NCS000007_HISTORICAL WITH APPLICATION_20080717

--___-STORMWATER-DIVISION-CODING-SHEET
PERMIT NO.
DOC TYPE
❑ FINAL PERMIT
❑ MONITORING INFO
APPLICATION
❑ COMPLIANCE
❑ OTHER
DOC DATE
❑-d0�0"7
YYYYM M D D

Re: [Fwd: Re: NCS000007 - Synthron, Inc., Burke County]
Subject: Re: [Fwd: Re: NCS000007 - Synthron, Inc., Burke County]
From: Starr Silvis <[e-mail]>
Date: Thu, 17 Jul 2008 13:25:19 -0400
To: Robert Patterson <Robert. Patterson@ncmail. net>
I haven't done a site visit because I talked to the EPA and they said it was fully cleaned up. Let me know
if you need me to go down there.
Robert Patterson wrote:
Have you had a chance to make it by this facility? After you check it out, I'll make the permit
"inactive" in BIMS.
Thanks!
Subject:
Re: NCS000007 - Synthron, Inc., Burke County
From: Robert Patterson <Robert.Patterson u,ncmail.net>
Date: Tue, 20 May 2008 07:04:13 -0400
To: Starr Silvis <Starr.Silvis ncmai].net>
To: Starr Silvis <[e-mail]>
CC: Chuck Cranford <Chuck.Cranford a ncmail.net>, Bradley Bennett
<B rad 1 ey. Bennett@ c m ai l . net>
Thanks Starr. I'm checking with Bradley to see how we should proceed with it. I do know that they
have added a new event in BIMS "inactive" for this type of case. I guess we can't "rescind" a permit
unless the owner asks us in writing to do so. Are you comfortable with EPA guiding the cleanup, or
do you think it would be worthwhile to check to see if there are any remaining exposures? I would
feel more comfortable if we have done a site visit before making it inactive.
Thanks.
Robert
Starr Silvis wrote:
Hi Robert,
I checked with staff who worked on the clean up. The facility is shut down and clean up has
been completed under EPA guidance. Let me know if we need to do a site visit.
Robert Patterson wrote:
Starr/Chuck,
Do you two know anything about this facility? I was beginning to review their individual
1 of 2 7/17/2008 1:29 PM

Re: [Fwd: Re: NCS000007 - Synthron, Inc., Burke County)
sw permit renewal submitted back in 2004/2005, but the phone number provided has been
disconnected. Did they go out of business after the explosion in 2006? If the facility is
shut down, we will likely need a site visit done to be sure the site has been cleaned up
enough to rescind the permit.
Thanks!
Starr Silvis, P.E. - Starr.Silvis a,ncmail.net
Environmental Engineer _
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Surface Water Protection Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax:[phone]
"If there is magic on this planet, it is contained in water."
Loren Eiseley
Starr Silvis, P.E. - Starr.Silvis@nc;nail.net
Environmental Engineer
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Surface Water Protection Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
"if there is magic on this planet, it is contained in water."
Loren Eiseley
Starr Silvis, P.E. <Starr. Silvispncmai ].net>
NC DENR - Asheville Regional Office
Division of Water Quality - Surface Water Protection Section
2 of2 7/17/2008 1:29 PM

[Fwd: [Fwd: Synthron Stormwater]]
Subject: [Fwd: [Fwd: Synthron Stormwater]]
From: Roger Edwards <[e-mail]>
Date: Fri, 29 Sep 2006 16:31:27 -0400
To: Bradley Bennett <Brad][e-mail]>, Tom Reeder <Tom. Reeder@ncmai 1. net>, Paul
Rawls <Paul.Rawls@ncmai].net>, Sandy Mort <Sandy.Mort@ncmai].net>, Jeff Poupart
<Jeff. Poupart@ncmai 1. net>
CC: Larry Frost <[e-mail]>
Please look at the attached data. The stormwater from the Synthron, McDowell
County explosion/fire site is continues to be toxic. EPA contractor is asking when
can the stormwater can be discharged. At present stormwater is captured and fed to
the City of Morganton collection system at a rate of 30 gallons per hours. A
1-inch rainfall event produces 24,000 gallons of stormwater, so the problem is
evident; the volume and time are a critical issue. The incident occurred January
2006, EPA clean-up contractor hired March 2006, anticipated clean-up completion is
November 2006.
This Synthron stormwater may be worse that typical stormwater or maybe not, we
don't know. Does DWQ consider the site "clean" when EPA signs off as the clean-up
complete? If so, stormwater could be allowed to flow from the site at that time.
The concern is that any further environmental damage be prevented, the decision
made be defensible and DWQ integrity be upheld.
Any guidance on dealing with this issue is appreciated.
Thanks,
R. Edwards
Roger Edwards - Roge.r.Edwards�iaca:a'i_ _ne-'t
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
2690 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Subject: [Fwd: Synthron Stormwater]
From: Larry Frost <[e-mail]>
Date: Fri, 29 Sep 2006 10:01:48 -0400
To: Roger Edwards <Roger.Edwards@ncmaiLnet>
CC: greg garrison <[e-mail]>
Roger
1 sent this message to Bradley and have received no response. Greg has been out of
Morganton this week and will return next week. I will be out next week.
I have received no answer from the Stormwater section and believe we owe the
contractor an answer. "When will they be allowed to discharge stormwater?"
If there is anything you can do to move this question along for an answer, I would
appreciate it.
Larry
Larry Frost - Larry. Fro:.tCnc:ma::. .re-
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
1 0; 3 t o/ ] 6/2006 9:19 AM

[Fred: [Fwd: Synthron Stormwater]]
Division of Water Quality - Water Quality Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Subject: Synthron Stormwater
From: Larry Frost <[e-mail]>
Date: Wed, 20 Sep 2006 15:10:49 -0400
To: Bradley Bennett <Bradley.Bennett a ncmail.net>, Roger Edwards <Roger.Edward [e-mail]>
CC: Sandy Mort <Sandy.Mort@ncmai].net>
The cleanup is winding down at Synthron. All stormwater continues to be processed thru the POTW.
Attached is the result of testing preformed on treated and untreated stormwater and toxicity testing on
the same. Sandy and I have talked extensively and agree the stormwater even treated remains too toxic
to discharge.
The question now is, at what point are we going to allow direct discharge.
Thanks
Larry
Larry Frost - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Larry Frost <larry.frost a,ncmail.net>
NC DENR - Asheville Regional Office
Division of Water Quality - Water Quality Section I
Larry Frost <Iarry.frostQncmai].net>
NC DENR - Asheville Regional Office
Division of Water Quality - Water Quality Section
Roger Edwards <Roger.Edwards a ncmai].net>
NC DENR - Asheville Regional Office
Division of Water Quality - Water Quality Section
[Fwd: Synthron Stormfvaterl Content -Type: message/rfc822
Content -Encoding: 7bit
Synthron Stormwater Content -Type: message/rfc822
Content -Encoding: 7bit
2 of 3 10/16/2006 8:19 AM

