NC0005312_Withdrawal of Application_20211207

BR O O V C ALEXANDER ELKAN
[�, �J I\ 2000 RENAISSANCE PLAZA
PI E RC E 230 NORTH ELM STREET
GREENSBORO,NC 27401
sO CI '
T 336.271.3134
F 336.232.9034
AELKAN1 1BROOKSPIERCE.COM
December 2, 2021 RECEIVED
VIA CERTIFIED U.S. MAIL and Email[[e-mail]] DEC 0 7 2021
NC DEQ, Division of Water Resources NCDEQIDWRINPDES
Water Quality Permitting Section—NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
ATTN: Mr. John Hennessy, Supervisor
Re: Notice of Duvaltex's Withdrawal of Application for Renewal and Modification of
NPDES Permit No. NC0005312
Notice of Duvaltex's Intent to Cease Operation of Elkin WWTP NPDES Permit No.
NC0005312 as of December 31, 2021
Dear Mr. Hennessy:
My law partner George House and I are environmental counsel for Duvaltex (US), Inc.
("Duvaltex"),with respect to the above-referenced NPDES Permit No.NC0005312 and in relation
to the True Textiles — Main Facility Brownfields Program Project Number 20080-16-86. For a
discussion of Duvaltex's involvement with these matters, including its ongoing operations of the
WWTP and efforts to cease such operations, I respectfully refer you to previous correspondence
to your office and the NC DEQ Brownfields Program from my firm regarding this matter,
including a letter from me to the Brownfields Program dated October 25, 2020. In that letter,
Duvaltex requested that the Brownfields Program require the Prospective Developer (JW
Industrial Group, LLC ("JW Industrial")) to shut off all influent of storm water and wastewater to
the WWTP from the Elkin Chatham textile mill(the "Mill Property") owned and operated by JW
Industrial so that Duvaltex could cease operating the WWTP. For your convenience, I have
attached as Exhibit A to this letter a copy of that October 25, 2020 letter (without exhibits due to
the volume of those materials).
The Brownfields Program responded to Duvaltex's request by including a provision in
paragraph 15 of the Brownfields Agreement that was entered into and subsequently recorded on
June 2, 2021 in the Surry County Registry of Deeds at Book 1764 Pages 867-929. Paragraph 15
requires the Prospective Developer to, within 90 days following the effective date of the
Brownfields Agreement, sever all storm water and wastewater connections to the WWTP and

I r
NC DEQ, DWR-NPDES Program
December 2, 2021
Page 2
prevent the Mill Property from contributing influent to the WWTP. It has now been approximately
180 days since the Brownfields Agreement was recorded—more than double the time allotted for
the Prospective Developer to fulfill these requirements. On or about October 28, 2021, a Division
of Waste Management Site Inspection Report was entered in the Brownfields Program files, see
Exhibit B hereto, pursuant to which the inspector reported on the status of the Prospective
Developer's work required by the Brownfields Agreement, including cutting off influent into the
WWTP.
Based on the Brownfields Agreement paragraph 15 requirements and the Inspection
Report, as well as additional information available to Duvaltex, it appears that there is no longer
any need for the WWTP to continue operations—in order to receive influent from the Mill Property
or otherwise. The additional information noted above includes: (1) recent WWTP flow records,
including from September, October and November 2021, showing no flow, see Exhibit C hereto;
and (2)observations by the WWTP operator that JW Industrial has apparently filled the lines
coming from the fly ash ponds and storm drains with concrete. The totality of this information
indicates that JW Industrial has accomplished the cutoffs required and eliminated influent flow
into the WWTP and that no discharge is occurring from the WWTP —there has been no apparent,
significant increase in influent to the WWTP from precipitation events, and influent flow is less
than.001 mgd and does not exit the WWTP as effluent.
Moreover, it is the Prospective Developer, and not Duvaltex, who should ensure that
wastewater and storm water from the Mill Property is appropriately and lawfully directed,treated,
and/or discharged.
As such, after effectively having been forced to spend more than two years and several
hundreds of thousands of dollars to continue to operate the WWTP in order to treat influent from
the Mill Property(which should have instead been treated by the Prospective Developer),Duvaltex
hereby gives notice to NC DEQ Division of Water Resources that as of December 31, 2021 it is:
(1)withdrawing its Application for Renewal and Modification ofNPDES Permit No.NC0005312,
which was submitted on behalf of Duvaltex by its environmental consultant Hart & Hickman on
March 30, 2020; and(2) withdrawing its Permit Renewal Application submitted on or about June
11, 2018. As a result of these withdrawals, in Duvaltex's view, the NPDES Permit will expire
effective 12:01 a.m. on January 1, 2021. In any event, it is Duvaltex's position that it should not
have been forced to operate the WWTP and has no obligation to continue to operate the WWTP.
Furthermore, whatever further steps may be necessary for additional operation and/or closure of
the WWTP are not Duvaltex's obligation, but rather are the responsibility of CMI Industries, Inc.
Specifically, Duvaltex respectfully reminds DEQ that Duvaltex does not have ownership
or use interest(s) in the WWTP property or equipment, which appear to be held exclusively by
CMI Industries, Inc. and/or its trustee, Stacy K. Taylor, Esq., McNair Law Firm, P.A., P.O. Box
11390, Columbia, South Carolina 29211 (copied on this correspondence). Duvaltex also reminds
DEQ that Duvaltex communicated extensively in writing with DEQ and the CMI trustee regarding
Duvaltex's intention to no longer operate the WWTP, including correspondence dated December
4, 2019 (attached as Exhibit D). Duvaltex's responsibilities under its lease of the WWTP from

NC DEQ, DWR-NPDES Program
December 2, 2021
Page 3
CMI were to deliver the WWTP to CMI in operating condition at the end of the lease term in 2019,
which Duvaltex did. Put simply, CMI is the owner of and responsible for the WWTP.
In summary, Duvaltex has been effectively forced to incur the burden and expense of
operating the WWTP for two years beyond its rightful obligations to do so. While Duvaltex's
efforts prevented potential environmental impacts caused by the Mill Property wastewater and
storm water directed into the WWTP,it also unduly and unjustly burdened Duvaltex and benefitted
JW Industrial and CMI and/or its Trustee. DEQ finally required JW Industrial to take
responsibility for the Mill Property storm water and wastewater — pursuant to the Brownfields
Agreement. As a result,there is no longer flow into or out of the WWTP, and thus no reason for
it to continue to operate.
We request that DEQ acknowledge Duvaltex's notice and cessation of WWTP operations.
We also request that DEQ properly look to CMI to fulfill its obligations as the owner of the
WWTP, and look to JW Industrial with respect to any issues with the Mill Property or adjacent
property wastewater or storm water.
Thank you for your attention to this matter.
Sincerely,
Alexander Elkan
C (via email only): Bruce Nicholson,NC DEQ DWM Brownfields Program
Jordan Thompson,NC DEQ DWM Brownfields Program
Drew Hargrove, Esq., counsel for NC DEQ
Kenny Lautenschlager, Esq., counsel for JW Industrial
Stacy K. Taylor, Esq., counsel for CMI
George House,Esq., counsel for Duvaltex
Daniel F. E. Smith, Esq., counsel for Duvaltex
Greg Kanellis, Hart&Hickman, environmental consultant for Duvaltex
Peter Paine, Duvaltex

