NCS000179_APPLICATION_20140409

STORMWATER DIVISION CODING SHEET
PERMIT NO.
��'(Q 1 Iq
DOC TYPE
❑ FINAL PERMIT
❑ MONITORING INFO
CYAPPLICATION f.,,V-V,nl
❑ COMPLIANCE
❑ OTHER
DOC DATE
❑ 261� Oil b 9
YYYYM M DD

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April 4, 2014
RE: Permit Number NCS000179 -- Permit Renewal Request
CERTIFIED MAIURETURN RECEIPT
Stormwater Permitting Program
Individual Permit Renewal
1612 Mail Service Center
Raleigh, NC 27699-1612
Dear Sir or Madam:
Tel.: [phone]
Tel.: [phone]
Fax: [phone]
[e-mail]
7r's ,».
.� �1r1
APR 0 9 2014 EJr
WZ,, f t DENR. WATER
" SMDSTOR� RANCH
Enclosed is our Renewal Application Form for renewing our Stormwater Permit. Please
note that I joined Bonar 6 months ago and have been overseeing the SWPPP since
then. I have ensured that the 2013 data was submitted to DWQ in Raleigh as required
by our permit. However, I do not have reference as to if the periods of 2010 — 2012
were submitted.
For what I have personally seen in the past 6 months and by reviewing both analytical
data and qualitative visual data, our outfalls appear to be in good shape and for the
most part within the benchmark values.
If you have question or concerns please feel free to contact me.
Respectfully Submitted, /.
Stephen C. Jenkins, CSP, REM
QHSE Manager
Enclosures
cc: Wayne Merritt, Director of Operations -- NAFTA, Bonar
Bart Austin, President — NAFTA, Bonar
SCANNED
SEP 10 2020
Bonar Inc.: 1301 Sand Hill Road • P.O. Box 1057 • Enka, NC 28728 • USA
w .bonar.conn ;lye

Permit Coverage Permit Number
®�n Renewal Application Form NCSO00179
NCDENR National Pollutant Discharge Elimination System
Stormwater Discharge Permit
The following is the information currently in our database for your facility. Please review this information carefully and make all
corrections/additions as necessary in the space provided to the right of the current information.
Owner Affiliation Information *Reissued Permit will be mailed to the owner address
Owner / Organization Name: Bonar Inc
Owner Contact: Bart Austin
Mailing Address: PO Box 1057
Enka, NC 28728
Phone Number:
Fax Number:
E-mail address:
Facility/Permit Contact Information
Facility Name: Bonar
Facility Physical Address: 1301 Sand Hill Rd
Enka, NC 28728
Facility Contact:
Mailing Address:
Phone Number:
Fax Number:
E-mail address:
Discharge Information
Receiving Stream Hominy Creek
Stream Class: C
Basin: French Broad River Basin
Sub -Basin: 04-03-02
Number of Outfalls:
Impaired Waters/TMDL
Does this facility discharge to waters listed as impaired or waters with a finalized TMDL? O Yes ❑ No ❑ Don't Know
( for information on these waters refer to http://h2o.enr.state.nc.uslsullmpaired Waters TMDL/ )
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.
Signature
Print or type name of person signing above
Date
Title
Stormwater Permitting Program
Please return this completed renewal application form Individual Permit Renewal
and other required supplemental information to: 1612 Mail Service Center
Raleigh, North Carolina 27699-1612

SUPPLEMENTAL INFORMATION REQUIRED FOR RENEWAL OF INDIVIDUAL NPDES
STORMWATER PERMIT
Two copies of each of the following shall accompany this submittal in order for the application to be
considered complete:
(Do not submit the site Stormwater Pollution Prevention Plan)
Initials
1. A current Site Map from the Stormwater Pollution Prevention Plan. The location of
industrial activities (including storage of materials, disposal areas, process areas and
loading and unloading areas), drainage structures, drainage areas for each outfall,
building locations and impervious surfaces should be clearly noted.
A summary of Analytical Monitoring results during the term of the existing permit (if your
permit required analytical sampling). Do not submit individual lab reports. The summary
can consist of a table including such items as outfall number, parameters sampled, lab
results, date sampled, and storm event data. I-1
/JV-3. A summary of the Visual Monitoring results. Do not submit individual monitoring reports.
The summary can consist of a table including such items as outfall number, parameters
surveyed, observations, and date monitoring conducted.
4. A summary of the Best Management Practices utilized at the permitted facility. Summary
should consist of a short narrative description of each BMP's in place at the facility. If the
implementation of any BMP's is planned, please include information on these BMP's.
O 5. A short narrative describing any significant changes in industrial.activities at the permitted
facility. Significant changes could include the addition or deletion of work processes,
changes in material handling practices, changes in material storage practices, and/or
changes in the raw materials used by the facility.
4- 6. Certification of the development and implementation of a Stormwater Pollution Prevention Plan
for the permitted facility (Sign and return attached form).
If the final year analytical monitoring of the existing permit term has not been completed prior
to filing the renewal submittal, then the last years monitoring results should be submitted within 30
days of receipt of the laboratory reports. (i.e. do not withhold renewal submittal waiting on lab results)

April 4, 2014
SDO Analytical Monitoring Results Summary 2010 — Current
Total
Rainfall
Inches
Total
Suspended
Solids mg/L
COD
Mg/L
pH
Standard
Units
Benchmark
N/A
100
120
6-9
Date of Sample
Collection
SDO
ID
11/26/13
SDO 1
2.05
10.9
<25
7.15
SDO 2
2.05
28.6
27
7.45
06/18/13
SDO 1
0.72
9.2
<25
7.4
SDO 2
0.72
3.1
<25
7.2
11/07/12
SDO 1
0.18
5
<25
6.6
SDO 2
0.18
6.4
125
7.2
1" Half 2012
Analytical Monitoring did not occur.
2nd Half 2011
03/O1/11
SDO12.5
<25
6.4
3.9
27
6.7
10/20/10
<5.3
65
6.6
<5.1
30
7.0
OS/21/10
<16.7
<25
6.5
<12.5
<25
6.7

April 4, 2014
SDO Analytical Monitoring Results Summary 2010 - Current
Total
Total -, ."
COD ,,,
pH,
Rainfall
.Suspended ' .
��-Mg/L^ .
Standard "]
..Inches .
.Solids mg/L `
Units :.
4 fsBenc15 aM `�Y
SON
s" RM
�c �]00, M
� MEwd
6-019104
Date of Sample
SDO
Collection
ID
2.05
10.9
SDO 1
<25
7.15
11/26/13
SDO 2
2.05
28.6
27
7.45
SDO1
0.72
9.2
<25
7.4
06/18/13
SDO 2
0.72
3.1
<25
7.2
SDO 1
0.18
5
<25
6.6
11/07/12
SDO 2
0.18
6.4
125
7.2
`
is Half 2012
Analytical Monitoring did not occur.
2nd Half 2011
SDO1
0.73
12.5
<25
6.4
03/01/11
SDO 2
0.73
3.9
27
6.7
SDO 1
0.10
<5.3
65
6.6
10/20/10
SDO 2
.0.10
<5.1
30
7.0
SDO1
0.29
<16.7
<25
6.5
05/21/10
SDO 2
0.29
<12.5
<25
6.7

April 4, 2014
SDO Visual Monitoring Results Summary 2010 — Current
Color
Odor
Clarity
Floating
Suspended
Foam
Sheen
Erosion
Solids
Solids
Date of
SDO
Observation
ID
$
SDO 1
Brownish
None
2
1
2
No
No
No
11/26/13
SDO 2
Brownish
None
2
1
2
No
No
No
SDO 1
Clear
None
1
1
1
No
No
No
06/18/13
SDO 2
Clear
None
1
1
1
No
No
No
Light
SDO I
None
2
1
1
Yes
No
No
Brown
06/07/11
Brownish
SDO 2
None
2
1
1
No
No
No
Green
Light
SDO 1
None
2
2
2
No
No
No
Grey
12/02/10
—
Light
SDO 2
None
2
1
2
No
No
No
Grey
SDO 1
Clear
None
1
1
1
No
No
No
08/13/10
Pale
SDO 2
None
2
1
2
No
No
No
Green
SDO I
Clear
None
2
1
2
No
No
No
05/07/10
Light
SDO 2
None
2
2
2
No
No
No
Green
Very
SDO 1
Light
None
2
1
2
No
No
No
01/08/10
Brown
Light
ISDO 2
None
21
1
2
No
No
No
Amber
I

April 4, 2014
SDO Visual Monitoring Results Summary 2010 — Current
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BMP IDENTIFICATION
T rtle Professional 111 Altamont Environmental Inc
Date:.08/15[13
BMP_ s '
_ Brief Description's of Activitles
_"
Good
•
Maintain dry and clean floors by using brooms, shovels, vacuum cleaners, or other cleaning methods.
Housekeeping
.
Regularly pick up and dispose of garbage and waste materials.
•
Routinely inspect for leaks or conditions that could lead to discharges of chemicals.
•
Train employees so that they understand this SWPPP and the importance of preventing stormwater pollution.
Preventive
•
Maintain all equipment, tanks, totes, and containers to prevent leaks.
Maintenance
Maintain secondary containment around ASTs.
•
Maintain spill response equipment.
Inspections
•
Inspect and maintain stormwater management equipment, clean aIs necessary.
•
Inspect and maintain facility equipment used for materials handling to identify potential failures or breakdowns.
•
Perform routine inspections of AST areas.
•
Inspect equipment, tanks, totes, and containers as prescribed in this SWPPP.
•
Inspect exterior "material storage and handling" areas and "waste storage and handling" areas as prescribed in this
SWPPP.
Spill Prevention
•
Follow the guidance provided in the Site's Spill/Release Control Plan.
Response
•
Train employees on this SWPPP, the Spill/Release Control Plan, and locations of spill response materials.
•
Store spill response materials under protected cover in each potential spill area.
•
Clean up small spills immediately.
Sediment and
•
For new construction, evaluate potential erosion areas and the available methods for controlling erosion or sediment
Erosion Control
runoff, prior to construction.
P:\Colbond\SWPPP\Appendices\App F - BMPs Table.doc

-:
Completed by: Brian Gant-
'BMP IDENTIFICATION
Ttie: ProfessionarIll, AltannontEnvvonmental Inc
bate: 08j15j13 -
BMPs
F Brief Descriptions of Activities
Good
Maintain dry and clean floors by using brooms, shovels, vacuum cleaners, or other cleaning methods.
Housekeeping
Regularly pick up and dispose of garbage and waste materials.
•
Routinely inspect for leaks or conditions that could lead to discharges of chemicals.
•
Train employees so that they understand this SWPPP and the importance of preventing stormwater pollution.
Preventive
•
Maintain all equipment, tanks, totes, and containers to prevent leaks.
Maintenance
•
Maintain secondary containment around ASTs.
•
Maintain spill response equipment.
Inspections
Inspect and maintain stormwater management equipment, clean as necessary.
•
Inspect and maintain facility equipment used for materials handling to identify potential failures or breakdowns.
•
Perform routine inspections of AST areas.
•
Inspect equipment, tanks, totes, and containers as prescribed in this SWPPP.
•
Inspect exterior "material storage and handling" areas and "waste storage and handling" areas as prescribed in this
SWPPP.
Spill Prevention
•
Follow the guidance provided in the Site's Spill/Release Control Plan.
Response
•
Train employees on this SWPPP, the Spill/Release Control Plan, and locations of spill response materials.
•
Store spill response materials under protected cover in each potential spill area.
•
Clean up small spills immediately.
Sediment and
For new construction, evaluate potential erosion areas and the available methods for controlling erosion or sediment
Erosion Control
runoff, prior to construction.
P:\Colbond\SWPPP\Appendices\App F - BMPs Table.doc