[Fwd: [Fw& Synthron Stormwater]]
Content -Type: application/pdf
Ceriodapllnia Test results.pdf
Content -Encoding: base64
NPH1991 FINAL 08 22 06 1613.pdf Content -Type: application/pdf
Content -Encoding: base64
Water treatment System Analytical.pdf Content -Type: application/pdf
Content -Encoding: base64
3oi3
10/16/2006 8:19 AM

•e !� _,`�:�;�i�K1.: L�rwi:+M�a1wt.': Ea:a7.. .:7, ��.i N'•'+-
'MichaeLF-Easley, Governor
li'iElialik Ry Jr., Secretary
North Carolina Department f En rot�im°ent and Nati"ral Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
SURFACE WATER PROTECTION
November 2, 2006
Mr. Greg Garrison
WRS
221 Hobbs Street, Suite 108
Tampa, Florida 33619
Subject: Stormwater Treatment
Synthron Incorporated
Permit Number NCS000007
Burke County
Dear Mr. Garrison:
On October 18, 2006 1 visited the Synthron Plant site with you. We reviewed the processing of
stormwater from the site, and the discharge of treated stormwater to the City of Morganton wastewater
collection system. We also, reviewed the plans for the removal of tanks, drums and final grading of
the site. At that time, it was my understanding that all tanks and all drums containing chemicals were
to be removed from the site the week of October 23, 2006. Furthermore, all empty drums were
scheduled for removal the week of October 30, 2006 and that final grading and hydro seeding of the
site would be completed by the week of December 4, 2006.
As a result of the visit of October 18, 2006 and the monitoring results provided to this office by
WRS it has been decided; that once all of the tanks and all of the drums containing material are
removed from the Plant site that treatment of stormwater may be discontinued, the stormwater may
be discharged as was done prior to the plant fire of January 2006.
As follow up to the removal of treatment it is requested that you;
- install two- (2) rock check dams and a silt fence in the drainage way to the stream to help
prevent sediment from reaching the stream.
- hydro seed the site at the earliest possible time.
- schedule one more stormwater sampling event. This event should occur between 30 and
60 days after the cleanup is completed. The sampling should be of a'/2 inch rainfall within a
24-hour period or greater storm event. The sampling should be done at the point where
stormwater leaves the plant site. The following are the requested sampling parameters;
o BOD, COD and TSS
o Metals
n�
nrthCarolina
AMU27!!y
North Carolina Division of Water Quality 2090 U.S. Highway 70 Swannanoa, NC 28778 Phone [phone] Customer Service
Internet: www.ncwaterqualft .org FAX [phone]
An Equal Opportunity/Afirmati:e Action Employer— 60% Recycledfl O% Post Corsumer Paper

Greg Garrison
November 2, 2006
Page 2
o Purgeable Organic compounds
o Acid and Base/Neutral Extractables
o The results should be provided to the Asheville Regional Office once they become
available.
The Division has also requested the City make a thorough inspection of the wastewater
collection system serving this site.
Finally, this letter and the actions described herein do not relieve Synthron Incorporated of its
responsibilities and obligations to comply with and abide by all of the laws, rules and/or regulations as
set forth by the State of North Carolina. If you should have any questions regarding this matter you
may contact me at [phone].
Sincerely,
" Z7,
rry Frost
Environmental Engineer
cc: Stormwater Unit
PERCS Unit
Perry Gauhan - US EPA Region IV, 61 Forsyth Street, Atlanta, Georgia 30303
Don Danforth — City of Morganton
Brent Burch — Division of Waste Management

Re: [Fwd: [Fwd: [Fwd: Synthron Stonnwater]]]
Subject: Re: [Fwd: [Fwd: [Fwd: Synthron Stormwater]]]
From: Ken Pickle <ken.pick] [e-mail]>
Date: Thu, 21 Dee 2006 13:14:03 -0500
To: Bradley Bennett <Bradley,[e-mail]>
Bradley,
a} I see that ARO has decided to allow discharge of site runoff as of December 2006,
as per Larry Frost's letter of November 2, 2006. Did you receive a copy of his
letter? I'll bring you a copy. It looks like I did not provide guidance to ARO in a
timely way, and they have moved ahead to release the clean-up contractor from the
obligation to treat the toxic stormwater runoff. b) Synthron holds NCS000007, expired
in 6/30/05. 1 don't know if they are still our permittee, or not.
Bradley Bennett wrote:
Ken
I think I forwarded this before. We need to take a look at this and get some
feedback to the region. Maybe we can talk about it early next week.
BB
-------- Original Message --------
Subject: [Fwd: [Fwd: Synthron Stormwater]]
Date: Fri, 29 Sep 2006 16:31:27 -0400
From: Roger Edwards <[e-mail]>
To: Bradley Bennett <[e-mail]>, Tom Reeder
<[e-mail]>, Paul Rawls <[e-mail]>, Sandy Mort
<[e-mail]>, Jeff Poupart <[e-mail]>
CC: Larry Frost <[e-mail]>
Please look at the attached data. The stormwater from the Synthron, McDowell
County explosion/fire site is continues to be toxic. EPA contractor is asking
when can the stormwater can be discharged. At present stormwater is captured and
fed to the City of Morganton collection system at a rate of 30 gallons per hours.
A 1-inch rainfall event produces - 24,000 gallons of stormwater, so the problem
is evident; the volume and time are a critical issue. The incident occurred
January 2006, EPA clean-up contractor hired March 2006, anticipated clean-up
completion is November 2006.
This Synthron stormwater may be worse that typical stormwater or maybe not, we
don't know. Does DWQ consider the site "clean" when EPA signs off as the clean-up
complete?. If so, stormwater could be allowed to flow from the site at that time.
The concern is that any further environmental damage be prevented, the decision
made be defensible and DWQ integrity be upheld.
Any guidance.on dealing with this issue is appreciated.
Thanks,
R. Edwards
Roger Edwards - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
1 of 3 12/21/2006 1:16 PM

Re: [Fwd: [Fwd: [Fwd: Synthron Stormwater])]
--------------------------------------------------------
Bradley Bennett
N.C. Division of Water Quality
Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: [phone] ext. 525
Fax: [phone]
email: [e-mail]
Website: htto://h2o.enr.state.nc.us/su/stormwater.html
Subject:
[Fwd: Synthron Stormwater]
From:
Larry Frost <[e-mail]>
Date:
Fri, 29 Sep 2006 10:01:48 -0400
To:
Roger Edwards <[e-mail]>
To:
Roger Edwards <[e-mail]>
CC:
greg garrison <[e-mail]>
Roger
I sent this message to Bradley and have received no response. Greg has been out of
Morganton this week and will return next week. I will be out next week.
I have received no answer from the Stormwater section and believe we owe the
contractor an answer. "When will they be allowed to discharge stormwater?"
If there is anything you can do to move this question along for an answer, I would
appreciate it.
Larry
Subject:
Synthron Stormwater
From:
Larry Frost <[e-mail]>
Date:
Wed, 20 Sep 2006 15:10:49 -0400
To.
Bradley Bennett <[e-mail]>, Roger Edwards
<[e-mail]>
To.
Bradley Bennett <[e-mail]>, Roger Edwards
<[e-mail]>
CC:
Sandy Mort <[e-mail]>
The cleanup is winding down at Synthron. All stormwater continues to be processed
thru the POTW. Attached is the result of testing preformed on treated and
untreated stormwater and toxicity testing on the same. Sandy and I have talked
2 of 3 12/21/2006 1:16 PM