EXHIBIT A
RECEIVED
nu 07 2021
NCDEQ/DWR/NPDtS

p
BROOKS ALEXANDER ELKAN
2000 RENAISSANCE PLAZA
PIERCE 230 NORTH ELM STREET
GREENSBORO,NC 27401
FOUNDED 1897
T 336.271.3134
F 336.232.9034
A ELKAN @ BROOKSPI ERCE.COM
October 16, 2020
VIA CERTIFIED U.S. MAIL and Email[[e-mail]]
Mr. Bruce Nicholson
Brownfields Program Manager
Division Waste Management
North Carolina Department of Environmental Quality
1646 Mail Service Center
Raleigh,NC 27699-1646
Re: Comments in Response to Notice of Intent to Redevelop Brownfields Property—True
Textiles—Main Facility Brownfields Project Number 20080-16-86
Dear Mr.Nicholson:
My law partner George House and I are environmental counsel for Duvaltex,LLC,and are
writing to provide comments and submit information on behalf of Duvaltex in response to the
Notice of Intent to Redevelop Brownfields Property—True Textiles—Main Facility Brownfields
Project Number 20080-16-86. The comment period opened on September 25 and will close
October 25, 2020.
I. Overview
As an initial matter, please note that for quite some time now, Duvaltex, through counsel
and Duvaltex's environmental consultant(Hart&Hickman—copied)has been in communications
with NC DEQ Division of Water Resources (Ms. Julie Grzyb and Mr. Lon Snider - copied) and
counsel(Mr. Drew Hargrove—copied)regarding the property that is the subject of the Notice,the
Prospective Developer (JW Industrial Group, LLC — whose counsel is also copied) and related
matters, which directly impact Duvaltex. See, e.g., Exhibit 1 (correspondence and materials
regarding requested downgrade of NPDES permit). As discussed below, Duvaltex would be
supportive of an appropriate Brownfields Agreement for the subject property (and related
properties)with additional requirements,but objects to the Brownfields Agreement as proposed in
the Notice.
As DEQ should know, Duvaltex is the current permittee for waste water treatment plant
NPDES Permit NC0005312, which is located south/southeast of the proposed Brownfields
Property, and apparently receives storm water and remains connected to waste water lines from
the proposed Brownfields Property and an adjacent property on which former fly ash basins are
4810-9530-2851.v1

NC DEQ Brownfields Program
October 16, 2020
Page 2
located. While Duvaltex has no legal obligation to the Prospective Developer or any other entity
to receive or treat waste water at the treatment plant, since December 2019 it has been effectively
forced to continue to operate the facility to treat storm water simply because it is the NPDES
permittee.
Duvaltex is actively seeking to downgrade and terminate its NPDES permit, and to cease
operation of the waste water treatment plant. However, DEQ Water Resources has apparently
taken a position that in order to rescind the NPDES permit,all connections to the treatment facility
must be disconnected, including domestic waste water connections and storm water connections
and diversions from the subject Brownfields Property as well as any connections from fly ash
basin(s)located on an adjacent property, which is owned by Elkin Partner Holdings,LLC. (Elkin
Partner Holdings,LLC,upon information and belief,is controlled by the principal of JW Industrial
Group, LLC, Mr. Dellinger, and is also the record title owner of three of the four parcels
comprising the proposed Brownfields Property. )
Duvaltex has requested that Mr. Dellinger and his entities remove those connections and
cease diversions of storm water to the waste water treatment facility,but,to date they have failed
and refused to do so. Duvaltex has also requested that DEQ Water Resources exercise its authority
to administratively order Mr. Dellinger and his entities to remove those connections and cease
those diversions. To date,upon information and belief,DEQ Water Resources has not issued any
such administrative order. Duvaltex has also instituted a lawsuit in Surry County Superior Court
requesting the Court to order the same,but,to date,no such order has been obtained.
Because Mr. Dellinger and his entities (JW Industrial Group, LLC [the Prospective
Developer] and Elkin Partner Holdings,LLC,the title owner of proposed Brownfield Property and
the ash basin property, which is improperly excluded from the proposed Brownfield Property)
have failed and refused to remove the connections and cease .diversions to the waste water
treatment facility, and DEQ has, to this point, not required such action by Mr. Dellinger and his
entities,but rather has simply informed Duvaltex that such connections must be removed prior to
rescission of the NPDES Permit, Duvaltex is effectively being forced to continue to operate the
waste water treatment plant for the sole benefit of Mr. Dellinger and his entities. This is an
untenable situation, which it appears NC DEQ may have authority to resolve through
administrative action.
Duvaltex is now again requesting that NC DEQ take appropriate administrative action to
ensure that the Prospective Developer timely remove all storm water and waste water connections
and diversions from its properties(and properties it controls through Elkin Partner Holdings,LLC)
to the waste water treatment plant, including, but not limited to, domestic waste water and storm
water connections and diversions from the subject Brownfields Property as well as any connections
from fly ash basins located on an adjacent property. Such administrative action should include,
but not be limited to, incorporating such requirements as conditions precedent to entry into any
proposed Brownfields Agreement, and as necessary components of an approved Environmental
Management Plan pursuant to any Brownfields Agreement.
II. Comments

NC DEQ Brownfields Program
October 16, 2020
Page 3
DEQ should not enter into the proposed Brownfields Agreement without first requiring
that the Prospective Developer timely remove all waste water and storm water connections and
diversions to the waste water treatment facility, including, but not limited to, for the reasons set
forth below.
A. Comments on September 22, 2020 Decision Memorandum
The Decision Memorandum indicates that DEQ has issued the Notice based on an incorrect
and incomplete understanding of relevant facts and circumstances.
• Page 2, Site History section, subsection i. acknowledges that, "The southern parent
parcel also contains the flood plain and fly ash basins previously associated with the Brownfields
Property."
However,there is no acknowledgement or indication that the parcel referred to (tax parcel
i.d. 495 1 1 5529647) is owned by Elkin Partner Holdings, LLC, the same entity that owns three
parcels of the Brownfields Property,and that the fly ash basins apparently remain connected to the
boiler room on the proposed Brownfields Property and the waste water treatment facility.
• Page 3, Environmental Overview section, subsection a. erroneously states the status of
waste water connections of the subject Brownfields Property, suggests there is no existing piping
network to the waste water treatment plant, and fails to acknowledge that the mill property piping
apparently remains connected to the waste water treatment plant.
In fact, the mill property waste water piping system apparently remains connected to the
waste water treatment facility and storm water is apparently diverted from the mill property to the
facility as well. Attached as Exhibit 2 are a mill property building map and piping schematic on
which Duvaltex, in consultation with the Yadkin Valley Sewer Authority, has indicated apparent
remainingconnections to the waste water treatment facility. All of these connections, as well as
tY
those from the fly ash basin(s)should be removed and all diversion of waste water and storm water
to the waste water treatment facility should be ceased.
• Page 4, Environmental Overview section, subsection g. states that the south adjacent
property containing the fly ash basins(also owned by Elkin Partner Holdings,LLC affiliated with
the Prospective Developer as stated above) is not part of the proposed Brownfields Agreement.
However, the Prospective Developer is contractually bound by a certain Equity Purchase
Agreement dated February 11, 2016. The Prospective Developer assumed contractual obligations
under that agreement to expeditiously "conclude and enter into an effective Brownfields
Agreement in respect of the entire Elkin Facility" and to comply with all requirements of the
Brownfields Agreement. See excerpts attached at Exhibit 3. The"Elkin Facility"is defined under
that agreement to include "the land consisting of Surrey County Parcels 495115534150,
495115641270, 495115528796,495115521832 and 495114227884." By attempting to enter into
a Brownfields Agreement with NC DEQ that omits two of the five required parcels, omits the fly
ash basin parcel, and does not require removal of waste water piping connections to the waste