AIR 0 9 2014 6
DENR • WATrR QUALITY
WmftsmD STORMWATER WAN0N
April 4, 2014
Tel.: [phone]
Tel.: [phone]
Fax: [phone]
[e-mail]
RE: Permit Number NCS000179 -- Renewal Statement of Significant Changes
Per my research, there has not been any significant changes to the industrial activity at
this location since the permit became effective November 1, 2009.
Respectfully Submitted,
Stephen C. Jenkins, CSP, REM
QHSE Manager
Bonar Inc.: 1301 Sand Hill Road • P.O. Box 1057 • Enka, NC 28728 • USA
www.bonar.com

Tel.: [phone]
BO^ ^ r Tel.: [phone]
partners In performance Fax:[phone]
[e-mail]
April 4, 2014
RE: Permit Number NCS000179 -- Renewal Statement of Significant Changes
Per my research, there has not been any significant changes to the industrial activity at
this location since the permit became effective November 1, 2009.
Respectfully Submitted,
Stephen C. Jenkins, CSP, REM
QHSE Manager
Boner Inc.: 1301 Sand Hill Road • P.O. Box 1057 • Enka, NC 28728 • USA
w .bonaccom

STORMWATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
North Carolina Division of Energy, Mineral, and Land Resources- Storm wa rPermitting
Facility Name: Bonar l�•—���r ,1,:z;
Permit Number. NCS000179 AP
Location Address: 1301 Sand Hill Rd R 0 9 yn,, tj(
Enka, NC 28728
County: Buncombe
"SANDgTORZA LIT I( C
I certify, under penalty of law, that the Stormwater Pollution Prevention Plan (SPPP) document and all attachments were developed and
implemented under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather
and evaluate the information required by the SPPP. Based on my inquiry of the person or persons who manage the system, or those persons
directly responsible for gathering the information, the information gathered is, to the best of my knowledge and belief, true, accurate and
complete."
And
"I certify that the SPPP has been developed, signed and retained at the named facility location, and the SPPP has been fully implemented at
this facility location in accordance with the terms and conditions of the stormwater discharge permit."
And
"I am aware that there are significant penalties for falsifying information, including the possibility of fines and imprisonment for knowing
violations."
Sign (according to permit signatory requirements) and return this Certification. DO NOT SEND
STORMWATER POLLUTION PREVENTION PLAN WITH THIS CERTIFICATION.
Signature
Print or type name of person signing above
Date q —- 1 J l I
_Qtf�F jY1�N.tr_i=_R
Title
SPPP Certification 10/13

STORMWATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
North Carolina Division of Energy, Mineral, and Land Resources - Stormwater Permitting
Facility Name:
Bonar
Permit Number:
NCS000179
Location Address:
1301 Sand Hill Rd
Enka, NC 28728
County:
Buncombe
"I certify, under penalty of law, that the Stormwater Pollution Prevention Plan (SPPP) document and all attachments were developed and
implemented under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather
and evaluate the information required by the SPPP. Based on my inquiry of the person or persons who manage the system, or those persons
directly responsible for gathering the information, the information gathered is, to the best of my knowledge and belief, true, accurate and
complete."
And
" I certify that the SPPP has been developed, signed and retained at the named facility location, and the SPPP has been fully implemented at
this facility location in accordance with the terms and conditions of the Stormwater discharge permit."
And
"I am aware that there are significant penalties for falsifying information, including the possibility of fines and imprisonment for knowing
violations."
Sign (according to permit signatory requirements) and return this Certification. DO NOT SEND
STORMWATER POLLUTION PREVENTION PLAN WITH THIS CERTIFICATION.
Signature
L�.
5��41q=A1 �� (IIr�Yd�I hY
Print or type name of person signing above
Date q — � J I l
CQ11�i- /Y1//i'NN�1x;rR
Title
SPPP Certification 10/13

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Low & Bonar Inc.
NC DEQ Stormwater Section
Meeting Agenda — November 15, 2017
Stormwater System Compliance Issues
1. Non -contact cooling water discharges are co -mingled with stormwa discharges at the exit
of the Slim Tank; which is the new wastewater compliance point. I��
2. Stormwater are measured in the Flood Gate immediately upstream of the East Ditch; which
was the previous stormwater AND wastewater compliance point. Discharges include
contributions from American Recycling.
Overview of Stormwater Changes Since May 2017
Prepared new facility maps/figures with updated changes to wastewater and stormwater lines.
1. Re-routed non -contact cooling water piping from direct stormwater discharge to indirect
discharge via the Slim Tank.
a. Chiller Water Cooling Tower System (058)
b. Compressor Air Cooling Tower System (054)
c. Cooper Cooling Tower System
2. Re-routed non -contact Boiler Condensates from direct stormwater discharge to MSD
discharge.
a. Receivers
b. Drip Legs
3. Installed discharged water and stormwater flow sensors that provide flow rates on gallon per
minute, gallon per day, and a non-resettable totalizer. Note: Have on -site NWS
meteorological station.
a. Slim Tank: Process Water
b. Flood Gate: Stormwater/Discharged Water
4. Installed discharged water de -chlorination system.
5. New Stormwater Sampling Locations. These sampling points are immediately upstream of
the property boundary.
a. From East Ditch to Flood Gate
b. From West Ditch to Manhole 17
6. Policy changes
a. Connections to stormwater downcomers re -piped to MSD
b. Inlet protection.
c. SPCC
d. SWPPP
e. Stormwater Sampling Plan
7. Should American Recycling have a Stormwater permit?

Riddle, Rick L
From: [e-mail]
Sent: Wednesday, December 06, 2017 5:08 PM
To: Kucken, Darlene; Riddle, Rick L
Cc: [e-mail]; [e-mail]; [e-mail];
[e-mail]
Subject: RE: [External] Hydraulic Spill from American Recycling -- Report
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to
Hello Darlene,
That date and time works fine for us. 1 think is will be good to have Rick look at this site's complexity
Dan was able to sample for our second required Storm Water Testing for 2017. He actually additionally sampled at a
manhole access for a baseline ( the site where we would like to move our sampling point to) and one from the West outfall
to Hominy Creek as specified by our current permit and another at East Ditch outfall. He took pictures of the difference
in clarity.... The west outfall is definitely being influenced by the piles of dirt on the Enka Partners — Fletcher Partners
Land as the TSS appears very prevalent. The sample at the manhole was clear... Thus one of the discussion points for our
meeting.
We look forward to it and hopefully we can work out some good sampling points that will meet the state's requirements
as well as be representative of only our contribution to the Stormwater.
Thanks and Best regards,
Steve
Steve Jenkins
HSE Manager North America
D [phone]
M [phone]
F + 1 828 665 3545
Progress Itmigh performance
P.O. Box 1057, Enka, NC 28728
1301 Sand Hill Road, Candler, NC 28715 USA
[phone] lowandbonar.com
From: Kucken, Darlene[mailto:[e-mail]]
Sent: Wednesday, December 06, 2017 9:52 AM
To: Jenkins, Steve<[e-mail]>; Riddle, Rick L <[e-mail]>
Cc: [e-mail]; [e-mail]; Macro, Clive <[e-mail]>; Merritt, Wayne
<wayne. merritt@ lowandbonar.com>
Subject: RE: [External] Hydraulic Spill from American Recycling -- Report

Riddle, Rick L
From:
Kucken, Darlene
Sent:
Wednesday, November 08, 2017 10:25 AM
To:
Riddle, Rick L
Cc:
Aiken, Stan E; Davidson, Landon; Wiggs, Linda
Subject:
Low & Bonar
Hi Rick,
Thanks for being available to do a site visit at the Low & Bonar site next Wednesday. Please note that I need to confirm
their availability first and 1 will get back to you as soon as 1 hear from them.
The permit number is NCS000179. The site is currently under an NOV with DWR as of June 21. DWR can let us know
the status of the NOV.
Under separate emails, I will send you a few email communications between DWR, DEMLR and the facility management
(Steve Jenkins) and their consultant (Daniel March).
Darlene Kucken - Darlene. [e-mail]
North Carolina Dept. of Environmental Quality
Asheville Regional Office
Division of Energy, Mineral, and Land Resources
2090 U.S.70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
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.
Go Green! Print this email only when necessary. Thank you for helping NCDENR be environmentally responsible.
APPROVE D
NOV 10 2017
NCDEO Stf rank !elte'
T,..

Riddle, Rick L
From:
Kucken, Darlene
Sent:
Wednesday, November 08, 2017 10:36 AM
To:
Riddle, Rick L
Subject:
FW: Meeting regarding Bonar facility
Darlene Kucken - Darlene. [e-mail]
North Carolina Dept. of Environmental Quality
Asheville Regional Office
Division of Energy, Mineral, and Land Resources
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax:[phone]
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.
`Wj Go Green! Print this email only when necessary. Thank you for helping NCDENR be environmentally responsible.
From: Wiggs, Linda
Sent: Wednesday, July 05, 2017 11:39 AM
To: Kucken, Darlene <[e-mail]>
Cc: pisgah-air ([e-mail]) <[e-mail]>; [e-mail]; Davidson, Landon
<[e-mail]>; [e-mail]
Subject: RE: Meeting regarding Bonar facility
Darlene,
DWR is dealing directly with Low and Bonar and has prescribed an initial sampling plan for wastewater. I am meeting
onsite tomorrow in order to ground truth this initial sampling plan and adjust as needed. After tomorrows site visit I will
have a more comprehensive idea of what DWR needs from Low and Bonar's wastewater evaluation.
Instream sampling will a component of our sampling requirement. Depending on what I see tomorrow, it is possible
"stormwater discharge outfall (SDO)" locations will be required as wastewater sampling locations, since it is reported
here is comingling. Hence, there may be 2verlan_with stormwater sampling locations and wastewater sampling locations;
it
wastewater sampling shall not be conducted as stormwater sampling is to be conduct4So, even though the waters
may comingle the sampling events cannot coincide.
1 understand this site is complex and stormwater issues remain unresolved. I will not be evaluating the entire site
tomorrow. However, of the areas 1 do evaluate, I will holistically observe for any water quality violation concerns. I will
discuss with you my findings from tomorrow visit.
Environmental Senior Specialist —Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4500 office
828 299 7043 fax
Email: linda.wiaos(5ricdenr.00v

2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
�` Nothing Compares
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Kucken, Darlene
Sent: Wednesday, July 05, 2017 9:00 AM
To: Davidson, Landon <[e-mail];
wavne.merritta,,lowandbonar.com
Cc: Wiggs, Linda <linda.wiggs(a ncdenr gov>; pisgah-air (pisgah-air vt.edu) <pis ah-airna vt.edu>
Subject: RE: Meeting regarding Bonar facility
I'm forwarding this on directly to Dan so he can work out a wastewater/Stormwater study approach.
Darlene Kucken - Darlene. Kucken@a ncdenr. gov
North Carolina Dept. of Environmental Quality
Asheville Regional Office
Division of Energy, Mineral, and Land Resources
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
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.
`A Go Green! Print this email only when necessary. Thank you for helping NCDENR be environmentally responsible.
From: Davidson, Landon
Sent: Friday, June 23, 2017 3:00 PM
To: steve.jenkinsAlowandbonar com; wayne.merrittna,lowandbonar.com
Cc: Kucken, Darlene <darlene.kucken(a)ncdenr gov>; Wiggs, Linda <linda.wiggs(a�ncdenr gov>
Subject: Meeting regarding Bonar facility
Mr. Jenkins and Mr. Merritt -
Thank you for taking the opportunity to speak with us regarding the wastewater issue at Bonar facility. The purpose of
this email is to capture the salient points of our meeting that include the following:
• Bonar will submit preliminary information to DWR characterizing the wastewater discharge. DWR will use this
information to prescribe a sampling plan. DWR understands this information will be submitted within the week
and may be in draft form only. The preliminary information will include:
o Revised, if any, estimates of the volume of wastewater discharged daily
o A list of biocides and any other additives used by Bonar that would be present in the wastewater
discharge (to Hominy Creek)
o Any biocide worksheets that may exist, whether draft or final form
o Any analytical data of the discharge that has not yet been submitted to DWR
• Bonar will begin an engineered, wastewater audit to determine/verify all contributing waste streams currently
being discharged to Hominy Creek. The final report of the audit must be sealed by a NC Professional Engineer.

