NC0000108_Permit (Modification)_20060526

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May 26, 2006
Ron Shemesh
159 Babcock Co., LLC
Excelsior Packaging Group
1379 Old Rosman Hwy.
Brevard, NC 28712
Michsd F. Essky, Governor
William 0. Roar Jr., Secretary
North Carofma DepsAerent of Bw mnmeot and Natural Rem men
Alan W. Klim k P.E. Director
Divww of Water Quality
Subject: NPDES Permit Modification
Permit NC0000108
Excelsior Packaging Group
formerly Coats American, Inc. - Sylvan Plant
WWTP
Transylvania County
Dear Mr. Shemesh.
Division personnel have reviewed and., r r .. ..1 your request to transfer ownership of the subject permit,
received on May 22, 2006. This permit modification documents the change in ownership.
Please find enclosed the revised permit All other tetras and conditions contained in the original permit remain
unchanged and in frill effect This permit modification is issued under the requirements of North Carolina General
Statutes 143 -215.1 and the Memorandum of Agreement between North Catch= and the U.S. Environmental
Protection Agency.
If you have any questions concerning this permit modification, please contact the Point Source Branch at (919)
733 -5083 extension 363.
Sincerely,
"!6�' C4
k&,
W. Klimek, P.E.
cc Central Files
Asheville Regional Office, Surface War Protection
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North Carolms Division of Water Qw* 1617 Mara Service Center Raleigh, NC 27699 -1617 Phone [phone] Customer Service
hoarnet hbowstalLmus 512 N. Salisbury St. Rskigk NC 27604 FAX [phone].623 -6748
An Equal 0ppahmllp /Afinnstive Adlon Employer — 50% Re*lsd110% Poet Cmiunw Papsr

Permit NC0000108
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143 - 215.1, other
lawful standards and regulations promulgated and adopted by the North Carolina
Environmental Management Commission, and the Federal Water Pollution Control Act,
as amended,
159 Babcock Co., LLC
is hereby authorized to discharge wastewater from a facility located at the
Excelsior Packaging Group
Old US Hwy 64 East
Northeast of Rosman
Transylvania County
to receiving waters designated as Galloway Creek in the French Broad River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions
set forth in Parts I, H, III and IV hereof.
This permit shall become effective May 26, 2006.
This permit and authorization to discharge shall expire at midnight on September 30, 2010.
Signed this day May 26, 2006.
f,py Alan W. Klimek, P.E., Director
Division of water Quality
By Authority of the Environmental Management Commission

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

Permit NC0000108
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS — FINAL
During the period beginning on the effective date of this permit and lasting until permit expiration, the Permittee is
authorised to discharge from outfoR 003: donate wastewater. Such discharges shall be limited and monitored
by the Permittee as specified below:
EFFLUENT
CHARACTERISTICS
9711
BOD.% 2000
Total Suspended Solids
NH3 as N'
Fecal Coliform (geometric mean)
Total Residual Chkxine2
Temperature, OC
pH3
LIMITS
MONITORING REQUIREMENTS
Monthly
Daily
Measurement Sample Type
Sample Location
Average
Maximum
Frequency
0.015 MGD
Weekly
Instantaneous
Influent or Effluent
30.0 mgA
45.0 mgA
Weekly
Grab
Effluent
30.0 mgA
45.0 m9A
Weekly
Grab
Effluent
21.0 mqA
35.0 mgA
Weekly
Grab
Effluent
2001100 ml
4001100 mI
Weekly
Grab
Effluent
28 ugA
2/Week
Grab
Effluent
Weekly
Grab
Effluent
241onth
Grab
Effluent
Footnotes:
1. From November 1 through March 31, NH3 -N shall not have a limit.
2. The TRC limit shall take effect on May 1, 2007. Until then, the permittee shall monitor TRC
(with no limit).
3. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

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

�, Mike BELL /US /COATS "'Ronnie Shemesh "' <rshemesh @excelsiorpkg.com >,
12/02/2005 06:01 PM To tcosta @costalawllp.com
jpellerin @monarchpropertygroup.com, Donna
✓ cc Arm strong /US /COATS @COATS,
V apinnix@arcadis- us.com, HClaxton @KSLAW.com,
bcc Mickey 01sen /US /COATS @Coats
Subject Phase II Limited Site Assessment Report - Coats
Rosman, NC Plant
Mr. Shemesh / Mr. Costa,
Attached is a letter of explanation regarding the also attached Phase II Limited Site Assessment report
recently submitted to the NC Department of Environment and Natural Resources for the former petroleum
underground storage tank release at the Coats Sylvan Plant in Rosman, NC Also included is a copy of
NC -DENR Instructions for Preparing a "Notice of Residual Petroleum" Referencing Land Use Restriction
referenced in my letter of explanation.
With the closing on the property scheduled in approximately two week and having not heard from you or
your representatives requesting information on environmental matters, I again bring to your attention the
need to coordinate with NC -DENR on these issues. In particular you may want to discuss the continuing
services of Tom Kitchen and Wesley Royal for operation of the wastewater treatment plant whose contact
information was provided in my November 10, 2005 letter to you.
Lastly, I will be sending you a list of the utility service providers and account numbers for the site for your
coordination in transferring the accounts and services at closing.
Please do not hesitate to call me about this information or as to how we may assist you in any matters
regarding the property.
Regards,
Mike Bell
Director, Environmental Engineering
Coats North America
(706) 886 -2141 Ext. 2248
(706) 886 -9182 Fax
(706) 491 -2431 Cell
Coats Rosman Final Phase II LSA Xmd 1211205.pdf Coats Rosman Phase II LSA Final 112905a.pdf NRP- lns.doc

