NC0005312_Approval_20110503

Belnick, Tom
From: Belnick, Tom
Sent: Tuesday, May 03, 2011 3:13 PM
To: 'Kristie L. Rabasca'; '[e-mail]'
Cc: Basinger, Corey
Subject: RE: BacShield Use at True Textiles
Regarding use of BacShield antimicrobial
True Textile (NPDES Permit NC0005312)
Surry County/Winston Salem Regional Office
The Division has reviewed your request to incorporate Bac-Shield antimicrobial into your process line. The active
ingredient is chitosan, a derivative of crab shells. Under worst case conditions (accidental spill of drum), you project 100
gallons at 2.5% concentration going to the wastewater treatment plant (WWTP). Under normal operations, you
estimate 30 gallons/week of leftover batch going to the WWTP. The product has a high BOD content (109,000 ppm) but
under worst case conditions would only add approx. 2 Ibs BOD to the WWTP, compared to a permit limit of 1,018
Ibs/day (daily max limit). Consequently, the additional BOD loading under worst case conditions would be
inconsequential. Likewise, there does not appear to be a toxicity concern, based on the significant dilution and the only
listed hazardous ingredient in the MSDS being acetic acid, which has an LC50 of 5,620 mg/l. This NPDES permit already
contains a quarterly chronic toxicity test at 1.9% effluent, which is used to indicate any toxicity concerns in the
wastewater discharge.
Based on this information, the Division will concur with your plans to incorporate the Bac-Shield antimicrobial
compound. This option appears to be more environmentally safe relative to the silver chloride antimicrobial product
previously discussed. There is no need to modify the NPDES permit at this time. Simply list this product use with your
next NPDES permit renewal application in 2013. However, if the worst case assumptions significantly change, or if you
decide to pursue another antimicrobial, the Division will need to re-evaluate.
Tom Belnick
Supervisor, Complex NPDES Permitting Unit
NC DENR/Division of Water Quality
1617 Mail Service Center, Raleigh, NC 27699-1617
[phone]; fax [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Kristie L. Rabasca [mailto:[e-mail]
Sent: Friday, April 29, 2011 12:30 PM
To: Belnick, Tom
Subject: FW: BacShield Use at True Textiles
Mr. Belkin,
We are providing this email on behalf of True Textiles Inc. in Elkin NC to request a determination if use of a
product would require any changes to the facility's WWTP Permit (NPDES No. NC0005312).
We have discussed this matter in the past with Sergei Chernikov — but the discussion was related to a different
compound (Silpur). Since those discussions, the facility has identified a different, more environmentally
friendly, compound that they would like to use. So we are requesting this determination for only this new

product, Bac-Shield. We understand you have spoken with Keith Ogden, the process engineer at the plant,
regarding Bac-Shield. Based on your initial review of the MSDS, you believed that no modification to the
WWTP permit would be necessary, but requested that we review the potential impact of the BOD and COD on
the WWTP before making this formal determination.
We have reviewed the potential WWTP impacts from operational use of this of this product and believe it will
not have any adverse impacts. Specific conditions that we reviewed include the following:
1. The BOD and COD loading impacts from an accidental release of a full drum or the accidental release
of a full batch of the product (100 gallons of Bac-Shield at a 2.5% concentration).
2. Sending approximately 30 gallons a week of leftover batch material that was not fully utilized in the
production process.
We have attached MSDS for your information.
Thank you for your consideration. Please reply and let us know if any changes to WWTP Permit would be
necessary. If you have any questions, feel free to contact me.
Kristie L. Rabasca P.E., LEED A.P.
Senior Environmental Engineer
Sevee & Maher Engineers, Inc.
4 Blanchard Road
Cumberland Center. Maine 04021
www.smemaine.com
(ph) 207.829.5016 ext.316
(fax) 207.829.5692
(cell) 207.415.5830
This electronic message contains information from Sevee & Maher Engineers, Inc. (SME), which may be confidential, privileged or otherwise
protected from disclosure. The information is intended to be used solely by the recipient(s) named. If you are not an intended recipient, be aware
that any review, disclosure, copying, distribution or use of this transmission or its contents is prohibited. If you have received this transmission in
error, please notify (SME) immediately at postmasterWsmemaine.com.

