NC0000108_Owner (Name Change)_20060526

NPDES DOCVNEMT SCANNIMS COVER SHEET
0
NPDES Permit: NC0000108
Document Type: Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Monitoring Report •
Instream Assessment (67B)
Environmental Assessment (EA)
Permit
History
Document Date: _May 26, 2006
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OF 1N ArFi9 Michael F.Easley,Governor
O� 4G
William G.Ross Jr.,Secretary
fNorth Carolina Department of Environment and Natural Resources
Alan W.Klimek,P.E.Director
Division of Water Quality
May 26,2006
Ron Shemesh
159 Babcock Co.,LLC
Excelsior Packaging Group
1379 Old Rosman Hwy.
Brevard,NC 28712
Subject: NPDES Permit Modification
Permit NC0000108
Excelsior Packaging Group
formerly Coats American,Inc. -Sylvan Plant
WWI?
Transylvania County
Dear Mr. Shemesh:
Division personnel have reviewed and approved your request to transfer ownership of the subject permit,
received on May 22,2006. This perndt modification documents the change in ownership.
Please find enclosed the revised permit; All other terms and conditions contained in the original permit remain
unchanged and in full effect. This permit modification is issued under the requirements of North Carolina General
Statutes 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S.Environmental
Protection Agency.
If you have any questions concerning this permit modification,please contact the Point Source Branch at(919)
733-5083 extension 363.
Sincerely,
n W. Klimek,P.E.
cc: Central Hes
Asheville Regional Office,Surface Water Protection
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North Carolina Division of Water Quality 1617 Mail Service Center Raleigh,NC 27699-1617 Phone[phone] Customer Service .
Intemet h2o.emstatemc.us 512 N.Salisbury St. • Raleigh,NC 27604 FAX (9l9)733-2496 1-877-623-6748
An Equal OppoctunilylAffirrnative Action Employer—50%RecycW10%Post Consumer Paper

^ Permit NCOOOO108
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other
lawful standards and regulations promulgated and adopted by the North Carolina
Environmental Management Commission, and the Federal Water Pollution Control Act,
as amended,
159 Babcock Co., LLC
is hereby authorized to discharge wastewater from a facility located at the
Excelsior Packaging Group
Old US Hwy 64 East
Northeast of Rosman
Transylvania County
to receiving waters designated as Galloway Creek in the French Broad River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions
set forth in Parts 1, II, III and IV hereof.
This permit shall become effective May 26, 2006.
This permit and authorization to discharge shall expire at midnight on September 30, 2010.
Signed this day May 26, 2006.
g a, Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NC0000108
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge
are hereby revoked. As of this permit issuance, any previously issued permit bearing
this number is no longer effective. Therefore, the exclusive authority to operate and
discharge from this facility arises under the permit conditions, requirements, terms,
and provisions included herein.
159 Babcock Co., LLC is hereby authorized to:
1. Continue to operate an existing 0.015 MGD extended aeration package wastewater
treatment system with effluent disinfection to discharge at outfall 003, located at
Excelsior Packaging Group, on Old US Highway 64 East, Transylvania County, and
2. Discharge from said treatment works at the location specked on the attached map
into Galloway Creek which is classified.0 waters in the French Broad River Basin.