Re: [Fwd: [Fwd: [Fwd: Synduon Stormwater]]]
extensively and agree the stormwater even treated remains too toxic to discharge.
The question now is, at what point are we going to allow direct discharge.
Thanks
Larry
Larry Frost - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
3 of 3 12/21/2006 1:16 PM

OF WArF
9Qri Michael F. Easley, Governor
O�
William Co. Ross Jr., Secretary
r North Carolina Department of Environmcnt and Natural Resources
'C Alan W. Klimek, P.E. Director
Division of Water Quality
SURFACE WATER PROTECTION
November 2, 2006
Mr. Greg Garrison
WRS
221 Hobbs Street, Suite 108 Nay n
Tampa, Florida 33619 7
w`�anas !rA
rich
Subject: Stormwater Treatment
Synthron Incorporated
Permit Number NCS000007
Burke County
Dear Mr. Garrison:
On October 18, 2006 1 visited the Synthron Plant site with you. We reviewed the processing of
stormwater from the site and the discharge of treated stormwater to the City of Morganton wastewater
collection system. We also, reviewed the plans for the removal of tanks, drums and final grading of
the site. At that time, it was my understanding that all tanks and all drums containing chemicals were
to be removed from the site the week of October 23, 2006. Furthermore, all empty drums were
scheduled for removal the week of October 30, 2006 and that final grading and hydro seeding of the
site would be completed by the week of December 4, 2006.
As a result of the visit of October 18, 2006 and the monitoring results provided to this office by
WRS it has been decided; that once all of the tanks and all of the drums containing material are
removed from the Plant site that treatment of stormwater may be discontinued, the stormwater may
be discharged as was done prior to the plant fire of January 2006.
As follow up to the removal of treatment it is requested that you;
- install two- (2) rock check dams and a silt fence in the drainage way to the stream to help
prevent sediment from reaching the stream.
- hydro seed the site at the earliest possible time.
- schedule one more stormwater sampling event. This event should occur between 30 and
60 days after the cleanup is completed. The sampling should be of a'/2 inch rainfall within a
24-hour period or greater storm event. The sampling should be done at the point where
stormwater leaves the plant site. The following are the requested sampling parameters;
o BOD, COD and TSS
o Metals
NorthCarolina
',/ 17hirall f
North Carolina Division of Water Quality 2090 U.S. Highway 70 Swannanoa, NC 28778 Phone [phone] Customer service
Internet: www.ncwalerquality.org FAX [phone]
An Equal Opportunity/Affirmative Action Employer— 50% Recydedfl0% Post Consumer Paper

Greg Garrison
November 2, 2006
Page 2
o Purgeable Organic compounds
o Acid and Base/Neutral Extractables
d The results should be provided to the Asheville Regional Office once they become
available.
The Division has also requested the City make a thorough inspection of the wastewater
collection system serving this site.
Finally, this letter and the actions described herein do not relieve Synthron Incorporated of its
responsibilities and obligations to comply with and abide by all of the laws, rules and/or regulations as
set forth by the State of North Carolina. If you should have any questions regarding this matter you
may contact me at [phone].
Sincerely,
IrryyFrost Z-"
Environmental Engineer
cc: Stormwater Unit
PERCS Unit
Perry Gauhan - US EPA Region IV, 61 Forsyth Street, Atlanta, Georgia 30303
Don Danforth — City of Morganton
Brent Burch — Division of Waste Management

Re: [Fwd: [Fwd: Synthron Chemical water treatment results]]
Subject: Re: [Fwd: [Fwd: Synthron Chemical water treatment results]]
From: Ken Pickle <ken. pick] e@ncmai 1. net>
Date: Fri, 28 Jul 2006 10:09:27 -0400
To: Larry Frost <[e-mail]>
CC: Bradley Bennett <Bradley. Bennett@ncmai 1. net>
Larry,
a) I note that there were hits on barium, cadmium. I don't know the significance of
the levels reported.
b) Intuitively I believe that the BOD report of <2.0 ppm is innocuous.
c) I note that the test data presented does not include some of the analytes that
were previously present in frac tanks 7-12. Many of the metals were not tested for
this time. Organics present in frac tanks 7-12, but not even tested for in -this data
include 4-methylphenol, acetone, methyl acetate, carbon disulfide, and 2-butanone.
I don't have enough of a water chemistry/water pollution background to know if these
omissions are significant, or not.
d) Our starting perspective is that the explosion resulted in a hazardous waste
spill. Runoff that has contacted a hazardous waste is hazardous waste, and cannot be
discharged under the current site stormwater permit. So, I think that as long as the
runoff can be considered to have been in contact with hazardous wastes it cannot be
discharged under our permit.
e) Now, moving on to: What about a cleaned up site? I think our preferred posture is
this: Synthron has a permit, and they're still responsible for the runoff from the
site. We tell other people that abandon a site that they continue to be responsible
for runoff under the permit until they have removed any potential exposure of wastes
or process materials. once that exposure, or potential exposure, is removed we can
rescind the permit at a closed or abandoned industrial site, if the permittee will
request it. I think that applies here. We typically ask the RO to visit the site
and confirm that the clean up has been accomplished as part of the recission
process. I think that ARO site confirmation is especially important in this case.
f) It seems to me that we may need some contact with the NC DWM folks to know what
the federal and state rules require in this sort of situation.
Ken
Larry Frost wrote:
Ken
Bradley is out, will look over the following and give me your thoughts.
Larry
Larry Frost - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Subject:
1 of 3 8/7/2006 2:17 PM

Re: [Fwd: [Fwd: Synthron Chemical water treatment results]]
[Fwd: Synthron Chemical water treatment results]
From:
Larry Frost <[e-mail]>
Date:
Fri, 28 Jul 2006 08:13:24 -0400
To:
Jeff Poupart <[e-mail]>, Bradley Bennett
<[e-mail]>, Sandy Mort <[e-mail]>
To:
Jeff Poupart <[e-mail]>, Bradley Bennett
<[e-mail]>, Sandy Mort <[e-mail]>
CC:
Roger Edwards <[e-mail]>
Guys
As you may or may not remember EPA contractors have been cleaning up the Synthron
Chemical Plant site for the last 2 months and since the explosion that destroyed
the plant they have been collecting all' runoff from the plant in tanks. They have
been discharging this contaminated water to the City of Morganton WWTP at a very
low flow rate to ensure no pass through at the WWTP. They are concerned that with
the on going rain events they continue to add more tanks and get further behind,
also tank rental is expensive and they continue to add tanks (currently 16).
Recently the contractors brought in a filtration unit consisting of progressive
filtration and activated carbon bed . They ran a test of the system on 7/20/06
with the attached results. Their desire is to continue to collect all runoff,
filter all of what is collected (all fire suppression water has been discharged to
the WWTP) and discharge to the stream, with some sort of monitoring (possibly
weekly effluent BOD, COD, TSS RCRA metals semi VOC's and VOC's) reported to ARO.
Please review the attached results and give me your comments/thoughts.
Thanks
Larry
Larry Frost - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
2090 U.S. 70 highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Subject:
Synthron Chemical water treatment results
From:
"Greg Garrison" <[e-mail]>
Date:
Thu, 27 Jul 2006 16:43:39 -0400
To:
<[e-mail]>
To:
<[e-mail]>
CC:
<[e-mail]>, <[e-mail]>
Mr. Frost,
I have attached the analytical results from the water treatment system effluent
sample. Please review for discharge into the storm water ditch on the south side
2 of 3 8/7/2006 2:17 PM