a
NC DEQ Brownfields Program
October 16, 2020
Page 4
water treatment facility, and otherwise is not in compliance with the Equity Purchase Agreement,
Prospective Developer is in violation of its contractual obligations to Duvaltex.
• Page 5, Environmental Overview section, subsection k. erroneously states that the
NPDES permit for the waste water treatment facility expired in 2018. This is incorrect. NPDES
permit NC0005312 is still active,and as discussed above,Duvaltex is actively seeking to terminate
the permit, but has been prevented from doing so by the Prospective Developer's actions and
failures to act, and DEQ's apparent position as to requirements for permit termination, which
untenably would require Duvaltex to undertake actions on the property of Prospective Developer
and its affiliates to remove connections to the waste water treatment facility.
• Page 6, Contaminated Media section, subsection on Surface Water, erroneously omits
any mention of storm water and waste water routed from the mill property to the waste water
treatment facility. Again, such connections should be removed by the Prospective Developer as a
condition precedent to entry into the agreement and a condition of the agreement itself.
B. Comments on Notice of Brownfields Property
The Notice of Brownfields Property is also incorrect and deficient, including, but not
limited to, as follows.
• Page 1 incorrectly identifies JW Industrial Group, LLC as the owner of the Brownfields
Property.
• The plat attached does not appear to comply with statutory requirements and does not
include the ash basin property, which should be included in the Brownfields Property.
• Contrary to the statement of compliance on page 2:
- The Prospective Developer, by failing to remove all waste water connections and
continuing to divert storm water to the waste water treatment facility, and by failing
connect all waste water piping to the municipal system, has failed to comply with all
applicable environmental laws and regulations and its contractual and common law
obligations to Duvaltex,and therefore DEQ may not enter into the proposed Brownfield
Agreement under N.C. Gen. Stat. § 130A-310.32(1).
- The Prospective Developer, by failing to remove all waste water connections and
continuing to divert storm water to the waste water treatment facility, and by failing
connect all waste water piping to the municipal system, has failed to protect public
health, and therefore DEQ may not enter into the proposed Brownfield Agreement
under N.C. Gen. Stat. § 130A-310.32(2).
- Upon information and belief, the Prospective Developer, does not have the financial,
managerial, and technical means to fully implement the proposed Brownfields
Agreement and assure the safe use of the brownfields property,and therefore DEQ may
not enter into the proposed Brownfield Agreement under N.C. Gen. Stat. § 130A-

8
NC DEQ Brownfields Program
October 16, 2020
Page 5
310.32(4). Notably, unless and until the Prospective Developer addresses the storm
water and waste water connections, escrow funds may be unavailable to use for
implementation of the applied-for Brownfields Agreement — contrary to the
Prospective Developer's representations to NC DEQ in its Brownfields application that
such funds would be available.
• Page 5, Land Use Restrictions, subsection n. should require any Environmental
Management Plan approved by DEQ to include removal of all connections to the waste water
treatment facility and routing of all waste water and storm water to the municipal system in accord
with applicable federal and state law and local ordinances.
C. Comments- Proposed Brownfields Agreement
The Notice of Brownfields Property is also incorrect and deficient, including, but not
limited to, in the following manner.
• Page 2 incorrectly states that entry into the agreement is in the public interest without
requiring the Prospective Developer to remove all connections to the waste water treatment facility
and properly route all waste water and storm water to the municipal system in accord with
applicable federal and state law and local ordinances.
• Page 6 Statement of Facts Section III, subsection 6 acknowledges that DEQ has erred
and failed to take into consideration the waste water treatment facility as a receptor of waste water
and storm water from the mill property or the ash basins.
• Page 7 Statement of Facts Section III, subsection 10 erroneously states that the
Prospective Developer is in compliance with applicable environmental laws and the Brownfield
Agreement will protect public health and the environment. This is erroneous because the
Prospective Developer has not properly and lawfully provided for the treatment of storm water
and waste water from the mill property by routing to the municipal system and has failed to remove
connections to the waste water treatment facility.
Therefore, DEQ may not enter into the proposed Brownfield Agreement under N.C. Gen.
Stat. § 130A-3 10.32.
• Pages 9 and 14 of Work To Be Performed Section IV, subsection 14 and subsection 15
k. do not, but should, require the Prospective Developer to remove all connections to the waste
water treatment facility and route all waste water and storm water to the municipal system in a
legally compliant manner.
III. Summary
For all of the reasons stated above, the Notice and proposed Brownfields Agreement are
deficient and erroneous. DEQ may not lawfully enter into the proposed Brownfields Agreement,
and should require the Proposed Developer to remove all connections to the waste water treatment
facility and route all waste water and storm water to the municipal system in a legally compliant
manner as a condition precedent to any Brownfields Agreement.

a
NC DEQ Brownfields Program
October 16, 2020
Page 6
Please contact me at 336-708-3134 to discuss this request, any questions you may have or
additional information you may require.
Thank you for your attention and assistance in this matter.
Sincerely,
Y
/s Alex Elkan
Alexander Elkan
C (via email only): Keith Ogden,Duvaltex
Julie Gryzb,NC DEQ Water Resources
Lon Snider,NC DEQ Water Resources
Jordan Thompson,NC DEQ Brownfields Program
Drew Hargrove,Esq., counsel for NC DEQ
Kenny Lautenschlager, Esq.,counsel for JW Industrial Group, LLC
George House,Esq., counsel for Duvaltex
Greg Kanellis,Hart&Hickman, environmental consultant for Duvaltex

Y j i
EXHIBIT B
RECEIVED
VEp
DEC 0 7 2021
NCDEQ/DWR/NPDES

DWM Brownfields Inspection Report
Submitted By: jkslaughter_ncdenr
Submitted Time: 10/28/2021 7:47 AM
I. Inspection Information
Date &Time: 10/15/2021 9:47 AM Inspection Type: Meeting
Brownfields Staff: Other Personnel:
Kevin Slaughter Will Dellinger- Elkin Partner Holdings
Location:
Lat: 36.24634301854045, Long: -80.8425365158898,
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True i'extales'RN) m
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Day St
axtiles Greenway
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Esri, NASA, NGA, USGS, FEIV1A I E:ri Community Map:Contrib . Powered by Esri