Coats
• North America
Mr. Ronnie Shemesh
Chief Executive Officer
159 Babcock Company, LLC
159 Alexander Street
Yonkers, NY 10701
Coats North America
PO Box 670
6212 Rose Lane
Toccoa, GA 30577
Phone: [phone]
Fax: [phone]
Via E -mail: rshemesh @excelsiorpkg.com
November 10, 2005
Reference: Additional Site Environmental Documentation
Coats Sylvan Plant
Rosman, North Carolina
Dear Mr. Shemesh:
Attached please find the following information relevant to the ongoing investigation of
the release from the former petroleum underground storage tank and the plant's
wastewater treatment system:
1. Letter, ARCADIS G &M, October 31, 2005, Subject: Notice of Release from an
Underground Storage Tank, Coats American Inc. Sylvan Facility, Old Highway 64,
Rosman, Transylvania County, North Carolina
2. Letter, ARCADIS G &M, November 4, 2005, Subject: Limited Site Assessment Work
Plan for Coats American Sylvan Plant
3. Letter, North Carolina Department of Environment and Natural Resources, Division
of Waste Management, Underground Storage Tank Section, November 4, 2005, RE:
Notice of Regulatory Requirements, 15A NCAC 2L .0115(c) Risk -based Assessment
and Corrective Action for Petroleum Underground Storage Tanks, Coats American
Inc. Sylvan Facility, Old Highway 64, Rosman, Transylvania County, Incident
Number: 28343
4. Letter, North Carolina Department of Environment and Natural Resources,
September 28, 2005, Subject: Issuance of NPDES Permit, NC0000108 Sylvan Plant
WWTP, Transylvania County with attached Permit to Discharge Wastewater Under
the National Pollution Discharge Elimination System, Permit NC0000108, Effective
November 1, 2005.
Investigation Release from an Underground Storage Tank
The first three attachments pertain to this subject. Consistent with Coats' history at
other former sites and our October 28, 2005 letter to you, we are continuing the
investigation this week as outlined in the Work Plan listed in Item 2 above. We have
asked ARCADIS to use expedited laboratory reporting services to provide further
information on the release as quickly as possible.

Additional Site Environmental Documentation
Coats Sylvan Plant, Rosman, North Carolina
November 10, 2005
Page 2
Wastewater Treatment Plant and Permit
As you may be aware, the plant's wastewater is treated on -site using a 15,000 gallon
per day package wastewater treatment system as authorized by a National Pollution
Discharge Elimination System Permit. The recently renewed permit listed in Item 4 is
included in this transmittal.
Having not received any questions from you concerning this permit or system, Coats
wants to make you aware of it. It is recommended you or your environmental
consultants review this permit and its conditions carefully. In particular, Coats
wished to bring to your attention the change in ownership requirements in paragraph
A.(4.) of the permit. While the permit states the documentation for this change shall
be submitted 180 days prior to the start of operations, I spoke with Wanda Frazer,
(828) 296 -4662 or 4600, at the Asheville Regional Office of NC -DENR who indicated
this requirement would not be enforced. However, she asked that the new owner
contact her as soon as possible prior to or after the closing to discuss permit transfer
requirements.
Regarding the historic or day -to -day operation of the wastewater treatment system or
the permit I will be glad to assist you with additional information and discussion as
you may request. You are welcome to contact the current licensed operator (and plant
caretaker), Tom Kitchen, at (828) 883 -8572. We also use the services of Wesley Royal
as the Operator in Responsible Charge who also operates the Town of Rosman WWTP
under contract. Wesley can best be contacted on his cell phone at (828) 506 -5572.
I apologize for the size of this transmittal and will be glad to send you a hard copy is you would
like. Please do not hesitate to call me at (706) 886 -2141 Ext. 2248 with any questions you may
have about this information.
Attachments
cc: (via E-mail)
Tom Costa
James Pellerin
Hadiya Claxton
Peter McGrath
Alan Pinnix
Donna Armstrong
Sincerely,
COATS NORTH AMERICA
N1�014 1 0
Mike Bell
Director Environmental Engineering