastly, please note that we have updated your site -vicinity map (see attached).
If you have questions, or if we can further assist you, please contact Joe R. Corporon L.G. at
[[e-mail]] or call his direct line [phone].
-Respectfully,
1�.
Linda Culpepper
Enclosure: Site -Vicinity Map
hc: Central Files
NPDES Program Files
DWR/RRO Supervisor, Danny Smith
ec: ATU, Susan Meadows
OCU, Maureen Kinney
DWR/RRO Supervisor, Danny Smith

T*
�a r
y4t Ikj(�
a'
U
B
tra
1 �
i fro f
1 \
Approximate Property
Boundary
etas
/ ' �
nC 1
rT
!
•
Outfall 001
(Flows north)
!
•
4+
0
NORTH C ROLINA
1YRgLETAI4 COLLEG
al33
M•
Iry
strst"tcrf v P'�tt•
•
IA
.r
.r
•
r3G
r=YitSa
( J
Aar
UT to Beach
Branch
VW
13°
1 0
-<PfG
INC Hwy 301
l 141h
•
t.
_.
Schlage Lock Company LLC
Former Schlage Lock Plant - GW-REM
Receiving Stream: UT of Beach Branch Drainage Basin: Tar -Pamlico
Latitude: 36° 01' 28" N Longitude: 77° 46' 04" W
Sub -Basin: 03-03-02 Permitted Flow: 0.124 MGD
State Grid / USGS Quad: C 27 SE / Drake, NC Stream Class: C-NSW
Facility
Location
not to scale
orth
NPDES Permit NC0079227
Nash Count

Attachment 4 — Short Form C-GW

NPDES PERMIT APPLICATION - SHORT FORM C - GW
For discharges associated with groundwater treatment facilities.
13. Applicant Certification
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.
Russell E. Eiler Director, Global EHS Compliance
Printed name of Person Signing Title
05( 3, izt<1
Signature of A plicant 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
Environmental Management Commission implementing that Article, shall be guilty of a misdemeanor punishable
by a fine not to exceed $25,000, or by imprisonment not to exceed six months, or by both. (18 U.S.C. Section
1001 provides a punishment by a fine of not more than $25,000 or imprisonment not more than 5 years, or both,
for a similar offense.)
Page 3 of 3
C-GW 6117

Attachment 5 — Figures

Legend
Stream
1111 Buildings
Belmont Lake
0
500 1,000
Feet
Mrs....
Discharge Point
Outfall 001
GW Treatment System
Basemap 'lt, :neMap
ti
ERM NC, Inc.
DESIGN: A Freeman
DRAWN. A Freeman
CHKD.: E H011ifleld
DATE. 3/14/2014
SCALE: AS SHOWN
REVISION: 0
FIGURE 2 - SITE LOCATION MAP
WITH NPDES DISCHARGE POINT
NPDES PERMIT NUMBER NC0079227
FORMER SCHLAGE LOCK FACILITY
3551 N. WESLEYAN BOULDVARD
ROCKY MOUNT, NORTH CAROLINA
Moen
Mien
ERM
FILE: T\Sharfile'P nandalGIS FILESIRYMOIMXDIRYMO NPDES Aenal.mxd

Legend
Stream
Buildings
Belmont Lake
110
0
G'c Q
+rn i
500 1,000
Feet III
an=
Former Schlage Facility
•
Discharge Point
Outfall 001
GW Treatment System
Basemap Copynght.©2013 National Geographic Sectary. i-cubed.
A
ERM NC, Inc.
DESIGN: A Freeman
DRAWN: A Freeman
CHKD.: E Hollifield
DATE 3/14/2014
SCALE: AS SHOWN
REVISION 0
FIGURE 1 - SITE LOCATION MAP
WITH NPDES DISCHARGE POINT
NPDES PERMIT NUMBER NC0079227
FORMER SCHLAGE LOCK FACILITY
3551 N. WESLEYAN BOULDVARD
ROCKY MOUNT, NORTH CAROLINA
ERM
FILE. T:1SharfilelAnandaIGIS FILESIRYMOIMXDIANSI A 8-5X11 Portrait.mzd

Attachment 6 —Effluent Analytical Data

aceAna j4icala
"wpacelabs.cem
Pace Analytical Services, LLC
6701 Conference Drive
Raleigh. NC 27607
[phone]
ANALYTICAL RESULTS
Project: NPDES Effluent 02-07-2019
Pace Project No.: 92416854
Sample: NPDES Effluent Lab ID: 92416854001 Collected: 02/07/19 09:59 Received: 02/07/19 10:20 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
Field Data Analytical Method:
Collected By WM 1 02/07/19 09:59
pH 7.61 Std. Units 0.10 1 02/07/19 09:59
Temperature 20.0 deg C 0.50 1 02/07/19 09:59
601/602 Volatiles by SM 6200 Analytical Method: SM 6200B
Benzene ND ug/L 1.0 1 02/19/19 14:25 71-43-2
Bromodichloromethane ND ug/L 1.0 1 02/19/19 14:25 75-27-4
Bromoform ND ug/L 1.0 1 02/19/19 14:25 75-25-2
Bromomethane ND ug/L 5.0 1 02/19/19 14:25 74-83-9
Carbon tetrachloride ND ug/L 1.0 1 02/19/19 14:25 56-23-5
Chlorobenzene ND ug/L 1.0 1 02/19/19 14:25 108-90-7
Chloroethane ND ug/L 1.0 1 02/19/19 14:25 75-00-3
Chloroform ND ug/L 1.0 1 ,/ 02/19/19 14:25 67-66-3
Chloromethane ND ug/L 1.0 1 02/19/19 14:25 74-87-3
Dibromochtoromethane ND ug/L 1.0 1 02/19/19 14:25 124-48-1
1,2-Dibromoethane (EDB) ND ug/L 1.0 1 02/19/19 14:25 106-93-4
1,2-Dichlorobenzene NO ug/L 1.0 1 02/19/19 14:25 95-50-1
1,3-Dichlorobenzene ND ug/L 1.0 1 02/19/19 14:25 541-73-1
1,4-Dlchlorobenzene ND ug/L 1.0 1 02/19/19 14:25 106-46-7
Dichlorodifluoromethane ND ug/L 1.0 1 02/19/19 14:25 75-71-8
1,1-Dlchloroethane ND ug/L 1.0 1 02/19/19 14:25 75-34-3
1,2-Dlchloroethane ND ug/L 1.0 1 02/19/19 14:25 107-06-2
1,1-Dlchloroethene ND ug/L 1.0 1 ✓ 02/19/19 14:25 75-35-4
cis-1,2-Dichloroethene ND ug/L 1.0 1 02/19/19 14:25 156-59-2
trans-1,2-Dichloroethene ND ug/L 1.0 1 02/19/19 14:25 156-60-5
1,2-Dichloropropane ND ug/L 1.0 1 02/19/19 14:25 78-87-5
cls-1,3-Dichloropropene ND ug/L 1.0 1 02/19/19 14:25 10061-01-5
trans-1,3-Dichloropropene ND ug/L 1.0 1 02/19/19 14:25 10061-02-6
Dlisopropyl ether ND ug/L 1.0 1 02/19/19 14:25 108-20-3
Ethylbenzene ND ug/L 1.0 1 02/19/19 14:25 100-41-4
Methylene Chloride ND ug/L 2.0 1 02/19/19 14:25 75-09-2
Methyl-tert-butyl ether ND ug/L 1.0 1 02/19/19 14:25 1634-04-4
Naphthalene ND ug1L 2.0 1 02119/19 14:25 91-20-3
1,1,2,2-Tetrachloroethane ND ug/L 1.0 1 02/19/19 14:25 79-34-5
Tetrachloroethene ND ug/L 1.0 1,-/ 02/19/19 14:25 127-18-4
Toluene ND ug/L 1.0 1,/ 02/19/19 14:25 108-88-3
1,1,1-Trichloroethane ND ug/L 1.0 1 02/19/19 14:25 71-55-6
1,1,2-Trichloroethane ND ug/L 1.0 1 / 02/19/19 14:25 79-00-5
Trichloroethene ND ug/L 1.0 1N/ 02/19/19 14:25 79-01-6
Trichlorofluoromethane ND ug/L 1.0 1 / 02/19/19 14:25 75-69-4
Vinyl chloride ND ug/L 1.0 1 V 02/19/19 14:25 75-01-4
Xylene (Total) ND ug/L 2.0 1 02/19/19 14:25 1330-20-7
m&p-Xylene ND ug/L 2.0 1 02/19/19 14:25 179601-23-1
o-Xylene ND ug/L 1.0 1 02/19/19 14:25 95-47-6
Surrogates
4-Bromofluorobenzene (S) 94 % 70-130 1 02/19/19 14:25 460-00-4
1,2-Dichloroethane-d4 (S) 93 % 70-130 1 02/19/19 14:25 17060-07-0
Date: 02/21/2019 02:07 PM
REPORT OF LABORATORY ANALYSIS
This report shell not be reproduced, except in full,
without the written consent of Pace Analytical Services, LLC.
Page 4 of 14