•
Brownfields Inspection Report:True Textiles(RN),20080-16-086
10/15/20219:47 AM
II. Project Information
Number: 20080-16-086 Name:True Textiles (RN)
Address: 304 E. Main St. City: Elkin County: Surry
III. Environmental
Current Use of Property: Commercial/Retail, Vacant Land
Structures on Property: Existing Structures Violation: No
Summary: Former textile mill present on the property. Several buildings are empty
although southern building has been purchased by, and is being used by the Foothills Art
Center. The far western building (Shipping/Receiving building) has also been purchased
and
Vapor Mitigation Systems: Not Observed Vapor Mitigation Violation: No
Summary: N/A
Use of Surface Water or Groundwater: Not Observed Water Use Violation: No
Summary: N/A
Exposed Soils: Not Observed Exposed Soils Violation: No
Summary: N/A
Page 2 of 9

Brownfields Inspection Report:True Textiles(RN),20080-16-086
10/15/2021 9:47 AM
Use of Basements: Observed Basement Violation: No
Summary: Although a basement was observed in a former spinning building northeast of
the Foothills Art Center, it is not currently in use, and no chemical storage was observed.
There is an additional large basement that is beneath the former dyehouse/chemical
storage building. The basement area is still being cleared out, and drains were being
sealed during the site inspection, with additional drains flagged for sealing. Piping
downflow of these drains have been sealed.
Storage of Chemicals: Observed Chemical Violation: Unknown
Summary: There were two ares of the site where chemicals were observed. On the
interior and exterior of the former maintenance shop, where there were three waste oil
AST,'s, and five 5-gallon buckets that were labeled Calcium Hypochlorite that appeared
to be at least partially full (Photo 4). In addition,there were numerous drums, totes, and
buckets of material (surfactants, acetic acid, oils, water repellants, etc.) that were left on-
site by a prior tenant within the former dyehouse/chemical storage building (Photos 5
and 6).
Groundwater Monitoring Wells: Observed Monitoring Well Violation: No
Condition: Unknown
Summary: Observed one former groundwater recovery well in the vicinity of the broken
culvert bordering Main St. that looked like it might be used for groundwater sampling.
The vault cover and well lid on this vault and well were not secured (Photo 10). There
was an additional recovery well, or sump pit (nothing appeared to drain to it) within the
Former Dye Area building (Photo 11), and a monitoring well vault in the warehouse on
western portion of site which was bolted shut.
Current Exposure to Public/Public Risk:
Not observed at the time of the site inspection. Other than building used for
warehousing on western portion of property, only other occupied space is the Foothills
Arts Center located on the southern portion of the property. Spoke with Leslie
Fesperman who is a director there, and building primary consists of small
studios/galleries where artists (clay, textiles, painting, etc.) work on projects, but not on a
daily basis.
Page 3 of 9

Brownfields Inspection Report:True Textiles(RN), 20080-16-086
10/15/2021 9:47 AM
IV. Inspector Comments
According to Mr. Dellinger, all three of the drainage lines that left the Mill property for
the former WWTP have been plugged in at least two locations, with additional cement
plugs installed on the opposite side of Main St., without any lines entering, leaving, or
interconnecting the former settling ponds or the former WWTP (all of which I observed).
In addition, extensive sealing of drains within the different buildings has been performed,
although there are additional drains still being uncovered, primary within the basement
level of the former dyehouse/chemical storage building (although others were observed
that will be sealed.
V. PHOTOGRAPHS
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Photo 1: Culvert area awaiting repair. Work planned on DOT culvert under main street, so Mr.
Dellinger is waiting until this work is performed to make the onsite culvert line repair.
Page 4 of 9

Brownfields Inspection Report:True Textiles(RN),20080-16-086
10/15/2021 9:47 AM
4.
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Photo 2:Typical example of exterior line blockage after filling piping and vault with concrete.
Observed approximately eight of these blockages sealing all floor drain lines leaving property.
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Photo 3: Several circular floor drains sealed within former dye area building.
Page 5 of 9

Brownfields Inspection Report:True Textiles(RN),20080-16-086
10/15/2021 9:47 AM
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Photo 4: Chemical storage within maintenance shop. Two additional used oil AST's located
outside maintenance building.
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Photo 5: One of several locations within northern ground floor portion of former
dyehouse/chemical storage building where former tenant left 55-gallon drums, smaller buckets,
and a metal caged chemical totes.
Page 6 of 9

1
Brownfields Inspection Report:True Textiles(RN),20080-16-086
10/15/2021 9:47 AM
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Photo 6: Surfactant tote, and blue poly barrel of Acetic Acid, both left in former
dyehouse/chemical storage building by former tenant.
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Photo 7: Future warehouse area within ground floor of dyehouse/chemical storage building.
No plans to fill trenches with cement, however, where trench drains exist grates at a single
location, discharge line has been filled with cement.
Page 7 of 9

Brownfields Inspection Report:True Textiles(RN),20080-16-086
10/15/2021 9:47 AM
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Photo 8: Photo of Foothills Arts Center building facing southwest.
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Photo 9: Ground floor of Foothills Arts Center building which consists of approximately ten
artists' studios. Studios were empty during site inspection, and tenants come and go on a
regular basis.
Page 8 of 9
l

Brownfields Inspection Report:True Textiles(RN), 20080-16-086
10/15/2021 9:47 AM
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Photo 10: Former groundwater recovery well located on northwest of culvert repair area. Vault
lid and 4" dia. recovery well cap unsecured.
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Photo 11: What appears to be a groundwater recovery well or possibly a sump pump pit
located within former dye area building on eastern portion of site. Requested vault be filled
with cement.
Page 9 of 9