Re: [Fwd: [Fwd: Synthron Chemical water treatment results]]
of the site or per Synthron's NPDES permit discharge point. If approval for
discharge can be expedited it would be greatly appreciated, the frac tanks are
quite expensive and we would like them off -site ASAP.
Thanks for you assistance in this matter,
Greg Garrison
Project Manager
WRS Infrastructure & Environment, Inc.
813-684-4400 (WRS Office)
828- 448-4888 ( Site Phone)
813-917-2542 ( Cell)
3 of 3 8/7/2006 2:17 PM

[Fwd: Synthron Wastewater Discharge]
Subject: [Fwd: Synthron Wastewater Discharge]
From: Dana Folley <[e-mail]>
Date: Fri, 16 Jun 2006 11:03:38 -0400
To: Larry Frost <[e-mail]>, Matt Matthews <Matt.Matthews@ncmai].net>, Jeff Poupart
<[e-mail]>
CC: Ken Pickle <[e-mail]>
FYI. Jeremy and I talked on Tuesday about the status, and he said that EPA had
informed the town a few weeks ago that they were going to haul off tanks 1-6, which
we both found interesting... what had EPA learned about these tanks that we didn't
know .... but in any case, that ended the discussion about those tanks. I did ask
Jeremy to let me know if he found out where they were hauling the tanks to.
That leaves 7-12. Each 20,000 gallon tank is 0.4% of the POTW's average flow of
5MGD, and 0.025% of the receiving stream with 76.93 MGD 7Q10. I will forward you
guys the toxicity results Jeremy and I discussed on Tuesday. These showed tanks 7-12
would not cause toxicity, with the possible exception of tank 10. I did this eval by
multiplying the LC50s by 0.01 per 15A NCAC 02B .0208(a)(1) to get the estimated
chronic value. In all cases, this was higher than the tank's % in the river, so OK -
no toxicity. I went over this with Matt to verify I was doing it right. The
exception was tank 10 whose LC50 was <6.25, which times 0.01 equals <0.065% which is
not all that far off from 0.025%. The problem was - how much less than 6.5% - so we
needed EPA to re -run the test with lower concentrations. Apparently EPA agreed to
haul this tank off, so end of that problem.
Note it appears EPA never ran the ASRIT tests, but they had already done the COD/BOD
thing with this big round of testing, and tanks 7-12, except for 10, had CODS less
than 1500, some quite a bit less. I had talked to Jeremy on Tuesday about what the
ASRIT test does and how he could do somewhat of one in his own lab by observing his
bugs under the microscope. He then pointed out that with his pure oxygen aeration
basin he can essentially measure oxygen uptake in his basins as the waste is fed in.
and be alerted to any oncoming inhibition. We also talked about doing settleability
tests, because he said he had done one on one of the tanks and the solids had never
settled! So it appears that he took all that, did his own tests, and decided to
forgo the ASRIT test requirement. I personally have no problem with this, and think
he will do a good job of monitoring his system.
Also FYI, I will be talking to Ken Pickle in Stormwater about ?I think when EPA will
be allowed to just start letting any new stormwater go? So more later.
-Dana
Subject: Synthron Wastewater Discharge
From: "Rees, Jeremy" <J Rees @ci. morganton. n c. us>
Date: Fri, 16 Jun 2006 08:27:19 -0400
To. "Dana Folley" <dana. folley@ncmail. net>
Dana,
We ran separate settleability tests with our mixed liquor and the calculated loading dose from each tank and saw
no difference compared with our normal mixed liquor.
We also set up a microscopic analysis with the Synthron water and our mixed liquor and saw no difference in bug
activity. We connected the microscope to a t.v. monitor and watched the bugs expire with normal conditions
observed. It took 40 - 45 min for them to dry up on the slide which is normal for us.
We talked with EPA about accepting the wastewater and they volunteered not to discharge FT-10. They will haul it
1 of 2 6/19/2006 8:23 AM

[Fwd: Synthron Wastewater Discharge]
off for disposal.
We are going to accept tanks 07,08,09,11 and 12. They are going to discharge them at a rate of 33 gpm over a 10
hour period. They will dump a tank on Monday, Wednesday and Friday.
After viewing all the lab results, settleability test and microscopic analysis, we felt pretty confident we can accept
the wastewater with no harm to the biological activity in the plant. We will continue to closely monitor the plant over
the next few weeks to look for any signs that the wastewater from the site is affecting the plant.
Jeremy E. Rees
Wastewater Superintendent
City of Morganton
Phone: [phone]
Fax: [phone]
Content -Type: message/rfc822
Synthron Wastewater Discharge;;
Content -Encoding: 7bit
2 of 2 6/19/2006 8:23 AM

Re: Synthron in Morganton
Subject: Re: Synthron in Morganton
From: Boyd Devane <[e-mail]>
Date: Fri, 16 Jun 2006 12:45:10 -0400
To: Ken Pickle <[e-mail]>
What is in the Critical area? the plant site? not the wwtp I assume? You might
make sure that Roger Edwards and Rick Shiver are aware of any correspondence.
Ken Pickle wrote:
Bradley,
Q: Do you think we need to stick our noses into this clean-up operation?
More background: Dana came to see me to fill me in on what's been happening in
her area, at Morganton. She has been in support of the city WWTP agreeing to
accept the contents of five of the frac tanks for final disposal. The very large
dilution available between a 5MGD WWTP and a very large receiving water has
persuaded her and Morganton that it's ok to accept the frac tank water. The
dilution argument, of course, does not apply for our concerns.
She was not aware of any participation by DWM, although I'm not sure that the
clean up aspect would be expected to be of concern to her anyway. She was not
aware of any participation by the local water supply watershed jurisdiction,
either. She did report that the UT adjacent to the site was killed dead by the
aftermath of the explosion.
I guess my limited perspective here rests on our experience with Ward
Transformer. I extend that experience to conclude that there is at least a
possibility that EPA is in control of the Synthron site without knowing what NC
DWQ might like them to do wrt stormwater and protection of this WS-IV CA receiving
water
Ken
1 of 1 6/19/2006 8:26 AM

