NC0004375_More Information (Received)_20040107

NPDES DOCUMENT SCANNINe COVER SHEET
NPDES Permit:
NC0004375
Clariant Corporation
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
Additional Information Receive
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
January 7, 2004
This document is printed on reutse paper - ignore any
conterit on the reirerse aside

Clariant
Clariant Corporation
Mt. Holly East Plant
P.O. Box 669246
Charlotte, NC 28266
Phone: [phone]
Ms. Jacquelyn M. Nowell
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
J A N 1 2 2004
January 7, 2004
Mr. D. Rex Gleason, P.E.
Division of Water Quality
919 North Main Street
Mooresville, North Carolina 28115
Re: NPDES Permit Number NC0004375; Addition of New Waste Source to the Site
Wastewater Treatment Plant
Dear Ms. Nowell and Mr. Gleason;
As required by Section A. (7) of our NPDES permit, I wish to inform you that an
additional on -site wastewater source will begin operations on January 22, 2004. The new source
is an oily water separation process that will be operated by Clariant. It is located in an operating
area of one of the old manufacturing units.
Clariant had originally contracted with Remedial Services Incorporated, RSI, of Satsuma,
Alabama for this work. Because of management problems and construction cost issues, RSI
withdrew from the contract. As a result, Clariant has decided to run the process itself.
Clariant will begin reporting effluent data in compliance with Tier 2 effluent limitations
and monitoring requirements effective January 26, 2004.
If there is any additional information that is needed by the Division, please let me know.
My phone number is 704-822-2787. My email address is [e-mail].
Sincerely;
Gary P. Sanderson, P.E.
Plant Services Manager
cc: David Goodrich-DENR, Nick Altman, Frank Rash, Erin Russell — Clariant

Clariant
Clariant Corporation
MI. Holly East Plant
P.O. Box 669246
Charlotte, NC 28266
Phone: [phone]
Ms. Jacquelyn M. Nowell
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
August 13, 2003
Mr. D. Rex Gleason, P.E.
Division of Water Quality
919 North Main Street
Mooresville, North Carolina 28115
Re: NPDES Permit Number NC0004375; Addition of New Waste Source to the Site
Wastewater Treatment Plant
Dear Ms. Nowell and Mr. Gleason;
As required by Section A. (7) of our NPDES permit, I wish to inform you that an
additional on -site wastewater source will begin operations on or about September 4, 2003. The
new source is an oily water separation process that will be operated by Remedial Services,
Incorporated of Satsuma, Alabama.
Accordingly, Clariant will begin reporting effluent data in compliance with Tier 2
effluent limitations and monitoring requirements in the permit.
If there is any additional information that is needed by the Division, please let me know.
My phone number is 704-822-2787. My email address is garv.sanderson(i;clariant.com.
Sincerely;
,40/1/ ,2,az„pie,t4e\_
Gary P. Sanderson, P.E.
Plant Services Manager
AUG 1 8 2003
cc: David Goodrich-DENR, Nick Altman, Frank Rash, Erin Russell — Clariant

Incident News Summary: September 19, 2000 -
October 13, 2000
Here are news summaries of some of the chemical incidents that were brought to
our attention between September 19 and October 13, 2000. In some cases, a more
detailed story is available at AcuSafe. Due to the overwhelming popularity of this
regular feature, we are expanding coverage to include more transportation -based
incidents and those that may be the result of sabotage. Issues of terrorism, site
security, and transportation are of interest to many of our readers. Readers are
welcome to contribute news stories that you may have read about. If you have read
about a story and would like to share it with other readers, please send it to
[e-mail].
September 17 Cardinal Chemical Co. Columbia, South Carolina Plant
Ordered to Shut Down Following Discovery of Tin; Company Vows to Fight
Order
Cardinal Chemical Co. completed its plant shutdown on September 17, following an
order from the South Carolina Department of Health and Environmental Control
(DHEC). DHEC ordered the shutdown on Friday after low levels of organic tin
compounds were found in a settling pond at Columbia's wastewater treatment
plant. The same chemicals were found earlier this year in Lexington County's Red
Bank Creek, where they are believed to have caused a massive fish kill. An
attorney for Cardinal Chemical rebutted the claims saying there is no proof that the
chemicals came from the Cardinal plant and that the company would fight the
shutdown order.
Sources and Disclaimer:
AcuSafe's Incident News Summary is primarily compiled from Reuters and AP
news wires, and from information shared on the U.S. Chemical Safety and Hazard
Investigation Board Chemical Incident Reports Center. An effort has been made to
summarize stories only from reputable sources, but neither AcuSafe nor AcuTech
Consulting can guarantee the accuracy of the story, nor do they necessarily reflect
the views of AcuTech, AcuSafe, and its staff. We make no effort to independently
corroborate the accuracy of the incident news stories.
ORGANOTIN COMPOUNDS
The greatest use of di-organotin compounds is stabilizers in the manufacture of polyvinyl
chloride, or PVC. The particular importance of these di-organotins lies in their outstanding
ability to preserve the clarity and transparency of PVC, not only when being processed but
also in subsequent service. Organotin-stabilized PVC is used in water pipes and in food
packaging applications as tin compounds used in these applications are known as
nontoxic. In contrast to the nontoxic compounds employed as stabilizers, some
tri-organotin compounds (e.g., tributyl- and triphenyltins) are powerful biocides and have
found use in a number of relevant applications, such as fungicides bactericide in underwater
and anti -fouling paints, preservatives for wood, textile, paper, leather, and glass, and
hospital and veterinary disinfectants. The tributyltin family of chemicals include bis
(tributyltin) oxide, or tributyltin oxide itself, tributyltin sulfide, bis (tributyltin) adipate,
tributyltin methacrylate, tributyltin fluoride, and tributyltin acetate. Tributyltin derivatives have

toxic properties to gram positive bacteria are used as disinfectants on surfaces such as
hospital floors and sports arenas, combined with gram negative bactericides. Tin chemicals
also used as flame retardants to treat fabrics and plastics.
Bis(tri-n-butyltin)oxide is used as fungicide or bactericide for wooden products and
antifouling paints.

EXTOXNET PIP - TRIBUTYLTIN (TBT) http://ace.orst.edu/info/extoxnet/pips/tributyl.htt
EXTOXNET
Extension Toxicology Network
Pesticide Information Profiles
A Pesticide Information Project of Cooperative Extension Offices of Cornell University, Oregon State
University, the University of Idaho, and the University of California at Davis and the Institute for
Environmental Toxicology, Michigan State University. Major support and funding was provided by the
USDA/Extension Service/National Agricultural Pesticide Impact Assessment Program.
EXTOXNET primary files maintained and archived at Oregon State University
Revised June 1996
Tributyltin (TBT)
Trade and Other Names: Trade names include Alumacoat, Bioclean, FloTin, Fungitrol, TinSan,
Ultrafresh and Vikol.
Regulatory Status: Some applications are Restricted Use, primarily those involving potential
exposures to non -target aquatic organisms, such as may occur with use of TBT-containing marine paints
[1]. Tributyltin is in EPA toxicity class II - moderately toxic. Depending on the product, labels will be
required to display the Signal Words DANGER or WARNING.
These paint uses are now regulated under the Organotin Antifouling Paint Control Act of 1988. This Act
sets guidelines on the amount and rate of TBT compounds leaching from marine paints into the aquatic
environment.
Chemical Class: trialkyl organotin compound
Introduction: The tributyltin compounds are a subgroup of the trialkyl organotin family of compounds.
They are the main active ingredients in biocides used to control a broad spectrum of organisms. Uses
include wood treatment and preservation, antifouling of boats (in marine paints), antifungal action in
textiles and industrial water systems, such as cooling tower and refrigeration water systems, wood pulp and
paper mill systems, and breweries. It is also used for control of shistosomiasis in various parts of the world
[188].
Tributyltin compounds are present in varying proportions in commercial products; ready -to -use wood
preservatives typically contain as little as 0.3% TBT, but some products used only in manufacturing may
contain as much as 48% [160].
Unless otherwise specified, all toxicity and environmental chemistry data presented are for tributyltin
1 of 5 8/12/03 10:22 AM