This same information will be valuable in completing an application for a discharge permit if elected. Please
report to the Division once a timeframe for completion of this study has been established.
• The June 28" meeting has been cancelled. A new meeting time will be established once DWR receives additional
information.
DWR also requests the following items:
• Bonar provide an estimate of the costs to pump and haul the current wastewater discharge
• Please explain why the current wastewater discharge cannot be captured and discharged to the MSD POTW
• Please list any changes in the quality or quantity of the current discharge compared to the quality and quantity of
the discharge previously covered under NCG500608
Please understand that the meeting's discussion nor the request for items listed above constitute, in any way, approval by
the DWR to allow the continued discharge of wastewater to Hominy Creek. The continuation of an unpermitted discharge
represents a continuing violation of NCGS 143-215.1.
Please contact Linda if you should have any questions regarding these items.
Regards,
Landon
G. Landon Davidson, P.G.
Regional Supervisor — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4680 office
828 230 4057 mobile
Landon. Davidson( ncdenr.gov
2090 U.S. Hwy. 70
Swannanoa, N.C.28711
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

Riddle, Rick L
From:
Kucken, Darlene
Sent:
Wednesday, November 08, 2017 10:37 AM
To:
Riddle, Rick L
Subject:
FW: Low & Bonar
Darlene Kucken - [e-mail]
North.Carolina Dept. of Environmental Quality
Asheville Regional Office
Division of Energy, Mineral, and Land Resources
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax:[phone]
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.
`' Go Green! Print this email only when necessary. Thank you for helping NCDENR be environmentally responsible.
From: Daniel March [maiIto: [e-mail]]
Sent: Tuesday, July 18, 2017 2:11 PM
To: Kucken, Darlene <[e-mail]>; [e-mail]; Lisa Manning
<mann i n g l a@yahoo. c om>
Subject: Re: Low & Bonar
Ms. Kucken:
During your site inspection at Low & Bonar on May 22, 2017, we discussed several items that were
necessary to be up to date with the stormwater permit. Those items are listed below:
1. Alternate stormwater sampling and analysis plan and sampling locations that attempts to
quantify the contributions of L&B process, those of on -site tenants, neighbors, and off -site
stormwater contributions.
2. Report to the NC DEQ stormwater staff that quantifies biocide impacts to Hominy Creek.
3. Request a letter from DEQ concerning status of Wolsley Industries uncovered material
storage. Do they need a permit? Or, should they have specific conditions under L&B's
permit?
4. Request - from the Raleigh Central Office - a change in stormwater sampling locations.
5. Present the results of an on -site sampling and analysis campaign that identifies off -site
impacts, equivalent sampling locations, and compliance points that are away from and
distinct from newly purchased properties by Fletcher Partners, Enka Partners, and American
Recycling.
6. An algorithm or calculation methodology to determine the dilution of L&B stormwater
discharges to Hominy Creek.
Do you have any other information needs?

Should additional items be added to the above list?
Thanks,
Dan March
On Mon, Jul 3, 2017 at 11:33 AM, Daniel March <pis ag [e-mail]> wrote:
Darlene:
Do you have any additional Low & Bonar information requests other than those listed in our June 6
email?
We have most of the information gathered and in a DRAFT response. But, we want to make sure we
covered everything necessary.
Thanks,
Dan March
---------- Forwarded message ----------
From: Daniel March <[e-mail]>
Date: Tue, Jun 6, 2017 at 1 1:36 AM
Subject: Low & Bonar
To: darlene.kucken(i�ncdenr.gov, steve.jenkins lowandbonar.com
Cc: Lisa Manning <manningla(a)yahoo.com>
Ms. Kucken
Thanks for your help at Low & Bonar a couple weeks ago. We really appreciate your advice on our
stormwater permit status.
We are finalizing a proposal to L&B for work products we discussed during our meeting. We want to
ensure that we cover all the issues in the first proposal. L&B has a rigorous contract review process
that does not appreciate cost over -runs or contract modifications.
Here are the topics we intend to address in a stormwater permit modification:
1. Alternate stormwater sampling and analysis plan and sampling locations that attempts to
quantify the contributions of L&B process, those of on -site tenants, neighbors, and off -site
stormwater contributions.
2. Report to the NC DEQ stormwater staff that quantifies biocide impacts to Hominy Creek.
3. Request a letter from DEQ concerning status of Wolsley Industries uncovered material
storage. Do they need a permit? Or, should they have specific conditions under L&B's permit?
4. Request - from the Raleigh Central Office - a change in stormwater sampling locations.
5. Present the results of an on -site sampling and analysis campaign that identifies off -site
impacts, equivalent sampling locations, and compliance points that are away from and
distinct from newly purchased properties by Fletcher Partners, Enka Partners, and American
Recycling.
6. An algorithm or calculation methodology to determine the dilution of L&B stormwater
discharges to Hominy Creek.

Do you have any other information needs?
Thanks,
Dan March
Pisgah Environmental Services, LLC
9 Woodvale Avenue
Asheville, NC 28804
pis ah-air ,vt.edu - Email
www.pisgah-air.com - Website
828-768-3335 - Cell
828-255-1092 - Fax
Pisgah Environmental Services, LLC
9 Woodvale Avenue
Asheville, NC 28804
pis ah-airnn vt.edu - Email
Www.piseah-air.com - Website
828-768-3335 - Cell
828-255-1092 - Fax
Pisgah Environmental Services, LLC
9 Woodvale Avenue
Asheville, NC 28804
Pisgah-air(@,vt.edu - Email
Www.oisgah-aircom - Website
828-768-3335 - Cell
828-255-1092 - Fax
9

Riddle, Rick L
From: [e-mail]
Sent: Wednesday, December 06, 2017 5:08 PM
To: Kucken, Darlene; Riddle, Rick L
Cc: [e-mail]; [e-mail]; [e-mail];
[e-mail]
Subject: RE: [External] Hydraulic Spill from American Recycling -- Report
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to
Hello Darlene,
That date and time works fine for us. I think is will be good to have Rick look at this site's complexity.
Dan was able to sample for our second required Storm Water Testing for 2017. He actually additionally sampled at a
manhole access for a baseline ( the site where we would like to move our sampling point to) and one from the West outfall
to Hominy Creek as specified by our current permit and another at East Ditch outfall. He took pictures of the difference
in clarity.... The west outfall is definitely being influenced by the piles of dirt on the Enka Partners — Fletcher Partners
Land as the TSS appears very prevalent. The sample at the manhole was clear... Thus one of the discussion points for our
meeting.
We look forward to it and hopefully we can work out some good sampling points that will meet the state's requirements
as well as be representative of only our contribution to the Stormwater.
Thanks and Best regards,
Steve
Steve Jenkins
HSE Manager North America
D [phone]
M [phone]
F + 1 828 665 3545
EJELOW&
0nar
Prmmss auaigh Wor rani
P.O. Box 1057, Enka, NC 28728
1301 Sand Hill Road, Candler, NC 28715 USA
[phone] lowandbonar.com
From: Kucken, Darlene [mailto:[e-mail]]
Sent: Wednesday, December 06, 2017 9:52 AM
To: Jenkins, Steve<[e-mail]>; Riddle, Rick L <[e-mail]>
Cc: [e-mail]; [e-mail]; Macro, Clive <[e-mail]>; Merritt, Wayne
<[e-mail]>
Subject: RE: [External] Hydraulic Spill from American Recycling-- Report

***WARNING*** This is an external e-mail and is not a part of internal communication. Please use caution when opening
attachments or when following embedded links.
Hi Steve,
Can you meet with us on site on Dec 12 about 1:45?
Darlene Kucken - Darlene. Kucken(ancdenr.gov
North Carolina Dept. of Environmental Quality
Asheville Regional Office
Division of Energy, Mineral, and Land Resources
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
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.
`A Go Green! Print this email only when necessary. Thank you for helping NCDENR be environmentally responsible.
From: steve.jenkinsna lowandbonar.com [maiIto: steve.ienkinsna lowandbonar.coml
Sent: Monday, November 13, 2017 12:55 PM
To: Kucken, Darlene <[e-mail]>
Cc: pis ah-air ,vt.edu; manninglana yahoo.com; clive.macro(a lowandbonaccom; wayne.merritt(@Iowandbonar.com
lowandbonar.com
Subject: RE: [External] Hydraulic Spill from American Recycling -- Report
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to
report.snamAnc.eov.
Hello Darlene,
Thanks for letting us know. Please keep us in the loop when scheduling gets worked out.
Best regards,
Steve
Steve Jenkins
HSE Manager North America
D [phone]
M [phone]
F + 1 828 665 3545
Progress ituouph performance
P.O. Box 1057, Enka, NC 28728
1301 Sand Hill Road, Candler, NC 28715 USA
[phone] lowandbonar.eom

From: Kucken, Darlene [mailto:darlene.kucken n ncdenceovl
Sent: Monday, November 13, 2017 12:46 PM
To: Jenkins, Steve <steve,jenkins e lowandbonar.com>
Cc: pis ah-airna vt.edu; [e-mail]; Macro, Clive <clive.macroQ1owandbonar.com>; Merritt, Wayne
<wayne. merri tt@ l owan dbonar.com>
Subject: RE: [External] Hydraulic Spill from American Recycling -- Report
***WARNING*** This is an external e-mail and is not a part of internal communication. Please use caution when opening
attachments or when following embedded links.
W
1 just got a call from Rick Riddle of our Stormwater staff in Raleigh and he is having to postpone this site visit. He sends
his apologies. He had another site visit scheduled and they canceled. He is trying to make just one trip to Asheville to
save time and money. 1 will get back to you as soon as 1 know the next date, but it will not be this week.
Thank you for your patience.
Darlene Kucken - Darlene. Kucken(t-r�ncdenr.gov
North Carolina Dept. of Environmental Quality
Asheville Regional Office
Division of Energy, Mineral, and Land Resources
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
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.
`3j Go Green! Print this email only when necessary. Thank you for helping NCDENR be environmentally responsible.
From: steve.jenkins(i lowandbonar.com [mailto:steve.jenkinsna Iowandbonar.COmI
Sent: Monday, November 13, 2017 11:35 AM
To: Kucken, Darlene <darlene.kuckenQ�ncdenr.gov>
Cc: pis ae h-air(�)vt.edu; mannin Ig [e-mail]; clive.macrona lowandbonar.com; wayne.merrittna lowandbonaccom
Subject: RE: [External] Hydraulic Spill from American Recycling-- Report
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to
Hello Darlene,
In case it is applicable and we can get to it, attached is a DRAFT agenda or talking points for discussion if you and Rick
wish to do so on Wednesday November 15.
We will be prepared to discuss the listed topics. If you have any other issues to discuss or information requests, please let
me know so that we can be fully prepared for your visit.
We look forward to seeing you both on Wednesday.
Our contractor Pisgah Environmental will be here on Wednesday as well to answer any questions regarding their work on
this project.