Permit NCOOOO108
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS — FINAL
During the period beginning on the effective date of this permit and lasting until permit expiration, the Permittee is
authorized to discharge from outfali OOS: domestic wastewater. Such discharges shall be limited and monitored
by the Permittee as specified below:
EFFLUENT LIMITS MONITORING REQUIREMENTS;
CHARACTERISTICS
" Monthly Daily', Measurement Sample Type Sample Location
Averse . Maxln3um Fwe uen ,
Flow 0.015 MGD Weekly Instantaneous Influent or Effluent
BODs,2DOC 30.0 mgA 45.0 mgA Weekly Grab Effluent
Total Suspended Solids 30.0 mgA 45.0 m Weekly Grab Efflueni
NH3 as N4 21.0 mg 35.0 mgA Weekly Grab Effluent
Fecal Coliform eomefic mean 200/100 ml 4001100 ml Weekly Grab Effluent
Total Residual Chlodne2 28 ugfi 2/Week Grab Effluent
Temperature,OC Weekly Grab Effluent
H3 2110onth Grab Effluent
Footnotes:
1. From November 1 through March 31, NH3-N shall not have a limit.
2. The TRC limit shall take effect on May 1, 2007. Until then, the permittee shall monitor TRC
(with no limit).
3. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Permit NC0000108
A. (2.)EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS -
FINAL
During the period beginning on the effective date of this permit and lasting until
permit expiration, the authorization to discharge from outfall 001 is suspended until
this permit is modified pursuant to Condition A. (4).
A. (3.)EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS -
FINAL
During the period beginning on the effective date of this permit and lasting until
permit expiration, the authorization to discharge from outfall 002 is suspended until
this permit is modified pursuant to Condition A. (4).
A. (4.)CHANGE IN OWNERSHIP OR USE OF THE FACILITY- FINAL
Prior to resuming operations at the Sylvan Plant or in the event that the facility
changes ownership, the permittee shall submit a request for permit modification
including the following documentation at least 180 days prior to the start of
operations:
1. Description of manufacturing processes, products, and expected annual
production.
2. Flow diagram indicating process and wastewater flow volumes.
3. Proposed treatment and characteristics of the wastewater to be discharged.
4. Description of any planned expansions or upgrades to the manufacturing or
treatment facilities.
5. Engineering Alternatives Analysis of wastewater disposal alternatives including
the connection to an existing municipal waste treatment facility and non-
discharge alternatives.
6. if the facility is sold a name ownership change form and required documentation
shall be submitted to the Division.
A. (5.) BIOCIDE CONDITION - FINAL
The permittee shall not use any biocides except those approved in conjunction with
the permit application. The permittee shall notify the Director in writing not later than
ninety (90) days prior to instituting use of any additional biocide used in cooling
systems which may be tonic to aquatic life other than those previously reported to the
Division of Water Quality. Such notification shall include completion of Biocide
Worksheet Form 101 and a map locating the discharge point and receiving stream.

Mike BELL/US/COATS "'Ronnie Shemesh"' <[e-mail]>,
Z1 00_ PM TO [e-mail]
% [e-mail], Donna
I cc Armstrong/US/COATS@COATS,
VO appinnix arcadis-us.com [e-mail],
bcc Mickey�lsen/US/COATS@Coats
Subject Phase II Limited Site Assessment Report-Coats
Rosman, NC Plant
Mr. Shemesh/Mr. Costa,
Attached is a letter of explanation regarding the also attached Phase It Limited Site Assessment report
recently submitted to the NC Department of Environment and Natural Resources for the former petroleum
underground storage tank release at the Coats Sylvan Plant in Rosman, NC Also included is a copy of
NC-DENR Instructions for Preparing a"Notice of Residual Petroleum"Referencing Land Use Restriction
referenced in my letter of explanation.
With the closing on the property scheduled in approximately two week and having not heard from you or
your representatives requesting information on environmental matters, I again bring to your attention the
need to coordinate with NC-DENR on these issues. In particular you may want to discuss the continuing
services of Tom Kitchen and Wesley Royal for operation of the wastewater treatment plant whose contact
information was provided in my November 10, 2005 letter to you.
Lastly, I will be sending you a list of the utility service providers and account numbers for the site for your
coordination in transferring the accounts and services at closing.
Please do not hesitate to call me about this information or as to how we may assist you in any matters
regarding the property.
Regards,
Mike Bell
Director, Environmental Engineering
Coats North America
[phone] Ext. 2248
[phone] Fax
[phone] Cell
Coats Rosman Final Phase II LSA Ynd 120205.pdf Coats Rosman Phase 11 LSA Rnal 112905a pdf NR.P-Ins.doc