Belnick, Tom
From: Kristie L. Rabasca [[e-mail] t
Sent: Friday, April 29, 2011 12:30 PM en7re� M ©. p M60
To: Belnick, Tom h W11 iL Vldw
Subject: FW: BacShield Use at True Textiles 14 CYil0
Attachments: Bac-Shield-MSDS.pdf
in r 0-2
Mr. Belkin, �j MdA1/S `
We are providing this email on behalf of True Textiles Inc. in Elkin NC to re st a determin 'on if use of a
product would require any changes to the facility's WWTP Permit (NPDES o. NC0005312).
We have discussed this matter in the past with Sergei Chernikov — but the discus s related to a different
compound (Silpur). Since those discussions, the facility has identified a different, more environmentally
friendly, compound that they would like to use. So we are requesting this determination for only this new
product, Bac-Shield. We understand you have spoken with Keith Ogden, the process engineer at the plant,
regarding Bac-Shield. Based on your initial review of the MSDS, you believed that no modification to the
WWTP permit would be necessary, but requested that we review the potential impact of the BOD and COD on
the WWTP before making this formal determination.
We have reviewed the potential WWTP impacts from operational use of this of this product and believe it will
not have any adverse impacts. Specific conditions that we reviewed include the following:
1. The BOD and COD loading impacts from an accidental release of a full drum or the accidental release
of a full batch of the product (100 gallons of Bac-Shield at a 2.5% concentration).
2. Sending approximately 30 gallons a week of leftover batch material that was not fully utilized in the
production process.
We have attached MSDS for your information.
Thank you for your consideration. Please reply and let us know if any changes to WWTP Permit would be
necessary. If you have any questions, feel free to contact me.
Kristie L. Rabasca P.E., LEED A.P.
Senior Environmental Engineer
Sevee & Maher Engineers, Inc.
4 Blanchard Road
Cumberland Center, Maine 04021
www.smemaine.com
(ph) 207.829.5016 ext.316
(fax) 207.829.5692
(cell) 207.415.5830
2. sia
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This electronic message contains information from Sevee & Maher Engineers, Inc. (SME), which may be confidential, privileged or otherwise
protected from disclosure. The information is intended to be used solely by the recipient(s) named. If you are not an intended recipient, be aware
that any review, disclosure, copying, distribution or use of this transmission or its contents is prohibited. If you have received this transmission in
error, please notify (SME) immediately at i>ostmaster.'a>mennainexom.

-Chem -Tex
�-t•. '171"
77AD.
MATERIAL SAFETY DATA SHEET
I. CHEMICAL PRODUCT & COMPANY INDENTIFICATION
PRODUCT NAME: Bac-Shield
PRODUCT TYPE: Antimicrobial
EPA REG#: 81446-1
CHEMICAL NAME: Aqueous solution of poly n-acetylglucosamine and
poly D-glucosamine
Manufacturer / Supplier Information
MSDS Prepared by: Emergency Phone Number
Chem -Tex Laboratories, Inc. Chemtrec 800-424-9300
P.O. Box 5228
Concord, NC 28027
For additional health, safety or regulatory information, call [phone].
II. Hazard Identification
Emergency Overview
APPEARANCE: Hazy Tan Liquid
ODOR: Slight sea -side odor
HMIS: Health = 1
Fire = 0
Reactivity = 0
PPE = A
Prepared. 02116107
MSDS Updated. N/A
Potential Health Effects
EYES:
Irritating
SKIN:
Irritating
INGESTION:
Irritating
INHALATION:
Irritating
III. COMPOSITION/ INFORMATION ON INGREDIENTS
Hazardous
Ingredients
CAS#
Percentage
LD5e
(mg/kg)
LC50
(ppm/hr)
SARA
Title Ill
Acetic Acid
64-19-7
<2
3,310
5,620
Yes