eaceAnal ical
wwwpacefabs.com
Pace Analytical Services, LLC
8701 Conference Drive
Raleigh, NC 27807
[phone]
ANALYTICAL RESULTS
Project: Sampling 2-5-19
Pace Project No.: 92416502
Sample: NPDES EFFLUENT Lab ID: 92416502001 Collected: 02/05/19 09:19 Received: 02/05/19 11:06 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
25400 Total Suspended Solids Analytical Method: SM 2540D-2011
Total Suspended Solids ND mg/L 5.0 1 02/07/19 15:21
Field Data Analytical Method:
Collected By WM 1 02/05/19 09:19
pH 7.65 Std. Units 0.10 1 02/05/19 09:19
Temperature 16.7 deg C 0.50 1 02/05/19 09:19
HEM, 011 and Grease Analytical Method: EPA 1664B
0il and Grease ND mg/L 4.8 1 02/19/19 06:15
Date: 02/19/2019 03:15 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced. except In full,
without the written consent of Pace Analytical Services, LLC.
Page 4 of 18

aceAnalytical
www.pacelabs.corn
Pace Analytical Services, LLC
8701 Conference Drive
Raleigh, NC 27807
[phone]
ANALYTICAL RESULTS
Project: TSS, Oil and Grease stock
Pace Project No.: 92418286
Sample: NPDES Effluent Lab ID: 92418266001 Collected: 02/19/19 09:22 Received: 02/19/19 11:15 Matrix: Water
Parameters Results Units Report Limit OF Prepared Analyzed CAS No. Qual
2540D Total Suspended Solids Analytical Method: SM 2540D-2011
Total Suspended Solids ND mg/L
HEM, Orland Grease Analytical Method: EPA 1664B
Oil and Grease ND m0/L
Date: 03/01/2019 03:23 PM
2.5 1
4.8 1
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, LLC.
02/20/19 10:47
03/01/19 06:30
Page 4 of 11

Effluent Toxicity Report Form - Chronic Pass/Fall and Acute LC50
Date 19-Feb-19
Facility Schlage Lock WWTP
Laboratory Performing Test:
x L3J1, j�11
Signature of Operator In R • h �-et
Signature of Laboratory Supervisor
MAIL ORIGINAL TO
NPDES# NC0079227 Pipe # 001 County Na8h
North Carolina_Cerlod$phnla Chronic PaealFall Reoroduction Toxlclty Test
CONTROL ORGANISMS
# Young Produced
Adult (L)Iva (D)eed
Effluent %
2 3 4 5
6
7
8
Comments
9
1D
11
Environmental Sciences Branch
Div. of Water Quality
N.C. DENR
1621 Mall Service Center
Raleigh, North Carolina 27699.1621
Chronic Test Results
Calculated t= 1 103
ritical Value= 2.508
12 Reduction= 5.8%
21
L
L
18
L
19
L
17
L
18
L
24
L
20
L
24
L
21
L
22
L
18
L
18
90.0%
TREATMENT 2 ORGANISMS
# Young Produced
Adult (L)Ive (D)ead
pH
Control
Treatment 2
D.O.
Control
Treatment 2
•
9
10
11
12
17
20
15
18
18
17
19
17
19
21
19
26
L
L
L
L
L
L
L
L
L
L
L
L
tat
ea o
7.5 7.9
7.8 8.2
alert end start end
8.2
9.4
8.5
8.8
Mortality Avg. Reprod.
0%
Control
20.0
Control
omplete Title for Either Test
Semple 1 05•Feb-19
0% 18.8
Treatment 2 Treatment 2
Control CV
12.1%
% 3rd Brood
100%
PASS FAIL
X
Teat Stan Date
06-Feb-19
Semple 2 07-Feb-19
Sample Tvoa rauon)
Semple 1
Semple 2
Grab
Comp
Duro on
Hardness (mg/L)
Spec. Cond. (pmhos)
Chlorine (mglL)
Sample Temp. et receipt ('C)
let 2nd
Tox Tox
[Mutton Sample Sample
48.0
183
156
148
<.05
0.2
<.05
0.3
LCSO/Acute Toxicity Test
(Mortality impressed es %, combining replicates)
■ ■ ■ ■ ■ ■ ■ ■ ■ ■
■ ■ ■•■ ■ ■ . ■ ■ ■
LC50 =
96% Confidence Limits
ncantrellon
Mortality
Method of Determination
Moving Average
Spearman Kerber
Probit
Other
111111
Organism Tested Ceriodaphnia dubia
start/end sled/end
i
Control
High Conc.
pH D.O.
DEM Form AT-1
Page 2 of 8

Attachment 7 — Sludge Management Plan

Sludge Management Plan

Schlage Lock Remediation System -Rocky Mount Sludge Management Plan
The former Schlage Lock facility in Rocky Mount, North Carolina utilizes a
ground water remediation system that is designed to remove chlorinated
solvents from ground water. Following is a brief summary of the process,
including sludge generation and management.
Treatment Process Summary
The ground water treatment process involves extracting impacted ground water
from multiple recovery wells, which are located strategically throughout the
facility property. The extracted ground water is piped to the centrally located
remediation system plant, where ground water first enters a settling (separation)
tank where solids, if present, are allowed to settle. Impacted ground water is
then pumped to an equalization tank, and then to an air stripper where volatile
organic compounds are removed from the ground water through vigorous
aeration "stripping". The treatment process is shown on the attached block
diagram.
Treated ground water is then pumped through bag filters for a final polish and
then discharged to the outfall (001) located on the unnamed tributary of Beech
Branch.
Sludge Management
The above process does not generate chemical sludge. The sludge that does form
in the treatment process is primarily silt and clay sediment that are carried from
the recovery wells in the water stream. Sediment is captured in the separation
tank that is primarily used in the treatment process to separate potential
chlorinated free product from the waste stream. Collected solids are drained
with the solvent phase into a product collection drum. Recovered solvent and
sludge is processed by Waste Management as hazardous waste.
Minor additional solids are captured in the bag filters at the end of the treatment
system. This material coats the bag -filters, which are periodically replaced and
disposed. Approximately six bags per month are generated by this process.
These bags have been analyzed for hazardous characteristics and are non
hazardous. The bag filters are air dried and taken by the Site Manager to the
Nash County Sanitary Landfill Convenience Center #7 for disposal as an
industrial waste.
No other sludge is generated at this facility.