[Fwd: FW: Update?]-synthron
Subject: [Fwd: FW: Update?]-synthron
From: Dana Folley <[e-mail]>
Date: Fri, 16 Jun 2006 11:04:13 -0400
To: Larry Frost <[e-mail]>, Matt Matthews <[e-mail]>, Jeff Poupart
<[e-mail]>, Ken Pickle <Ken. Pick] e@ncmail. net>
Subject: FW: Update?
From: "Rees, Jeremy" <[e-mail]>
Date: Tue, 13 Jun 2006 11:59:15 -0400
To: "Dana Folley" <[e-mail]>
Dana,
Attached is the information on the toxicity results from Synthron. I am
not sure what they mean exactly. Any help would be greatly appreciated.
Thanks,
Jeremy Rees
City of Morganton
628-438-5375
-----Original Message -----
From.- [e-mail]
[mailto:[e-mail]
Sent: Tuesday, June 13, 2006 8:57 AM
To: Rees, Jeremy
Cc: [e-mail]; [e-mail];
[e-mail]; [e-mail]
Subject: Re: Update?
Hi Jeremy,
Final report is due tomorrow, but here is the prelim. I will be back
in Morganton tomorrow afternoon. Can we get together to discuss the
result?(See attached file: SynthronSummary.doc)
Barbara F. Scott
On Scene Coordinator
U.S. EPA Region IV
61 Forsyth Street, 11th Floor
Atlanta, GA 30303
Phone - [phone]
[e-mail]
"Rees, Jeremy"
<[e-mail]
ton.nc.us>
Barbara Scott/R4/USEPA/US@EPA
06/12/2006 12:47
To
cc
1 of 2 6/19/2006 8:25 AM

[Fwd: FW: Update?]-synthron
PM
Subject
Update?
Have you received any information on the toxicity results?
Jeremy E. Rees
Wastewater Superintendent
City of Morganton
Phone: [phone]
Fax: [phone]
- -
Content -Type: message/rfc822
!VFW: Update? f Content -Encoding: 7bit `
Content -Description: SynthronSummary.doc
SynthronSummary.doc l Content -Type: application/msword
Content -Encoding: base64
2 of 2 6/19/2006 8:25 AM �I

Summary of the Synthron Fire 96-Hour Acute Toxicity Tests with Ceriodaphnia dubia
Sample ID
Media Lethal Concentration {%)
(LC50)
95% Confidence Limits
FT-07
42.23
33.96 - 52.52
FT-08
73.2
66.67 - 80.37
FT-09
73.03
66.25 - 80.5
FT-10
<6.25
Non calculable
FT-11
24.22
18.38 - 31.94
FT-12
> 100
NA

[Fwd: [Fwd: Fw: Frac Tank analysis]]
Date: Tue, 23 May 2006 11: i 0:43 -0400
To: [e-mail], [e-mail], [e-mail]
La rry,
Here are the results for the stormwater tanks including the BOD/COD info. I will be on the
road this afternoon, so please call my cell - 404-229-9495.
Hope you are feeling better!
Barbara F. Scott
On Scene Coordinator
U.S. EPA Region IV
61 Forsyth Street, 11th Floor
Atlanta, GA 30303
Phone - [phone]
scott.barbara@epa._go_v
-----Forwarded by Barbara Scott/R4/USEPA/US on 05/23/2006 11:06AM -----
To: Barbara Scott/R4/USEPA/US@EPA
From: "Robinson, Robert -- EMI" <[e-mail]>
Date: 05/22/2006 05:41PM
cc: [e-mail]
Subject: Frac Tank analysis
Attached is the analysis of FT-07 thru FT-12 (tanks located within the
fence). The BOD may be a little high; they used a dilution of 10 with
all of the samples.
Thanks,
Rob
Content -Type: message/rfc822
Fw: Frac Tank analysis.eml
Content -Encoding: 7bit
Content -Type: application/pdf
FT_47-12 with BOD.pdf
;I Content -Encoding: base64
2 of 2 6/7/2006 5:35 PM

[Fwd: [Fwd: Fw: Frac Tank analysis]]
Subject: [Fwd: [Fwd: Fw: Frac Tank analysis]]
From: Bradley Bennett <[e-mail]>
Date: Tue, 23 May 2006 16:40.59 -0400
To: Ken Pickle <ken.pickle@ncmai 1. net>
Ken
How about take a look at this and let's discuss. We haven't been involved in this to this point so 1 don't
know who directed them to collect the water, etc. Is this ours or would we say it isn't stormwater?
I'll send a second email also.
-------- Original Message--------
Subject:[Fwd: Fw: Frac Tank analysis]
Date:Tue, 23 May 2006 16:11:36 -0400
From:Larry Frost <Larry.FrostPncmail.net>
To:Bradley Bennett <Bradley.BennettPncmaii.net>, Roger Edwards
<Roger. Edwards(u,ncm ail. net>
Bradley
I need stormwater help.
In February'06 Synthron, a chemical, plant in Morganton had a major explosion (the plant was leveled).
Since that day the owner and now EPA have been collecting stormwater from the site at some cost ( I
don't know the cost). They have analyzed all the tanks of collected water and are making plans to
dispose of it thru the POTW. All that said attached is the analysis of the last 12 tanks (FT-12 the most
recent). Looking at the analysis when will EPA (the site manager) be allowed to discharge stormwater
again, under what criteria, etc...
Note: Sandy Mort of Aquatic Tox has reviewed the data and says, that just the metals are 5 times more
toxic than they would recommend in FT-12. Sandy is sending her spreadsheets.
Your units assistance is requested.
Larry
Larry Frost - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of water Quality -- Water Quality Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Subject: Fw: Frac Tank analysis
From: [e-mail]
i of 2 6/7/2006 5:35 PM

Re: [Fwd: [Fwd: Fw: Frac Tank analysis]]
Subject: Re: [Fwd: [Fwd: Fw: Frac Tank analysis]]
From: Ken Pickle <[e-mail]>
Date: Thu, 15 Jun 2006 14:40:43 -0400
To: Bradley Bennett <Bradley. Bennett@ncmai Lnet>
CC: Mike Randall <[e-mail]>
Bradley,
Here's my analysis of the situation in Morganton.
a) First, my response is all intuitive, since I'm not familiar enough with the big
picture rules/laws that might apply in this overall situation. b) And, of course, if
EPA is site manager, they certainly have some idea of what they have to do wrt
stormwater,
c) And, I suspect this is a question that deserves major input from the Div of Waste
Management.
Background,
d) Synthron holds NCS000007, which expired on dune 30, 2005. They discharge to a UT
to Hunting Creek, a class WS-IV CA receiving water in the Catawba River Basin. Their
renewal application was received 1/10/05, and is in our office awaiting action. The
expired permit requires quarterly sampling in the fourth year only, for COD, TSS, and
TKN. File information is limited, but it appears to me that their operation was a
chemical manufacturer, chenical recycler, or chemical disposal site. I guess there
is some questionas to whether our permittee,Synthron, even exists anymore.
So,
e) I think the explosion and fire has resulted in a hazardous waste spill.
f) I'm unclear on whether the contents of the frac tanks are fire suppression waters,
or subsequent stormwaters, or both. (Call placed today to Larry Frost for
clarification.) Assuming for the moment that we're talking about stormwaters, and
assuming that the contents of frac tank 12 are relatively recent, then I conclude
that the frac tank analyses indicate that the hazardous waste spill has not yet been
cleaned up.
g) Liquids generated from contact with hazardous wastes are not stormwater, even if
they originate from the sky; the liquids become hazardous wastes themselves.
h) We certainly cannot allow the discharge of the frac tank contents under NCS000007,
their current stormwater permit. (And Larry's not asking that anyway.)
i) Similarly, we cannot allow the discharge of hazardous waste (i.e. runoff from the
site) under their current permit. I mean, our permittee, Synthron, (or perhaps
whoever is in control of the site, presumably EPA - the site manager), cannot use
our stormwater permit to discharge hazardous waste.
j) As to when EPA or Synthron can begin to allow stormwater to be discharged again, I
suggest we think in terms of being consistent with our perspective when we consider
recission of any existing permit at an abandoned or demolished site. I mean, we
typically tell industrial permittees that their obligation at an abandoned or
demolished site ends only upon the removal of any residuals that might constitute
stormwater exposure. I would apply a similar perspective to this situation, even
though the circumstances are not exactly the same.
k) Given that EPA is in control of the site, and that Synthron may not even exist
anymore, meaning that we may not have a permittee for this expired permit, here's my
overall picture of what our posture could be: First, obviously, EPA cannot discharge
the current frac tank contents into this Critical Area water supply water. Second,
EPA must continue to collect the hazardous waste runoff until the site is cleaned up
below hazardous waste levels, and also provided that the site clean up is evidenced
by the reduction of the levels of metals, organics, and standard pollutants in the
runoff. Third, in addition, EPA must continue to collect stormwater runoff from the
1 of 3 6/15/2006 2:41 PM