Page 2 of 4
IV. First Aid Measures
EYES: Immediately flush eyes with plenty of water for at least
15 minutes. Call a physician.
SKIN: In case of skin contact, the compound is not hazardous
however, cleansing the skin after use is advisable.
INGESTION: If swallowed, no specific intervention is indicated as the
compound is not likely to be hazardous by ingestion.
However, consult a physician if necessary.
INHALATION: Prolonged inhalation of vapors can cause irritation to respiratory
system. If prolonged inhalation is necessary use an approved
NIOSH/MSHA respirator.
V. Fire Fighting Measures
FLAMABILITY:
Non -Flammable
FIRE AND EXPLOSION HAZARDS:
No fire or explosive hazards.
EXTINGUISHING MEDIA:
Not specified
SPECIAL FIRE FIGHTING INSTRUCTIONS:
None
VI. Accidental Release Measures
PERSONAL PRECAUTIONS: Use appropriate PPE
ENVIRONMENTAL: Use absorbent
material to soak up small spills. Use
appropriate
method to contain larger spills
VII. Handling and Storage
STORAGE TEMPERATURE:
5-50°C is recommended
SHELF LIFE:
2 Years
SPECIAL SENSITIVITY:
None known
HANDLING/STORAGE PRECAUTIONS:
Store in dry place at ambient temperature.
Keep containers covered to prevent
contamination.
VIII. Exposure Control / Personal Protection
EYE PROTECTION REQUIREMENTS:
SKIN PROTECTION REQUIREMENTS:
RESPIRATOR REQUIREMENTS:
Safety glasses are recommended
Not required for periodic use
Use of NIOSH/MSHA approved respirator
required for vapor or misting applications
only.

LOCAL EXHAUST:
MECHANICAL EXHAUST:
ADDITIONAL PROTECTIVE MEASURES
Page 3 of 4
N/A
Not required
Emergency showers and eye wash stations
are suggested. Employees should wash their
hands before eating or drinking.
Hazardous
Ingredients
CAS#
Percentage
OSHA-PEL
ACGIH TLV
Acetic Acid
64-19-7
<2
1 10 PPM
10 PPM115STEL
IX. Physical and Chemical Properties
APPEARANCE:
Hazy Tan Liquid
SOLUBILITY:
Soluble in water
SPECIFIC GRAVITY:
1.03 g/cm}
FLAMMABILITY:
Non -Flammable
BOILING POINT:
> 100°C (1 % Conc.)
FREEZING POINT:
0°C (1 % Conc.)
ODOR:
Slight seaside odor
PH:
4.5 ± 0.5
VOC:
< 2%
X. Stability and Reactivity
STABILITY:
HAZARDOUS POLYMERIZATION:
INCOMPATIBILITIES:
DECOMPOSITION:
INSTABILITY CONDITIONS:
DECOMPOSITION TEMPERATURE:
DECOMPOSITION PRODUCTS:
XI. Toxicological Information
ANIMAL DATA
ACUTE TOXICITY:
Acute Oral LD 50 (Rat):
Acute Dermal LD50 (Rat):
Acute Inhalation LC50 (Rat):
Skin Irritation Study (Rabbit):
Primary Eye Irritation Study (Rabbit):
Dermal Sensitization (G. Pig):
Stable
Will not occur
Incompatible with strong oxidants and
strong bases.
Will not occur
Stable at normal temperature and storage
conditions.
Will not occur
None known
> 5000 mg/kg (No Mortality)
>5000 mg/kg (No Mortality)
2.07 mg/I (No Mortality)
PDII = 0.7 (Slightly Turning)
PI1= 9.3 (Unrinsed), 7.3 (Rinsed) (Mildly Irritating)
Not A sensitizer