Thanks and best regards,
Steve
Steve Jenkins
HSE Manager North America
D [phone]
M [phone]
F + 1 828 665 3545
ELOW&
Bonai
Progress l"h performance
P.O. Box 1057, Enka, NC 28728
1301 Sand Hill Road, Candler, NC 28715 USA
[phone] lowandbonar.com
From: Jenkins, Steve
Sent: Monday, November 13, 2017 9:18 AM
To: 'Kucken, Darlene' <darlene.kucken n ncdenr.gov>
Cc: Daniel March <pis ah-air(a,vt.edu>; Lisa Manning <[e-mail]>; Macro, Clive
<clive.macro@lowandbonar com>; Merritt, Wayne (wavne.merrittct lowandbonar.com)
<wayn e. m err itt@ l owandbon ar.com>
Subject: RE: [External] Hydraulic Spill from American Recycling -- Report
Thank you Darlene,
We look forward to it
Best regards,
Steve
From: Kucken, Darlene [mailto:darlene.kucken@ncdenr gov]
Sent: Monday, November 13, 2017 9:10 AM
To: Jenkins, Steve <[e-mail]>
Subject: RE: [External] Hydraulic Spill from American Recycling -- Report
***WARNING*** This is an external e-mail and is not a part of internal communication. Please use caution when opening
attachments or when following embedded links.
Steve — we should arrive on site about 9:30ish on Wednesday.
Darlene Kucken - Darlene.Kucken(2ncdenr.eov
North Carolina Dept. of Environmental Quality
Asheville Regional Office
Division of Energy, Mineral, and Land Resources
2090 U.S. 70 Highway
Swannanoa, NC 28778

Tel: [phone]
Fax: [phone]
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.
AGo Green! Print this email only when necessary. Thank you for helping NCDENR be environmentally responsible.
From: steve.jenkins(iNowandbonar com[mailto:steve.'[e-mail]
Sent: Friday, November 10, 2017 9:56 AM .
To: Kucken, Darlene <darlene.kuckenQncdenr.gov>
Cc: clive.macro@lowandbonar com; wayne.merritt@lowandbonar com; BClarke@roberts-stevens com;
Mark.olivier(ar,lowandbonar com; [e-mail]; manningla(awahoo.com
Subject: [External] Hydraulic Spill from American Recycling -- Report
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to
Hello Darlene,
Per our phone conversation where 1 yerbally informed you of a spill that occurred at American Recycling which impacted
our East Ditch Storm Water area, attached is the requested Spill Report.
Please note that oil collection booms are still in place and will remain until the all the oil sheen is resolved.
Thank you for your help and consideration.
Best regards,
Steve
Steve Jenkins
HSE Manager North America
D [phone]
M [phone]
F + 1 828 665 3545
LO
Bonar
Prograss Ihrough performance
P.O. Box 1057, Enka, NC 28728
1301 Sand Hill Road, Candler, NC 28715 USA
[phone] lowandbonar.com
This communication may contain confidential, proprietary or legally privileged information. It is intended for the perion(s) to whom it is addressed only. If
you are not an intended recipient, you may not read, use, retransmit, disseminate or take any action in reliance upon it. Please notify the sender by
return e-mail that you have received it in error and immediately delete. the entire communication, including any attachments, from your system. This e-
mail has been sent in the course of the business of a member of the Low & Bonar group. In the context of the monitoring of professional a -mails this e-
mail and any response to it or any other e-mail sent to this address may be read by that company, including in its capacity as an employer.
Members of the Low & Bonar group do not encrypt and cannot ensure the confidentiality or integrity of external e-mail communications and, therefore,
cannot be held responsible for any unauthorized access, disclosure, use or tampering that may occur during transmission. This communication is not
intended to create or modify any obligation, contract offer, contract, acceptance of a contract offer or warranty of members of the Low & Bonar group,
unless that member clearly expresses such an intent. This e-mail does not constitute consent to the use of the sender's contact information for direct
marketing purposes or for transfers of data to third parties.

Low 8 Bonar PLC is a limited liability company registered in Scotland with registered number SC008349. Our registered office is Whitehall House, 33
Yeaman Shore, Dundee DDt 4BJ.

h
a
JA
A
Amtricas
Recycling
w

Georgoulias, Bethany
From:
Wiggs, Linda
Sent:
Monday, June 12, 2017 3:32 PM
To:
[e-mail]
Cc:
Davidson, Landon; Davidson, Alison; Kucken, Darlene; Georgoulias, Bethany; pisgah-
[e-mail]
Subject:
Bonar-Enka site
Hello Steve,
I understand you are now the Environmental Manager for Bonar. I inspected the Enka
site in 2013 when Jeremy Nauert was the Environmental Manager. Dan March was
acting consultant at that time.
The Enka site has come to my attention again, primarily concerning wastewater
questions but also stormwater questions. These questions relate to the complexity of
this site and the conduits of water; stormwater (SW), wastewater (WW), comingled
(SW/WW), waterbodies, etc. At my inspection on September 4, 2013, I was informed
by Mr. March and Bonar personnel that it had been determined all conduits of water
carrying any type of wastewater flowed to the lift station and were discharged to
Metropolitan Sewage District (MSD). The WW permit (NCG500608) rescission request
followed and then was granted based on this information. Furthermore, an ongoing
annual Certification as required by your Stormwater Permit (permit #NCS000179, Part
II, Section A 1. e.) remains in effect.
Please submit to me the final study report that determined the conduits of water at the
Enka facility, including any video recording of those conduits and an up to date map
delineating all conduits of water. Also submit the last two years of sampling data from
the Enka site and most recent signed Certification as required under SW permit
(NCS000179; Sampling - Part II Section B, Certification - Part II, Section A 1. e.). Once
I have received these documents we can arrange an onsite meeting to further discuss.
Thank you,
Environmental Senior Specialist - Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ - Division of Water Resources
828 296 4500 office
828 299 7043 fax
Email: linda.w gs ;ncdenr.gov_
2090 U.S. Hwy 70
Swannanoa, N.0 28778

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Water Resources
Environmental Quality
June 16, 2017
CERTIFIED MAIL # 7016 1370 0001 6571
RETURN RECEIPT REQUESTED
Low and Bonar, Inc.
Steve Jenkins
PO Box 1057
Enka, NC 28728
Subject: Notice of Violation and Intent to
NOV-2017-DV-0148
Incident No.: 201701034
Low and Bonar —1301 Sand Hill Road
Buncombe County, N.C.
Dear Mr. Jenkins,
On June 15, 2017, the Division of Water
correspondence from you regarding wast
facility.
ROY COOPER
Governor
MICHAEL S. REGAN
Secretory
S. JAY ZIMMERMAN
Director
Civil Penalty
ces (DWR) Asheville staff received
discharge to waters of the State from the subject
Chapter 143, Article21 of the North Carolina General Statutes (G.S.) authorizes and directs the
Environmental Management Commission of the Department of Environment & Natural
Resources to protect and preserve the water
Resources has the delegated authority to eni
regulations.
Based on your notification, the following
irces of the State. The Division of Water
adopted water pollution control rules and
were noted:
Violation I. Discharge Without a Valid Permit
G.S. 143-215.1 (a) states that no person shall dol any of the following things or carry out any of
the following activities unless that person has received a permit from the Commission and has
complied with all conditions set forth in the permit:
G.S. 143-215. 1 (a)(1) - Make any outlets into the�waters of the State.
State of North Carolina I Environmental Quality I Water Resources
2090 U.S. Highway 70, Swannanoa, North Carolina 28778

G.S. 143-215:1(a)(2) — Construct or operate any sewer system, treatment works or disposal
system within the State.
G.S. 143-215.1(a)(6) - Cause or permit any waste, directly or indirectly, to be discharged to or in
any manner intermixed with the waters of the State in violation of the water quality standards
applicable to the assigned classifications or in violation of any effluent standards or limitations
established for any point source, unless allowed as a condition of any permit, special order or
other appropriate instrument issued or, entered into by the Commission under the provisions of
this Article.
A Notice of Violation/ Intent to Assess Civil Penalty is being issued for the noted violations of
North Carolina General Statute (G.S.) 143-215.1. Pursuant to G.S. 143-215.6A, a civil penalty
of not more than twenty-five thousand dollars ($25,000.00) may be assessed against any person
who violates or fails to act in accordance with the terms, conditions, or requirements of any
permit issued pursuant to G.S. 143-215.1.
If you wish to provide information regarding the noted violations or discuss overall compliance,
please respond in writing within ten (10) business days after receipt of this Notice. You will then
be notified of any civil penalties that may be assessed regarding the violations. If no response is
received in this Office within the 10-day period, a civil penalty assessment may be
prepared. DWR may pursue enforcement actions for this and any additional or continuing
violations.
If you have any questions conceming the matter, please contact Linda Wiggs of the Asheville
Regional Office at 828-296-4500.
Sincerely,
G. Landon Dav1 on; P.G.
Regional Supervisor Water Quality Regional Operations, DWR
Asheville Regional Office
cc: DWR WQROS Asheville Files
DWR Enforcement Unit — John Hennessy
DEMLR ARO Stan Aiken
G:\WR\WQ\Bmwmbe\Compleints\201701034 Low and BonwWOV(NOl)-2017-1)V-0148.do

Bonar
June 15, 2017
RE: Answers to Questions on Email dated June 12, 2017
HAND DELIVERED TO THE ASHEVILLE REGIONAL OFFICE
Ms. Linda Wiggs, Environmental Senior Specialist
NCDEQ Division of Water Quality
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
Dear Ms. Wiggs:
Thank you for your time in reviewing our stormwater
In your email (attached) you mentioned Low & Bonar's
wastewater. I cannot, nor can the new site manager unc
believe that it was a total misunderstanding of what the
Waste Water Treatment Plant that served this site many
Low & Bonar Inc.
PO Box 1057
Enka, NC 28728
T 828 665 5000
F 828 665 3737
lowandbonar.com
S. JENKINS I JUN `15 2017 '
Regional Operations
rescission of their General NC DEQ permit for industrial
and the circumstances that lead to this decision. I have to
iit was. It could have been it was associated with the old
s ago.
Low & Bonar is not the same company that existed in 2013. There was a complete regime change that occurred in 2014
starting with a new CEO (London) in August 2014. The changes also affected Asheville's on -site personnel. None of the
Bonar personnel that were part of the inspection and request for the Waste Water Permit to be rescinded (Including the
President/Site Manager) are still employed by the company.
To explain how we have come full circle back to the point of interest, The Waste Water Permit, Low & Bonar has
mandated a program entitled "Project Planet" where Business Sustainability and Corporate Responsibility are a must for
all its manufacturing facilities globally. Part of this initiative is ISO 14001. As you may know ISO 14001 goes beyond
compliance and is the catalyst for continual improvement to processes and procedures to reduce pollution and improve
efficiencies.
I received funding for the ISO 14001 initiative in C
conduct an independent analysis/audit of our env
requirements. This process was the gateway to a
conducted a re-evaluation the basis of need, the r
environmental permits.
The Compliance Obligations audit process consumed the
storm water issues, I reached out to Alison Davidson as A
us in contact with the correct personnel to help us resolve
storm water was broken into two entities now. In a previ
Mooresville office.
2016. This enabled me to hire outside consultants to
al compliance obligations to fulfill § 6.1.3 of ISO 14001:2015
de environmental evaluation. Ultimately, we have
;, recordkeeping, and reporting requirements for all of our
•st four months of 2017. As we began realizing that we had
was with NCDEQ DEACS in February. I knew she could place
Sur problems. It is unfortunate that I did not realize that
as job I just dealt with one person, Michael Parker, out of the
go I I 0 j 6-)11 foli - a of l'I -Dv- vl 0$

Upon completion of the Compliance Obligations Audit, we realized we had three areas that needed attention. 1)
stormwater (which with the revelation that waste water discharge was different, we added the third category.) 2)
POTW sewerage wastewater, and 3) surface wastewater areas. Low and Bonar chose to address those deficiencies in
that order. To date, we have completed NC DEQstormwater inspection by Darlene Kucken, and the Metropolitan
Sewerage District (MSD) wastewater permit renewal. We are now reaching out to you to address or readdress our
surface wastewater issues with your office.
The following points address questions in your email.
1. Water Conduits
Low and Bonar conducted four recent studies of wastewater and stormwater sources to determine volumes and
pollutant concentrations. Those studies are described below.
a. ISO 14001-- Compliance Obligations
This clause required us to look at all our activities including effluent management. During this process, Low &
Bonar initial engineering estimates were that 28,848 to 54,781 gallons of wastewater from various processes are
discharged to the East Ditch conveyance to Hominy Creek. Table 1 lists those preliminary estimates of effluent
sources and volumes. This was our first concrete indication that something was amiss from data in our files.
The ISO study revealed that cooling tower blowdowns are co -mingled with stormwater discharges to the East
Ditch, see Figure 1.
b. 1SO 14001— On -site Audit
The extension office of Georgia Tech conducted an ISO 14001 preliminary audit of Low & Bonar in May 2017.
That audit reinforced the water issues and concerns described by our consultant.
C. Metropolitan Sewerage District (MSD) Wastewater Permit Renewal
Low & Bonar completed Its wastewater discharge permit renewal to MSD in May 2017. This renewal provided a
sharper focus on all wastewater effluents by differentiating between wastewater treatment plant effluents and
surface water discharges. The MSD permit renewal estimates wastewater to range from 18,850 to 21,370
gallons per day. Table 2 lists those updated effluent sources and volumes. Note, those values are in part
engineering judgements; they are not data from flow measuring devices.
d. Stormwater inspection
NC.DEQ stormwater staff conducted an inspection in May 2017.
Our evaluations show that Low & Sonar does discharge to Hominy Creek the following:
a. Non -Contact Cooling Waters
b. Atmospheric Cooling Systems Condensates
C. Blowdown Wastewaters
d. Exempt Stormwaters
e. Similar wastewaters
2. Wastewater Piping Video
I do not have any videos of our discharges.