Re: [Fwd: [Fwd: Fw: Frac Tank analysis]]
site until the character of the runoff will not cause or contribute, or have the
potential to cause or contribute, to a violation of water quality standards in this
WS-IV CA water. (I note that eventually we may have to agree on some numerical values
for these two levels.) Fourth, we should consider whether EPA needs to apply for a
NCS under the theory that they have control of a site with residuals from prior
industrial activity, subject to the NPDES permitting program, which are exposed to
stormwater. Fifth, DWQ should review the EPA's plan for the clean up of this site (in
whatever form that plan takes, whether one document, or a succession of several
documents) to be sure that whatever EPA plans to do protects the WS-IV CA receiving
water. (I guess, if it's a WS water, then a local jurisdiction may want to get
involved in that review, too.)
Mike, do you have any thoughts to contribute here?
Next steps: Bradley, if you want me to chase this further after Larry Frost returns
my call, I'd call Linda Culpepper to find out what DWM knows about this, and to check
my understandings wrt haz waste sites, EPA's status/immunity as site manager, etc.
I'd also find out from Larry who the players are, so far. Perhaps MPT needs to be in
on this if it turns out to be a joint -Division effort. Given our workload, I'm not
sure how much more time to spend on this, or what our end product should be in this
effort. I'm available to discuss at your convenience, as long as it doesn't
interfere with my preferred activities related to depositions and mediations.
Ken
Bradley Bennett wrote:
Ken
How about take a look at this and let's discuss. We haven't been involved in this
to this point so I don't know who directed them to collect the water, etc. Is
this ours or would we say it isn't stormwater?
I'll send a second email also.
BB
-------- Original Message --------
Subject: [Fwd: Fw: Frac Tank analysis]
Date: Tue, 23 May 2006 16:11:36 -0400
From: Larry Frost <[e-mail]>
To: Bradley Bennett <[e-mail]>, Roger Edwards
<[e-mail]>
Bradley
I need stormwater help.
In February '06 Synthron, a chemical, plant in Morganton had a major explosion
(the plant was leveled).
Since that day the owner and now EPA have been collecting stormwater from the site
at some cost ( I don't know the cost). They have analyzed all the tanks of
collected water and are making plans to dispose of it thru the POTW. All that said
attached is the analysis of the last 12 tanks (FT-12 the most recent). Looking at
the analysis when will EPA (the site manager) be allowed to discharge stormwater
again, under what criteria, etc...
Note: Sandy Mort of Aquatic Tox has reviewed the data and says, that just the
metals are 5 times more toxic than they would recommend in FT-12. Sandy is sending
her spreadsheets.
Your units assistance is requested.
Larry
Larry Frost - [e-mail]
North Carolina Dept. of Environment and Natural Resources
2 of 3 6/15/2006 2:41 PM

Re: [Fwd: [Fwd: Fw: Frac Tank analysis]]
5�
.1
Asheville Regional Office
Division of Water Quality - Water Quality Section
2090,U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Subject:
Fw: Frac Tank analysis
From:
[e-mail]
Date:
Tue, 23 May 2006 11:10:43 -0400
To:
[e-mail], [e-mail], [e-mail]
To:
[e-mail], [e-mail], [e-mail]
Larry,
Here are the results for the stormwater tanks including the BOD/COD info. I will
be on the road this afternoon, so please call my cell - 404-229-9495.
Hope you are feeling better!
Barbara F. Scott
On Scene Coordinator
U.S. EPA Region IV
61 Forsyth Street, 11th Floor
Atlanta, GA 30303
Phone - [phone]
[e-mail] <mailto:[e-mail]>
-----Forwarded by Barbara Scott/R4/USEPA/US on 05/23/2006 11:06AM -
To: Barbara Scott/R4/USEPA/US@EPA
From: "Robinson, Robert -- EMT" <[e-mail]>
Date: 05/22/2006 05:41PM
cc: [e-mail]
Subject: Frac Tank analysis
Attached is the analysis of FT-07 thru FT-12 (tanks located within the
fence). The BOD may be a little high; they used a dilution of 10 with
all of the samples.
Thanks,
Rob
3 of 3 6/15/2006 2:41 PM

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Alan W. Klimek, P.E., Director
November 5, 2004
SYNTHRON INCORPORATED
ATTN: RAYMOND N PINARD, OR SUCCESSOR
305 AMHERST RD
MORGANTON, NC 28655
Dear Permittee:
NCDENR
NORTH CAROUNA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: NPDES Stormwater Permit Renewal
Synthron Incorporated
Permit Number NCS000007
Burke County
Your facility is currently covered for stormwater discharge under NPDES Permit NCS000007. This permit expires
on June 30, 2005. North Carolina Administrative Code (15A NCAC 2H.0105(e)) requires that an application for
permit renewal be filed at least 180 days prior to expiration of the current permit. In order to assure your continued
coverage under your permit, you must apply to the Division of Water Quality (DWQ) for renewal of your permit.
To make this renewal process easier, we are informing you in advance that your permit will be expiring. Enclosed
you will find an individual permit renewal application form, supplemental information request, and Stormwater
Pollution Prevention Plan certification.
Filing the application form along with the requested supplimental information will constitute your application for
renewal of your permit. As stated above, the application form must be completed and returned along with all
requested information by January 7, 2005 in order for the permit to be renewed by June 30, 2005.
Failure to request renewal by January 7, 2005 may result in a civil assessment of at least $500.00. Larger penalties
may be assessed depending on the delinquency of the request. Discharge of stormwater from your facility without
coverage under a valid stormwater NPDES permit would constitute a violation of NCGS 143-215.1 and could
result in assessments of civil penalties of up to $25,000 per day.
If you have any questions regarding the permit renewal procedures please contact Bill Mills of the Stormwater and
General Permits Unit at [phone], ext. 548.
Sincerely,
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
cc: Central Files
Stormwater and General Permits Unit Files
Asheville Regional Office
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% pose -consumer paper