EXHIBIT C
RECEIVED
DEC 0 7 2021
NCDEQ/DWR/NFDtS

•
• NPDES PERMIT NO.:NC0005312 PERMIT VERSION:4.0 PERMIT STATUS:Expired
FACILITY NAME:Duvaltex CLASS:WW-4. COUNTY:Surry
OWNER NAME:Duvaltex US Inc ORC:Glen Edward Gary ORC CERT NUMBER:989696
GRADE:WW-4. ORC HAS CHANGED:No
eDMR PERIOD:09-2021(September 2021) VERSION:1.0 STATUS:Submitted
SAMPLING LOCATION: EFFLUENT DISCHARGE NO.: 001 NO DISCHARGE*: YES
50050 00010 00400 50060 QD310 QD530 31616 C0600 C0665
E E
1= g F y
i E• — 8 n
4 'E "e_ m Continuous 5 X week 5 X week 5 X week 5 X week 5 X week 2 X month Monthly Monthly
e a f
Iu C o ii Recorder Grab Grab Grab Composite Composite Grab Composite Composite
a a a`
A U F+ O O O Z FLOW TEMP-C pH CHLORINE DOD-Qty Daily TSS-Qty Daily FCOLI BR TOTAL N- TOTAL P-Cone
2400 clock Hra 2400 dock Hrs Y/B/N mgd deg c su ug/I lbs/day lbs/day Il/100m1 mg/1 mg/1
1 0715 24 0700 9 y NOFLOW
2 0715 24 - 0700 9 y NOFLOW
3 0715 24 0700 9 y NOFLOW
4 0630 2 n NOFLOW
5 0630 2 n NOFLOW
6 0715 24 0630 2 n NOFLOW
7 0715 24 0700 9 y NOFLOW
8 0715 24 0700 9 y NOFLOW
9 0715 24 0700 9 y NOFLOW
10 0715 24 0700 9 y NOFLOW
II 0700 2 y NOFLOW
12 0700 2 y NOFLOW
13 0715 24 0700 9 y NOFLOW
14 0715 24 0700 9 y NOFLOW
15 0715 24 0700 9 y NOFLOW I
16 0715 24 0700 9 y NOFLOW
17 0715 24 0700 9 y NOFLOW
18 0630 2 n NOFLOW
19 0630 2 n NOFLOW
20 0715 24 0700 9 y NOFLOW
21 0715 24 0700 9 y NOFLOW
22 0715 24 0700 9 y NOFLOW
23 0715 24 0700 9 y NOFLOW
24 0715 24 0700 9 y NOFLOW
25 0700 9 y NOFLOW
26 0700 2 y NOFLOW
27 0715 24 0700 2 y NOFLOW
28 0715 24 0700 9 y NOFLOW
29 0715 24 0700 9 y NOFLOW
30 0715 24 0700 9 y NOFLOW
Monthly Average Limit: 4 101.6 272.3 200
Monthly Average:
Daily Maximum:
Daily Minimum:
****No Reporting Reason:ENFRUSE=No Flow-Reuse/Recycle; ENVWTHR=No Visitation—Adverse Weather; NOFLOW=No Flow; HOLIDAY=No Visitation—Holiday
Discharge Monitoring Report-Copy Of Record(COR_NC0005312_Ver_1.0_9 2021.pdf)

NPDES PERMIT NO.:NC00053 12 PERMIT VERSION:4.0 PERMIT STATUS:Expired
FACILITY NAME:Duvaltex CLASS:WW-4. COUNTY:Surry
OWNER NAME:Duvaltex US Inc ORC:Glen Edward Gary ORC CERT NUMBER:989696 I
GRADE:WW-4. ORC HAS CHANGED:No
eDMR PERIOD:09-2021(September 2021) VERSION:1.0 STATUS:Submitted
SAMPLING LOCATION: EFFLUENT DISCHARGE NO.: 001 NO DISCHARGE*: YES (Continue)
01034 00340 32730 00745
E 9 _ :
F i F U g
31 ~ O
1 .=. e` Leo 2 X month Weekly 2 X month 2 X month
2 a f
u O . Composite Composite Grab Grab
g U a 1
2 F° O & O Z' Cr-TOTAL COD PHEN,TR SULFIDE
2400 dock lira 2400 dock Hra yrn/N lbs/day lbs/day lbs/day lbs/day
1 0715 24 0700 9 y NOFLOW
2 0715 24 0700 9 y NOFLOW
3 0715 24 0700 9 y NOFLOW
4 0630 2 n NOFLOW I',
5 0630 2 n NOFLOW
6 0715 24 0630 2 n NOFLOW
7 0715 24 0700 9 y NOFLOW
0 0715 24 0700 9 y NOFLOW
9 0715 24 0700 9 y NOFLOW
10 0715 24 0700 9 y NOFLOW
11 0700 2 y NOFLOW
12 0700 2 y NOFLOW
13 0715 24 0700 9 y NOFLOW
14 0715 24 0700 9 y NOFLOW
15 0715 24 0700 9 y NOFLOW
16 0715 24 0700 9 y NOFLOW
17 0715 24 0700 9 y NOFLOW
18 0630 2 n NOFLOW
19 0630 2 n NOFLOW
20 0715 24 0700 9 y NOFLOW
21 0715 24 0700 9 y NOFLOW
22 0715 24 0700 9 y NOFLOW
v 0715 24 0700 9 y NOFLOW
24 0715 24 0700 9 y NOFLOW
25 0700 9 y NOFLOW
26 0700 2 y NOFLOW
27 0715 24 0700 2 y NOFLOW
20 0715 24 0700 9 y NOFLOW
29 0715 24 0700 9 y NOFLOW
30 0715 24 0700 9 y NOFLOW r
Monthly Average Llmit: 15 1526.5 1.5 3
Monthly Average:
Daily Maximum:
Dolly Minimum:
****No Reporting Reason:ENFRUSE=No Flow-Reuse/Recycle; ENV WTHR=No Visitation—Adverse Weather; NOFLOW=No Flow; HOLIDAY=No Visitation—Holiday
Discharge Monitoring Report-Copy Of Record(COR NC0005312_Ver_1.0_9_2021.pdf)

NPDES PERMIT NO.:NC0005312 PERMIT VERSION:4.0 PERMIT STATUS:Expired
FACILITY NAME:Duvaltex CLASS:WW-4. COUNTY:Surry
II OWNER NAME:Duvaltex US Inc ORC:Glen Edward Gary ORC CERT NUMBER:989696
GRADE:WW-4. ORC HAS CHANGED:No
eDMR PERIOD:09-2021(September 2021) VERSION:1.0 STATUS:Submitted
COMPLIANCE STATUS:Compliant CONTACT PHONE#:[phone] SUBMISSION DATE: 10/11/2021
Electronically Certified by Glen E Gary on 2021-10-07 08:53:38.519
ORC/Certifier Signature : Glen E Gary Phone # : (336 ) 835 - 1083 Date
I certify that this report is accurate and complete to the best of my knowledge.
The permittee shall report to the Director or the appropriate Regional Office any noncompliance that potentially threatens public health or the environment.
Any information shall be provided orally within 24 hours from the time the permittee became aware of the circumstances.A written submission shall also be
provided within 5 days of the time the permittee becomes aware of the circumstances.The written submission shall be made as required by part II.E.6 of the
NPDES permit.
Electronically Signed by Peter Paine on 2021-10-11 11:00:46.952
Permittee/Submitter Signature: ** *Peter Paine Phone #:207+876+ 1248 Date
Permittee Address:304 E Main St Elkin NC 28621 Permit Expiration Date: 12/31/2018
I certify,under penalty of law,that this document and all attachments were prepared under my direction or supervision in accordance with a system designed
to assure that qualified personnel properly gather and evaluate the information submitted.Based on my inquiry of the person or persons who managed the
system,or those persons directly responsible for gathering the information,the information submitted is,to the best of my knowledge and belief,true,
accurate,and complete.I am aware that there are significant penalties for submitting false information,including the possibility of fines and imprisonment for
knowing violations.
CERTIFIED LABORATORIES
LAB NAME:Duvaltex US Inc
CERTIFIED LAB#:5010
PERSON(s)COLLECTING SAMPLES:Glen Gary,Billy Stone
PARAMETER CODES
Parameter Code assistance may be obtained by visiting https://deq.nc.gov/about/divisions/water-resources/edmr/user-documentation.
FOOTNOTES
Use only units of measurement designated in the reporting facility's NPDES permit for reporting data.
*No Flow/Discharge From Site:YES indicates that No Flow/Discharge occurred and,as a result,no data is reported for any parameter on the DMR for the
entire monitoring period.
**ORC on Site?:ORC must visit facility and document visitation of facility as required per 15A NCAC 8G.0204.
***Signature of Permittee:If signed by other than the permittee,then delegation of the signatory authority must be on file with the state per 15A NCAC 2B
.0506(b)(2)(D).
Discharge Monitoring Report-Copy Of Record(COR_NC0005312_Ver_1.0_9_2021.pdf)