3. Site/Process Map of Wastewater Discharge
Figure 1 is a Site Map of Wastewater Discharge. Sources
collection systems. Figure 1 shows individual sources ai
those wastewater sources and volumes ranging from 2d
facility engineering department has provided estimates
to Hominy Creek. However, these are estimates; they a
would provide. Tables 1, 2, and 3 do provide some cool
some wastewater streams.
4. . Stormwater Sampling/DischargeData
Stormwater Discharge Monitoring Reports for 2015 ai
comingled stormwater and wastewater steams in the
Stormwater effluents limits and with the Stormwater
(COD) and pH.
S. Annual Stormwater Certification Statement
Attached with the Monitoring reports is a certification
Manager during this time. After the full scope regime
presented to me regarding non process discharges. I tl
until I could have a comprehensive evaluation done of
what I had been'told by Bonar personnel ... the ones w
Please contact me to request any other data necessary
your schedule for this inspection.
The ISO 14001 certification process has been very in
that the process does indeed go beyond compliance
procedures to reduce pollution and improve efficien
Low & Bonar Intends to comply with all State and Fec
NPDES wastewater permit is appropriate for our site.
Respectfully Submitted,
441�1 c&
Step en C.1enk , CSP, REM
HSE Manager North America
Attachment A - Stormwater Discharge Monitoring
Attachment B— Lind a Wiggs Email June 12, 2017
This is a recent upgrade of an older figure of stormwater
I provides discharge destinations and volumes. Table 3 lists
368 to 34,581 gallons per day. Table 3 is not complete; our
f most of the wastewater discharges to the East Ditch and then
a not the definitive measurements that flow measuring devices
wity; internally, we continue to discuss the actual disposition of
116 are Included in Attachment A. These reports show that
Ditch conveyance to Hominy Creek comply with all
it (NCS000179) effluent limits for Chemical Oxygen Demand
nt table ... Bart Austin was the President and Site
I was uncertain to the validity of what had been
efore elected to not certify the discharges after August 6, 2014
storm water situation. My first year here, I took at face value
ask you for the recession.
your site inspection. We are ready to accommodate
tive and illuminating for Low & Bonar staff. We have found
Is the catalyst for continual improvement to processes and
I discharge limitations. Ultimately, we believe that an Individual
for 2015 and 2016

Figiue,l., I:ow and Bay —Wastewater Sduroes

ATTACHMENT A
Low & Bonar Annual Stormwater Reports and
Non-Stormwater As Certifications

Bonar
partners in Performance
September 4, 2015
RE: Permit Number NCS000179
CERTIFIED MAIURETURN RECEIPT
N.C. Division of Water Quality
Attn: DWQ Central Files
1617 Mail Service Center
Raleigh, NC 27699-1617
Dear Sir or Madam:
Tel.: [phone]oo
Tel.: [phone]
Fax: 828-665-SW9
Info-usa®bonor.conn
Enclosed are the results of our 1st hatf 2015 Storm Water Discharge Outfall Monitoring
Report. All outfalls are within the benchmark values. We will conduct our 2"d testing
during late October or early November.
Please note the delay in getting this to you is due to us wanting to meet the new permit
and It's requirements that is due to be sent to us. In checking the Permit Tracking
Software we see that it was received and entered into your data base during April of
2014. While we are still waiting on our permit renewal to be processed, we will
continue under the 2009 parameters unless we hear otherwise from you or we receive
the new permit.
Respectfully Submitted,
Stephen C. Je Vins,4CSP, REM
QHSE Manager
Enclosures (2)
cc: Wayne Merritt, Director of Operations — NAFTA, Bonar
Bonar Inc.: 1301 Sand WTI Road • P.O. Box 1057 • Enka, NC 28728 • USA
w .bonorcom

Permit Number NCS 01-71
FACILITY NAME
CERTIFIED LABORATORY(S)
Part A. Specific Monitoring Requirements
-..STORMWATER DISCHARGE OUTFALL (sDO)
MONITORING REPORT
SAMPLES COLLECTED DURING CALENDAR ENDAR yEARv 01 O l s .
(This monitoring report shag be received by the Division no later than 30 days from
the date the facility receives the sampling results from the laboratory.)
COUNTY X7 tAwCOM(iE
i+6K 45 PHONE NO,f8. 6bR'-So00
q e� —
SIGNATURE OF PERMITTEE OR DESIGNEE 1
REQUIRED ON PAGE 2 '
•
I.ZTl���l�^iill�t�3C�!���r
Does this facility perform Vehicle Mamtenenoe Activities using more than 55 gallons of new motor oil per month? _ yes Xm
(if yes, complete Part B)
......o..,..u..caaace
Outfali
No.
ncwv11Ymonnotsn
Data
$ample
Collected
50050 ..
tntements
-
-
00596
,.:
OOSaB
004M
Totall7ovv
(if applicable)
Total
Rain aB ' .
Ofi &Grease,'
(ifappL) ::
..,
Non polar .::::
O&G/M.:.:
(Method 1664'
SGT-)iEM), it
appl.
Tow. ..
§uip4hded ..
_
�OBda..
P
;..
New Motor
OAUsage
molddlyr
MG-
inches
TMEOunit
o
Form SWU-247, lost revised 2WO12
Page 1 of 2

STORM EVENT CE ARACI'ERISTTCS:
Date // /
Total Event Precipitation (inches):
EventI/ureffoa(hoats): (only if applicable — see pe:mit.)
(if more than one storm event was sampled)
Date
Total Event Precipitation (Inches):
Event Duration (hoara): (only if applicable — sapermit.)
Mail Original and one copy to:
Division of Water Quality
Arta: Central Files _
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
"I certify, under penalty of law, that this document and all attachments were prepared under
system designed to assure that m9 direction or and on my in accordance with n gaati5ed petaoand prepeAy 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 betiey true, accurate, and complete. I am aware that there arc significant penalties for submitting false Information,
Including the possibility of fines and im"ament for knowing violation&,,
4tu4rc o ermittee) 71—
S� lS`
Form SWU-247, last revised ZZ2012
Page 2 of 2

Bonar
partners in performance
December 7, 2015
RE: Permit Number NCS000179
CERTIFIED MAIURETURN RECEIPT
N.C. Division of Water Quality
Attn: DWQ Central Files
1617 Mail Service Center
Raleigh, NC 27699-1617
Dear Sir or Madam:
Enclosed are the results of our 2nd half 21
Report. All outfalls are within the bench
Tel.: [phone]
Tel.: [phone]
Fox: 828-665-5009
info-usa®bonarcom
15 Storm Water Discharge Outfall Monitoring
lark values.
Please note we are still operating under our November 1, 2009 - October 31, 2014
permit parameters while we await our renewal permit.
In checking the Permit Tracking Software
your data base during April of 2014 and it
waiting on our permit renewal to be proce
Parameters unless we hear otherwise fror
Respectfully Submitted,
Stephn CJ in , CSP, REM
QHSE Mana er
Enclosures (2)
cc: Wayne Merritt, Director of
Sonar Inc.: 1301 Sand HIII Road • P.O. Box 1067 • Enka, NC 28728
w .bonar.com
fe see that It was received and entered into
lications are it is in review. While we are still
aed, we will continue under the 2009
you or we receive the new permit.
- NAFTA, Boner

STORMWATER DISCHARGE OUTFALL (SDO)
MONITORING REPORT
Permit Number NCS-0O 0 / 7 q
FACKM NAME
PERSON COLLECT INU SAMPLF,(S)
CERTIFIED L WRATORY(S) Lab
Ieb#
Part A. Specific Monitoring Requirements
SAMPLES COLLECTED DURING CALENDAR YEAR ,20�6
(iMis monitoring report shall be received by the Division no later than 30 days from
the date the fiddly, receives the sampling results &am the laboratory.)
COUNTY�Un/CD i F,s
PHONE NO.
SIGNATURE OF PERMTITEE OR DESIGNEE
REOUM" ON PAGE 2.
Wl
Does dus &c lily perform Vehicle Maintenance Activities ushig more than 55 gallons of au motor oil per month? _ yes iio
Of yes. convIcte Plot B)
Part R. Vehicle Maintenance AetivltV Monitoring R•aniM .ngre
Ov1Lll
No.
Date
Sample
Colloeted
50050.
OOM6
00.430
00400
Tom, Flow
(if app9eable)
Total
ROOM
on & Grease
Of sppl)
Non -polar
O&G(IpH
(Metbod'1664 .
SGT-HEM if
anal.
Total
SmOemkd
Solkls
pH
New Motor
Orl Usage
mold
MG
inches
mZ4
mz4
Will
Umo
Form SWIJ-247, last revised2lZi2012
Page I of 2

STORM EVENT CHARACTERISTICS:
Date
total vent Precgritation Cinches): 3, b
Event Duration (hours): (only if applicable — see permit.)
(if more than one storm event was sampled)
Date
Total Event Precipitation (inches):
Event Duration (hours): (only if applicable — see permit.)
Mail Original and one copy to:
Division of water Quality
Attn: Central Files
1617 Mail Service Cuter
Raleigh, North Carolina 27699-1617
"I cerft 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 property gather and evaluate the information submitted. Based on my inquiry of the person
or persons who manage the system, or those parsons directly responsible for gathering the information, the information submitted $ to the
best of my.lmowledge and.belief, tray, accurate, and complete. -I am aware that then are significant penalties forsubmittiug false information,
including the possibility of lines and imprjionment for imgwtng violations"
S
(Date)
Form SWU-247, tact revised 2WO12
Page 2 of 2

Tel.' 8.28-665-5000
Tel,: 800-365-7391
Fax: [phone]
infu .1 Jsuj'bollurcon. I
April 21, 20113
RE! Permit Number NCS0001 79
CERTIFIED MAILIRETURN RECEIPT
N.C. Division of Water Quality
Attn-. DWQ Central Files
1617 Mail Service.Center
Raleigh,. NC' 27699-16.17
Deair:Sir or Madam:
triciosed are the results .of our 1 st half201 6 Storm Water Discharge Outfall Monitoring
Report. All outfallsare within the bi§hbhtharkValUes:
.Please note we are still operating under our November 1, 2009 � Octclbiar 31, 2614
permit :parameters; while we -await our renewal,peftnit.
.In checking the Permit Tracking Software we see that it was received and entered into
your data base.cluding Apri[of 2014and indications-ar6 it is in review. While: we are:still
waiting, on:our permit, renewal to be processed, we, will. conflnue under the. 2009.
parameters unless we hear otherwise from you,orwe receive the new perrhit.
Respectfully Submitted,
Stephen C. Jl�� /ins.,.CSP, REM
QHSE Manager
Enclosures (2)
cc: Wayne Merritt, Director of Operations 113.61hpir. Inc.
Marc Anton, Group HS.E Director — Low & Bonar, London
Bonar life:: 1301 Sand Hill, Road - P. - 0. Box 1057 - Enka. NC 28728,-'USA
wwW.bdndrconn