Page 4 of 4
MI. Ecological Information
BOD (5 day) 109,000 ppm
COD (5 day) 198,500 ppm
XIH. ra tons
Landfill, sewer, or incinerator disposal must be in accordance with applicable Federal,
State/Provincial, and Local regulations.
XIV. Transport Information
Under the regulations of the US Department of Transportation (DOT), Bac-Shield is
classified as non -hazardous.
XV. Regulatory Information
OSHA STATUS: Bac-Shield is not hazardous under the criteria of the Federal
OSHA Hazard.
TSCA STATUS: Bac-Shield components are on the TSCA inventory.
RCRA: If discarded in its purchased form, this product would not be a
hazardous waste. Under RCRA, it is the responsibility of the
product user to determine if the product or a derived form of the
product should be classified as a hazardous waste.
XVl. Other Information
N/A
Disclaimer
This material safety data sheet was prepared solely for the purpose of providing employees with
information regarding potential hazards presented by listed substance(s). It was prepared in the context of
reasonable foreseeable exposure situations, which may arise give the nature and the expected use of the product.
The substance(s) may present greater or lesser hazard under other circumstances. The data and recommendations
presented herein are based upon our research and the research of others but Chem -Tex Laboratories, Inc. makes no
warranty of any kind expressed or implied, except that the product supplied will be of standard quality of Chem -Tex
Laboratories, Inc and the user assumes all risk and liability resulting from reliance of the information contained on
this Material Safety Data Sheet and the use of the product, whether used singularly or in combination with other
substances. This disclaimer does not, however apply to an independent statutory or contractual obligations, which
may otherwise exist between Chem -Tex Laboratories, Inc and any other person.

Beinick, Tom
From: Keith Ogden [[e-mail]]
Sent: Friday, March 25, 2011 9:49 AM ✓ 1 1
Su AntiBelnmicrobial Product
�%0Hj l00K1'1' R( TOJ$✓)
Subject: Antimicrobial Product J
Attachments: Bac-Shield-MSDS.pdf aelTllidicroti�t,�woy��C:f
Good morning Tom,
Thank you again for taking time the other day to explain to me the details involved in our request with respect
to water quality. As we also had discussed, I have a couple of other antimicrobial options that do not employ
Silver as the active ingredient. I am including some information below as well as the MSDS on another that I
am interested in. Please let me know what your thoughts are in this product in terms of its impact on our system
as well as our permit when you have an opportunity.
From a usage standpoint, I would expect to possibly send ab t 30 galloDofaste to our treatment plant each
week or possibly every 2 weeks. This would contain about 6 of thebial product in the formulation
resulting in about 15.01 #'s of the product going to treatment.
Please let me know if u have any other q tions and/or concerns about this product. You can reach me vie
email and also by pho at 336-526-0503.
Thanks again for your help.
Keith
Here is a little information about the product along with the MSDS.
Bac-ShieldTM is the antimicrobial product of Chem -Tex Laboratories.
When used as directed, Bac-Shield protects treated articles against bacterial growth, fungal growth, mold and
mildew.
Bac-Shield is different from products that clean or disinfect articles. Bac-Shield works between cleanings to
inhibit the growth of bacteria, mold, mildew, and fungi that cause odor, stains, discoloration, decay and
deterioration of treated materials.
Bac-Shield's active ingredient is chitosan, a derivative of discarded snow crab shells, an abundant, renewable
resource with a long history of use. Chitosan is classified as Category III on the EPA's toxicity scale. (PDF of
MSDS). Refer to EPA-HQ-OPP-2007-0566-0019 for statements regarding toxicity of Chitin and Chitosan for
humans and animals and the effects of both on the environment.
Bac-Shield is registered under the Treated Article Exemption with the EPA. It will not trigger shellfish
allergies. Articles treated with Bac-Shield have passed industry standard tests: AATCC-100, 147 and 174 and
ASTM 2149.

Let me know what you think.
Thanks,
Keith

Chem -Tex
MATERIAL SAFETY DATA SHEET
I. CHEMICAL PRODUCT & COMPANY INDENTIFICATION
PRODUCT NAME:
Bac-Shield
PRODUCT TYPE:
Antimicrobial
EPA REG#:
81446-1
CHEMICAL NAME:
Aqueous solution of poly n-acetylglucosamine and
poly D-glucosamine
Manufacturer / Supplier Information
MSDS Prepared by: Emergency Phone Number
Chem -Tex Laboratories, Inc. Chemtrec 800-424-9300
P.O. Box 5228
Concord, NC 28027
For additional health, safety or regulatory information, call [phone].
II. Hazard Identification
Emergency Overview
APPEARANCE: Hazy Tan Liquid
ODOR: Slight sea -side odor
HMIS: Health = 1
Fire = 0
Reactivity = 0
PPE = A
Prepared. 02116107
MSDS Updated. N/A
Potential Health Effects
EYES:
Irritating
SKIN:
Irritating
INGESTION:
Irritating
INHALATION:
Irritating
Ill. COMPOSITION/ INFORMATION ON INGREDIENTS
Hazardous
Ingredients
CAS#
Percentage
LD50
(mg/kg)
LC50
(ppm/hr)
SARA
Title Ill
Acetic Acid
1 64-19-7
<2
3,310
5,620
Yes

Page 2 of 4
IV. First Aid Measures
EYES: Immediately flush eyes with plenty of water for at least
15 minutes. Call a physician.
SKIN: In case of skin contact, the compound is not hazardous
however, cleansing the skin after use is advisable.
INGESTION: If swallowed, no specific intervention is indicated as the
compound is not likely to be hazardous by ingestion.
However, consult a physician if necessary.
INHALATION: Prolonged inhalation of vapors can cause irritation to respiratory
system. If prolonged inhalation is necessary use an approved
NIOSH/MSHA respirator.
V. Fire Fighting Measures
FLAMABILITY: Non -Flammable
FIRE AND EXPLOSION HAZARDS: No fire or explosive hazards.
EXTINGUISHING MEDIA: Not specified
SPECIAL FIRE FIGHTING INSTRUCTIONS: None
Vx. Accidental Release Measures
PERSONAL PRECAUTIONS: Use appropriate PPE
ENVIRONMENTAL: Use absorbent material to soak up small spills. Use
appropriate method to contain larger spills
VH. Handling and Storage
STORAGE TEMPERATURE: 5-50°C is recommended
SHELF LIFE: 2 Years
SPECIAL SENSITIVITY: None known
HANDLING/STORAGE PRECAUTIONS: Store in dry place at ambient temperature.
Keep containers covered to prevent
contamination.
VIII. Exposure Control / Personal Protection
EYE PROTECTION REQUIREMENTS:
SKIN PROTECTION REQUIREMENTS:
RESPIRATOR REQUIREMENTS:
Safety glasses are recommended
Not required for periodic use
Use of NIOSH/MSHA approved respirator
required for vapor or misting applications
only.

LOCAL EXHAUST:
MECHANICAL EXHAUST:
ADDITIONAL PROTECTIVE MEASURES
Page 3 of 4
N/A
Not required
Emergency showers and eye wash stations
are suggested. Employees should wash their
hands before eating or drinking.
Hazardous
Ingredients
CAS#
Percentage
OSHA-PEL
ACGIH TLV
Acetic Acid
64-19-7
<2
1 10 PPM
]0 PPM115STEL
IX. Physical and Chemical Properties
APPEARANCE:
Hazy Tan Liquid
SOLUBILITY:
Soluble in water
SPECIFIC GRAVITY:
1.03 g/cm3
FLAMMABILITY:
Non -Flammable
BOILING POINT:
> 100°C (I % Cone)
FREEZING POINT:
0°C (1%Cone)
ODOR:
Slight seaside odor
PH:
4.5 ± 0.5
VOC:
< 2%
X. Stability and Reactivity
STABILITY:
HAZARDOUS POLYMERIZATION
INCOMPATIBILITIES:
DECOMPOSITION:
INSTABILITY CONDITIONS:
DECOMPOSITION TEMPERATURE:
DECOMPOSITION PRODUCTS:
XI. Toxicological Information
ANIMAL DATA
ACUTE TOXICITY:
Acute Oral LD 50 (Rat):
Acute Dermal LD50 (Rat):
Acute Inhalation LC50 (Rat):
Skin Irritation Study (Rabbit):
Primary Eye Irritation Study (Rabbit):
Dermal Sensitization (G. Pig):
Stable
Will not occur
Incompatible with strong oxidants and
strong bases.
Will not occur
Stable at normal temperature and storage
conditions.
Will not occur
None known
> 5000 mg/kg (No Mortality)
>5000 mg/kg (No Mortality)
2.07 mg/I (No Mortality)
PDII = 0.7 (Slightly Turning)
PII = 9.3 (Unrinsed), 7.3 (Rinsed) (Mildly Irritating)
Not A sensitizer

Page 4 of 4
XII. Ecological Information
BOD (5 day) 109,000 ppm
COD (5 day) 198,500 ppm
XIII. Disposal Considerations
Landfill, sewer, or incinerator disposal must be in accordance with applicable Federal,
State/Provincial, and Local regulations.
XIV. Transport Information
Under the regulations of the US Department of Transportation (DOT), Bac-Shield is
classified as non -hazardous.
XV. Regulatory Information
OSHA STATUS: Bac-Shield is not hazardous under the criteria of the Federal
OSHA Hazard.
TSCA STATUS: Bac-Shield components are on the TSCA inventory.
RCRA: If discarded in its purchased form, this product would not be a
hazardous waste. Under RCRA, it is the responsibility of the
product user to determine if the product or a derived form of the
product should be classified as a hazardous waste.
XVI. Other Information
N/A
Disclaimer
This material safety data sheet was prepared solely for the purpose of providing employees with
information regarding potential hazards presented by listed substance(s). It was prepared in the context of
reasonable foreseeable exposure situations, which may arise give the nature and the expected use of the product.
The substance(s) may present greater or lesser hazard under other circumstances. The data and recommendations
presented herein are based upon our research and the research of others but Chem -Tex Laboratories, Inc. makes no
warranty of any kind expressed or implied, except that the product supplied will be of standard quality of Chem -Tex
Laboratories, Inc and the user assumes all risk and liability resulting from reliance of the information contained on
this Material Safety Data Sheet and the use of the product, whether used singularly or in combination with other
substances. This disclaimer does not, however apply to an independent statutory or contractual obligations, which
may otherwise exist between Chem -Tex Laboratories, Inc and any other person.

Pf ✓M l � 714, r) 04t�'t 1NiLt/ P/00/V G b,3 ✓1 n%/"v V71411
Tom Add r f'N,^ 4 l-U4 /" 0 C= A C
From: Belnick, Tom
Sent: Tuesday, February 15, 2011 12:40 PM
To: Chernikov, Sergei /V
Subject: RE: Question regarding discharge at True Textiles
Tru-P
Sergei- I would consider this a major modification- since it results in a change in the wastewater characteristics (a new
pollutant of concern). This facility is permitted at 4 MGD, the s7Q10= 314 cfs, resulting in a dilution factor of 51.65. Our
chronic action level for silver = 0.06 ug/I, x dilution factor (51.65) = 3.1 ug/I allowable effluent concentration. The facility
would need to show that they could treat below this level, or pass the chronic toxicity test with anticipated effluent
silver levels (per Action Level Policy), before we would allow this new process line. Are there any new effluent
guidelines that would also apply?
Tom Belnick
Supervisor, Complex NPDES Permitting Unit
INC DENR/Division of Water Quality
1617 Mail Service Center, Raleigh, NC 27699-1617
[phone]; fax [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Chernikov, Sergei
Sent: Tuesday, February 15, 2011 10:23 AM
To: Kristie L. Rabasca
Cc: 'Dave Walker'; Belnick, Tom
Subject: RE: Question regarding discharge at True Textiles
Hello Kristie,
Thank you for contacting the DWQwith your questions! I can confirm that the discharge to the treatment plant will be
allowed. The permit would have to be modified, this requirement is based on our regulations (15A NCAC 02H.0114). I
will discuss this issue with my supervisor and will let you know what king of the modification is needed (Major or Minor).
Please let me know if you have any other questions.
Thank you!
Sergei
Sergei Chernikov, Ph.D.
Environmental Engineer II
Complex Permitting Unit
Phone: [phone], fax [phone]
1617 Mail Service Center
Raleigh, NC 27699-1617
Express mail: 512 North Salisbury St.
Raleigh, NC 27606
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.

From: Kristie L. Rabasca [mailto:[e-mail]] ✓ 1 / KC l �K?t
Sent: Tuesday, February 15, 2011 10:09 AM e
To: Chernikov Sergei '
Cc: 'Dave Walke
Su uestion regarding discharge at True Textiles
Good Morning Sergei,
Thank you for speaking with Dave Walker and me this morning. We are providing a summary of the anticipated
discharge associated with a new product line that True Textiles is considering at their Elkin Maine mill.
Elkin currently operates a WWTP to treat industrial and sanitary discharges from the mill (Permit NC0005312). The
finishing department currently treats fabrics with latex and other products that were previously disclosed in the
application. The mill is considering adding treatment using a silver chloride solution as an antibacterial product. We
have evaluated the potential effect of discharges on the WWTP. We believe that the discharge is allowed under our
current permit according to Part III Other Requirements Section C Changes in Discharges of Toxic Substances. This
section states that NCDENR needs to be notified whenever there are operational changes resulting in routine discharges
of toxic pollutants above 100 ug/L. The following is a summary of True's anticipated discharge:
The antibacterial silver chloride solution to be applied to the fabric contains 30 mg/L silver ion. Approximately 30
gallons per week of this solution may be discharged at the end of each run.
The discharge would result in a maximum concentration of 5 to 30 ug/L in the equalization basin (worst case assessment
assuming all silver chloride stays in solution). We have reviewed articles that identify that the silver chloride is treatable
through activated sludge, and would convert to metallic silver, and precipitate out, ending up in the wasted activated
sludge, however to be conservative, the worst case discharge from the treatment plant would be just 5 to 30 ug/I if all of
the silver chloride just passed through the plant in aqueous phase.
Our review of Part III of the permit (Section C) shows that we do not need to notify NCDENR. However, we understand
that we may need a minor modification of the permit to add silver and chloride as monitoring parameters. Please let us
know if we do need a minor modification, or need to provide you with other information to assess this potential
discharge.
Also, though I did not ask you on the phone, I do want to confirm with you that this discharge to the treatment plant
would be allowed — If we were to ship this waste off -site for stabilization and disposal, the waste misht carry the D011
hazardous waste code for toxicity due to silver. However if it were treated in the WWTP, it would excluded from being a
hazardous waste. (My review of NCDENR rule -15A NCAC 13A .0106 Identification and Listing of Hazardous Wastes
references 20 CFR Part 261.4 Hazardous waste exclusions - and item 2 says "Industrial wastewater discharges that are
point source discharges are exempt from being hazardous wastes).
We would prefer to have the silver treated in the treatment plant, but I wanted to confirm whether the discharge would
be allowed because of this exclusion.
My contact information is below. Thanks again for your consideration of these questions.
Kristie L. Rabasca P.E., LEED A.P.
Senior Environmental Engineer
Sevee & Maher Engineers, Inc.
4 Blanchard Road
Cumberland Center, Maine 04021
www.smemaine.com

(ph) 207.829.5016 ext.316
(fax) 207.829.5692
(cell) 207.415.5830
This electronic message contains information from Sevee & Maher Engineers, Inc. (SME), which may be confidential, privileged or otherwise
protected from disclosure. The information is intended to be used solely by the recipient(s) named. If you are not an intended recipient, be aware
that any review, disclosure, copying, distribution or use of this transmission or its contents is prohibited. If you have received this transmission in
error, please notify (SME) immediately at postmastcr.a smemame.com.