MONITORING REPORT(MR) VIOLATIONS for:
Report Date: 03/11/20 Page 1 of 1
Permit: NC0079227 MRs Betweei 3 - 2015 and 3 - 2020
Facility Name: % Param Name%
Major Minor: %
Region: % Violation Category:% Program Category:
County: % Subbasin:% Violation Action:
PERMIT: FACILITY: COUNTY: REGION:
MONITORING VIOLATION
REPORT LOCATION PARAMETER DATE FREQUENCY
UNIT OF
MEASURE
LIMIT
CALCULATED
VALUE Over
VIOLATION TYPE VIOLATION ACTION

Whole Effluent Toxicity Testing and Self Monitoring Summary
= — -
- a - - == — •
S = ! 1 1 L e• 11 L q q 41.
• • _ • • _ • • _ 0 •
1 0 _ 0 0 _ 0 0 _ 0 •
1 0 _ 0 0 _ 0 0 _ 0 •
Former Schlage Comp. GWR NC0079227/001 County: Nash Region: RRO Basin: TAR02 Feb May Aug Nov SOC JOC:
Ceri7dPF Begin: 6/1/2015 Chr Monit: 90% NonComp: Single 7Q10: 0.0 PF: 0.124 IWC: 100.0 Freq: Q
J F M A M J J A S 0 N
2016 Pass Pass - - Pass - - Pass
2017 - Pass - - Pass - - Pass - - Pass
2018 - Pass - - Pass - - Pass - - Pass
2019 - Pass - - Pass - - Pass - - Pass
2020 - Pass - - - - - -
D
— .= — •
! ii 9 il t I. 1. 1 11 q 1 ••
• - • • - • • - • • - •
• - • • - • • - • • - •
• - • • - • • - • • - •
• - • • • • • • • • • •
—
4 !
•
•
•
•
- — -
-- —•
•
• - • • • • - • •
• • • - • • •
• - - • - • • - • •
• • • • • • • • • •
—— - - —•
! ! S q el L e• i L i! q
• • _ • •
Legend: P= Fathead minnow (Pimphales promelas), H=No Flow (facility is active), s = Split test between Certified Labs
Page 45 of 120

ROY COOPER
C „vrrncr.
MICHAEL 5. REGAN
:tre: ary
LINDA CULPEPPER
Direrxr
Mr. Russell Eiler
SchIage Lock Company, LLC
11819 N Pennsylvania Street
Carmel, IN 46032
Subject:
Mr. Eiler:
r.ORTH CAROLIN
Environreentu! Quality
December 91I1, 2019
Compliance Evaluation Inspection
NPDES Wastewater Discharge
Permit No. NC0079227
Schlage Nash Remediation
Nash County
On December 9th, 2019, Josh Brigham of the Raleigh Regional Office (RRO) conducted a site visit at the
subject facility. Present during the inspection was Mr. William Minchew, the Operator in Responsible
Charge, whose help and guidance was greatly appreciated. Findings during the inspection were as
follows:
1. At the time of the inspection, the NPDES permit was issued effective June 151, 2015, and expired
on October 3I'`, 2019. The Division received Schlage Lock Company's permit renewal
application on June 7111, 2019, and is in the process of renewing the permit. Please note that Part
II, Section B. 10 of the subject permit requires the permittee to request permit renewal at least
180 days prior to expiration in order to maintain authorization to discharge after the expiration
date (May 4t°, 2019).
The facility is authorized to operate and discharge wastewater from a facility which discharges to
receiving waters designated as an unnamed tributary to Beech Branch classified as Class B,
Nutrient Sensitive Waters in the Tar -Pamlico River Basin.
3. The facility consists of the following units: collection wells, product separator, equalization tank
with transfer pump, air stripper and blower, discharge tank with effluent pump, bag filters, and
effluent flow meter with totalizer. Outfall 001 was observed and was free of solids and foam.
4. A review of laboratory results indicates that a!I parameters are being monitored and analyzed
according to the permit.
5. The only field parameter collected at the site is pH and the meter is calibrated prior to collection
by Mr. Minchew. Other sample analysis is performed by Pace Labs.
6. The treatment system was discharging effluent at the time of the inspection.
N a+1fl t..tr I ii ht p a to r Ili of For, .: it r: 1 'II QLZ r!iry f )iaisi.tn .tf %V tc•r ktrsnuttes
R.t' 111 lit rfl11•1 U•I • i s(1(1 {i: • I' Dr ;-4. R +I •;r:fi.:r'c•rtl, C.trt,l:n•t !ii,f}ry
u1,1 irll ,1 1(1r1

If you have questions concerning this report please contact Josh Brigham at 919-791-4251 or e-mail at
joshua.brighamig ncdenr.gov.
Sincerely,
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office, Division of Water Resources, NCDEQ
Attachments: EPA Water Compliance Inspection Report
cc: RRO DWR File Copy
Laserfiche
William Minchew via e-mail at WNlinchew a Geosvntec.com
71P;i

EPA
United Stales Environmental Protection Agency
Washington. D.0 20450
Water Compliance Inspection Report
Section A: National Data System Coding (i.e., PCS)
Form Approved.
OMB No 2040-0':57
Approval expires 8-31-98
Transaction Code NPDES yr/mo/day Inspecti-- Type Inspector Fat Type
1 lid 2 u 3 I NC0079227 111 12 I 19/12/09 117 18I I 19 1 c I 2011
21I I11 I I I I I I II I I I I I I I I I I I I I I I I I I I I I I III i I I 1 1 r6
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 OA Reserved
67 I 1 70 f , 71 LI 72 1 ., 1 731 1 J 74 71 11 I I I 1 180
Section B Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW also include
POTW name and NPDES permit Number)
Nash remediation site
3551 N Weslyan Blvd
Rocky Mount NC 27804
Name(s) of Onsite Representative(s)1Tides(s)1Phone and Fax Number(s)
lid
William Atlas Minchew/ORC/252-212-5996/
Entry Time/Date
09 45AM 19/12/09
Permit Effective Date
15:06.01
Name, Address of Responsible Official/Title/Phone and Fax Number
Russell E Eiler.11819 N Pennsylvania 51 Carmel IN 46032/Global EFTS
C o m pl is nce/317-810-38741
Contacted
No
Exit TimelDate
11 15AM 1912/09
ether Facility Data
Section C Areas Evaluated During Inspection (Check only those areas evaluated)
Ill Permit Flow Measurement • Operations & Maintenance Records/Reports
Self -Monitoring Program I. Facility Site Review El Effluent/Receiving Waters Laboratory
Other
Permit Exp.raton Date
19:10.31
Section D Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s)
Age y/Office:Phone and Fax Numbers Date
Joshua 5 Brigham D WRrpRO W0/919-791-4200/
Signature of Mana went 0 A Reviewer Agency/Office/Phone and Fax Numbers
EPA Form 3560-3 (Rev 9-94) Previous ed bons a•e obsc:etc
Datete
/�'//a/ /?
Page# 1

NPOES
31 NC0079227 111 121
pima/day
19/12/09
117
lnspecton Type
18 IL, ,.1
(Cont )
1
Section D Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
1. The current permit was issued and became effective June 1st, 2015. The permit expired on
October 31 st, 2019. A new permit was submitted on June 6th, 2019. It is recommended that in the
future you submit six months in advance.
2. The facility is authorized to operate and discharge water from a facility which discharges to
receiving waters designated as an unnamed tributary to Beech Branch classified as Class B, Nutrient
Sensitive Waters in the Tar -Pamlico River Basin.
3. The facility consists of the following units: collection wells, product separator, equalization tank with
transfer pump, air stripper and blower, discharge tank with effluent pump, bag filters and effluent flow
meter with totalizer. Outfall 001 was observed and was free of solids and foam.
4. A review of laboratory results indicates that all parameters are being monitored and analyzed
according to the permit.
5. The only field parameter collected at the site is pH and the meter is calibrated prior to collection by
Mr. Minchew. Other sample analysis is performed by Pace Labs.
6. The treatment system was discharging effluent at the time of the inspection.
Page' 2

Permit: NC0079227 Owner Facility: Nash remediation site
Inspection Date: 12/0912019
Inspection Type: Compliance Evaluation
Permit
(If the present permit expires in 6 months or less}. Has the permittee submitted a new
application?
Is the facility as described n the permit?
# Are there any special condlticns for the permit/
Is access to the plant site restricted to the general public?
Is the inspector granted access to all areas for :nspection?
Comment: Permit expired October 31 st, 2019. New submitted June 7th, 2019.
Flow Measurement - Effluent
# Is flow meter used for reporting?
Is flow meter calibrated annually?
Is the flow meter operational?
{If units are separated) Does the chart recorder match the flow meter?
Comment. Row meter calibrated or replaced and calibrated at the factory annually.
Yes No NA NE
• ❑ ❑ ❑
1 ❑ ❑ ❑
▪ ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Yes No NA NE
•❑ ❑ ❑
• ❑ ❑ ❑
11000
❑ ❑ ■ ❑
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? E ❑ ❑ ❑
Does the facility analyze process control parameters, for ex MLSS, MCRT, Settleable 1110 ❑ ❑
Solids. pH, DO, Sludge Judge and other that are appl.cable?
Comment:
Equalization Basins
Is the basin aerated?
Is the basin free of bypass lines or structures to the natural envircnmer.t
Is the basin free of excessive grease?
Are all pumps present?
Are all pumps operable?
Are float controls operable?
Are audible and visual alarms operable?
# Is bas:n sizevolume adequate?
Comment:
,Effluent Pipe
Is right of way to the outfall prcperly maintained?
Yes No NA NE
• ❑• ❑
❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Yes No NA NE
▪ ❑ ❑ ❑
Page# :s