Permit Number NCS-D 0 6 t -L9 -
FACELITY NAME
'Tart A: Specific Monitoring Requirements
STORKWATER DISCHARGE OUTFALL (SDO)
MONITORING REPORT
SAMPLES COLLECTED DURING CALENDAR YEAR:- A 0 1
(This monitoring report sball be received by the Division no later than 30 days from
the date the facility receives the samp)ing results from the laboratory.)
COUNTY '[3 tw a 21—n 13 U . .
3RITU25-- PHONENO.(BaR) (0(-6---6-060
4 A10
=SIGNATURE OF PERMITTEE OR DESIGNEE
C I
MO�U=MED ON PAGE 2.
"W1
-11,4L
�.c . .... -A
Does this facility perform Vehicle Maintenance Activities using mom than 55 gallons ofneiv cuotDr oWper nwnth? —Yw no
&yes, wnVlete Part B)
Tart is: venicle
mamwasnce wcuvny
MIUM.
OMO•. +'
00400�-f
-�
Total Flak r
NO
.. .. .....
.
;N, F�
Siiiioi
an U
In
n
:Form SWU-24111 last revised 21212012
.Page I of 2

STORM EVENT CHARACTERISTICS:
Date Ik
TotalEEv`en`t recipitationCtuches):.
.EveutMratiou (hours): sce permit (only if aivii6able rmit)
(if nmre than one storm eves was sampled)
Date
Total Event Precipitation -
Event Durstfon(hours): Precipitation-
I _ (onlyif applicable — se.e permiL)
that
Mail Original and one copy to;
Division of Water Quality
Ann: Central'Files
1617 MWIService Cmter
Rakikh,'North Carolina 27699-1617
tua, or those persons directly responsible for gathering the information, the information s'ubm^ ktad is, --to the-:---
, true, --accurate, and complete. I am swam that them are significant penalties for submitting false information,
and imprisonment f6r,kno*.ing vlolatious.!'
-Form SWU-247, Tart mW . sed 21212012
Pagel of,2

Low&
Low BBm
PO Box 105757
Boner
Enka,NC 26726
T 828 665 5000
F 828 665 3737
lowandbonuxom
December 29, 2016
RE: Permit Number NCS000179
CERTIFIED MAIURETURN RECEIPT
N.C. Division of Water Quality
Attn: DWQ Central Files
1617 Mail Service Center
Raleigh, NC 27699-1617
Dear Sir or Madam:
Due to the extensive extreme drought period for our region, we are delaying our 2nd
half of 2016 sampling schedule until the 1st quarter of 2017, when hopefully we will
have a more favorable weather pattern. Also note, that when precipitation patterns
occurred during this period which produced enough rain to sample, our staff members
who are responsible for sample collection could not be on site to collect them. Our plan
is to obtain 3 samplings for the 2017 year, one for the makeup and two for normal
permit requirements.
Please note we are still operating under our November 1, 2009 — October 31, 2014
permit parameters while we await our renewal permit.
In checking the Permit Tracking Software we see that it was received and entered into
your data base during April of 2014 and indications are it is In review. While we are still
waiting on our permit renewal to be processed, we will continue under the 2009
parameters unless we hear otherwise from you or we receive the new permit.
Respectfully Submitted,
-S4 �. y
Stephen C. Je , CSP, REM
HSE Manager
cc: Wayne Merritt, Manufacturing'/ Site Manager — Low & Boner Inc.
Clive Macro, Group HSE Director — Low & Boner PLC, London

Low&
Low It Sonar Inc.
PO Box 1057
BonarEnka,
NG28728
T828.665,5000
F 828 665'3737
lowandbonar.com
April 18, 20117
RE: Permit Number NCS000179
CEIRTIFIEUMAIURETURN RECEIPT
N.C;,, Division of WaterQuality
Attn: DWQ:Central Files
1617'Mall Service Center
Raleigh, .NC 27609-161.1
Dear Sir or Madarn:
Enclosed arethe, results of our:2nd half 2016: Storm Water Discharge Outfall Monitoring
Report. All ouffalls are within the benchmark: values.
Due to the extensive extreme drought period for our region, we delaVad our 2nd half
2016 sampling UntiI.Ap(M 3, 2017.1 1 I
Our plan for 2011 forwa,rd i.s;afferappropriate dwell time between sampling events, at
least 60.days, we will obtain 2 more samplings for our normal, permit requirements.
Please ,note we are still'operating under our November 1, 2009 October 31, 2014
permit. parameters, While we await our renewal permit.
In checking the Permit Tracking Software we see that itwas received and.entered into
,Your date base during April of 2014 and'indications are �it i inreview. Whil
e Have are still
wafting on our to be prooessedi we will continue under the 2009
parameters- unless we.hear otherwise from you of we receive. the new permit.
Respectfully Submitted,
—�ve'7' C. oar-"�
Stephen C: Jenkins,: CSP, REM,
HSE Manager
.cc: Wayne Merritt, M anufacturing /IS!te Manager — Low4 Bonar Inc.
Clive. Macro,j Group.HSE Director— Low & Bonar PLC, London

STORMWATER DISCPIARGE OUTFALL(SDO)
MONITORING REPORT
Permit Number NCS000179 SAMPLES;COLLECTEDDURING CALENDAR YEAR:;2417--Aao I
(This monitoring report sball.be received by the Division no;later theo30.days: from
& date.the f icflityrmeives:the:sampQng resoles from the laboratory:)'
FACILITY NAME 4,o + 8owa✓ Ylt4-- . COUNTY;
PERSON COLLECTIIVG SAMPLE.. : <, c i ,. rer „1 PHONE NO, (Q aR ).
CERTIFIED'LABORATORY(S)_Acir ,ivrpon wry _Lab#_ yb
Lab.#
SIGNATURE OF PERMITTEE`OR DESIGNEE
Part A: Specific Monitoring Requirements REQUIRED ON PAGE 2.
Does this facility Perform Vehicle Mainknauce Activides.using more than 55 `gallons Of new motor oil per: monib7 yes yy
(if Yes, �mpiete:Part H); _
Part li: Vehicle Maintenance AcdvHy Monitoring Reaniremente.
OutfeQ'
Dater
SODSO '°
s. i
00530
00400
No
Sampk t�i=`
TotalFlowY
,
Total
OQ&Grease
Non polar
TotalF '-
NewMotoi '
rsM
Collected
(tfappQeabk
Rawtall �y�
Cifappl)
O&GfTPH1'P:
Sns-Jdd r
r
'w
pQIIsagE
(Me" IVOa
b
),
SGT HEMapp
mo/d
MG
inches �,_:3_
ti�ar
a
,• Py..r--_.nntt
Form SWU-247, last revised 21212012
Page I of2

STORM EVENT CHARAcrERimcs:
Date 4XZ6W,,?17
Total Event Precipitation (in - chn): 1. 6'9-
EventDaration (hours): (only if apolicable — see permiL)
(if more then one storm event was sampled)
Date -
Total Event Precipiterflon(!rich")..
Event Duration (hours): _ (only if appljcjble — see:permit
.'I
or
I am aware
Alaff Original and one copy to:
Division of Water QiWity
Attn: Central Files
1617 MailService Center
Raleigh; North Carolina , 27699461T
orsupervision
.. 11ased on my
there are significant penalties for sabwittiig false
116 — d-O Iq
(Date)
a
Form SWU-247, last revised 2)WO12
PageXof2

®OR
Stormwater Discharge Outfall (SDO)
Qualitative Monitoring Report
Porguldanceon/ill6{gout thisform,please visit: hU:Itportal.ncdenr.oretweh&J npdes-stormwater/
Permit No.: ! 1Vjf1! /P 12/_f -7
Facility Name: A &MAR -7"WC-
County:
Inspect
Date of
Time of
or Certificate of Coverage No.:
Total Event Precipitation (inches): G / 6 "
Was this a "Representative Storm Event' or "Measureable Storm Event" as defined by the permit?
(See Information below.)
E Yes ❑ No
Please verify whether qualitative Monitoring must be performed during a "representative storm
eveneor "measureab/estorm evento (requirements vary, depending on the permit).
Qualitative monitoring requirements vary. Most permits require qualitative monitoring to be
performed during a "representative storm event" or during a "measureable storm event." However,
some permits do not have this requirement Please refer to these definitions, if applicable.
A "representative storm event" is a storm event that measures greater than 0.1 inches of rainfall
and that is preceded by at least 72 hours (3 days) in which no storm event measuring greater than
i 0.1 Inches has occurred. A single storm event may contain up to 10 consecutive hours of no
precipitation.
I A "measurable storm event" is a storm event that results in an actual discharge from the j
permitted site outfatl. The previous measurable storm event must have been at least 72 hours
prior. The 72-hour storm interval does not apply if the permittee is able to document that a shorter I
Interval is representative for local storm events during the sampling period, and the permittee
obtains approval from the local DWQ Regional Office.
By this slgnatures j certify that this report Is accurate and complete to the best of my knowledge:
Page 1 of 2
SWU•242,Laetmoafled 10/25/2012

L Outfall Description:
Outfall No. S il D - I Structure �,a:a.0
(p e, ditch, etc.)
Receiving Stream:
De cribe the indu al activitles4itat occur within the alitiall drai age area:
2. Color. Describe the color of the discharge using basic colors (red, brown, blue, etcj and tint
(light, medium, dark) as descriptors: r?,
3. Odor. Describe any di,s tinct odors that the discharge may have (i.e., smells strongly of oil,
weak chlorine odor, etc.):
4. Clarity: Choose the number which best describes the clarity of the discharge, where i is
clear and 51s very cloudy:
10 2 3 4 5
S. Floating Solids: Choose the number which best describes the amount of floating solids in
the stormwater discharge, where 1 is no solids and 5 is the surface covered with floating solids:
1 2 3 4 5
6. Suspended Solids: Choose the number which best describes the amount of suspended
solids in the stormwater discharge, where 1 is no solids and 5 is extremely muddy:
`n
10 2 3 4 5
7. Is there any foam in the stormwater discharge? Yes No
a Is there an oil sheen In the stormwater discharge? Yes No D
9. Is there evidence of erosion or deposition at the outfall? Yes tjvo
10. Other Obvious Indicators of Stormwater P011utio :
List and de scribe V, be _f) Gl i,11 GJ, G_A�:
Note: Low clarity, high solids, and/or the presence of foam, off sheen, or erosion/deposidon
may be indicative of pollutant exposure. These conditions warrant further investigation.
Page 2 of 2
SWU-242.I.astmodifled 10/25/2012

Dffik
Stormwater Discharge Outfall (SDO)
Qualitative Monitoring Report
Forguidanceonjlllingout thisfonn,please visit bM;//portatncdenrore/web/irlandec-stormwater/
Permit No.: h1/i;6/Q/0 /o%L/ 7/�/ or Certificate of Coverage No.:
Facility Name:
County: Phone No.
Inspector. —
Date oflnspectianG
Time of Inspection:
Total Event Precipitation (inches): 0, le, I
Was this a "Representative Storm Event" or "Measureabie Storm Event" as defined by the permit?
(See info ation below.)
Yes ❑ No
Please verf& whether Qualitative Monitoring must be performed during a 'representative storm
event"or "measureable storm event' (requirements vary, depending on the permit).
Qualitative monitoring requirements vary. Most permits require qualitative monitoring to be —
performed during a "representative storm event or during a "measureable storm event" However,
some permits do not have this requirement Please refer to these definitions, if applicable.
A "representative storm event" is a storm event that measures greater than 0.1 inches of rainfall
I and that is preceded by at least 72 hours (3 days) In which no storm event measuring greater than
0.1 inches has occurred. A single storm event may contain up to 10 consecutive hours of no
precipitation.
A "measurable storm event" is a storm event that results in an actual discharge from the
1 permitted site outfall. The previous measurable storm event must have been at least 72 hours
prior. The 72-hour storm interval does not apply if the permittee is able to documentthat a shorter
interval is representative for local storm events during the sampling period, and the permittee
L. obtains approval from the local DWQ Regional Office. 1
By this sig�ecertify that this report i;Gccurate and Complete to the best of my knowledge:
or
Pagel of2
SWU-242, Lestmodifled 10125/2012