EXTOXNET PIP - TRIBUTYLTIN (TBT) http://ace.orst.edu/info/extoxnet/pips/tributyl.hO
oxide, a representative compound.
Formulation: Tributyltin compounds are present in varying proportions in commercial products;
ready -to -use wood preservatives typically contain as little as 0.3% TBT, but some products used only in
manufacturing may contain as much as 48% [160].
Toxicological Effects:
• Acute toxicity: Acute toxicity of organotin compounds is strongly influenced by the length of the
alkyl chains attached to the tin [160,191]. Tributyltin (TBT) is generally less toxic than trimethyl-
and triethyltins [160]. Generally, the toxicity of organotin compounds is influenced more by the
alkyl substituents than the ionic substituent, which may form the rest of the molecule (for example,
salicylate, acrylate, etc.) [191]. Tributyltin compounds are moderately toxic via both ingestion and
dermal absorption. Reported oral LD50 values for tributyltin oxide (TBTO) range from 55 to 87
mg/kg in mice and rats [191,192]. Dermal LD50 values are 200 mg/kg in rats and mice, [191,192]
and 900 mg/kg in rabbits [31,192]. The tributyltin compounds may be strongly irritating to the skin
in humans, especially the hair follicles, and skin exposure may result in chemical burns in only a few
minutes if the concentration of tributyltin is high enough [191]. Shipyard workers exposed to TBT
(occupationally exposed to dusts and vapors) developed irritated skin, dizziness, difficulty breathing,
and flu -like symptoms [8]. Other mucous membranes such as the eyes and nasal passages may also
become irritated upon exposure.
• Chronic toxicity: Although the effects of tributyltin on humans are uncertain, there have been cases
of human exposure reported. Underwear treated with TBT caused severe skin irritation in wearers,
and shipyard workers occupationally exposed reported reduced sense of smell, chronic headaches,
and feelings of musculoskeletal stiffness [191]. Prolonged exposure to organotin compounds has
produced bile duct damage in several mammalian species [191] and TBT may be a potent
immunotoxic agent [192]. One study of male rats fed TBTO daily for 6 weeks resulted in decreased
resistance to infection [193,194].
• Reproductive effects: Data regarding reproductive effects are limited. In one study, increased fetal
mortality was observed in rats at doses of 16 mg/kg/day [195].
• Teratogenic effects: In a teratology study of tributyltin acetate on pregnant Wistar rats, a dose of 16
mg/kg/day administered on days 7 to 17 of pregnancy resulted in increased fetal mortality, incidence
of cleft palate, irregularities in rib cage, and decreased fetal birth weights [195]. Tributyltin was
associated with offspring behavior abnormalities in another study of rats at doses up to 5 mg/kg/day
[196]. These effects are unlikely in humans at expected exposure levels.
• Mutagenic effects: Tributyltin did not appear to be mutagenic in a large battery of mutagenicity
assays, but produced DNA nucleotide base pair substitutions (point mutations) in one bacterial strain
tested [192]. It produced mutations in Chinese hamster ovary cells as well [192]. The evidence for
mutagenicity is inconclusive.
• Carcinogenic effects: While one study indicates that rats have developed pituitary gland tumors
after exposure to high doses of TBT, the evidence is not conclusive [8] and the carcinogenic status
of TBT is still uncertain [191].
• Organ toxicity: In mammals, high levels of TBTO can affect the endocrine glands, upsetting the
hormone levels in the pituitary, gonad, and thyroid glands. Large doses of TBT have been shown to
damage the reproductive and central nervous systems, bone structure, and the liver bile duct of
mammals. TBT compounds can also damage the immune system.
• Fate in humans and animals: In mice, TBTO is excreted mainly unchanged via the feces,
indicating low absorption by the body. In mammalian species, tributyl compounds may be
2 of 5 8/12/03 10:22 AM

EXTOXNET PIP - TRIBUTYLTIN (TBT)
http://acc.orsiedu/info/extoxnet/pips/tributyl.htt
metabolized to dibutyltin derivatives and related metabolites [192]. An undetermined amount of this
compound is known to remain in fat, liver, kidney, and lung tissues.
Ecological Effects:
• Effects on birds: No treatment -related mortality was observed in a 13-week study of toxic effects of
TBTO in Japanese quail at dietary levels of 150 ppm; at 375 ppm, egg production, eggshell
thickness, fertility, and hatchability were reduced [197]. Thus, tributyltin can be considered
moderately toxic to birds.
• Effects on aquatic organisms: Tributyltin compounds are highly to very highly toxic to many
species of aquatic organisms. TBT exposure to non -target aquatic organisms such as mussels, clams,
and oysters, at low levels, may cause structural changes, growth retardation, and death [198,199].
TBT is very highly toxic to crustaceans. Lobster larvae show a nearly complete cessation of growth
at just 1.0 ug/L TBT [200]. Molluscs, used as indicators of TBT pollution because of their high
sensitivity to these chemicals, react adversely to very low levels of TBT (0.06-2.3 ug/L). They
release TBT very slowly from their bodies after it has been absorbed. Imposex, the development of
male characteristics in females, has been initiated by TBT exposure in several snail species. In
laboratory tests, reproduction was inhibited when female snails exposed to 0.05 ug/L of TBT
developed male characteristics [200]. Imposex was also noted in the mud snail, or dogwhelk, at less
than 3 ppt TBT [200]. Oysters in France and England's marine waters are adversely affected by TBT
exposure. TBT-exposed oysters have abnormal shell development, poor weight gain, brittle shells,
and imposex. TBT toxicity in the field may be substantially underestimated in laboratory studies
[200]. TBT binds to the sides of containers and plankton which contributes to this underestimation
of its potential toxicity. Generally, the larvae of any tested species are more sensitive to tributyltin
exposure than are the adults. TBTO has been shown to inhibit cell survival of marine unicellular
algae at very low concentrations; the 72-hour EC50 ranges from 0.33 ug/L to 1.03 ug/L [200]. TBT
is lipophilic and tends to accumulate in oysters, mussels, crustaceans, molluscs, fish, and algae.
Freshwater species will bioaccumulate more TBT than will marine organisms. Oysters
bioaccummulate TBT compounds readily, reach an equilibrium uptake soon after exposure, and are
slow to release this chemical. Oysters exposed to very low TBTO concentrations bioaccumulated
TBT 1000 to 6000 fold. Juvenile chinook salmon accumulate TBT immediately upon exposure to
low TBT concentrations. TBT and its metabolite, DBT, were found in the salmon's muscle tissue
[201].
• Effects on other organisms: No data are currently available.
Environmental Fate:
• Breakdown in soil and groundwater: Under aerobic conditions, tributyltin takes 1 to 3 months to
degrade [201]. But in anaerobic (airless) soils, this compound will persist for more than 2 years.
Tributyltin compounds may be moderately to highly persistent. Degradation depends on temperature
and the presence of microorganisms. The breakdown of TBT leads eventually to the tin ion [201].
All of the breakdown products are less toxic than TBT itself. It has not been found in groundwater.
• Breakdown in water: Because of the low water solubility of TBT and other properties, it will bind
strongly to suspended material such as organic material or inorganic sediments [160] and precipitate
to the bottom sediment [201]. Rates of sedimentation vary with location, organic content, particle
size, and type of material. Reported half-lives of the compound in freshwater are 6 to 25 days; in
seawater and estuarine locations, it is 1 to 34 weeks, depending on the initial concentration [202].
Because of the low levels of UV light beyond the topmost few centimeters, it is unlikely photolysis
plays a major role in degradation of tributyltin compounds [202]. Levels up to 0.800 ug/L have been
3 of 5 8/12/03 10:22 AM

EXTOXNET PIP - TRIBUTYLTIN (TBT) hup://ace.orst.edu/info/extoxneUpips/tributyl.ho
found along the East Coast of the United States. In the Great Lakes, concentrations from 0.020 to
0.840 ug/L have been recorded. In San Diego Bay a concentration of 1.0 ug/L TBT has been found
[198].
• Breakdown in vegetation: No data are currently available.
Physical Properties:
• Appearance: The physical property data presented are for tributyltin oxide, which is a slightly
yellow, combustible liquid [8].
• Chemical Name: Bis(tributyltin)oxide [8]
• CAS Number: 56573-85-4
• Molecular Weight: 595.62
• Water Solubility: ca. 4 mg/L @ 20 C and pH 7.0 [8]
• Solubility in Other Solvents: Not Available
• Melting Point: 53 C [8]
• Vapor Pressure: 0.1 mPa @ 20 C [8]
• Partition Coefficient: 5500 in 32% seawater [203]
• Adsorption Coefficient: Not Available
Exposure Guidelines:
• ADI: Not Available
• MCL: Not Available
• RfD: 0.00003 mg/kg/day [13]
• PEL: 0.1 mg/m3 (as Sn) (8-hour) [14]
• HA: Not Available
• TLV: Not Available
Basic Manufacturer:
Agtrol Chemical Products
7322 Southwest Freeway
Suite 1400
Houston, TX 77074
• Phone: Not Available
• Emergency: Not Available
References:
References for the information in this PIP can be found in Reference List Number 10
DISCLAIMER: The information in this profile does not in any way replace or supersede the information
on the pesticide product labeling or other regulatory requirements. Please refer to the pesticide product
4 of 5 8/12/03 10:22 AM

EXTOXNET PIP - TRIBUTYLTIN (TBT) _ http://ace.orst.edu/info/extoxnet/pips/tributyl.htr
labeling.
5 of 5 8/12/03 10:22 AM

AUG 07 2003 17:54 FR CLARIANT CORP ENGINEE
8226529 TO 19197330719 P.01/10
Clariant Corporation
Mt. Holly East Plant
P.O. Box 669246
Charlotte, North Carolina 28266-9246
Plant Services Telefax Number: [phone]
11701 Mt. Holly Road
Charlotte, NC 28214
TELEFAX TRANSMITTAL
To: Jackie Nowell
Location/Company: DENR - Div. of Water Quality
Telefax Number:..- . [phone]
Number of Pages (including Cover Sheet): 11
Subject: Quota iou 4 Profile Number
From: Gary att.4erson
Date: August 8 20Q3 -... Phone Number [phone]
Notes: 7aolsio, AttaJhcd is the profile and analytical data on the storp wEdetlhai EPA ....
has been sending iis. Please let me know if you need any additional information.

AUG 07 2003 17:54 FR CLARIANT CORP ENGINEE
8226529 TO 19197330719 P.02/10
Clariant Corporation
Mount Holly East
Waste Treatment
Pre -Shipment Sample Analysis
MHE Profile Number
MHE-2003-0018
Waste Name
Rainwater (Environmental Management)
•
Analysis
Perform Test
Results
PH
Specific Gravity
COD
Yes X
Yes X
Yes X
No
No
No
6.46
1.006
223
Phenols
Respirometry
BOD, 5-Day
Yes X
Yes X
Yes X
No
No
No
Flash Point
1 .w
Metals Scan
Volatiles Scan
Semi-Volatiles Scan
•
Color Description 1r-
Odor Description 06 um
Appearance
Viscosity
Other Observations
Additional Information from Generator or Mt. Holly Observations

AUG 07 2003 17: 54 FR CLAR I ANT CORP Eh UG I HEE
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Clariatit
Clarisot Corporation
Mount Holly Fatt
Wastewater Treatment Facility
(704) 827-901
Profile Number �•�7Z, c°cv -cm1
L Generator Information
C"xen,erator Name
5 A- o `
Physical Address
ccdkg?A ern4c 61 a: Qt0 5. P,arlf 4,‘,.e 64v4
City, State., Zip Code
evjuMtrrA, 5r- 212,13r
Mailing Address
(, I fixA sit. $ W /P- Pic A Q /6 / C ,/, ,r--
City, State, Zip Code
444/4, GA S o 5 a 3 - -
Phone Number
'A ' 7di - A 04 8
Pax Number
(01. 7a oo e q
EPA ID Number
5417 Qb 33' ijc/q:-
Prvnary Contact
T:2ty re4Js
Site Business Description
kiyer-F .../ . -creel
SIC Code(s) of Facility
_ —
IL Bl linit Information
Customer
CMt3
Address
jdr t.bity'r,`" Cr+1 i- Dr.
SW ,le 38
City, Stat
Code
CAArtes f St. ZTL112
Contact Name
at M-ite 1,04
Phone Number
ji 3. K2,. -7-S
Fax Number
$L 1. 76 2_, 7 7u3
ILL 'Waste tion
Write Nam_Ida
Description of Process
Geneaatinn Waste
ids
t lr� ra; e „,1__ D •, ; ¢�
SIC Code® Associated
withthe Generation of this
Waste Stream
___9
EPA Waste Codes)
IV. Waste Characterit es
Physical Mate
■ S +lid if Liquid
Sludge
Layering
IOt+ one Bilayer
Multiaver
Viscosity
R. Low • Medium
Thick
Specific Gravi
Flash Point
None < 140 F
> 140 F
PH Ras e
fS 4 xo "'j
Odor
rnoy
Color
clot" - G(iv 4- la.110.,
-
1
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FEB 21 2023 1.4:34
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AUG 07 2003 17:55 FR CLAP• I RNT CORP ENG I NEE
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Mount /folly rats
Wastewater Treatu1eat >r aciltty
(704) 9274651
Chemiell Compositioi LIST S A.R.A. 313 T.RI. CHEMIGALS P.K.. ,WV.1
Conrtftuent
]R2n e
op_
Units
Is a Material Safety Data Sheet Attached? ❑ Yes IS‹
VI, TLCP Certification
1 Above Below Actual
•• i Above elory Actual
11Fl
D001- �r'tabili — —
■
■ D023 — o-Cresol
0
■
11 !1 - 1 ■
11111111111111111
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■
1
D003-Reactivity
11 D025 — r Cresol
I004 —Arsenic
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11 D026 — Cresol
DOOS — Btuium
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D027 — r-Dichlorobenraa
1
11
11
D006 - Cadaliu ' -
0007 — Chromium_ .- _. _ _�_--_-
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!I 0028 - l�2-D;chlaratitanC
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D009 M
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DOI2 — Endrin
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11
D034 — i cxarrhlmolrthane
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D013 — Lindanc
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11
D035 —Meth TEt.L 1Kctiuo
D014 — Mcthoachlor
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D038 — P 'dine
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D017 — 2,4,5-TP(Silvex)
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DO3P - Tetrachloreethene
DO 18 —Benzene
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11
D040 -• Tricolor ,et}tC�ne
13019 — Carbon Tetrachloride
D041 — 2,4.5-Trichloropbenol
1 D020 — Chlordane
1.1
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D042 — 2,4.6-Trichlorvpbenol
�■ 11
D021 — Chlorobenzene
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■
11 D043 — Vinyl Chloride
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D022 — Chloroform _ _
Above TCLP Based on Actual TestinGenerator Knowled
Is this waste a listed waste pursuant to 40 CFR Pant 261? ■ Yes
Is -dais waste a decharacterrized RCRA DUQ2 corrosive waste?
2 of 4
Both --
FEE 21 2003 14:34
7627763 PAG6.03

AUG 07 2003 17:55 FR CLAR i ANT CORP EHG I NEE
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8226529 TO 19197330719 F. 05.i 10
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Oartaat Corporatdou
Mort Bolffy East
Wutewater Treatment.acdlity
[phone]
VII. Other Components
Does the waste stream contain any of the following components?
Component -
-
Yes No Actual Concentration
.4
PCBs
Cyanides
Sulfides
- . _ ..-. - - _
-
-]Pesticides
0
-
Phenolics
_Phenolics
\ _ _
._
T
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J
Halogens - _ -
-0
Mar'. Shipping information
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One Time Weald onthly II Quarterly E Yearly
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Drums S Cs ILVBulk Tanker 0 Oath
DOT Shipping Name
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Hazard Class
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YJN/NA Number
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IX. Categorical Standard Determination
Is the process generating the waste lasted in the
"categorical" standards pursuant to 40 CFR
Subchapter N7
0 Yes
[No
If you answered yes to the previous question,
which "categorical" standard is the waste
subject to?
3 of 4
FED 21 2003 14:35
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AUG 07 2003 17:55 FR CLAP. I ANT CORP ENIG I NEE
I f UIII•LIVY It\LJI IYIl-�rinuriu!
9226529 TO 19197330719 P.07/10
l VLJ •v • -,V ••vr.- . •vv•
•• iBtosYrrEMs
c1ie=t #: PTL-12-030101
Adr3res,a: CP3C, Inc.
2010 Beltline Blvd.
Columbia, SC 2920:-
Attn: C. Leggett
Sampla Doincriptibn:
Cazdinal Chemical Site
Parameter
.. +u•.•vvlsMtompcunaL
11-Mit 'csoci_mot.hylanint
Dhenol
Bim(2-Chlorot+thyl) Ether
2 -Ch1 arop!Sencl
2„ 3-D: c.171.orobenzeme
1, 4-Dich7.arabenter'id
1,2-Dichlorobe_nLene
Bid (2-Cbl,oroi opropy1) Zther
N-Nitrocodi-n-ptopylani E
l;exachlcrQsthane
'iitrobenzelto
1=opaoront
2-1/itraphenal
2, 4-piir•nthylp?>,enol
/31 (2-chloroctroxy)mothane
2,1-Dichlarophaaoi
1, 2, d • TrAchl orobenaezle
Naphthalene
Hexzchlorabutadiene
4 -Ch14ro-3-Metby1phe;,o1
HbxAeAl.orocyr.loperte e,
2,4,6-Trihlorophencl
2-Ch1oronapht?a1ene
DimeChy1phthal ecia
2, 6-Dtnitrotoluman
Acenaphthylene
Acenapht?:ene
2,4-Oinitrnhenal
2,4-Dinitr,otoluene
Page: Pogo 1 of 4
Data: 01/27/2003
Log #: L72042-1
Analytical Report: CC-SW'r-01
Date' Sampled! 01/20/2003
Time Sampled; 03:00
Ante Received: 01/21/2002
Collected By; Client
Rteul,ta Qnits Method.
Roportablc Sxtr. hn1y.
Limit Data Date R,r:alyet
5,01, ug/1 625 10 C1/22 01/23 Gri
5DL ug/1 625 10 01/22 o1./23 GM
RDL '_g/1 625 10 01/22 0a/23 GN
DDL ugJ1. 625 10 01/22 01/23 GM
:Mt, 11g/1 625 10 o1/22 01/22 GAS
EDL 1.1g/1 525 10 01/23 01/23 GM
221, t1gil Eli 10 01/22 01/23 GM
P77., U5/1 625 10 01/22 01/33 GM
3DL ug/1 625 10 01/22 01/23 GM
8=1. ug/1 G25 10 01/22 01/23 GM
'WI, ug/1 625 10 01/22 01/23 ell.
907, ug/1 625 10 03./22 01/23 C,1
EDL 0g/1 c25 50 01/22 01/33 GM
am ug/1 6::5 le 01/22 QI./23 GM
Dnz. ug/1. 625 10 01/22 01/2) rm
:AD1. ug/1 625 10 01/22 fl:,/23 GM
9L ug/1 625 10 01/aa 01/23 G1
MIL ug/1 625 10 01/22 01/23 QM,
P•bL uc/1 525 10 01/22 41/23 GM
}rDL uq/1 5z5 10 o J 2 0J /23 GIB
nDI,, ug/1 625 10 01/22 01/2^s G14
EDI, ug/1 625 10 01/22 01/23 GM
PDT.. ug/1 625 10 01/22 01/33 GM
nm ug/1 625 10 0102 01/33 GM
Zvi.) ug/1 625 10 01/22 01/23 GM
DDT, t;,g/k 625 10 01/7.2 01/23 GM
sDrJ ugil 625 10 0l/22 02/23 GM
bDL ug/1 625 50 01/22 01/23 C-?4
Dx ug/1 625 10 01/22 01/23 CM
U9 Diorysta1L'C 3t3t ?%r 7th xYaau'a Soca Rates, FL 33431 (668) 862'5227
FEB 21 2033 14 36 7627763 PAGE.07

AUG 07 2003 17:56 FR CLARI NT CORP ENGIHEE
rrom•ENY1I'MVIYLINItL51U1 IUGI!U.1
8226529 TO 19197330719 P.08/1,O
ULI" L. LI LVVV Pa•-ry .rvvv I .vvv
Client #s FTL-12-030.01
Address: CMC, Inc.
2010 Be .tline Blvd.
Columbia, SC 29201
Attn: C. Leggett
sample Description:
Cardinal C:neriica1 site
parameter
4.7ritrophena7
Diathylphthelnte
Fluorene
4-c1:1orapheny .-phorylotber
4, 6-Dinizro-o-C:7er,cl
Z .Nitrgsodiphnylami.n3
4-Bso:zophenyl-phenylether
Heyachlorobenzene
wentachloroplmnur
Phec i.:nth.reme
Antb"sccna
pi -ir. sutylprthal dte
luvranther.e
tenz'1nimm
Pyrene •
Butylbeazyl]hthalate
de3zo fel anth7rtsccne
3, 3'=Dic)-119 cboatidin_
ehryMenn
Ai,n (2-Bthylhexyll Pathal,ate
Di-N-Oczylphthelate
3eilLo P. ] �luoxantztne
RNt2Le [k] fluexenc}±sr.e
5enzolo)pyrrne
ind000(1„2,3-cC]l?yx e
1:ibenzo [tz, hJ 1 thracene
'`ense gig, h, !.l pezylana
Dilation Factcz
Surrogate RoCoveriec:
2-Fluorcphanol
Q}ibtlol - is
Nitrobenzene-d5
2.1,1uo_ cbi,phanyl
2. 4, 5-:•ribromophenol,
Texp:n n ayl- F_1 t
q "µ 7 i" utlde
aromQd i chloz ome thsna
Results
(continued)
2DL
SAL
BDL
3aL
�{7V
Snit'
EDL
BD!.
2Pt
2DL
]snit
SDL
3,DL
5DL
9�L
EaD1,
BOL
3ML
SZ L
nDL
EDL
t+1:+
SOL
L.7
Page: ?5e 2 cf 4
Dat.ct C1/27/2003
Log 43 L72042-1
Analytl:al gopoxt=:
Date sampled:
Time Sampled:
Date Received:
Collected eyi
CC-SWT-01
01/20/2003
08:00
01/21/2003
Rapor table Extr.
Daita 2Sethad Limit Date
ply.
eat,"
Analyst
.ls/1 625 10 01/22 01/23 GM
119/1 f25 10 01/22 01/23 GM
ug/1 625 10 01/22 01/23 GM
ug/1 625 10 of/22 01/23 GM
ug/1 625 60 b1/22 e1/23 GM
ug/'- 625 13 01/22 01/23 GM
ug/1 f25 _] 01/22 01/23 GM
ug/1 E25 43 01/22 01/23 G}
us/1 E25 57 01/22 01/23 GA:
'.3g/1 E25 10 01/22 01/12 Gi5
uy/1 C25 10 61/22 01/23 G1,
ug/1 625 10 71/22 01/23 Cl,
ug/L 625 10 C1/22 171/43 OM
us/1 Gas 30 02/22 01/23 GM
v.,�/1 E2; 10 01/22 01/23 GM
uc/], G25 10 01/22 Q1/2! GM
1.15/1 66 10 01/22 01/23 CN
ug/1 G20 20 02/22 0L/22 am
ugh 425 10 01/22 01/23 CM
us/1 625 10 01/22 01./23 GM
ug/1 625 10 01/22 01/231 GM
v./l 625 10 071/22 01/23 GM
un/1. 625 10 01/22 01/23 QM
115/1 625 10 D1/22 Oli2.3 GM
ug/1 525 10 01/22 03/23 .M
115/1 623 10 71/22 01/23 3.1
x4g/1. 625 10 111/22 01J13 GM
525 011�2 0I/23 cm
25.0 a 62t 10-1.}•3 01/22 Al/J G31
21.0 k 625 10-137 01/22 01/23 GM
57.0 t 625 2a-116 01/22 01/22 rM
75,0 b 625 45-126 01/22 01/23 GM
79,0 625 51-114 61/22 01/23 CM
06,0 k 639 50-14.6 01/22 07./23 Gm
liDJ4 ug!1 524 1.0 01/22 01/22 DL
4911 ' 52i 1.0 o1/22 01/22 9b
vt Biosysteu8 :271 `SW 7th hVe_ua A7c, 24E5n, 7I. 37431 (6;1)&52.5227
-+^-•-r,•— �'1'� .•4•i i• �. 'i.. ...r itii �t: .. •'�f�, 'f•. :.1' .:i
FEB 21. 2003 14 : 36 7527763 P11GE. 6B

AUG 07 2003 17:56 FR CLARIANT CORP ENGINEE
1 t Um•I-i\r 1lwirinLlri 11t_mu i
8226529 TO 19197330719 P.09/10
V4. ca. C..%# .v 'WV IIvvv
Client 4#: M..12430101
Ad tress: CMC, 7no.
2010 Raltline Blvd_
ColumbiA, SC 29203.
AZ= C. LeggeCX
Sample Desariptic1n:
cardinal Chemical Site
par tar
3zo=sorm
Eromemethare
Cauca Tatrtehlorids
Q1orobanzeme
Ch1=oe:khene
2-Chloreetryl'ir_yl Ethos
C) lorofvrn
Chlorotiathx. e
D31:ranoe7.110rome than s
1, 2-DAchlorobenze:la
1,1-DichlOr0b0t2e710
1, 4.0i ch1orokemzertt
Dichler011f1morcRetba.ne
1,1-DiehlcrOQthbne
1, 2-Di411croethene
10.-Dighlcroathana
Cls-1.2-D1ahloraeChaist
Tr.r2-1,2-Diebloroethen6
1.2-Dietio='opcopene
cio-1,3-Diehleropsopene
Tr sans .1. 3 -D_ chl orapropece
_thylbehzene
};errhylxor Chloride
MTBE
1,1,212-Tec_a_hloroethene
Tetrechl,droat.r6ne
Telmer,
DOt01 Xv1enes
1,1, 1-7rit:aloroethana
1,1,2-'Frich1 rckthane
Tric hloreetltene
Tr ic111orcEluarocetbane
vivyl Chloride
Diluti0h Factor
sterogata Re eaveriaar
Di rotoatluoscfi4tha c
2 1tIe a-tae
4-3romo4luorobarze e
ito cul is
(Gertinued)
EDL
air•
bDL
3Dr
DnL,
2D1
?t:L.
SDI.
ErL
3r1.
DLL
soL
err.
tarsi,
5t2..
DLL
EDL
E>,�
EDL
BDL
DDL
3y�D�yL
2Dir
-2DL
EDL
EDL
311.
1.0
a2,0
68.0
Pages Page 3 of 4
Date; 01/27/2003
Lag #: L72042
Analytical Report:
Data Sampled:
Yuma SamFled:
Dater' Received:
Co11$ctad 8y:
CC- SW a'- 01
01/20/2003
00:00
01/21/2003
Client
RapQrb.ble txtr.
Unita Method Limit Vast*
C24 1.0
624 1.0
624 1.0
624 1.0
824 1.0
524 10
52. 1.0
624
424 1.0
E24 1.0
524 1.0
621 1.0
E?4 1.0
624 1.0
624 2.9
624 1.0
624 L.0
6-4 1.0
624 1.0
514 1.0
624 1.0
624 1.0
624 5.0
624 L.0
624 1.0
624 1.4
624 1.0
624 2.0
624 1.0
624 1.0
624 1.0
624 1.0
624 1,0
624
624
624
624
5E-145
64-2:13
54-135
ya1y.
Data Ma3YRt
01/22 01/22
01/22 01/22
01/22 01/22
01/22 01/22
01/22 01/22
01/22 01/22
02/22 01/22
01/42 02122
01/22 01/23
01/22 01/22
01/22 01/22
01/23 01/22
01/22 01:22
01/23 01/22
0z/22 01/22
01/22 01/22
01/22 03/22
01/22 01/22
Cs/23 02./22
01/23 0_/22
11/22 1V22
01/22 1 /23
C1/22 01/22
01/22 01/22
01/22 01/22
01/22 01/223
0sl22 01/22
01/222 01/22
01/22 01/22
41./22 01/22
01/21 01/3's
01./22 pin:
01/22 01/22
01/32 01/22
01/22
02/22
01/22
t/* ■iory.iti1 . $5Ai inn 7th lutru■ 13ee4 Assoc, 1rt 19424 044j1:4-S227
01/22
01i27
01/22
2L
ZU
3L
EL
6L
9L
131
FL
3L
EL
SL
EL
5L
oL
EL
BJ
EL
9L
gL
8t.
BL
aL
21.
EL
�lr
rL
ZL
EL
sL
EL
aL
8L
EL
8L
FEB 21 2003 14:37 7627763 PAGE.09

AUG 07 2003 17:57 FR CLARIANT CORP ENGINEE
rr uni•L.ir7 inviymuricLmui rvc.r,vv
8226529 TO 19197330719 P.10/10
VL/ i. ( LVVV IY-v.• nvvv
client 4: Try.-12-030101
,ddre su s CMC, I77.C.
2013 3eltline Blvd,
Columbia. $C 29201
Attn: C. ieggett
Sample 1 eacri.ptions
Cardinal Chemical Site
Parss:loter
Page: Page 4 of 4
Date: 01/27/2003
Log #t 1.72042..
Analytical, Report: CC-3WT-01
Date Sampled: 01/20/2003
Time Sampled: 08:00
Date Received: 01/21/2003
Collected By: Client
Repmveable Mar. An1y.
results Mitt NOt}t6d Limit DAta bate Analyst
Antimony ROL %OA 200.7 0.0F0 0L/22 01/27 F9
resole nm , mg/1 200.7 0.010 0./22 01/22 SB
Beryllitst > L mg/1 200.7 0.0040 01/22 01/22 SB
Cadmium BM mg/3 200.7 0,00so 01/42 01/22 sB
Chromium o.oc7, - ma/a 250_7 0,00s0 01/22 01122 s3
copgT_ obis : mall 270.7 0,010 0./22 01/22 s8
Leach =ix ma/1 220,7 0.0030 01f22 01/Z2 S5
Nickel ( 0.53 meJ1 270.7 0.00;0 01[22 01/27 53
Seltsniu;n -- DU rye/1 200.7 0.010 01(02 01/22 03
Silver SDL M7/1 200.7 0.010 01/22 01/22 S3
halls= BDL ng/X 200.7 0.010 01/27 01/21 S3
zinc 2.3_ MV/3 200.7 0.20 01/22 01/22 S3
mercury "ICL mg/1 20.1 0.0c020 oa/z5 oa/23 lir.
agROMEIWWWiggRa
Chsrtrical exygsn Demand mg/1 0.0.4 10 DI/27 01/27 CC
PH PH units 150.1 0.10 01/27 01/27 AK
A11 oralYop. ticis peofesa+ad %msns =lax, xeT4. r753N. U¢•la, eD seirtara arr.t.:de chi eev i:itd t, asst ►:61AC iegs'.te7rn;+.
}71„cr Z t. Oe v*p rt;'tG liR4r4 DL•=37:41,0d p+ir.: 1.-�te:s $.nere'..ab 145 ilr:Lrr 141.0A:.-:Y Jrl4At:i; .sGr 0.-ra.t: 021.
71J7r: CFk'T'hiCA tel•: ru•ann d■CiCt(R:. ertin.Ile3)r SIS-tm :'CH :S,aiFsr dv-c7y'.I w-vaC 14j Ctif•sce mtudhed Cat
JJi+,Kr fleas: J all-ermiumhe4 l:aurz :xi: 7:av kreY1 oe reit. ;mCC Lai is 6{ yr 4+oic7lx :-e- csZnpsaacIT t3a. pzctc. 1
leaf Ab521 L-.ncraa oa}dl:..e:dnr C-1•n:d:a7 :lar KeLs l.v:urn. In Flank
FLO27 Y a ,, !' show. ' r priscrvor.0 :1 3-ca:cn. i<rC tk=eei :err,, :•Ncul= >7eSroin X= a14 T' L
Ohre J.q:.a halts/ 310.4e ?C =To tal
147a cpng 001's.^.E4?C9.e0a0411 MEN nig iq;d4 1t, tlttt;`JI =o4e70
EC cr'i v i031031 1N C::w:i :205
Mac 0A CER:p S17
V, Cfkrp C0375 r.EDA 6c11 PtrAttii S.,3 7i0
Eesp4Cl:4L1y s bmd.ted,
Stave Waltoh
Clitat 7CeCi:nival Svcs. mar.auar
um hiamyotsma limit UN 7th 1Yo:rda► xroaa flacon, 11 311J3 (ani)1024«27
FEB 21 2003 14:3? 7627763 PAGE.le
** TOTAL PAGE.10 **

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ital=1/11_
A
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pi
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14I14111.11111111111
11•
-
kaINON11111111
Ell
INElidriErAlEfiinfail•
III
IN
4,
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ma
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( 4I Air/ oc/cF

AUG 06 2003 09:48 FR CLARIANT CORP ENGINEE
8226529 TO 19197156048 P.01/04
is : Tei_c / 42- `. b\A "-1 i
Cl ari ant
P.O. Box 669246
11701 Mt. Holly Rd.
Charlotte, NC 28266
Phone: [phone]
Fax: [phone]
Fax
To: t 1q 0; 101"1.1u-ei
Fax: '� l r�.,r-7 (/ �%' Date d D 6 ^ r .
Phone:
From:
Pages:
Clariant
die/ 6-PA
CC:
❑ Urgent kor Review ❑ Plcasc Comment ❑ Please Reply
Comments:
Sk J )` S i (. e Lc p t f oa
45 s,sram)
fr t-kd uu inA.0 1_ f Iekc C.
QL) s rV 5.

AUG 06 2003 09:48 FR CLARIANT CORP.ENGINEE 8226529 TO 19197156048 P.02/04 •
Clariant
Jack Cowart
USEPA
61 Forsyth Street SW
Atlanta, GA 30303
Clariant Corporation Mt. Holly East Plant
P.O. Box 669246
Charlotte, N.C. 28266-9246
Phone [phone]
FAX [phone]
May 28, 2003
Re: Request for Approval to Receive Off -site Non -hazardous Wastewater front CERCLA
Sites
Dear Mr. Cowart;
Earlier this spring the Clariant Mt. Holly East facility began receiving stormwater from a
facility in South Carolina that is being cleaned up by the EPA. The site is Cardinal Chemical
and is located in Columbia, South Carolina.
Mr. Ben Frank of USEPA and I discussed the need for disposing of the water in an
apRroved. "off -site" disposal location. As a result of bis phone call and my call to you on May
227 ', we wish to make application for "off site" approval.
The site's physical address is:
Clariant Corporation -- Mt. Holly East Plant
11701 Mt. Holly Road
Charlotte, North Carolina 28214
The site is located in Mecklenburg County, North Carolina. Our mailing address is in the
header section of this page. Please address any correspondence to the mailing address and to my
attention. If you prefer to correspond via email, my email address is
gary.sandcrson(clariant.corn.

AUG 06 2003 09:48 FR CLARIANT CORP ENGINEE 8226529 TO 19197156048 P.03/04
Letter to Mr. Jack Cowart, dated May 28, 2003 page 2
The Clariant plant disposes of non -hazardous wastewater for many customers in a
classical activated sludge wastewater treatment plant. The site has an extensive approval protocol for prospective waste streams. We test each shipment and compare the results with
analytical results obtained from "preshipment" sample(s). Non -complying shipments are not
unloaded unless the generator can provide sufficient information to assure Clariant as to
treatability of the load.
Below is a list of our existing environmental permits, the contact person with the North
Carolina Department of Environmental Protection and date of last site inspection_
1. NC0004375, direct discharge wastewater
Permit Writer: Ms. Jacquelyn M. Nowell, phone [phone] Phone 704-663�
Last Facility Inspection: May 30, 2002, conducted by Mr. John Lesley.
1699
2. NCD00110365, RCRA facility identification and Part B permit number
Permit Writer Mr. Karim Pathan, P.E., phone [phone] efts. Phone 704-
Last Facility Inspection: May 21, 2003, conducted by Mr. Mark Bum
282-0697
3. WQ0000537, sludge residuals landfill cell
Permit Writer: Ms. Shannon Thornburg, phone [phone]
Last Facility Inspection: Sunnier 2002, conducted by Ms. Ellen Huffman and Ms. Peggy
Finley. Phone [phone]
4. 08542R16, air emission permit
Permit Writer: Mr. Ken Babb, phone [phone]
Last Facility Inspection: Week of September 2, 2002, conducted by Ms. Janet Boyer.
Phone [phone]
5. NCS000037, stormwater permit
Permit Writer Not known
Last Facility Inspection: None in the last five years
As I mentioned in our telephone conversation, the plant site is a Superfund Site. I have
enclosed a one page history of the site and a one page environmental brief as well. Hopefully,
these will provide you with sufficient summary information. If you need more details, we are
happy to send more details. The person in EPA that is the most familiar with the site is Mr.
Michael Townsend of Region IV.
I am enclosing a few more documents that may be of help in assessing our site. One of
those is the protocol we use to investigate and approve prospective wastewater streams.

AUG 06 2003 09:49 FR CLARIANT CORP ENGINEE 8226529 TO 19197156048 P.04/04
Letter to Mr. Jack Cowart, dated May 28, 2003 page 3
I did not include drawings or design specifics of our wastewater treatment plant, WWTP,
but will summarize it's specifics below.
The WWTP is a large conventional industrial plant process. The headworks consist of
pH neutralization facilities, settling, and solids filtration. There is a 4 million gallon equalization
pond that the headworks system feeds into. A 2.5 million gallon activated sludge oxidation unit
removes organic molecules. Two 2.5MM GPI) clarifiers follow the oxidation unit.
The WWTP is designed to treat 4.9MIvi GPD of heavy chemical industry wastewater.
Our normal throughput is only 600,000 gallons per day.
Thank you for the helpful information regarding what details you need in order to assess
our acceptability as a vendor for treatment of CERCLA wastewater. We are more than happy to
send you any additional materials you may need. You are welcome to visit and tour the site at
any time.
Sincerely.,
Gary P. Sanderson, P.E.
Plant Services Manager
Enclosures:
1. Site History and Environmental Brief
2. ROD Fact Sheet
3. Wastewater Acceptance Protocol
cc: Mr. Nick Altman, Clariant
Mr. Williams Grier, Clariant
** TOTAL PAGE.04 **

Clariant Corporation (MHE) - Jack Cowart Telephone Call
Subject: Clariant Corporation (MHE) - Jack Cowart Telephone Call
Date: Wed, 06 Aug 2003 10:48:40 -0400
From: Shannon Thornburg <[e-mail]>
Organization: NC DENR DWQ
To: Mark Mcintire <[e-mail]>,
Jackie Nowell <[e-mail]>
CC: Ellen Huffman <[e-mail]>,
Peggy Finley <[e-mail]>, John Lesley <[e-mail]>
Jackie & Mark,
I talked with Mark about this situation before I knew that you, Jackie,
were the permit writer for this NPDES permit. But, I wanted to let you
know that I am going to send down copies of the letter that Clariant
Corporation sent to Jack Cowart of EPA Region IV. It took me awhile to
obtain a copy because Mr. Cowart would not fax it to me and my contact
at Clariant and I just finally got in touch with each other this morning.
To summarize this situation, Mr. Cowart called several people at MRO to
ask if it was o.k. for Clariant to receive Superfund waste into their
facility. Unfortunately, he did not provide enough information, so we
all were a little confused. But, here is the deal: Clariant would like
to accept non -hazardous stormwater and groundwater from a third party
site (Cardinal Chemical in Columbia, SC) that is being remediated by EPA
under the Superfund program. The stormwater and groundwater would be
introduced into the NPDES facility (as opposed to the on -site monofill,
which is how I got involved) and treated with Clariant's wastewater.
My contact at Clariant, Glenn Pysell, states that the NPDES permit does
allow the acceptance of third -party wastewater. But what Mr. Cowart
needs is some sort of assurance that there is not a problem on a State
level with his writing of a Notice of Acceptability. Now, that I
finally understand where this waste is being introduced into the
wastewater treatment process, I do not see it being an issue from our
monofill permit point of view. However, Mark indicated to me previously
that a minor modification of the NPDES permit may be required. I would
like to call Mr. Cowart back and let him know that everything is o.k.
from the non -discharge side and would like to tell him that someone from
the NPDES Unit will be contacting him directly about that permit. Would
one of you be willing to talk with him about the possible
acceptability/unacceptability of Clariant's request from NPDES's
standpoint? His telephone number is (404-562-8591). If some sort of
minor modification of the NPDES permit would be required, someone may
want to call Glenn at Clariant (704-822-2719) to discuss what needs to
happen, etc. Also, I would be interested in what you guys decide!
Thanks for your help!
Shannon
�+4
7by a12 -27v7
1 of 1 8/6/03 11:41 AM

Re: Clariant Corporation (MHE) - Jack Cowart Telephone Call
Subject:
Date:
From:
Organization:
To:
CC:
Re: Clariant Corporation (MHE) - Jack Cowart Telephone Call
Wed, 06 Aug 2003 11:41:22 -0400
Jackie Nowell <[e-mail]>
NC DENR DWQ
Shannon Thornburg <[e-mail]>
Mark Mcintire <[e-mail]>,
Dave Goodrich <[e-mail]>
Hello Shannon, I talked with Mr. Cowart yesterday and Gary Sanderson of
Clariant last week. I'm in the process of reviewing Clariant's permit to
confirm that this additional stormwater can be added. The most recently
issued permit had tiered limits pages for when Clariant would take on
additional third party wastewater. Clariant currently accepts ww from other
sources and they anticipated taking on more, so additional limits and
monitoring were included.
The stormwater and well water from Cardinal Chemical is supposed to be
nonhazardous. Information that I've found said that Cardinal used to
produce organotin compounds which was used to make PVC. Since the cleanup of
the Cardinal Chemical site has been going on for a couple of years, I'm
assuming that this is not the most contaminated stormwater. Mr. Sanderson
has indicated that preliminary sampling of the stormwater they would be
receiving shows its pretty "clean".
I'm checking the permit to see if proper monitoring/limits for this
stormwater are included. Will let you know what our final decision is, but
right now it appears that Clariant had prepared for taking on additional ww
from third party sources.
Shannon Thornburg wrote:
Jackie & Mark,
I talked with Mark about this situation before I knew that you, Jackie,
were the permit writer for this NPDES permit. But, I wanted to let you
know that I am going to send down copies of the letter that Clariant
Corporation sent to Jack Cowart of EPA Region IV. It took me awhile to
obtain a copy because Mr. Cowart would not fax it to me and my contact
at Clariant and I just finally got in touch with each other this morning.
To summarize this situation, Mr. Cowart called several people at MRO to
ask if it was o.k. for Clariant to receive Superfund waste into their
facility. Unfortunately, he did not provide enough information, so we
all were a little confused. But, here is the deal: Clariant would like
to accept non -hazardous stormwater and groundwater from a third party
site (Cardinal Chemical in Columbia, SC) that is being remediated by EPA
under the Superfund program. The stormwater and groundwater would be
introduced into the NPDES facility (as opposed to the on -site monofill,
which is how I got involved) and treated with Clariant's wastewater.
My contact at Clariant, Glenn Pysell, states that the NPDES permit does
allow the acceptance of third party wastewater. But what Mr. Cowart
needs is some sort of assurance that there is not a problem on a State
level with his writing of a Notice of Acceptability. Now, that I
finally understand where this waste is being introduced into the
wastewater treatment process, I do not see it being an issue from our
monofill permit point of view. However, Mark indicated to me previously
that a minor modification of the NPDES permit may be required. I would
like to call Mr. Cowart back and let him know that everything is o.k.
from the non -discharge side and would like to tell him that someone from
the NPDES Unit will be contacting him directly about that permit. Would
one of you be willing to talk with him about the possible
1 of 2 8/8/03 2:08 PM

Re: Clariant Corporation (MHE) - Jack Cowart Telephone Ca11
> acceptability/unacceptability of Clariant's request from NPDES's
> standpoint? His telephone number is (404-562-8591) . If some sort of
> minor modification of the NPDES permit would be required, someone may
> want to call Glenn at Clariant (704-822-2719) to discuss what needs to
> happen, etc. Also, I would be interested in what you guys decide!
> Thanks for your help!
> Shannon
2 of 2 8/8/03 2:08 PM

[Fwd: [Fwd: Clariant Stormwater acceptance]]
Subject: [Fwd: [Fwd: Clariant Stormwater acceptance]]
Date: Tue, 05 Aug 2003 16:04:17 -0400
From: Jackie Nowell <[e-mail]>
Organization: NC DENR DWQ
To: Dave Goodrich <[e-mail]>
CC: Jackie Nowell <[e-mail]>
Dave, received a call from Jack Cowart of EPA regarding the subject
facility. He indicated that Clariant would be receiving nonhazardous
stormwater and nonhazardous well water. There is an "offsite rule" that
requires that Clariant receive a notice of acceptability.
He wants to know from us whether Clariant has any significant violations
and any significant releases. He has talked with John Leslie of MRO who
has told him that Clariant had neither of the above. EPA wants to know
if Clariant needs to modify their permit to receive this wastewater. Or
if there is any condition in the permit that would prevent them from
accepting this ww that's going directly into their treatment plant.
He doesn't believe that the source of the ww, Cardinal Chemical in
Columbia, SC really needs to go through this, he thinks the water can
probably be dumped on the ground (?). The company may just need to
cover themselves by sending it to another place to have it treated.
He's not even sure that the Cardinal Chem cleanup qualifies as a
Superfund site.
If Clariant's NPDES permit says that they cannot take it, then he'll
deny the notice of acceptance.
Subject: [Fwd: Clariant Stormwater acceptance]
Date: Wed, 30 Jul 2003 17:38:47 -0400
From: Jackie Nowell <[e-mail]>
Organization: NC DENR DWQ
To: Jackie Nowell <[e-mail]>
Gary's email is [e-mail]
Phone # [phone]
Subject: Clariant Stormwater acceptance
Date: Mon, 28 Jul 2003 16:38:31 -0400
From: Jackie Nowell <[e-mail]>
Organization: NC DENR DWQ
To: Dave Goodrich <[e-mail]>
Dave, I got a call from Gary Sanderson about Clariant accepting
stormwater from Cardinal Chemical in SC. The stormwater is basically
clean water, however Cardinal can't treat it. Clariant would accept it
as wastewater influent and treat in their plant. EPA has gotten
involved and says that Clariant needs a CERCLA(?). Jack Coward of EPA
may be calling us to see if Clariant can accept this stormwater.
Gary has told the company that he thought they could accept the SW and
any ww with biodegradable organics. the water will be tested before
being sent to Clariant. the volume to be discharged will vary because
Clariant will not be the only site accepting the SW. So, there is no
set volume of SW to be received and no end date for how long it will be
received.
The analytical tests show some organics at the 30ppb range, BOD at 1
ppm, the samples are clear and look like drinking water.
1 of 2 8/8/03 2:09 PM

[Fwd: [Fwd: Clariant Stormwater acceptance]]
Told Gary that I would consult with you and get back to him. It would
seem that with the low concentrations of the constituents, there should
not be a problem. However, if the wastewater is too clean it may effect
the treatment plant. Gary and his people should be aware of that. Will
talk with you on Wed. or Thursday.
2 of 2 8/8/03 2:09 PM

POLREP #1, 08/20/01
BACKGROUND
The Cardinal Chemical Company,Site is located at 2010 South Beltline Blvd. in Columbia,
Richland County, South Carolina. Cardinal has
been involved in the manufacturing and research of organic chemicals since the early 1950's.
The primary product line consists of organic
tin stabilizing compounds (organotins) which are used in the production of polyvinyl chloride
(PVC).
In February, 2000, a spill occurred at a company which utilizes the same organotin compounds
as Cardinal, in the neighboring town of
Lexington, South Carolina. Organotin compounds are extremely toxic to aquatic life at low
concentrations. The spill severely impacted the
Lexington POTW and resulted in a large fish kill. In September, 2000, as a result of the spill
and subsequent fish kill in Lexington, the City
of Columbia announced that they would ban all tin based products from entering the Columbia
Metro Wastewater Treatment Plant .
Subsequently, the City of Columbia discontinued Cardinal's discharge permit for their storm
water which contains organotin compounds.
Since their discharge permit was revoked, Cardinal has accumulated approximately 2.2 million
gallons of organotin contaminated storm
water. The water is stored in a 650,000 ast, rail cars, smaller vessels, and 82 (20,000 gallon.'
each) frac tanks. With limited space available
for any additional storm water, a heavy rain could overwhelm the remaining capacity of the
tanks and the contaminated storm water would
be released into the surface water drainage pathways and eventually into Gills Creek adjacent to,.
the site.
In June, 2001 Cardinal informed the SCDHEC that they were planning to cease all operations at
the Site at the end of the month. The
secured creditor, GMAC, remained on site in an attempt to salvage any remaining items of
value from the property. On August 10, 2001
the SCDHEC issued Cardinal Chemical an order to cease and desist, at which time the
SCDHEC took control of the property. The
SCDHEC mobilized with their contractor to secure the property and assess the hazards. The
SCDHEC and their contractor initiated a
storm water management strategy which included offsite transportation and disposal of the
wastewater in order to maintain sufficient
freeboard in the large ast. The SCDHEC then referred the Site to EPA's Emergency Response
and Removal Branch.
ACTIVITIES DURING REPORTING PERIOD
The following actions were taken during the period of record:
1. The EPA and the ERRS contractor, IT Corp.mobilized to the site on August 8, 2001 to
initiate removal activities.
2. EPA, SCDHEC, IT, and Cardinal representatives conducted a kickoff meeting and site walk
through at plant 1 and plant 2.
3. IT Corp. began preparations to manage the storm water in the event of heavy rainfall, and
initiated sub contract arrangements for the

offsite transportation and disposal of the wastewater.
FUTURE ACTIONS
Actions to be taken during the next reporting period:
1. Update frac tank inventory, to include collecting pH readings on all 82 tanks.
2. Circulate caustic solution in frac tanks containing the brine wastewater waste stream to raise
the pH prior to disposal.
3. Begin transportation and disposal of the contaminated storm water, reservoir water, and brine
wastewater.
4. Continue re-routing clean storm water runoff off of the property.
5. Conduct lab packing and subsequent offsite disposal of laboratory chemicals.
6. EPA will meet with GMAC representatives on 8/28/01 to discuss future site operations.
EPA Home I Privacy and Security Notice I Contact Us
Last updated on Tuesday, December 10th, 2002
URL: http://www.epa.gov/region4/waste/errb/cardnlpr.htm