Permit: NC0079227 Owner -Facility: Nash remediation site
Inspection Date: 12/09/2019 Inspection Type: Compl ante Evaluation
Effluent Pipe
Are the receiving water free of foam other than trace amounts and other debrs?
If effluent (diffuser pipes are required) are they operating properly?
Comment:
Laboratory,
Are field parameters performed by certified personnel or laboratory,
Are all other parameters(excluding field parameters:, performed by a certified lab?
# Is the facility using a contract lab?
# Is proper temperature set for sample storage (k-pt at less thaor equal to 6 0 degrees
Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+.'- 0 2 degrees?
incubator (BOD) set to 20.0 degrees Celsius +.-1 0 degrees?
Comment: Lab picks up samples and stores at appropriate temperature.
Record Keeping
Are records kept and maintained as required by the permit?
Is all required information readily available, complete and current?
Are all records maintained for 3 years (lab. reg. required 5 years)?
Are analytical results consistent with data reported on DMRs?
Is the chain -of -custody complete?
Dates. times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
Has the facility submitted its annual compliance report to users and DWQ?
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator
on each shift?
Is the ORC visitation log available and current?
Is the ORC certified at grade equal to or higher than the facility classification?
Is the backup operator certified at one grade less or greater than the facility classification?
Is a copy of the current NPDES permit available on site?
Yes No NA NE
■ ❑ ❑ ❑
❑ ❑ • ❑
Yes No NA NE
• ❑ ❑ ❑
▪ ❑ ❑ ❑
• ❑ ❑ ❑
▪ ❑ ❑ ❑
❑ ❑ 0 ❑
❑ ❑ 11 ❑
Yes No NA NE
▪ ❑ ❑ ❑
• ❑ ❑ ❑
11000
• ❑ ❑ ❑
• ❑ ❑ ❑
•
•
•
11
•
• ❑ ❑ ❑
❑ ❑ •❑
00110
• ❑ ❑ ❑
▪ ❑ ❑ ❑
▪ ❑ ❑ ❑
• ❑ ❑ ❑
Page# 4

Permit: NC0079227
Owner • Facility' Nash remediation site
Inspection Date: 12/09/2019 Inspection Type. 'cmpl ance Evaluation
Record Keening Yes No NA NE
Facility has copy of previous year's Annual Report on file for review?
Comment: Corporate (Geosvntec) produces annual report. but this is not kept on site.
Other
Comment:
Yes No NA NE

2016 Generic RPA (non -hardness dependent) - 95% Probability/95% Confidence
MAXIMUM DATA POINTS = 58
REQUIRED DATA ENTRY
Table 1. Project Information
Facility Name
WWTP/WTP Class
NPDES Permit
Outfall
Flow, Qw (MGD)
Receiving Stream
Stream Class
7Q10s (cfs)
7Q1Ow (cfs)
30Q2 (cfs)
QA (cfs)
1Q10s (cfs)
Data Source(s)
❑ CHECK TO APPLY MODEL
❑ CHECK IF HQW OR ORW
Former Schlage Lock Facility
PC-1
NC0079227
001
0.12400
UT to Beech Branch
C; NSW
0.00
0.00
0.00
0.00
0.00
DMR data Nov2015-Apr2020
Follow directions for data entry. In some cases a
comment menu list the available choices or a
dropdown menu will provide a list you may select
from. Error message occur if data entry does not
meet input criteria.
Table 2. Parameters of Concern
Par01
Par02
Par03
Par04
Par05
Par06
Par07
Par08
Par09
Par10
4 Par11
Par12
Par13
Par14
Par15
Par16
Par17
Par18
Par19
Par20
Par21
Par22
Name
Type Chronic Modifier Acute
PQL Units
Chloroform
C
2000
HH
fag/L
Toluene
NC
11
FW
fag/L
1,1-dichloroethylene
NC
200000
HH
fag/L
Tetrachloroethene
C
3.3
HH
fag/L
Trichloroethene
C
30
HH
fag/L
Vinyl Chloride
C
2.4
HH
fag/L
NC0079227 RPA, input
6/24/2020

REASONABLE POTENTIAL ANALYSIS
Chloroform
Date Data
11/5/2015 < 1
2/4/2016 < 1
5/5/2016 < 1
8/4/2016 < 1
11/3/2016 < 1
2/9/2017 < 1
5/4/2017 < 1
8/3/2017 < 1
11/9/2017 < 1
2/8/2018 < 1
5/3/2018 < 1
8/9/2018 < 1
11/8/2018 < 1
2/7/2019 < 1
5/9/2019 < 5
8/8/2019 < 5
11/7/2019 < 1
2/4/2020 < 1
BDL=1/2DL Results
0.5 Std Dev.
0.5 Mean
0.5 C.V.
0.5 n
0.5
0.5 Mult Factor = 1.6100
0.5 Max. Value 2.5 pg/L
0.5 Max. Pred Cw 0 DETECTS pg/L
0.5
0.5
0.5
0.5
0.5
0.5
2.5
2.5
0.5
0.5
Use "PASTE SPECIAL.
Values" then "COPY"
. Maximum data
points = 58
0.6468
0.7222
0.8955
18
2
Toluene
Date Data
11/5/2015 < 1
2/4/2016 < 1
5/5/2016 < 1
8/4/2016 < 1
11/3/2016 < 1
2/9/2017 < 1
5/4/2017 4.8
8/3/2017 < 1
11/9/2017 < 1
2/8/2018 < 1
5/3/2018 < 1
8/9/2018 < 1
11/8/2018 < 1
2/7/2019 < 1
5/9/2019 < 1
8/8/2019 < 1
11/7/2019 < 1
2/4/2020 < 1
Use "PASTE SPECIAL.
Values" then "COPY"
. Maximum data
points = 58
BDL=1/2DL Results
0.5 Std Dev. 1.0135
0.5 Mean 0.7389
0.5 C.V. 1.3717
0.5 n 18
0.5
0.5 Mult Factor = 1.9000
4.8 Max. Value 4.8 pg/L
0.5 Max. Pred Cw 9.1 pg/L
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
_2
NC0079227 RPA, data
6/24/2020

REASONABLE POTENTIAL ANALYSIS
1,1-dich to roethylen e
Date Data BDL=1/2DL Results
1 11/5/2015 < 1 0.5 Std Dev.
2 2/4/2016 < 1 0.5 Mean
3 5/5/2016 < 1 0.5 C.V.
4 8/4/2016 < 1 0.5 n
5 11/3/2016 < 1 0.5
6 2/9/2017 < 1 0.5 Mult Factor = 1.0000
7 5/4/2017 < 1 0.5 Max. Value 0.5 pg/L
8 8/3/2017 < 1 0.5 Max. Pred Cw 0 DETECTS pg/L
9 11/9/2017 < 1 0.5
10 2/8/2018 < 1 0.5
11 5/3/2018 < 1 0.5
12 8/9/2018 < 1 0.5
13 11/8/2018 < 1 0.5
14 2/7/2019 < 1 0.5
15 5/9/2019 < 1 0.5
16 8/8/2019 < 1 0.5
17 11/7/2019 < 1 0.5
18 2/4/2020 < 1 0.5
Use "PASTE SPECIAL.
Values' then "COPY"
. Maximum data
points = 58
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
0.0000
0.5000
0.0000
18
5
Tetrachloroethene
Date Data BDL=1/2DL Results
1 11/5/2015 < 1 0.5 Std Dev.
2 2/4/2016 < 1 0.5 Mean
3 5/5/2016 < 1 0.5 C.V.
4 8/4/2016 < 1 0.5 n
5 11/3/2016 < 1 0.5
6 2/9/2017 < 1 0.5 Mult Factor = 1.0000
7 5/4/2017 < 1 0.5 Max. Value 0.5 pg/L
8 8/3/2017 < 1 0.5 Max. Pred Cw 0 DETECTS pg/L
9 11/9/2017 < 1 0.5
10 2/8/2018 < 1 0.5
11 5/3/2018 < 1 0.5
12 8/9/2018 < 1 0.5
13 11/8/2018 < 1 0.5
14 2/7/2019 < 1 0.5
15 5/9/2019 < 1 0.5
16 8/8/2019 < 1 0.5
17 11/7/2019 < 1 0.5
18 2/4/2020 < 1 0.5
Use "PASTE SPECIAL.
Values" then "COPY"
. Maximum data
points = 58
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
0.0000
0.5000
0.0000
18
-3-
NC0079227 RPA, data
6/24/2020