1. Oatfall Description:
Outfall No. Structure (pipe, ditch, exc
Receiving Stream: �.i. iTr�i Y1S
Des
,Obe the industryactivities that occur within the
2. Color: Describe the color of the dlsclqirge using basic colors (red, brown, blue, etc.) and tint
(light, medium, dark) as descriptors: /1 Aetw.
3. Odor. Describe any distlpct odors that the discharge may have (i.e., smells strongly of oil,
weak chlorine odor, etc.): iEht
4, Clarity: Choose the number which best describes the clarity of the discharge, where 1 is
clear and 5 is very cloudy
2 3 4 5
S. Floating Solids: Choose the number which best describes the amount of floating solids in
the stormwater discharge, where 1�is no solids and 5 is the surface covered with floating solids:
( 1/ 2 3 4 5
6. Suspended Solids: Choose the number which best describes the amount of suspended
solids in the stormwater discharge, where 1 is no solids and 5 is extremely muddy:
�1 2 3 4 5
7. Is there any foam in the stormwater discharge? Yes
8. Is there an oil sheen in the stormwater discharge? Yes
9. Is there evidence of erosion or deposition at the outfall?
10. Other Obvious Indicators of Stormwater Pollution:
List and describe /��i�/ /� �-
No
No
No
Yes
Note: Low clarity, high solids, and/or the presence of foam, oil sheen, or erosion/deposition
may be indicative of pollutant exposure. These conditions warrant further investigation.
Page 2 of 2
SWU•24Z Lest modified 10/25/2012

NC®E R
Stormwater Discharge Outfall (SDO)
Qualitative Monitoring Report
Forguldance on filling out thlsform, please vW&
Permit No.: 1UC�1?/1/7_/5/ or Certificate of Coverage No--
PacilftyName: r Z"ivd•
County: 'aun1NDmN Phone No. 13A8-GGi-!5Z1dD
inspector. SrFia/hral Ti;nZjr--5
Date of Inspection: A QI/Fr7�Qr`�9� /g a -0/
Time of Inspection: -,At) - f Sa D - 1
Total Event Precipitation (inches): it y r
Was this a "Representative Storm Event or "Measureable Storm Event as defined by the permit?
(See Information below.)
[R/Yes ❑ No
Please verify whether Qualitative Monitoring must be performed during a "representative storm
event" or "measureable storm event" (requirements vary, depending on the permit).
Qualitative monitoring requirements vary. Most permits require qualitative monitoring to be
performed during a "representative storm event or during a "measureable storm event' However,
I some permits do not have this requirement Please refer to these definitions, if applicable.
A "representative storm event" is a storm event that measures greater than 0.1 inches of rainfall
and that is preceded by at least 72 hours (3 days) in which no storm event measuring greater than
0.1 inches has occurred. A single storm event may contain up to 10 consecutive hours of no
precipitation.
A "measurable storm event" is a storm event that results in an actual discharge from the
permitted site outfall. The previous measurable storm event must have been at least 72 hours j
prior. The 72-hour storm interval does not apply if the permittee Is able to document that a shorter
interval is representative for local storm events during the sampling period, and the permittee
obtains approval from the local DWQ Regional Office.
By this signature, I certify that this report is accurate and complete to the best of my knowledge:
Page 1 of
SWU-242, Las[ modi0ed 10/25/2012

L Outfali Description:
Outfafl No. --Q h - 1 .
Receiving Stream:
2. Color. Describe the color of the discharge using basic colors red, brown, blue, etc.) and tint
(light medium, dark) as descriptors: j4{14
3. Odor: Describe any disti ict odors that the discharge may have (i.e., smells strongly of oil,
weak chlorine odor, etc.):
4. Clarity: Choose the number which best describes the clarity of the discharge, where 1 is
clear and 5 is very cloudy.
10 3 4 5
S. Floating Solids: Choose the number which best describes the amount of floating solids in
the stormwater discharge, where 1 is no solids and 5 is the surface covered with floating solids:
G) 2 3 4 5
6. Suspended Solids: Choose the number which best describes the amount of suspended
solids in the stormwater discharge, where 1 is no solids and 5 is extremely muddy:
1 Z 3 4 5
7. Is there any foam in the stormwater discharge? Yes
& Is there an oil sheen in the stormwater discharge? Yes
9. Is there evidence of erosion or deposition at the outfall?
10. Other Obvious Indicators of Stormwater Pollution:
Note: Low clarity, high solids, and/or the presence of foam, on sheen, or erosion/deposition
may be indicative of pollutant exposure. These conditions warrant further investigation.
Page 2 of
SWIY24ZWtmod11W 20/25/2012

9DENR
Stormwater Discharge Outfall (SDO)
Qualitative Monitoring Report
Forguldonce on filling out thisform, please visit: 1tW://oortal.ncdrnr ora/mb/Jrfnpdeo-eormwater/
Permit No.:
Facility Name: _V10
County. C36. _
Inspector.
Date of Inspection:
Time of Inspection: 09 i y —
or Certificate of Coverage No.: 1 1f1fi/_/—J_/,_/_/_/
Phone No.
Total Event Precipitation (inches): 4 b
Was this a °Representative Storm Event or "Measureable Storm Event" as defined by the permit?
(See information below.)
(t�i"Yes ❑ No
Please verily whether Qualitative Monitoring must be performed during a "representative storm
event* or "measureable storm event" (requirements vary, depending on the permit).
Qualitative monitoring requirements vary. Most permits require qualitative monitoring to be
performed during a `representative storm event or during a "measureable storm event' However,
I some permits do not have this requirement Please refer to these definitions, if applicable.
A `representative storm event is a storm event that measures greater than 0.1 inches of rainfall
and that is preceded by at least 72 hours (3 days) in which no storm event measuring greater than
0.1 inches has occurred. A single storm event may contain up to 10 consecutive hours of no
precipitation.
`A "measurable storm event is a storm event that results in an actual discharge from the !
1 permitted site outfall. The previous measurable storm event must have been at least 72 hours i
prior. The 72-hour storm interval does not apply if the permittee is able to document that a shorter '
interval is representative for local storm events during the sampling period, and the permittee
obtains approval from the local DWQ Regional Office.
By this signature, I certify that this re5nrt is jccurate and complete to the best of my knowledge:
(Signature o"ermittee or
Page 1 of 2
SWU-242,Lastmodi0ed 10/2S12012

L Outfall Descril
Outfall No. 600_�-
Receiving Stream:
Describe the industrial
cture (pipe, ditch, etc) "'`>
may_ t (1 / EIY
that occur within the outfall drainage area
2. Color: Describe the color of the discharge usin basic colors (red, brown, blue, etc.) and tint
(light, medium, dark) as descriptors: 0T„n-
3. Odor. Describe any dispnct odors that the discharge may have (Le., smells strongly of oil,
weak chlorine odor, etc): A 5096
4. Clarity: Choose the number which best describes the clarity of the discharge, where 1 is
clear and 5 is very cloudy: /'�
1 2 03 4 5
S. Floating Solids: Choose the number which best describes the amount of floating solids in
the stormwater discharge, where 1 is no solids an45 is the surface covered with floating solids:
01 3 4 5
6. Suspended Solids: Choose the number which best describes the amount of suspended
solids in the stormwater discharge, where 1 is no solids and 5 is extremely muddy:
1 `0 3 4 5
7. Is there any foam In the stormwater discharge? Yes
& Is there an all sheen in the stormwater discharge? Yes No
9. Is there evidence of erosion or deposition at the outfall? Yes 10
10. Other Obvious Indicators of Stormwater Pollution:
List and describe
Note: Low clarity, high solids, and/or the presence of foam, oil sheen, or erosion/deposition
may be Indicative of pollutant exposure. These conditions warrant huther Investigation.
Page 2 of 2
SWU•242, I.Mmodiaed 20/2S/2012

WWA
AmIk;AV
A�-
NCURR
Storlinwater Discharge Outfall (00)
Qualitative Monitoring Report
Forguldance onfilling out thishrm please vigt-* /web Ar/npdcs-stomwater/
.Permit,No.: or Certificate of Coverage No.: ,
County- Phone.No. 75.21
Inspector: 14-5
Date of Inspection: 3 / / / .�-
Time of Inspection: 4—.- J, ?,
Total Event Precipitation (inches): 4�s
Was this a "Representative Storm Event" or "MeasureableStorm Event" as defined bythe Permit?
(See Information below.)
C2..; Yes D No
Please verify whether Qualitative Monitoringmuls,t be perforn!ed during a "representative storm
eVeWor "rheasureable storm event" (requirements vary, depending on thepermit).
Qual ' itative.monitoring requirements Vary. Most permits require,qualitative monitoring to
performed during a "representative storm. event" or during a 'rneasureable storm event" However,,!,
some Permits do not have this requirement Please refer to these definitions; if applicable.
A"repTeseqtRtIve storm event" is storm event that measures greater than'.0.1 inches of rainfall
dithat is preceded by at least 72 hours 1 (3 days) In which no storm event measuring greater than
0.1 inches hass occurred. A single storm: event may contaimup to AO consecutive hours of no
precipitation.
A'measurable storm 6,venr is a storm.event that resultsinan actual discharge from the
permitted site outfall. The previous measurable:stohtevent must have been at least 72 hours
prior. The 721-hour,,storm interval does not apply if the permitteels able todocurnent that a Aorter
mtervalis representative for local storm events during the sampling period, and the,permittee
obtains approval from tthe local DWQ Regional Office.
By this signature, I certify that this, report's accurate and, complete to the ,best of my. knowled,ge:
/9
(Signature
Pike I- of 2
5WU-Z4Z;LUtmodS0ed 10/25/2012,

L Outfall Description;
2. Colon Describe the color of the discharge using basic colors (red, brown, blue, etc.) and tint
(jight,;medium, dark) as,descriptors; 1?
3. Odor'. Describe any distinct odors that the discharge,may have (i.e., smellsstrongly of ofl,
weak chlorine odor, etc.): A;) i fjil-
4s Clarity:s Iffhoosethemumber. Which best describes the clarity of the.discharge, Where f4s:
clear ands is very'doudr.
2 3 4 5
S. Floating Solids: Choose the number which best describes the amount of floating solids in
the;stormwater discharge, where 1. is no solids and 5 is the surface covered with floating solids:
2 3 4 S
6. Suspended'Solids: Choosethe number which best describes theawount of suspended.
solids in the stormwater discharge, where I is no solids and 5 is extremely muddy:
2 3 4 5
7. Isthere any foamln the stormwater discharge? Yes No
a Is there anloll sheen inthe stormwater discharge? 'Yes
9. Is there evidence oferosion or deposition at the outfalP Yes
`No
10. Other Obvious Indicators of Stormwater. poftudon:.
Note: Low clarity, high solids, and/or the presence of foam
oil sheen, or erosion/deposition
nisybe hadicative.ofpollutintexposure. These conditions warrantfurierinvestigation
Page 2 of 2
M-2142, Last Modifled 10/25/2012