r
Coats Coats North America
PO Box 670
6212 Rose Lane
Toccoa,G(7 30577
North America
Phone: (706)8$6-2141
UT
Fax: [phone]
Via E-mail: [e-mail]
ayemli !W072005
Mr. Ronnie Shemesh
Chief Executive Officer
159 Babcock Company,LLC
159 Alexander Street
Yonkers,NY 10701
Reference: Additional Site Environmental Documentation
Coats Sylvan Plant
Rosman,North Carolina
Dear Mr.Shemesh:
Attached please find the following information relevant to the ongoing investigation of
the release from the former petroleum underground storage tank and the plant's
wastewater treatment system:
1. Letter, ARCADIS G&M, October 31, 2005, Subject: Notice of Release from an
Underground Storage Tank, Coats American Inc. Sylvan Facility, Old Highway 64,
Rosman, Transylvania County, North Carolina
2. Letter, ARCADIS G&M, November 4, 2005, Subject: Limited Site Assessment Work
Plan for Coats American Sylvan Plant
3. Letter, North Carolina Department of Environment and Natural Resources, Division
of Waste Management, Underground Storage Tank Section, November 4, 2005, RE:
Notice of Regulatory Requirements, 15A NCAC 2L .0115(c) Risk-based Assessment
and Corrective Action for Petroleum Underground Storage Tanks, Coats American
Inc. Sylvan Facility, Old Highway 64, Rosman, Transylvania County, Incident
Number: 28343
4. getler, NorthLCarolinalDepartm'i e tTo-f3En`vironmenC.aTc Natural1Resources,
September 28;=2005,,ZSubject:-1ssix ance•of-NPDES-Kermit,,NFC0000108,,Sy.1vvaan Plana
WWTP,.Transylvania Gounty with attached.Permit=to DnschaTge�Wastewater'Under
the�National Pollution-Discharge-Elimination:System;Per1
it-NC0000108;YEffectve--
Novem_ ber 1 2005 " _' _ -_. . --
Investigation Release from an Underground Storage TankRelease from an Underground Storage Tank
The first three attachments pertain to this subject. Consistent with Coats'history at
other former sites and our October 28, 2005 letter to you, we are continuing the
investigation this week as outlined in the Work Plan listed in Item 2 above. We have
asked ARCADIS to use expedited laboratory reporting services to provide further
information on the release as quickly as possible.

Y ,
Additional Site Environmental Documentation
Coats Sylvan Plant,Rosman,North Carolina
November 10,2005
Page 2
Wastewater Treatment Plant and Permit
As you may be aware, the plant's wastewater is treated on-site using a 15,000 gallon
per day package wastewater treatment system as authorized by a National Pollution
Discharge Elimination System Permit. The recently renewed permit listed in Item 4 is
included in this transmittal.
Having not received any questions from you concerning this permit or system, Coats
wants to make you aware of it. It is recommended you or your environmental
consultants review this permit and its conditions carefully. In particular, Coats
wished to bring to your attention the change in ownership requirements in paragraph
.A.(4.) of the permit. While the permit states the documentation for this change shall
be submitted 180 days prior to the start of operations, I spoke with Wanda Frazer,
[phone] or 4600, at the Asheville Regional Office of NC-DENR who indicated
this requirement would not be enforced. However, she asked that the new owner
contact her as soon as possible prior to or after the closing to discuss permit transfer
requirements.
Regarding the historic or day-to-day operation of the wastewater treatment system or
the permit I will be glad to assist you with additional information and discussion as
you may request. You are welcome to contact the current licensed operator (and plant
caretaker), Tom Kitchen, at [phone]. We also use the services of Wesley Royal
as the Operator in Responsible Charge who also operates the Town of Rosman WWTP
under contract. Wesley can best be contacted on his cell phone at [phone].
I apologize for the size of this transmittal and will be glad to send you a hard copy is you would
like. Please do not hesitate to call me at(706)886-2141 Ext. 2248 with any questions you may
have about this information.
Sincerely,
COATS NORTH AMERICA
Mike Bell
Director Environmental Engineering
Attachments
cc: (via E-mail)
Tom Costa
James Pellerin
Hadiya Claxton
Peter McGrath
Alan Pinnix
Donna Armstrong