DHEC News - Emergency Order issued against Cardinal Companies
http://www.scdhec.net/news/releases/2000/html/nr9car00.htm
News
Division of Media Relations
2600 Bull Street
Columbia, S.C. 29201
[phone]
PROMOTE P1M1 Eel PROSPER
FOR IMMEDIATE RELEASE
September 15, 2000
Emergency Order issued against Cardinal Companies
COLUMBIA -- The S.C. Department of Health and Environmental Control has issued an Emergency
Order against Cardinal Companies, of Columbia, to cease production operations at its facilities on South
Beltline Boulevard.
"Production will not be allowed to restart until an independent chemical safety consultant, acceptable to
DHEC, can be secured by the company," said DHEC Commissioner Douglas E. Bryant. "That
consultant shall conduct a thorough safety analysis of all processes that have a potential for uncontrolled
releases either to the environment or to the City of Columbia's wastewater system."
Speaking at a news conference in Columbia, Bryant said the action is another step in DHEC's
investigation that began in February with the pollution of Red Bank Creek and the damage to a
wastewater treatment plant in Lexington County by toxic levels of tin compounds. As part of the
expanding investigation, DHEC took a sample of the discharge from the City of Columbia's wastewater
treatment plant and found organotin contamination. That discovery prompted DHEC to notify and
instruct the City of Columbia to conduct additional studies. Results of the city's testing were received by
DHEC late last week.
"The similarities of events in Lexington County and now in Columbia cannot be dismissed as a mere
coincidence," Bryant said. "Both wastewater plants had experienced an increase in toxicity levels from
an unknown source or sources for several months. The same types of compounds have been found in
both wastewater plants."
Bryant said that while DHEC's investigation continues, a recommendation is being issued limiting the
consumption of fish caught in the Congaree River from the boat landing at Rosewood Drive to U.S.
Highway 601 to one meal a week. A meal is considered eight ounces. The agency also recommends
avoiding contact with or consuming water from the Congaree River area for a distance of approximately
two miles downstream of the City of Columbia's wastewater treatment plant discharge.
"Our recommendations are based on limited information, but we believe it is better to provide the
information to the public and let each person decide for themselves," Bryant said.
DHEC inspectors will remain at Cardinal facilities during the shutdown process to ensure compliance
with the emergency order.
"The order issued today against Cardinal Companies is not meant to be a permanent closure," Bryant
said. "We will assess the company's response, and when we are satisfied that Cardinal can safely
manage their materials and processes onsite, operations may resume."
For further information:
1 of 2 8/5/03 5:16 PM

Incident News Summary: September 19, 2000 -
October 13, 2000
Here are news summaries of some of the chemical incidents that were brought to
our attention between September 19 and October 13, 2000. In some cases, a more
detailed story is available at AcuSafe. Due to the overwhelming popularity of this
regular feature, we are expanding coverage to include more transportation -based
incidents and those that may be the result of sabotage. Issues of terrorism, site
security, and transportation are of interest to many of our readers. Readers are
welcome to contribute news stories that you may have read about. If you have read
about a story and would like to share it with other readers, please send it to
[e-mail].
September 17 Cardinal Chemical Co. Columbia, South Carolina Plant
Ordered to Shut Down Following Discovery of Tin; Company Vows to Fight
Order
Cardinal Chemical Co. completed its plant shutdown on September 17, following an
order from the South Carolina Department of Health and Environmental Control
(DHEC). DHEC ordered the shutdown on Friday after low levels of organic tin
compounds were found in a settling pond at Columbia's wastewater treatment
plant. The same chemicals were found earlier this year in Lexington County's Red
Bank Creek, where they are believed to have caused a massive fish kill. An
attorney for Cardinal Chemical rebutted the claims saying there is no proof that the
chemicals came from the Cardinal plant and that the company would fight the
shutdown order.
Sources and Disclaimer:
AcuSafe's Incident News Summary is primarily compiled from Reuters and AP
news wires, and from information shared on the U.S. Chemical Safety and Hazard
Investigation Board Chemical Incident Reports Center. An effort has been made to
summarize stories only from reputable sources, but neither AcuSafe nor AcuTech
Consulting can guarantee the accuracy of the story, nor do they necessarily reflect
the views of AcuTech, AcuSafe, and its staff. We make no effort to independently
corroborate the accuracy of the incident news stories.
ORGANOTIN COMPOUNDS
The greatest use of di-organotin compounds is stabilizers in the manufacture of polyvinyl
chloride, or PVC. The particular importance of these di-organotins lies in their outstanding
ability to preserve the clarity and transparency of PVC, not only when being processed but
also in subsequent service. Organotin-stabilized PVC is used in water pipes and in food
packaging applications as tin compounds used in these applications are known as
nontoxic. In contrast to the nontoxic compounds employed as stabilizers, some
tri-organotin compounds (e.g., tributyl- and triphenyltins) are powerful biocides and have
found use in a number of relevant applications, such as fungicides bactericide in underwater
and anti -fouling paints, preservatives for wood, textile, paper, leather, and glass, and
hospital and veterinary disinfectants. The tributyltin family of chemicals include bis
(tributyltin) oxide, or tributyltin oxide itself, tributyltin sulfide, bis (tributyltin) adipate,
tributyltin methacrylate, tributyltin fluoride, and tributyltin acetate. Tributyltin derivatives have

toxic properties to gram positive bacteria are used as disinfectants on surfaces such as
hospital floors and sports arenas, combined with gram negative bactericides. Tin chemicals
also used as flame retardants to treat fabrics and plastics.
Bis(tri-n-butyltin)oxide is used as fungicide or bactericide for wooden products and
antifouling paints.

EPA Announces the Availability of ...1 site in Columbia, South Carolina
http://www.epa.gov/cgi-bin/epaprintonly.cgi
U.S. Environmental Protection Agency
PUBLIC AFFAIRS
erving a • ama, ona, eorgia, ' en uc y, T ississippi, ' ort aro ina, o
Carolina, Tennessee
Contact Us I Search: r 1
EPA Home > Region 4 > Public Affairs > Press Releases > Press Release 05/29/2002
GO
oi
EPA ANNOUNCES THE AVAILABILITY OF THE
REMOVAL ADMINISTRATIVE RECORD FOR THE
CARDINAL CHEMICAL SITE IN COLUMBIA, RICHLAND
COUNTY, SOUTH CAROLINA
The United States Environmental Protection Agency (EPA) announced today that the Administrative
Record for the Cardinal Chemical site in Columbia, Richland County, South Carolina is available for public
review.
The Administrative Record file includes documents that form the basis for selection of the removal action.
Documents in the record include: preliminary assessment and inspection reports, test results, and the
Action Memorandum. All interested persons are encouraged to review and comment on the documents.
The documents will be available for public review during normal business hours at the following locations:
John Hughes Cooper Branch
Richland Public Library
5317 North Trenholm Road
Columbia, SC 29206
Attn: Ann Bagwell
US EPA Records Center - Region 4
Sam Nunn Federal Center -11 th Floor
61 Forsyth Street, Southwest
Atlanta, Georgia 30303-3104
Attn: Debbie Jourdan
EPA will accept comments regarding the Administrative Record during the public comment period which
begins on May 24, 2002 and ends on June 24, 2002. Comments should be addressed to John Nolen,
Federal On -Scene Coordinator, U.S. EPA Region 4, ERRB, 11th Floor, 61 Forsyth Street, S.W., Atlanta,
Georgia 30303-3104. At the end of the 30-day comment period, a written response to all pertinent
comments will be prepared in a responsiveness summary and placed in the file.
Cardinal Chemical Company was involved in the manufacture and research of organic chemicals since the
early 1950s. The site is located at 2010 South Beltline Boulevard in Columbia in a mixed
commercial/industrial setting.
-0- May 23, 2002
CONTACT: Dawn Harris -Young, EPA Press Relations, [phone]
For information about the contents of this page please contact Fred Thomburg
EPA Home I Privacy and Security Notice I Contact Us
This page was generated on Tuesday, August 5, 2003
View the graphical version of this page
at: http://www.epa.gov/region04/oeapages/02press/052902.htm
1 of 1 8/5/03 4:47 PM