6ItAR
Stormwater Discharge,Outfall (SDO)
Qualitative Monitoring Report
Forguidanceonfllfingout thisform.please visit I�tn•//nortalnedenr:arg/web/ir/nndecctnrmwater/
Permit or Certificate of Coverage No.: N/f/S,/JJ_IJ—IJ
County:; *,' xd i.nRL" P. no. c"-LA rLa c'�::..
Inspector: S T� ��YV. /�/Vk ! /V
Date of inspectiow.
Time of Inspection.:' / r
Total Event Precipitation finchesl:
Was this`a "Representative Storm Event" or'"Measureable Storm Event" as defined by the permit?
(See information below.).
O'J
Yes ❑ No
Please verify whether Qualitative Monitoring must be performed' during a "representative storm.
event" or'measureable storm:event" (requirements vary,;dependinq on the permit).
Qualitativemonitoring requirements vary: Most permits requirequalitative monitoring to be
performed during "representative storm event" or during a `measureable storm event." :However,.
' somep6inits do not have this requirement. Please refer to these definitions,'. if applicable.
A "representative storm evem";is a storm eventthat measures greater than 0.1 inches of rainfall
and that Is preceded'by at leasv72 hours (3:days) in which no storm event measuring':greater than
0.1 inches has occurred. A single,storm event may:contain up to;10 consecutive'hours of no.
precipitation.
A "measorabW storm event" is a storm event that results in an actual: discharge from the
permitted site outfalL The previous measurable storm event must have been at least 72 :Flours
prior., The 72-hour storm interval does not apply if the permftteeis able to document that ashorter
intervai.fs representative for local storm events during;* sampling period, and the permtttee
I[.obtains•approval from the local DWQRegtonalOfflce,
"%
L,
sw_o-z42. Unmodified 10/25/z012
accurate and complete to the best of My. :knowledge:
Page 1 of 2

1. Outfallbescrloon:
OutfidlNo. ',<012 2, Structure ditch, etc.): /2-41
Receiving Stream: i '1L'edM'2M;4
drainage area-,
2. Color: Describe the, c0lorofthediscl iarge using basic colors (red, brown, blue, etc.) and tint
(light, imdium, darkj as descriptors: L; Zclpli
3. War: Describe a
Weak chlorine odor, etc.):
hilVefte., smells strongly of oil;.
4. Clarity: Choose the,number which best describes the clarity,ofthe:discharge, where I is.
clear and'S is very doudy-
_ l) 2 3 4 S
S. Floating Solids: Choose the number which best describes the amount of floating solldsin
the stonnwater discharge, whereAls no solids and 5 Is the surface covered wlth,hloadng solids:
1 i 2 3 4 5
6. Suspended Solids: Choose the number which1est describes the amount of suspended
solids in the stom-water discharge, where 1 is no solids and.S is extreme . lymuddy.
2 3 4 5
7. It there any foam in the stormwater discharge? Yes wo
9. Is there an oll.,sheen in the stormwater'discharge? Yes .No.J
9. Is there evidence of erosion or deposition at the outiall? Yes N. o
10. -other Obvious Indicators of Stormw2ter Pollution:
list and :describe
Note: Low clarity, high solids, and/or,the presence of foam; off sheen, or erosion/deposition
may be Indicative of pollutant oxppsure.. These conditions
itions warrant further Investigation.
Page 2 of 2
SWU-M, lAltmoMed.10/25/2012

#D-AW,
Stormwater Discharge Outfall (SDO)
Qualitative Monitoring Report
ForguldanceonJillingout thisform,please visit- httn:llportal.ncdenr.org/web/Ir/iipdes�stormwatbtl
Permit No.: ,or Certificate of Coverage No.: Wst/_/_/J—J�—/
FachityName: "60 *80 MA tree
i -
County: f3 PwO-oOl &Y Phone No.
Time of Inspection:
Total Event Precipitation (inches):
Was this a ".Representative Storm Evenr".or "Measure.able Storm Bvent"'as defined by the permit?
(See information below.)
2"Yes ❑ :No
Please verify whether Qualitative Monitoring. must be performed during o 'representative storm
event" or "measureablestorm event"(requirements vary;,depending,on the permit).
Qualitative monitoring requirements vary. Most permits require;qualitative monitoring to be
perforimei during a "representative storm;event" or during a "measureable storm event'+ However,
some permits do not have this requirement.. Please refer to these definitions; if applicable.
A -"representative storm event" is a storm event that measures,greater than 0.1 inches of rainfall
and that.is preceded by ai least 72:hours (3 days) in'whith no storm event measuring, greater than
oxinches has occurred. A single storm event may contain up to 10 consecutive hours of no
precipitation.
A "measurable storm ;event" is a storm.event that results,in. an actual discharge from the:
permitted site outfalL The previous measurable storm ;event must have been at least,72hours
prior. The 72-hour storm interval does not apply if the;permittee isable to document that a shorter
interval is representative for local storm events during.the sampling period, and the permittee
By:thissignature, bcertify that this report is.accurate and complete to the best of mylvlowledge:
Page 1 of 2.
SM-M,lairmodinedlo f25/2012

1-. OUMIlDescliption:
Outfall No.,.S4)0 -1 Structure (pipe, ditch, etc.)
RprphAna Cfrn�.- 1-1 - -- . --. I.. n A ;--
UeS.Cribe theindostrial actiAtiesthat 06cur within the'outfall drainage area:. RFC g-idirgiv
AcrivIrig.4 ..me 60.1-1p -h&f2rG
2. Color. Describe the ' color of the discharge using basic colors (red, brown, blue; etc.)and tint
Oightineditim,,dark) asOescziptars:—,4,oh,- %Le4 JjArr
3. Odor. Describe any distinct odors that the'discharge may.have (i.e., smells strongly of oil,
weak chlorine odor, etc.): —NW'r.
4. C"W. Choose the number which best describes the clarity of the discharge; where I is
clear and 5 Is Very claud3r.
I LV 3 4 5
S. FloatingSolids: Choose the numberwhichbest de.scribe.p.the)amount .6tfloating solids in
the stormwater discharge, where 1 Is nosolids and 5 is the surface covered with floating solids:
.2 3 4
6. S.USPended Solids:
Ids: Choose the number which best describes the 'mount of suspended
solids in.thestormwater.discharge, where I is no solids and 5 Is extremely muddy:
3 4
7. Is there any foam In the stormwater discharge? Yes
0 0
8. Is there an, oil sheen in the stormwater discharge? Yes (-go
9. Isthere evidence oferosion or deposition at,the outfall? Yes
101. Other Obvious Indicators of Stermwater pollution:
Note: Low clarity;rn
- hlgh solids, and/or the presence of foam, oil sheen, or erosion/deposition
may beindicatiYeOf pollutant exposure. These conditions warrant further . in
vestigatlon.
Page 2 of 2L
SWU-242, Lxt Modifted 10125/2012

MUM
Stormwater Discharge Outfall (SDO)
Qualitative Monitoring Report
Forguidanceon/illfngoutthisfornplease;visit htto(//onrtal.ncdenr:org/we or/nodes-stormwat&I
Permit No.: i9 U5_10_1.R1A1IJJ/5_l or:CertificatebfCoverage No.:
County,
Date of Inspection:
Time Iof nspectoni
Total`Event Precipitation (inches):
Was this a "Representative Storm Evene or"Measureable Storm Event" as defined by the permit?
(See information below.)
O/Yes ❑ No
Please: verify wheMer Qualitative Monitoring must he performed during; a_ =representative storm
event" or "measureable storm event" (requirements vary,;depending on the;permit).
qualitative monitoring requirements vary. Most permits require.qualitadve monitoring to be
performed during a "representative storm•event" or during a "measureable storm event." However, ,
some permits do not have this requirement Please refer to these definitions; if applicable.
Vrepresentative storm event" is a storm event that measures.greater than 0.1inches of rainfall
and tha f is preceded by at least 12 hours (3 days) in which no storm event measuring greater than
0.1 inches has occurred. A single:storm event may contain up to 10 consecutive hoursof no
precipitation.
A "measurable storm event' isa storm event that results in an actual discharge from the
permitted site outfall...The previous:measurable storm event must been at least 7Zhours
prior. The 72-hour storm interval does not apply if the permittee.is able to document thata shorter
interval is representative for local storm events during the sampling period, and the permittee
i certify thattlfs report is accurate and complete to the best of my knowledge:
Pagel of 2
SWU•242; Last mudilled,10125 /2012

I. OutfAIDescriptlow
outfall No. n
Receiving Stream: JXpr-h
2; ColorDescribe the color of the discharge using basic colors
3. Odor., Descr ibeany
Weak chlorine odor, etc.):
blue, etc.) and'dnt
discharge may have (Le, smells strongly of oil,
4. Clarity ., Choose the number whi i ch:best describes.the clarity of the discharge, whe.re'.1. is
clear and Sis very cloudy:
1 02 8 4 5
5. Floating Solfds: Choose. the. number which. best describes theamountof floating s6lids'in
66 ftormWater discharge, where 1 is no solids and S is the sur
face solids:
0 2
6. SuspendedSollds: Choose the number which best describes the amount of.suspended
solids In the stormwater discharge, whereo ;l is no solids and . Sis:extremely muddy
1 02 3 4 5
7. Is there any foam in the stonnWater discharge? Yes:
—(90
8. Is therean oil sheen in the stormwater.discharge?, Yes
9. Is thereevidence of erosion or deposition attheoutfhIlT Yes 6D
10. Other Obvious Indicators of Stormwater Pollution:
Note:, LAW clarity, high solids, and/of the presence of fbam, oil sheen, or e.ros1qp/depqsl tion
may be indicative ,
. I -o (pollptant exposure.; These, conditions WA17"Aht forther.ifivestIgadon.
Page 2 of 2
SWU-242, LastmodiUd 10/25/2012

�,' "'-� ,,� -:7�
Date
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CERTIFICATION
I, (responsible corporate official), certify under penalty of law that this document and all attachments were
prepared under my direction or supervision In accordance with a system,designed to assure that qualified personnel properly gathered and
evaluated 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 Is, to the best of my knowledge and belief, true, accurate, and complete. Lam aware
that there are significant penalties for submitting false information, including the possibility of fine and Imprisonment for knowing violations.
A. Name & Official Title (type or print):
B. Area Code and Telephone No.:
�A �, e,✓
SAS - 66S-1-051
C. Si lure
D. Date Signed:
0Cs R a a 1-3 -
P:\Colbond\SWPPP\Appendioes\AppDi-NonSWeertiricationoloc .,

ATTACHMENT B
Linda Wiggs Email June 12, 2017
From: Wiggs, Linda [mailto:[e-mail]]
Sent: Monday, June 12, 2017 3:32 PM
To: Jenkins, Steve <[e-mail]>
Cc: Davidson, Landon <[e-mail]>, Davidson, Alison <[e-mail]>;
Kucken, Darlene <[e-mail]>, Georgoulias, Bethany
<[e-mail]>; [e-mail]
Subject: Bonar-Enka site
***WARNING*** This is an external e-mail and is not a part of internal communication.
Please use caution when opening attachments or when following embedded links.
Hello Steve,
I understand you are now the Environmental Manager for Bonar. I inspected
the Enka site in 2013 when Jeremy Nauert was the Environmental Manager.
Dan March was acting consultant at that time.
The Enka site has come to my attention again, primarily concerning
wastewater questions but also stormwater questions. These questions relate
to the complexity of this site and the conduits of water; stormwater (SW),
wastewater (WW), comingled (SW/WW), waterbod]es, etc. At my inspection
on September 4, 2013, I was Informed by Mr. March and Bonar personnel
that It had been determined all conduits of water carrying any type of
wastewater flowed to the lift station and were discharged to Metropolitan
Sewage District (MSD). The WW permit (NCG500608) rescission request
followed and then was granted based on this information. Furthermore, an
ongoing annual Certification as required by your Stormwater Permit (permit
#NCS000179, Part II, Section A 1. e.) remains in effect.
Please submit to me the final study report that determined the conduits of
water at the Enka facility, including any video recording of those conduits
and an up to date map delineating all conduits of water. Also submit the last
two years of sampling data from the Enka site and most recent signed
Certification as required under SW permit (NCS000179; Sampling - Part II
Section B, Certification - Part II, Section A 1. e.). Once I have received these
documents we can arrange an onsite meeting to further discuss.
Thank you,

Environmental Senior Specialist — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4500 office
828 299 7043 " fax
Email: Iinda.wicosAncdenr.00v
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
c':� Nothing Compares....,..
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.