o�of warFROG PERMIT COVERAGE
Y RENEWAL APPLICATION FORM Permit Number
National Pollutant Discharge Elimination System NCS000007
Stormwater Discharge Permit
THIS APPLICATION MUST BE SIGNED AND RETURNED ALONG WITH THE REQUESTED SUPPLEMENTAL
INFORMATION TO THE DIV. OF WATER QUALITY IN ORDER FOR YOUR FACILITY TO QUALIFY FOR
RENEWAL OF YOUR SPORMWATER PERMIT NCS000007
The following is the information currently in our database for your facility. Please review this information carefully
and make all corrections as necessary in the space provided to the right of the current information.
OWNER INFORMATION
Owner/Org. Name: SYNTHRON INC
Owner Contact:
Mailing Address:
Phone Number:
Fax Number
E-mail address:
FACILITY INFORMATION
Facility Name: SYNTHRON INCORPORATED
Facility Contact:
Facility Address: 305 AMHERST RD
MORGANTON, NC 28655
Phone Number:
Fax Number-
E-mail address:
PERMIT INFORMATION
Permit Contact:
RAYMOND N PINARDMailing
F
Address:
305 AMHERST RD
MORGANTON. NC 28655CD
Phone Number:
B28a37861t
Fax Number:
°
E-mail address:
DISCHARGE INFORMATION
Discharge Receiving Water: UT HUNTING CREEK
Stream Class: wSIV CA
Basin:
Sub -Basin #: .030831
Number of outfalls:
CERTIFICATION
Synthront Inc. % Protex International
Peter Bowers, Vice President
305 Amherst Road
Morganton, NC 2865.5
828-437-8611
828-437-4126
[e-mail]
Synthron, Inc.
Peter Bowers, Vice President
ozo—ij r-ou
828-437-41
synthronCh
Peter Bowe
9R-4�7-41
Catawba
1 outfall SDO-001
I certify that I am familiar with the information contained in the application and that to the best of my knowledge and
belief such information is true compIct and accurate.
Signature Date 1 2�ra�1
Peter Bowers Vice President.
Print or type name of person signing above Title
Please return this completed renewal application form to:
Individual Permit Renewal
Altn! Bill Mills
Stormwater and General Permits Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

SUPPLEMENTAL INFORMATION REQUIRED FOR RENEWAL OF INDIVIDUAL NPDES
STORMWATER PERMIT
Two copies of each of the following shall accompany this submittal in order for the application to be
considered complete:
Initials
(Do not submit the site Stormwater Pollution Prevention Plan)
I. A current Site Map from the Stormwater Pollution Prevention Plan. The location of
industrial activities (including storage of materials, disposal areas, process areas and
loading and unloading areas), drainage structures, drainage areas for each outfall, building
locations and impervious surfaces should be clearly noted.
2. A summary of Analytical Monitoring results during the term of the existing permit (if your
permit required analytical sampling). Do not submit individual lab reports. The summary
can consist of a table including such items as outfall number, parameters sampled, lab
results, date sampled, and storm event data. *
3. A summary of the Visual Monitoring results. Do not submit individual monitoring reports.
The summary can consist of a table including such items as outfall number, parameters
surveyed, observations, and date monitoring conducted.
4. A summary of the Best Management Practices utilized at the permitted facility. Summary
should consist of a short narrative description of each BMP's in place at the facility. If the
implementation of any BMP's is planned, please include information on these BMP's.
5. A short narrative describing any significant changes in industrial activities at the permitted
facility. Significant changes could include the addition or deletion of work processes,
changes in material handling practices, changes in material storage practices, and/or
changes in the raw materials used by the facility.
6. Certification of the development and implementation of a Stormwater Pollution Prevention
Plan for the permitted facility (Sign and return attached form).
it If the final year analytical monitoring of the existing permit term has not been completed
prior to filing the renewal submittal, then the last years monitoring results should be
submitted within 30 days of receipt of the laboratory reports. (i.e. do not withhold renewal
submittal waiting on lab results)
Representative storm sampling may now be conducted anytime during the year (the April to
November window has been eliminated) and the representative rainfall event is now
defined as a storm event that measures greater than 0.1 inches and is preceded by at least 72
hours in which no storm event measuring greater than 0.1 inches has occurred.

HAZARDCIUS
DRUM AND TOTE STORAGE PAVED DRUM AND TOTE S70RAGE
TANKER DRUM AND TOTE STORAGE DRUM AND TOTE STORAGE DRUM AND TOTE STORAGE c ♦ \
r � UtORAGE
`�-'r_ SECO1+ GRAVEL
PAYED
OONTNNMENT _ _ _ _ _ __
FIT M O T
0O0 U �
KA
GRINDER BAG HOUSE TANK FARM °�"�`
O
\ ❑ O
OIUYEL
OQ�000 0�0�0 000�
W PAVEMENT
>
OMAINTENANCE SCRUBBER
i-
w
U) � s
RGpI flOGM
II 12
v, JJ RIYELENT
MANUFACTURING
Y
LAB (UPSTAIRS)
+nwREHOUSE
W `
C 3 DRUMMING AREA
ILL W (DOVVNSTAJRS)
O Q PAVEMENT LOADINGOCK D
RAVV
OUTSIDE
MATERLAL DRUM
WALKWAY STORAGE STORAGE
PAVEMENT \
RN�11110 Y�
covEPAG
DAM
BTGRAGE STGFAGE
PROPANE TANK' \ y
~� Ditch__ Berm-001
D1T�i �J
1
AMHERST ROAD LaSDO 5932 N
Long.:-8-1.65682 W
0 s0 120
J� = Local Flow Direction �� —
SCALE: 1" = &Y
INENCO,Inc. Synthrm SWP3 SITE MAP
(704) 66MI92 INCORPORATED 12/15/2004 Supplemental Info. - Item 1

Supplemental Information Item IA.
Map for Synthron, Inc.
Location of SDO-001
40
4A
8 D50 !0 1
L
4PV
1A
r;
dF
4&
Q
P�
hill
r
I '-j 17
1:12,000 'v —
Morganton North
7.5-minute Quadrangle
Index map
NC SPCS E. 369376.7, N:226112.2 meters (NAD83)
Long: -81.6568200 W, Lat: 35.7593200 N (NAD83)

Item 2 - Summary of Analytical Monitoring Results
Synthron, Inc.
Stormwater Permit Renewal - Permit No. NCS000007
Summary of Analytical Monitoring Results
Analytical Monitoring Summary of monitoring performed prior to the 4th Year of the Permit Term Specific Monitoring Requirements (mg/1)
Outfal] Number
Date Sampled
Total Precipitation
(inches)
Event Duration
(hours)
Total Discharge Flow
(MG)
COD
TSS
TKN
SDO - 00 i
August 20, 2000
0.26
1 5.50
0,013910
206
30
5.34
SOO - 001
June 13, 2001
0.41
8.50
0.005920
919
194
16.88
Average Values:
0.34
7.00
0.009915
563
112
11.11
Analytical Monitoring Summary for the 4th Year of Permit Term (June 1, 2003 through May 31, 2004) Specific Monitoring Requirements (mg/1)
Outfall Number
Date Sampled
Total Precipitation
(inches)
Event Duration
(hours)
'Total Discharge Flow
(MG)
COD
TSS
TKN
SDO - 001
June 27, 2003
0.87
3.20
0.001392
732
984
10.4
SDO - 001
September 3, 2003
0.53
2.10
0.004840
203
105
2.11
SDO - 001
December 10, 2003
1.35
8.50
0.013730
161
142
4.49
SDO - 001
March 30, 2004
0.25
3.83
0,002430
419
396
10.9
Average Values:
0.75
4.41
0.005598
379
407
6.98
Synthron, Inc. - Permit No. NCS000007 1 of 1 Stormwater Analytical Monitoring Summary