• NPDES PERMIT NO.:NC0005312 PERMIT VERSION:4.0 PERMIT STATUS:Expired
FACILITY NAME:Duvaltex CLASS:WW-4. COUNTY:Surry
OWNER NAME:Duvaltex US Inc ORC:Glen Edward Gary ORC CERT NUMBER:989696
GRADE:WW-4. ORC HAS CHANGED:No
eDMR PERIOD:10-2021(October 2021) VERSION:1.0 STATUS:Submitted
SAMPLING LOCATION: EFFLUENT DISCHARGE NO.: 001 NO DISCHARGE*: YES
50050 00010 00400 50060 QD310 QD530 31616 C0600 C0665
E g q
F a
E u " •
1 -= e g
eo
Continuous 5 X week 5 X week 5 X week 5 X week 5 X week 2 X month Monthly Monthly
I a h r
u o` Recorder Grab Grab Grab Composite Composite Grab Composite Composite
e o 8 ,42
o U' F. O O O Z FLOW TEMP-C pH CHLORINE BOD-Qty Dolly TSS-Qty Dolly FCOLI BR TOTAL N. TOTAL P-Co...
2400 dock Hra 2400 dock Hr. Y/B/N mgd deg c su ug/1 lbs/day lbs/day 0/100m1 mg/I mg/I
I 0715 24 0700 9 y NOFLOW
2 0630 2 n NOFLOW
3 0630 2 n NOFLOW
4 0715 24 0700 9 y NOFLOW
5 0715 24 0700 9 y NOFLOW
6 0715 24 0700 9 y NOFLOW
7 0715 24 0700 9 y NOFLOW
8 0715 24 0700 9 y NOFLOW
9 0700 2 y NOFLOW
10 0700 2 y NOFLOW
11 0715 24 0700 9 y NOFLOW
12 0715 24 0700 9 y NOFLOW
13 0715 24 0700 9 y NOFLOW
14 0715 24 0700 9 y NOFLOW
15 0715 24 0700 9 y NOFLOW
16 0630 2 n NOFLOW
17 0630 2 n NOFLOW
18 0715 24 0700 9 y NOFLOW
19 0715 24 0700 9 y NOFLOW
20 0715 24 0700 9 y NOFLOW
21 0715 24 0700 9 y NOFLOW
22 0715 24 0700 9 y NOFLOW
23 0700 2 y NOFLOW
24 0700 2 y NOFLOW
25 0715 24 0700 9 y NOFLOW
26 0715 24 0700 9 y NOFLOW
27 0715 24 0700 9 y NOFLOW
29 0715 24 0700 9 y NOFLOW
19 0715 24 0700 9 y NOFLOW
30 0630 2 n NOFLOW
31 0630 2 n NOFLOW
Monthly Avenge Limit: 4 Inl.n 2723 2110
Monthly Average:
Daily Maximum:
Daily Minimum:
9999 No Reporting Reason:ENFRUSE=No Flow-Reuse/Recycle; ENVWTHR=No Visitation—Adverse Weather; NOFLOW=No Flow; HOLIDAY=No Visitation—Holiday
Discharge Monitoring Report-Copy Of Record(COR NC0005312_Ver_1.0_10 2021.pdt)

NPDES PERMIT NO.:NC0005312 PERMIT VERSION:4.0 PERMIT STATUS:Expired
FACILITY NAME:Duvaltex CLASS:WW-4. COUNTY:Surry
OWNER NAME:Duvaltex US Inc ORC:Glen Edward Gary ORC CERT NUMBER:989696
GRADE:WW-4. ORC HAS CHANGED:No
eDMR PERIOD:10-2021(October 2021) VERSION:1.0 STATUS:Submitted
SAMPLING LOCATION: EFFLUENT DISCHARGE NO.: 001 NO DISCHARGE*: YES (Continue)
01034 00340 32730 00745
E FsKZfi O▪ E' P* i
E _ e
e g 2 X month Weekly 2 X month 2 X month
it. ¢ i=
• u O . Composite Composite Grab Grab
o 2 5 u a"
O U F+ O O O Z
Cr-TOTAL COD PHEN,TR SULFIDE
2400 clock Hrs 2400 dock Hrs Y/B/N lbs/day lbs/day lbs/day lbs/day
1 0715 24 0700 9 y NOFLOW
2 0630 2 n NOFLOW
3 0630 2 n NOFLOW
4 0715 24 0700 9 y NOFLOW
5 0715 24 0700 9 y NOFLOW
6 0715 24 0700 9 y NOFLOW
7 0715 24 0700 9 y NOFLOW
8 0715 24 0700 9 y NOFLOW
9 0700 2 y NOFLOW
10 0700 2 y NOFLOW
11 0715 24 0700 9 y NOFLOW
12 0715 24 0700 9 y NOFLOW
13 0715 24 0700 9 y NOFLOW
14 0715 24 0700 9 y NOFLOW
15 0715 24 0700 9 y NOFLOW
16 0630 2 n NOFLOW
17 0630 2 n NOFLOW
18 0715 24 0700 9 y NOFLOW
19 0715 24 0700 9 y NOFLOW 1
20 0715 24 0700 9 y NOFLOW
21 0715 24 0700 9 y NOFLOW
22 0715 24 0700 9 y NOFLOW
23 0700 2 y NOFLOW
24 0700 2 y NOFLOW
25 0715 24 0700 9 y NOFLOW 1
26 0715 24 0700 9 y NOFLOW
27 0715 24 0700 9 y NOFLOW
28 0715 24 0700 9 y NOFLOW
29 0715 24 0700 9 y NOFLOW
30 0630 2 n NOFLOW
31 0630 _2 n NOFLOW
Monthly Average Limit: 15 1526.5 1.5 3
Monthly Average:
Daily Maximum:
Daily Minimum:
*089No Reporting Reason:ENFRUSE=No Flow-Reuse/Recycle; ENVWTHR=NoVisitation—AdverseWeather, NOFLOW=No Flow; HOLIDAY No Visitation—Holiday
Discharge Monitoring Report-Copy Of Record(COR NC0005312_Ver_1.0_10_2021.pdf)

• NPDES PERMIT NO.:NC0005312 PERMIT VERSION:4.0 PERMIT STATUS:Expired
FACILITY NAME:Duvaltex CLASS:WW-4. COUNTY:Surry
OWNER NAME:Duvaltex US Inc ORC:Glen Edward Gary ORC CERT NUMBER:989696
GRADE:WW-4. ORC HAS CHANGED:No
eDMR PERIOD:10-2021(October 2021) VERSION:1.0 STATUS:Submitted
COMPLIANCE STATUS:Compliant CONTACT PHONE#:[phone] SUBMISSION DATE: 11/08/2021
Electronically Certified by Glen E Gary on 2021-11-05 11:16:55.747
ORC/Certifier Signature : Glen E Gary Phone # : ( 336) 835 - 1083 Date
I certify that this report is accurate and complete to the best of my knowledge.
The permittee shall report to the Director or the appropriate Regional Office any noncompliance that potentially threatens public health or the environment.
Any information shall be provided orally within 24 hours from the time the permittee became aware of the circumstances.A written submission shall also be
provided within 5 days of the time the permittee becomes aware of the circumstances.The written submission shall be made as required by part II.E.6 of the
NPDES permit.
Electronically Signed by Peter Paine on 2021-11-08 10:15:11.998
Permittee/Submitter Signature: * **Peter Paine Phone #:207+876+ 1248 Date
Permittee Address:304 E Main St Elkin NC 28621 Permit Expiration Date: 12/31/2018
I certify,under penalty of law,that this document and all attachments were prepared under my direction or supervision in accordance with a system designed
to assure that qualified personnel properly gather and evaluate the information submitted.Based on my inquiry of the person or persons who managed the
system,or those persons directly responsible for gathering the information,the information submitted is,to the best of my knowledge and belief,true,
accurate,and complete.I am aware that there are significant penalties for submitting false information,including the possibility of fines and imprisonment for
knowing violations.
CERTIFIED LABORATORIES
LAB NAME:Duvaltex US Inc
CERTIFIED LAB#:5010
PERSON(s)COLLECTING SAMPLES:Glen Gary,Billy Stone
PARAMETER CODES
Parameter Code assistance may be obtained by visiting https://deq.nc.gov/about/divisions/water-resources/edmr/user-documentation.
FOOTNOTES
Use only units of measurement designated in the reporting facility's NPDES permit for reporting data.
*No Flow/Discharge From Site:YES indicates that No Flow/Discharge occurred and,as a result,no data is reported for any parameter on the DMR for the
entire monitoring period.
**ORC on Site?:ORC must visit facility and document visitation of facility as required per 15A NCAC 8G.0204.
***Signature of Permittee:If signed by other than the pennittee,then delegation of the signatory authority must be on file with the state per 15A NCAC 2B
.0506(b)(2)(D).
Discharge Monitoring Report-Copy Of Record(COR NC0005312_Ver_1.0_10_2021.pdt)

• NPDES PERMIT NO.:NC0005312 PERMIT VERSION:4.0 PERMIT STATUS:Expired
FACILITY NAME:Duvaltex CLASS:WW-4. COUNTY:Suny
OWNER NAME:Duvaltex US Inc ORC:Glen Edward Gary ORC CERT NUMBER:989696
GRADE:WW-4. ORC HAS CHANGED:No
eDMR PERIOD:11-2021(November 2021) VERSION:1.0 STATUS:Certified
SAMPLING LOCATION: EFFLUENT DISCHARGE NO.: 001 NO DISCHARGE*: YES
50050 00010 00400 50060 QD310 QD530 31616 C0600 C0665
1- 5 in
1F O 4
m — E _E` m Continuous 5 X week 5 X week 5 X week 5 X week 5 X week 2 X month Monthly Monthly
EQ EI. - 0
v c c Recorder Grab Grab Grab Composite Composite Grab Composite Composite
= e " c a"
A U 2 O O O r FLOW TEMP-C pH CHLORINE BOD-Qty Daily TSO-Qty Daily FCOLI BR TOTAL N- TOTAL P-Cone
2400 clock Hrs 2400 dock Hrs Y/B/N mgd deg c su ug/I lbs/day lbs/day #/100m1 mg/1 mg/I
1 0715 24 0700 9 y NOFLOW
2 0715 24 0700 9 y NOFLOW
3 0715 24 0700 9 y NOFLOW
4 0715 24 0700 9 y NOFLOW
5 0715 24 0700 9 y NOFLOW
6 0700 2 y NOFLOW
7 0700 2 y \ NOFLOW
8 0715 24 0700 9 y NOFLOW
9 0715 24 0700 9 y NOFLOW
10 0715 24 0700 9 y NOFLOW
11 0715 24 0700 9 y NOFLOW
12 0715 24 0700 9 y NOFLOW
13 0630 2 n NOFLOW
14 0630 2 n NOFLOW
15 0715 24 0700 9 y NOFLOW
16 0715 24 0700 9 y NOFLOW
17 0715 24 0700 9 y NOFLOW
10 0715 24 0700 9 y NOFLOW
19 0715 24 0700 9 y NOFLOW
20 0700 2 y NOFLOW
21 0700 2 y NOFLOW
22 0715 24 0700 9 y NOFLOW
23 0715 24 0700 9 y NOFLOW
24 0715 24 0700 9 y NOFLOW
25 0715 24 0630 2 ❑ NOFLOW
26 0715 24 0630 2 n NOFLOW
27 0630 2 n NOFLOW
2s 0630 2 n NOFLOW
29 0715 24 0700 9 y NOFLOW
30 0715 24 0700 9 y NOFLOW
Monthly Average Limit: 4 101.6 272.3 200
Monthly Average:
Daily Maximum:
I Daily Minimum:
****No Reporting Reason:ENFRUSE=No Flow-Reuse/Recycle; ENVWTHR=No Visitation—Adverse Weather, NOFLOW=No Flow; HOLIDAY=No Visitation—Holiday

•
• NPDES PERMIT NO.:NC0005312 PERMIT VERSION:4.0 PERMIT STATUS:Expired
FACILITY NAME:Duvaltex CLASS:WW-4. COUNTY:Sutry
OWNER NAME:Duvaltex US Inc ORC:Glen Edward Gary ORC CERT NUMBER:989696
GRADE:WW-4. ORC HAS CHANGED:No
eDMR PERIOD:11-2021(November 2021) VERSION:1.0 STATUS:Certified
SAMPLING LOCATION: EFFLUENT DISCHARGE NO.: 001 NO DISCHARGE*: YES (Continue)
01034 00340 TGP3B 32730 00745
. F F- O S
4g t I m 2 X month Weekly Quarterly 2 X month 2 X month
e a - f
u e• ` Composite Composite Composite Grab Grab
e o 0 O O 2O u a`
a Cr-TOTAL COD CERI7DPF PHEN,TR SULFIDE
U F Z
2400 dock Hrs 2400 dock Hrs Y/B/N lbs/day lbs/day pass/fail lbs/day lbs/day
1 0715 24 0700 9 y NOFLOW
2 0715 24 0700 9 y NOFLOW
3 0715 24 0700 9 y NOFLOW
4 0715 24 0700 9 y NOFLOW
5 0715 24 0700 9 y NOFLOW
6 0700 2 y NOFLOW
7 0700 2 y NOFLOW
8 0715 24 0700 9 y NOFLOW
9 0715 24 0700 9 y NOFLOW
10 0715 24 0700 9 y NOFLOW
11 0715 24 0700 9 y NOFLOW
12 0715 24 0700 9 y NOFLOW
13 0630 2 a NOFLOW
14 0630 2 n NOFLOW
15 0715 24 0700 9 y NOFLOW
16 0715 24 0700 9 y NOFLOW
17 0715 24 0700 9 y NOFLOW
t8 0715 24 0700 9 y NOFLOW
19 0715 24 0700 9 y NOFLOW
20 0700 2 y NOFLOW
21 0700 2 y NOFLOW
I
22
0715 24 0700 9 y NOFLOW
23 0715 24 0700 9 y NOFLOW
24 0715 24 0700 9 y NOFLOW
25 0715 24 0630 2 a NOFLOW
26 0715 24 0630 2 n NOFLOW
27 0630 2 n NOFLOW
28 0630 2 n NOFLOW
29 0715 24 0700 9 y NOFLOW
30 0715 24 0700 9 y NOFLOW
Monthly Average Limit: 1.5 1526.5 I 3
Monthly Average:
Daily Maximum:
•
Daily Minimum:
****No Reporting Reason:ENFRUSE=No Flow-Reuse/Recycle; ENVWTHR=No Visitation—Adverse Weather; NOFLOW=No Flow; HOLIDAY No Visitation—Holiday

•
NPDES PERMIT NO.:NC0005312 PERMIT VERSION:4.0 PERMIT STATUS:Expired
FACILITY NAME:Duvaltex CLASS:WW-4. COUNTY:Surry
OWNER NAME:Duvaltex US Inc ORC:Glen Edward Gary ORC CERT NUMBER:989696
GRADE:WW-4. ORC HAS CHANGED:No
eDMR PERIOD:11-2021(November 2021) VERSION: 1.0 STATUS:Certified
COMPLIANCE STATUS:Compliant CONTACT PHONE#:[phone] SUBMISSION DATE:
12/02/2021
ORC/Certifier Signature: Glen E Gary E-Mail:[e-mail] Phone #:[phone] Date
I certify that this report is accurate and complete to the best of my knowledge.
The permittee shall report to the Director or the appropriate Regional Office any noncompliance that potentially threatens public health or the environment.
Any information shall be provided orally within 24 hours from the time the permittee became aware of the circumstances.A written submission shall also be
provided within 5 days of the time the permittee becomes aware of the circumstances.The written submission shall be made as required by part II.E.6 of the
NPDES permit.
/ /
Permittee/Submitter Signature: *** E-Mail: Phone #: Date
Permittee Address:304 E Main St Elkin NC 28621 Permit Expiration Date: 12/31/2018
I certify,under penalty of law,that this document and all attachments were prepared under my direction or supervision in accordance with a system designed
to assure that qualified personnel properly gather and evaluate the information submitted.Based on my inquiry of the person or persons who managed the
system,or those persons directly responsible for gathering the information,the information submitted is,to the best of my knowledge and belief,true,
accurate,and complete.I am aware that there are significant penalties for submitting false information,including the possibility of fines and imprisonment for
knowing violations.
CERTIFIED LABORATORIES
LAB NAME:Duvaltex US Inc
CERTIFIED LAB#:5010
PERSON(s)COLLECTING SAMPLES:Glen Gary,Billy Stone
PARAMETER CODES
Parameter Code assistance may be obtained by visiting https://deq.nc.gov/about/divisions/water-resources/edmr/user-documentation.
FOOTNOTES
Use only units of measurement designated in the reporting facility's NPDES permit for reporting data.
*No Flow/Discharge From Site:YES indicates that No Flow/Discharge occurred and,as a result,no data is reported for any parameter on the DMR for the
entire monitoring period.
**ORC on Site?:ORC must visit facility and document visitation of facility as required per 15A NCAC 8G.0204.
***Signature of Permittee:If signed by other than the permittee,then delegation of the signatory authority must be on file with the state per 15A NCAC 2B
.0506(b)(2)(D).

r
EXHIBIT D
►RECEIVED
nrr 07 2021
NCDEQ/DWR/NPDtS

BROOKS2000 RENAISSANCE PLAZA
230 NORTH ELM STREET
PI E R C E GREENSBORO,NC 27401
FOUNDED 1897 T 336.373.8850
F 336.378.1001
W W W.BROOKSPIERCE.COM
December 4,2019
Stacy K. Taylor,Esq.
McNair Law Firm,P.A.
Post Office Box 11390
Columbia, S.C. 29211
Re: CMI Industries, Inc.Elkin,N.C. Waste Water Treatment Plant
Duvaltex intends to cease paying for the operation of the referenced Waste Water
Treatment Plant(WWTP) on December 16,2019.
Attached is a Renewal of Land Application Permit WQ0013982 that Duvaltex pursued for
the benefit of the Trustee of CMI Industries, Inc. In all aspects, the WWTP is in as good, if not
better condition, than when it was originally leased to True Textiles. It is being knowledgably
operated by Glen Gary.
Duvaltex has stopped all operations generating a discharge of water. However,the WWTP
still receives a daily inflow of 50,000 gallons a day when water is pumped to the main reservoir to
supply and maintain the facilities' fire suppression system and to manage groundwater. Even if
no pumping to the reservoir is occurring,there is still a minimum flow of around 20,000 gallons a
day from sources unknown and piping unknown. There is literally a maze of piping under the old
plant buildings.
If Mr. Dellinger intends to reuse any of the buildings for other purposes, most of the
sanitary water will flow to the WWTP, as has happened during Duvaltex's usage. It will be a
significant investment in time and money to locate and redirect all of the sanitary water to the
City's WWTP.
When there is a rainfall event, the WWTP will regularly receive approximately 500,000
gallons of water over several days through the internal piping system. Mr. Gary monitors the plant
daily and when enough volume of water is flowing to cause a discharge, he takes a water quality
sample,records the result and monitors the discharge.
Although the current operations are minimal,flow to the WWTP cannot be stopped and it
cannot be closed or abandoned without substantial investment in time and money to manage and
re-route water at the site.
Writer's Direct Dial: Phone:[phone] Fax: [phone] ghou se@ brookspierce.com
Brooks,Pierce,McLendon,Humphrey&Leonard,L.L.P.
Attorneys and Counsellors at Law
4828-4206-3533.v7

i
In any event,all management of the plant will left to the Trustee and/or Mr.Dellinger after
December 16.
Sincerely,
- • C4-
, ii-N,..„-- --;4,z
Gorge W. fuse
GWH/bbh
Enclosure
cc: Mr. Will Dellinger,Elkin Partner Holdings, LLC, 2130 N. Tryon Street,
Charlotte,NC 28206
Mr. Lon Snider(NCDEQ)via email: [e-mail]