REASONABLE POTENTIAL ANALYSIS
Trichloroethene
Date Data
11/5/2015 < 1
2/4/2016 < 1
5/5/2016 < 1
8/4/2016 < 1
11/3/2016 < 1
2/9/2017 < 1
5/4/2017 < 1
8/3/2017 < 1
11/9/2017 < 1
2/8/2018 < 1
5/3/2018 < 1
8/9/2018 < 1
11/8/2018 < 1
2/7/2019 < 1
5/9/2019 < 1
8/8/2019 < 1
11/7/2019 < 1
2/4/2020 < 1
BDL=1/2DL Results
0.5 Std Dev.
0.5 Mean
0.5 C.V.
0.5 n
0.5
0.5 Mult Factor = 1.0000
0.5 Max. Value 0.5 pg/L
0.5 Max. Pred Cw 0 DETECTS pg/L
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
Use "PASTE SPECIAL.
Values" then "COPY"
. Maximum data
points = 58
0.0000
0.5000
0.0000
18
7
Vinyl Chloride
Date Data
11/5/2015 < 1
2/4/2016 < 1
5/5/2016 < 1
8/4/2016 < 1
11/3/2016 < 1
2/9/2017 < 1
5/4/2017 < 1
8/3/2017 < 1
11/9/2017 < 1
2/8/2018 < 1
5/3/2018 < 1
8/9/2018 < 1
11/8/2018 < 1
2/7/2019 < 1
5/9/2019 < 1
8/8/2019 < 1
11/7/2019 < 1
2/4/2020 < 1
BDL=1/2DL Results
0.5 Std Dev.
0.5 Mean
0.5 C.V.
0.5 n
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
Use "PASTE SPECIAL.
Values" then "COPY"
. Maximum data
points = 58
0.0000
0.5000
0.0000
18
Mult Factor = 1.0000
Max. Value 0.5 pg/L
Max. Pred Cw 0 DETECTS pg/L
-4-
NC0079227 RPA, data
6/24/2020

Former Schlage Lock Facility REASONABLE POTENTIAL ANALYSIS
NC0079227
Qw (MGD) = 0.12400
1Q10S (cfs) = 0.00
7Q1OS (cfs) = 0.00
7Q10W (cfs) = 0.00
30Q2 (cfs) = 0.00
Avg. Stream Flow, QA (cfs) = 0.00
Receiving Stream: UT to Beech Branch
2016 Generic RPA (non -hardness dependent) - 95% Probability/95% Confidence
MAXIMUM DATA POINTS = 58
WWTP/WTP Class: PC-1
IWC @ 1Q10S = 100.00%
IWC @ 7Q1OS = 100.00%
IWC @ 7Q1 OW = 100.00%
IWC @ 30Q2 = 100.00%
IWC @ QA = 100.00%
Stream Class: C; NSW
Outfall 001
Qw = 0.124 MGD
PARAMETER
TYPE
(i)
STANDARDS & CRITERIA (2)
PQL
UNITS
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
NC WQS / Applied `/z FAV /
Chronic Standard Acute
n # Det. Max Pred Cw Allowable Cw
Chloroform
C
2000 HH
µg/L
18 0
NO DETECTS
Acute: NO WQS
Chronic: 2,000.00
Max MDL = 5
No detects
Toluene
NC
11 FW
µg/L
18 1
9.1
Acute: NO WQS
Chronic: 11.00
No value > Allowable Cw
_
No RP, Predicted Max >_ 50 % of Allowable Cw
apply Quarterly Monitoring
1,1-dichloroethylene
NC
200000 HH
µg/L
18 0
NO DETECTS
Acute: NO WQS
Chronic: 200,000.00
Max MDL = 1
No detects
Tetrachloroethene
C
3.3 HH
µg/L
18 0
NO DETECTS
Acute: NO WQS
Chronic: 3.30
Max MDL = 1
No detects
Trichloroethene
C
30 HH
µg/L
18 0
NO DETECTS
Acute: NO WQS
Chronic: 30.00
Max MDL = 1
No detects
Vinyl Chloride
C
2.4 HH
µg/L
18 0
NO DETECTS
Acute: NO WQS
Chronic: 2.40
Max MDL = 1
No detects
Page 5 of 5
NC0079227 RPA, rpa
6/24/2020

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Rocky Mount Telegram
July 10, 2020
Government Publications - Miscellaneous
Public Notice
North Carolina Environmental
Management Conunission/NPDES Unit
1617 Mail Service Center
Raleigh: NC 27699-1617
Notice of Intent to Issue a NPDES Wastewater Permit N0079227 Nash Remediation Site
The North Carolina Environmental Management Commission proposes to issue a NPDES
wastewater discharge permit to the person(s) listed below. Written comments regarding the
proposed permit will be accepted until 30 days after the publish date of this notice. The Director
of the NC Division of Water Resources (DWR) may hold a public hearing should there be a
significant degree of public interest. Please mail comments andfor information requests to DWR
at the above address. Interested persons may visit the DWR at 512 N. Salisbury Street, Raleigh,
NC to review information on file. Additional information on NPDES permits and this notice may be
found on our website: http:/.'deq.nc.goviabout{divisions.'water-resources"water-resources-
permits(wastewater-branch/npdes-wastewater.'public-notices,or by calling [phone].
Schlage Lock Company LL _ Nash County, applied to renew NPDES permit IN 0079227] for its
ground water remediation system discharging treated wastewater to an unnamed tributary to
Beech Branch, Tar Pamlico River Basin.
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RE: Drafting Initiated for NC0079227 Schlage Lock Company LLC - Former
Schlage Lock Plant (GW-REM)
Brigham, Joshua S <[e-mail]>
Wed 6/24/2020 7:30 AM
To: Denard, Derek <[e-mail]>
Cc: Vinson, Scott <[e-mail]>
Hello Derek,
Thank you for contacting me. Currently nothing comes to mind. They were running a tight ship when I
was over there for my inspection last year.
Thanks,
Joshua S. Brigham -Environmental Specialist
NCDEQ-Division of Water Resources
Raleigh Regional Office
Office: 919-791-4251
❑® cid:[e-mail]
CO2CC0
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
may be disclosed to third parties.
From: Denard, Derek
Sent: Tuesday, June 23, 2020 3:46 PM
To: Brigham, Joshua S <[e-mail]>
Cc: Vinson, Scott <[e-mail]>
Subject: Drafting Initiated for NC0079227 Schlage Lock Company LLC - Former Schlage Lock Plant (GW-
REM)
Josh,
I have started on the renewal for NC0079227 Schlage Lock Company LLC - Former Schlage
Lock Plant (GW-REM). I will have a draft ready soon. Let me know if you have any information
that comes to mind for the renewal.
Thanks,
Derek Denard
Environmental Specialist
N.C. Division of Water Resources

N.C. Department of Environmental Quality
919 707 3618 office
919 707 9000 main DWR
[e-mail]
1617 Mail Service Center
Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

RE: Peer Review NC0079227 Schlage Lock Co
Phillips, Emily <[e-mail]>
Thu 6/25/2020 10:58 AM
To: Denard, Derek <[e-mail]>
Looks good
From: Denard, Derek <[e-mail]>
Sent: Wednesday, June 24, 2020 12:25 PM
To: Phillips, Emily <[e-mail]>
Subject: Peer Review NC0079227 Schlage Lock Co
Emily,
Got another peer review for you to look at. Please update Access for the public notice state. Eveything is
in the folder "peer review".
E4 Peer Review
Thanks!!
Derek Denard
Environmental Specialist
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919 707 3618 office
919 707 9000 main DWR
[e-mail]
1617 Mail Service Center
Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

[External] RE: Request for Approval of Electronic Transmittals for the Renewal of NPDES
Permit NC0079227 - Schlage Lock Company LLC - Former Schlage Lock Plant (GW-REM)
Eller, Russ <[e-mail]>
D/30/2020 9:30 AM
To: Denard, Derek <[e-mail]>
Cc: [e-mail] <[e-mail]>; 'Amber, Wayne ([e-mail])'
<[e-mail]>
LtoUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment
[e-mail]
Mr. Denard:
I approve of the transmittal of documents through e-mail that are related to Schlage Lock Company.
Russ
Russell E. Eller, CEF,RIWP-M,CHMM
Director, Global EHS Compliance
ANALYTICAL, CONTEXT, INDIVIDUALIZATION, RESTORATIVE, HARMONY
"Objective, data -driven observer and fixer"
Allegion plc
c/o Schlage Lock Company LLC
11819 N. Pennsylvania Street
Carmel, Indiana 46032 USA
Office +1.317.810.3874
NOTE NEW CELL PHONE NUMBER
Cell +1.317.414.4070
Fax [phone]
Email: Russ.Eiler©Allegion.com
allegion.com
Join Microsoft Teams Meeting [teams.microsoft.com]
+1.317.749.0991 United States, Indianapolis (Toll)
Conference ID: 270808#
Local numbers [dialin.teamS.miCrOSOft.COm] I Learn more about Teams [go.microsoft.com]
• •
4
ALLE I N
COSA ■ interflex • LCN • =■ VON DUPRIN
From: Denard, Derek <[e-mail]>
Sent: Monday, June 29, 2020 5:00 PM
To: Eiler, Russ <[e-mail]>

Cc: [e-mail]
Subject: Request for Approval of Electronic Transmittals for the Renewal of NPDES Permit NC0079227 - Schlage
Lock Company LLC - Former Schlage Lock Plant (GW-REM)
EXTERNAL MESSAGE: use caution with replies, links, and attachments.
Mr. Eller,
Drafting has been initiated for the renewal of NPDES Permit NC0079227. A draft will be submitted for
your review and to public notice within the next couple of weeks.
In order to provide more convenience, control, and security to our permittees and assist them in
processing their transactions, the Division of Water Resources is currently transitioning towards
electronic correspondence. This will hopefully provide more efficient service to our permittees
and other partners and will allow us to more effectively process and track documents. We are
writing to ask you for your approval of the transmittal of documents related to your permitting
and related activities with the Division in an electronic format. Documents will be emailed to the
appropriate contact person(s) in your organization in a PDF format.
Please respond to me through email with verification that transmittal of your documents in an
electronic manner is acceptable to you. If you have any questions, please feel free to contact
me.
Sincerely
Derek Denard
Environmental Specialist
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919 707 3618 office
919 707 9000 main DWR
[e-mail]
1617 Mail Service Center
Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

[External] Re: Draft NPDES Permit NC0079227 - Former Schlage Lock Plant (GW-REM)
Grade I Physical Chemical WPCS
Eiler, Russ <[e-mail]>
7/6/2020 4:47 PM
To: Denard, Derek <[e-mail]>; [e-mail] <[e-mail]>
Cc: Brigham, Joshua S <[e-mail]>; Vinson, Scott <[e-mail]>; Kinney, Maureen
<[e-mail]>; Headrick, Hannah <[e-mail]>; Moore, Cindy
<[e-mail]>; Wayne Amber <[e-mail]>
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment
to [e-mail]
Dear Mr. Denard:
I am confirming receipt of a copy of the document that I am able to open and view, and I have saved a copy for my
records. We will complete a thorough internal review and submit any comments, if any, within the 30-day period.
Russ
Russell E. Eiler, CEF,RIWP-M,CHMM
Director, Global EHS Compliance
ANALYTICAL, CONTEXT, INDIVIDUALIZATION, RESTORATIVE, HARMONY
"Objective, data -driven observer and fixer"
Allegion plc
c/o Schlage Lock Company LLC
11819 N. Pennsylvania Street
Carmel, Indiana 46032 USA
Office +1.317.810.3874
Cell +1.317.414.4070
Fax [phone]
Email: Russ.Eiler©Allegion.com
allegion.com
• •
ALLEGION
c1SA • 43, interftex ■ LCN ■ a= ■ VON DUPRIN
From: "Denard, Derek" <[e-mail]>
Date: Monday, July 6, 2020 at 4:11 PM
To: "Russell E. Eiler CHMM" <[e-mail]>, William Minchew
<[e-mail]>

Cc: "Brigham, Joshua S" <[e-mail]>, "Vinson, Scott"
<[e-mail]>, "Kinney, Maureen" <[e-mail]>, "Headrick,
Hannah" <[e-mail]>, "Moore, Cindy" <[e-mail]>
Subject: Draft NPDES Permit NC0079227 - Former Schlage Lock Plant (GW-REM) - Grade I
Physical Chemical WPCS
EXTERNAL MESSAGE: use caution with replies, links, and attachments.
Dear Mr. Eiler,
Please find the attached Draft NPDES Permit NC0079227 for the Former Schlage Lock Plant (GW-
REM).
Please respond to this email confirming that you received the attached document(s),
were able to open and view the document(s) and have saved/printed a copy for your
records.
Sincerely,
Derek Denard
Environmental Specialist
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919 707 3618 office
919 707 9000 main DWR
[e-mail]
1617 Mail Service Center
Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

Re: [External] RE: Draft NPDES Permit NC0079227 - Former Schlage Lock Plant
(GW-REM) - Grade I Physical Chemical WPCS
Denard, Derek <[e-mail]>
Thu 7/16/2020 3:37 PM
To: Eller, Russ <[e-mail]>
Thanks!
Derek Denard
Environmental Specialist
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919 707 3618 office
919 707 9000 main DWR
[e-mail]
1617 Mail Service Center
Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Eiler, Russ <[e-mail]>
Sent: Thursday, July 16, 2020 9:03 AM
To: Denard, Derek <[e-mail]>
Cc: Brigham, Joshua S <[e-mail]>; Vinson, Scott <[e-mail]>;
'Amber, Wayne ([e-mail])' <[e-mail]>;
[e-mail] <[e-mail]>
Subject: RE: [External] RE: Draft NPDES Permit NC0079227 - Former Schlage Lock Plant (GW-REM) -
Grade I Physical Chemical WPCS
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to [e-mail]
Derek:

Thank you for your prompt reply. As I now understand it, our onsite technician is a certified contract
lab operator and is capable of taking field pH measurements. However, we currently do not have the
equipment to complete the onsite temperature measurements.
In any event, I appreciate your willingness to add the footnote indicating that the temperature
monitoring only applies when thermal groundwater treatment is in use. Your assumption is correct
that this is likely to never occur again.
Per your request, I have attached a complete PDF version of Form C -GW from the May 31, 2019
submission for your records.
Thank you again for your assistance with our renewal.
Russ
Russell E. Eiler, CEF,RIWP-M,CHMM
Director, Global EHS Compliance
ANALYTICAL, CONTEXT, INDIVIDUALIZATION, RESTORATIVE, HARMONY
"Objective, data -driven observer and fixer"
Allegion plc
c/o Schlage Lock Company LLC
11819 N. Pennsylvania Street
Carmel, Indiana 46032 USA
Office +1.317.810.3874
NOTE NEW CELL PHONE NUMBER
Cell +1.317.414.4070
Fax [phone]
Email: [e-mail]
allegion.com
❑® ALLERGBV
0
From: Denard, Derek <[e-mail]>
Sent: Wednesday, July 15, 2020 3:41 PM
To: Eiler, Russ <[e-mail]>
Cc: Brigham, Joshua S <[e-mail]>; Vinson, Scott <[e-mail]>;
'Amber, Wayne ([e-mail])' <[e-mail]>;
[e-mail]
Subject: Re: [External] RE: Draft NPDES Permit NC0079227 - Former Schlage Lock Plant (GW-REM) -
Grade I Physical Chemical WPCS
EXTERNAL MESSAGE: use caution with replies, links, and attachments.

Russ,
It was not clear to me how the narrative standard was being met for temperature. See 15A
NCAC 02B .0208 (b), .0211 (14). I added temperature monitoring to establish a database
because it is a simple field parameter (temperate, pH & DO) that is often taken with grab
samples. This permit requires pH. So they are taking pH as lab parameter instead of a field
parameter? I understand that they don't have training to take field parameters. Contract labs
should be certified to take field parameters.
I overlooked the fact that the thermal groundwater treatment ended in 2019.
I believe we can settle this by adding a footnote that indicates temperature monitoring only
applies when thermal groundwater treatment is in use. I am assuming that this may never
occur again.
By the way, I was looking for pages 1 and 2 for Form C -GW. I only have the signature page 3. I
don't have a hard copy on hand. I'm thinking it was missed when it was scanned into
Laserfiche. Could you please send me the pages for Form C-GW? Here is a link to what I have:
https://edocs.deq.nc.gov/WaterResources/DocView.aspx?
id=915731&dbid=0&repo=WaterResources
Thanks,
Derek Denard
Environmental Specialist
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919 707 3618 office
919 707 9000 main DWR
[e-mail]
1617 Mail Service Center
Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Eller, Russ <[e-mail]>
Sent: Tuesday, July 14, 2020 5:26 PM
To: Denard, Derek <[e-mail]>

Cc: Brigham, Joshua S <[e-mail]>; Vinson, Scott <[e-mail]>;
Kinney, Maureen <[e-mail]>; Headrick, Hannah <[e-mail]>;
Moore, Cindy <[e-mail]>; 'Amber, Wayne ([e-mail])'
<[e-mail]>; [e-mail] <[e-mail]>
Subject: [External] RE: Draft NPDES Permit NC0079227 - Former Schlage Lock Plant (GW-REM) - Grade
I Physical Chemical WPCS
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to [e-mail]
Mr. Denard:
I would ask that you please consider removing the temperature monitoring requirement from Schlage
Lock Company's NPDES permit renewal. I attach for your review an e-mail containing a letter dated
June 13, 2018 from NCDEQ's Division of Water Resources indicating that, even during Schlage's
thermal groundwater treatment event that began in 2018 and ended in mid-2019, temperature
monitoring was determined to be unnecessary. Schlage currently does not have the equipment in-
house to complete the monitoring nor the personnel trained to do so. Schlage has completed the
thermal remediation project at the site with great success and the groundwater pump and treat
system, which is the premise for the NPDES permit and the only source of discharge water, is currently
in standby mode and we expect to have no flow from the facility in the foreseeable future.
If you would prefer these questions/comments to be formalized and mailed to your office, I would be
happy to do so.
Thank you in advance for your consideration. If you have any questions, please feel free to contact me
directly.
Best regards.
Russ
Russell E. Eller, CEF,RIWP-M,CHMM
Director, Global EHS Compliance
ANALYTICAL, CONTEXT, INDIVIDUALIZATION, RESTORATIVE, HARMONY
"Objective, data -driven observer and fixer"
Allegion plc
c/o Schlage Lock Company LLC
11819 N. Pennsylvania Street
Carmel, Indiana 46032 USA
Office +1.317.810.3874
NOTE NEW CELL PHONE NUMBER
Cell +1.317.414.4070
Fax [phone]
Email: [e-mail]
allegion.com

0 ALLERGBV
0
From: Denard, Derek <[e-mail]>
Sent: Monday, July 6, 2020 4:11 PM
To: Eiler, Russ <[e-mail]>; [e-mail]
Cc: Brigham, Joshua S <[e-mail]>; Vinson, Scott <[e-mail]>;
Kinney, Maureen <[e-mail]>; Headrick, Hannah <[e-mail]>;
Moore, Cindy <[e-mail]>
Subject: Draft NPDES Permit NC0079227 - Former Schlage Lock Plant (GW-REM) - Grade I Physical
Chemical WPCS
EXTERNAL MESSAGE: use caution with replies, links, and attachments.
Dear Mr. Eller,
Please find the attached Draft NPDES Permit NC0079227 for the Former Schlage Lock Plant
(GW-REM).
Please respond to this email confirming that you received the attached document(s),
were able to open and view the document(s) and have saved/printed a copy for your
records.
Sincerely,
Derek Denard
Environmental Specialist
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919 707 3618 office
919 707 9000 main DWR
de rek.denard [e-mail]
1617 Mail Service Center
Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

1/30/2021 Mail - Denard, Derek - Outlook
RE: Draft NPDES Permit NC0079227 - Former Schlage Lock Plant (GW-REM) - Grade I
Physical Chemical WPCS
Headrick, Hannah <[e-mail]>
Wed 7/8/2020 5:17 PM
To: Denard, Derek <[e-mail]>
1 attachments (22 KB)
Comments on Draft NPDES Permit NC0079227.docx;
Derek —
Just a few simple comments from ATB.
Hannah
Hannah Headrick
Environmental Biologist
Division of Water Resources
Department of Environmental Quality
Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has
adjusted operations to protect the health and safety of the staff and public. Many employees are working
remotely or are on staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting
public access to appointments only. Please check with the appropriate staff before visiting our offices, as we may
be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the
public during this challenging time.
Email AT Forms to Hannah at: [e-mail]
Please note new number - 919 743 8439
[e-mail]
Mailing: 1621 Mail Services Center, Raleigh, NC 27699-1621
Physical: 4401 Reedy Creek Road, Raleigh, NC 27607
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Denard, Derek
Sent: Monday, July 06, 2020 4:11 PM
To: [e-mail]; [e-mail]
Cc: Brigham, Joshua S <[e-mail]>; Vinson, Scott <[e-mail]>; Kinney, Maureen
<[e-mail]>; Headrick, Hannah <[e-mail]>; Moore, Cindy
<[e-mail]>
Subject: Draft NPDES Permit NC0079227 - Former Schlage Lock Plant (GW-REM) - Grade I Physical Chemical WPCS
Dear Mr. Eiler,
Please find the attached Draft NPDES Permit NC0079227 for the Former Schlage Lock Plant (GW-REM).
https://outlook.office365.com/mail/AAMkADdhYTVmZDBILTESZDctNG15MC04Zj1iLWU4MjVhZTBhMmJkMgAuAAAAAADg3GZR8iZnTYW56121 cjmNA... 1/2

1/30/2021 Mail - Denard, Derek - Outlook
Please respond to this email confirming that you received the attached document(s), were able
to open and view the document(s) and have saved/printed a copy for your records.
Sincerely,
Derek Denard
Environmental Specialist
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919 707 3618 office
919 707 9000 main DWR
derek.denard ncdenr.gov
1617 Mail Service Center
Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
https://outlook.office365.com/mail/AAMkADdhYTVmZDBILTESZDctNG15MC04Zj1iLWU4MjVhZTBhMmJkMgAuAAAAAADg3GZR8iZnTYW56121 cjmNA... 2/2

Draft NPDES 0079227 Review
Former Schlage Lock Plant (GW-REM)
Nash County
1. ATB is certain this will be captured later, but update the expiration date for the permit when the issued date
is finalized.
2. Please use the following updated template language for section A. (2.):
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Ceriodaphnia dubia at an effluent concentration of _%.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in
the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," (Revised December 2010, or
subsequent versions) or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"
(Revised December 2010, or subsequent versions). The tests will be performed during the months of
, and . These months signify the first month of each three-month toxicity
testing quarter assigned to the facility. Effluent sampling for this testing must be obtained during
representative effluent discharge and 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 -December 2010, 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, DWR Form AT-
3 (original) is to be sent to the following address:
North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
Or, results can be sent to the email, [e-mail].
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section 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
Water Sciences Section at the address cited above.
Freshwater Ceriodaphnia Chronic Limit Version 09/19

Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring
will be required during the following month. Assessment of toxicity compliance is based on the toxicity
testing quarter, which is the three-month time interval that begins on the first day of the month in which
toxicity testing is required by this permit and continues until the final day of the third month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division
of Water Resources 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.
Freshwater Ceriodaphnia Chronic Limit Version 09/19

NPDES PERMIT NEW / RENEWAL
DRAFT / FINAL
CHECK LIST
Permittee
Schlage Lock Company LLC
Facility
Former Schlage Lock Plant
Permit No.
NC0079227
Stream Class
C; NSW
Regional Office
RRO
Permit Writer
Derek Denard
Permit Drafting Initiated [BIMS Events] (review application for completeness)
08/28/2019
RO staff report requested [BIMS Events], sent email to:
Joshua S Brigham [[e-mail]]; Scott Vinson [[e-mail]]
06/23/2020
RO staff report received [BIMS Events] :
Joshua S Brigham [[e-mail]]; Scott Vinson [[e-mail]]
06/24/2020
EAA Review (new or expanding)
NA
Complete Draft Permit, Cover Letter, Create Edit Map
06/18/2020
Update/ Create Permit Outfall (Lat/Lon, HUC code, etc.) [BIMS]
No Access
Data/RPA Review
06/24/2020
Draft Fact Sheet & Fact Sheet Binder
06/24/2020
Proof Read for Peer Review
06/24/2020
Submit Cover, Permit, Map, Factsheet Binder (including Application, Add. Info.) for Peer Review
by Emily Phillips
06/24/2020
Peer Review Completed
06/25/2020
Region comments on draft requested to (see draft to whom list):
Brigham, Joshua S <[e-mail]>; Vinson, Scott <scott.vinson(zncdenr.gov>
07/06/2020
Region comments on draft received from:
Brigham, Joshua S <[e-mail]>
No comments
Request for Approval of Electronic Transmittals
06/29/2020
Response
06/30/2020
Prepare Public Notice Statement
06/24/2020
Proof Read Draft for Public Notice
07/06/2020
Updated Public Notice System
06/25/2020
Submitted for Public Notice on (emailed to Wren)
07/06/2020
Draft to additional reviewers ATB [BIMS Events]:
[e-mail]; [e-mail]
07/06/2020
Draft from additional reviewers ATB [BIMS Events]:
hannah.he [e-mail]
07/08/2020
Draft to additional reviewers WOCG [BIMS Events]:
[e-mail]
07/06/2020
Draft from additional reviewers WOCG [BIMS Events]:
[e-mail]
No comments
Public notice published [BIMS Events]
07/10/2020
BIMS Scheduled Issuance Date [BIMS Events - automatic]
08//24/2020
Expiration Date
10/31/2024
Final to DocuSign (proof read):
02/01/2021

4/23/2021 Mail - Denard, Derek - Outlook
[External] RE: Issuance of Permit NC0079227 - Schlage Lock Company LLC - Former
Schlage Lock Plant (GW-REM)
Eller, Russ <[e-mail]>
Fri 2/12/2021 10:42 AM
To: Denard, Derek <[e-mail]>
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment
to Report Spam.
Electronic transmittal is acceptable to me.
I received a copy of the permit, I was able to download the permit, it is viewable and I have saved/printed/shared
a copy of the permit for my/our records.
Thank you.
Russ
Russell E. Eiler, CEF, RIWP-M, CHMM, CSP
Director, Global EHS Compliance
ANALYTICAL, CONTEXT, INDIVIDUALIZATION, RESTORATIVE, HARMONY
"Objective, data -driven observer and fixer"
Allegion plc
c/o Schlage Lock Company LLC
11819 N. Pennsylvania Street
Carmel, Indiana 46032 USA
Office +1.317.810.3874
Cell +1.317.414.4070
Fax [phone]
Email: [e-mail]
allegion.com
AEI
• II
ALLEGION
440- COSA ■ 4 interflex ■ L.CN
• - •
VON DUPRIN
From: Denard, Derek <[e-mail]>
Sent: Thursday, February 11, 2021 5:37 PM
To: Eiler, Russ <[e-mail]>; [e-mail]
Cc: Brigham, Joshua S <[e-mail]>; Vinson, Scott <[e-mail]>; Thomas, Zachary
T <[e-mail]>; Moore, Cindy <[e-mail]>; Weaver, Charles
<[e-mail]>
Subject: Issuance of Permit NC0079227 - Schlage Lock Company LLC - Former Schlage Lock Plant (GW-REM)
https://outlook.office365.com/mail/AAMkADdhYTVmZDBILTESZDctNG15MC04Zj1iLWU4MjVhZTBhMmJkMgAuAAAAAADg3GZR8iZnTYW56121 cjmNA... 1/2

4/23/2021 Mail - Denard, Derek - Outlook
EXTERNAL MESSAGE: use caution with replies, links, and attachments.
Dear Mr. Eller:
In order to provide more convenience, control, and security to our permittees and assist them in
processing their transactions, the Division of Water Resources is currently transitioning towards
electronic correspondence. This will hopefully provide more efficient service to our permittees and
other partners and will allow us to more effectively process and track documents. We are writing to ask
you for your approval of the transmittal of documents related to your permitting and related activities
with the Division in an electronic format. Documents will be emailed to the appropriate contact
person(s) in your organization in a PDF format.
Please respond to me through email with verification that transmittal of your documents in an
electronic manner is acceptable to you.
Please respond to this email confirming that you received the attached document(s), were able
to open and view the document(s) and have saved/printed a copy for your records.
If you have any questions, please feel free to contact me.
Sincerely
Derek Denard
Environmental Specialist
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919 707 3618 office
919 707 9000 main DWR
[e-mail]
1617 Mail Service Center
Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
https://outlook.office365.com/mail/AAMkADdhYTVmZDBILTESZDctNG15MC04Zj1iLWU4MjVhZTBhMmJkMgAuAAAAAADg3GZR8iZnTYW56121 cjmNA... 2/2

4/23/2021 Mail - Denard, Derek - Outlook
Re: Issuance of Permit NC0O79227 - Schlage Lock Company LLC - Former Schlage Lock
Plant (GW-REM)
Denard, Derek <[e-mail]>
Fri 4/23/2021 10:57 AM
To: Weaver, Charles <[e-mail]>
Charles,
QA/QC was good for this one. Doing some spring cleaning here on stuff that has been sitting around on
my virtual desk.
Derek
Derek Denard
Environmental Specialist
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919 707 3618 office
919 707 9000 main DWR
[e-mail]
1617 Mail Service Center
Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Weaver, Charles <[e-mail]>
Sent: Friday, February 12, 2021 9:06 AM
To: Denard, Derek <[e-mail]>
Subject: RE: Issuance of Permit NC0079227 - Schlage Lock Company LLC - Former Schlage Lock Plant (GW-REM)
The permit has been issued in BIMS. You can QA/QC at your discretion.
CHW
From: Denard, Derek <[e-mail]>
Sent: Thursday, February 11, 2021 5:37 PM
To: Eiler, Russ <[e-mail]>; [e-mail]
Cc: Brigham, Joshua S <[e-mail]>; Vinson, Scott <[e-mail]>; Thomas, Zachary
T <[e-mail]>; Moore, Cindy <[e-mail]>; Weaver, Charles
<[e-mail]>
Subject: Issuance of Permit NC0079227 - Schlage Lock Company LLC - Former Schlage Lock Plant (GW-REM)
https://outlook.office365.com/mail/AAMkADdhYTVmZDBILTESZDctNG15MC04Zj1iLWU4MjVhZTBhMmJkMgAuAAAAAADg3GZR8iZnTYW56121 cjmNA... 1/2

4/23/2021 Mail - Denard, Derek - Outlook
Dear Mr. Eiler:
In order to provide more convenience, control, and security to our permittees and assist them in
processing their transactions, the Division of Water Resources is currently transitioning towards
electronic correspondence. This will hopefully provide more efficient service to our permittees and
other partners and will allow us to more effectively process and track documents. We are writing to ask
you for your approval of the transmittal of documents related to your permitting and related activities
with the Division in an electronic format. Documents will be emailed to the appropriate contact
person(s) in your organization in a PDF format.
Please respond to me through email with verification that transmittal of your documents in an
electronic manner is acceptable to you.
Please respond to this email confirming that you received the attached document(s), were able
to open and view the document(s) and have saved/printed a copy for your records.
If you have any questions, please feel free to contact me.
Sincerely
Derek Denard
Environmental Specialist
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919 707 3618 office
919 707 9000 main DWR
[e-mail]
1617 Mail Service Center
Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
https://outlook.office365.com/mail/AAMkADdhYTVmZDBILTESZDctNG15MC04Zj1iLWU4MjVhZTBhMmJkMgAuAAAAAADg3GZR8iZnTYW56121 cjmNA... 2/2