Item 3 - Summary of Visual Monitoring Results
Synthron, ine.
Stormwater Permit Renewal - Permit No. NCS000007
Summary of Visual Monitoring Results
Ourfall Number
Season
Date Sampled
Color
Odor
Clarity
Floating Solids
Suspended Solids
Foam
Oil Sheen
Other Indicators
SDO - 001
Spring 2000
June 28. 2000
dark brown
slight chemical odor
very cloudy
some (2 out of 10)
very muddy
none
none
none
(8 out of 10)
(8 out of 10)
SDO - 001
fall 2000
August 20, 2000
light brown
slight chemical odor
mostly clear
(3 out of (6)
none
non
mostly
mostly clear
0 out of 10)
none
none
SUO - 001
Spring 2001
June 13, 2001
dark brown
slight chemical odor
Very cloudy)
(9 out of 10
none
muddy
(6 out ] 0)
none
none
none
SDO-001
Pall 2001
October 25, 2001
light brown
slight chemical odor
cloudy
(5 out of 10)
none
muddy
(5 out of 10)
none
none
none
SDO - 001
Spring g 2002
P 6
May 10, 2002
S
dark brown
very slight chemical odor
very' cloudy
(8 out of 10)
Pollen (3 out of 10)
very muddy
(8 out of 10)
none
none
none
SDO - 001
fall 2002
September 25, 2002
medium brown
slight chemical odor
out
(5 clod ]0)
none
(5 out omuddfyl0)
none
none
none
SDO - 001
Spring 2003
June 27, 2003
dark brown
slight chemical odor
very cloudy
none
very muddy
none
none
none
(9 out of 10)
(8 out of 10)
SDO - 001
Pall 2003
September 3, 2003
medium brown
slight chemical odor
Very cloudy
none
muddy
none
none
none
(8 out of 10)
(5 out of 10)
SDO - 001
Spring 2004
March 30, 2004
light brown
weak cherical odor
very• cloudy
(9 out of 10)
pollen (4 out of 10)
muddy
(7 out of 10)
none
none
none
SDO - 001
Full 2004
September 28, 2004
light brown
weak chemical odor
somewhat cloudy (4
none
slightly muddy
none
none
one
Out of 10)
(4 out of 10)
Synthron, Inc. - Permit No. NCS000007 1 of 1 Stormwater Visual Monitoring Summary

Supplemental Information
Item 4
Best Management Practices
The following is a summary of Best Management Practices (BN Ps) utilized at the
Synthron, Inc. facility to help reduce and/or eliminate stormwater pollution:
1. Provide employee training on good housekeeping practices, spill prevention,
hazard communication, hazardous materials handling, forklift operation, material
segregation, and stormwater pollution prevention through the use of good
management practices, runoff management and sediment & erosion control.
2. Conduct preventative maintenance of equipment, tools, storage and reaction
vessels, pipes, lines, valves, and other conveyances as required to maintain a safe
and properly operating work environment.
3. Perform regular inspections of chemical and material storage areas, reaction
vessels, safety and preventative systems, good housekeeping, and drainage areas.
4. Ensure that proper chemical segregation, secondary containment, the SPCC Plan,
and employee training are part of spill prevention and response management
practices.
5. Maintain and ensure sediment and erosion control through regular maintenance of
grassed and vegetative areas, berms, ditches, swells, and other on -site
conveyances to direct stormwater runoff toward SDO-00 i .

Supplemental Information
Item 5
Significant Changes in Industrial Activities
During the term of the recent Stormwater Permit through 2004, there have been no
significant changes in the industrial activities conducted at this facility that would affect
stormwater runoff or contribute to stormwater pollution.

STORMWATER POLLUTION PREVENTION PLAN
DEVELOPMENT. AND IMPLEMENTATION_
CERTIFICATION ' .
N.C. Division of Water Quality, Stormwater and General Permits Unit
Facility Name: SYNTHRON INCORPORATED
Permit Number: NCS000007
Location Address: 305 AMHERST RD
MORGANTON, NC 28655
County: BURKE
"I certify, under penalty of law, that the Stormwater Pollution Prevention Plan (SPPP) document and all attachments
were developed and implemented under my direction or supervision in accordance with a system designed to assure
that qualified personnel properly gather and evaluate the information required by the SPPP. Based on my inquiry of
the person or persons who manage the system, or those persons directly responsible for gathering the information,
the information gathered is, to the best of my knowledge and belief, true, accurate, and complete"
"I certify that the SPPP has been developed, signed and retained at the facility location and the SPPP has been fully
implemented at the named facility location in accordance with the terms and conditions of the stormwater general
permit."
"I am aware that there are significant penalties for falsifying information, including the possibility of fines and
imprisonment for knowing violations"
Sign (according to permit signatory requirements) and return this Certification. DO NOT SEND THE
STORMWATER POLLUTION PREVENTION PLAN WITH THE CERTIFICATION.
Signature
Peter Bowers
Print or type name of person signing above
Date t Lt 0
Vice President
Title
SPPP Certification 2/99

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
February 19, 1999
RAYMOND PINARD
SYNTHRON, INC.
305 AMHERST ROAD
MORGANTON, NC 28655
�••
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: NPDES Stormwater Permit Renewal
Synthron, Inc.
Permit Number NCS000007
Burke County
Dear Permittee:
Your facility is currently covered for stormwater discharge under NPDES Permit NCS000007. This permit
expires on August 31, 1999. In order to assure your continued coverage under your permit, you must apply to the
Division of Water Quality (DWQ) for renewal of your permit. To make this renewal process easier, we are
informing you in advance that your permit will be expiring. Enclosed you will find an individual permit renewal
application form, supplemental information request, and Stormwater Pollution Prevention Plan certification.
Filing the application form along with the requested supplimental information will constitute your application for
renewal of your permit. The application form must be completed and returned along with all requested
information within thirty days of receipt of this letter in order to constitute a timely renewal filing.
Recent legislation modified the fee structure for DWQ permits. Renewal fees have been eliminated and annual
fees have been changed. The new annual fee for your permit is now $715.00 (you will be invoiced later this year
for your annual fee.) A copy of the new fee schedule is enclosed in this package.
Failure to request renewal within the time period indicated may result in a civil assessment of at least $250.00_
Larger penalties may be assessed depending on the delinquency of the request. Discharge of stormwater from
your facility without coverage under a valid stormwater NPDES permit would constitute a violation of NCGS
143-215.1 and could result in assessments of civil penalties of up to $10,000 per day.
If you have any questions regarding the permit renewal procedures please contact Bill Mills of the Stormwater
and General Permits Unit at [phone], ext. 548.
Sincerely,
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
cc: Central Files
Asheville Regional Office
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper