NCS000533_COMPLIANCE_20150512

STORM WATER -DIVISION CODING -SHEET
PERMIT NO.
Np0D�
DOC TYPE.
❑ FINAL PERMIT
❑ MONITORING INFO
❑ APPLICATION
f� COMPLIANCE
❑. OTHER
DOC DATE
❑U t� v S E
YYYYM M DD

w
May 4, 2015
NC DENR/DWQ/Environmental Sciences Section
1621 Mail Service Center
Raleigh, NC 27699-1621'
RE: 2015 Acute Toxicity Monitoring Report — Form AT-2
To Whom It May Concern:
Enclosed are the three copies of the DWQ Form AT-2 for Acute Pass/Fail forms April 2014 for r�
Silar Laboratories under Permit NCS000533 for Outfalls SWOO1. SW002, SWO05, and SWO10
4�
TAA3B Acute Toxicity LC50: SW001 No Flow; SWO02 Pass; SWO05 Fail; SWO10 Fail.
If you have any questions regarding this submittal, I can be contacted at [phone] 101 or
[e-mail]
Brandon Sproles
Environmental Safety and Health Manager
Silar Laboratories
333 Neils Eddy Road
Riegelwood, NC 28456
p(910)-655-4212 ext.101
f (910-655-8201).-,
[e-mail]
300 N. 3rd Street • Suite 120 • Wilmington, NC 28401
�1
RECEIVED
MAY 12 2015
DENR-LAND Ql1ALITy
STORMWATER PERMITTING
(p): 910.762.5800 • (f): 910.228.5033 • www.silar.com

m PO Box 7565
® Asheville, NC 28802
:. Phone: [phone]
«` O Fax: [phone]
Environmental Testing Solutions, Inc.
Effluent Toxicity Report Form - Acute Pass/Fail Date: April 17, 2015
Facility: Enviro Chemists NPDES #: NC- S000533 Pipe #: SWO02 County: Columbus
Silar Labs
Laboratory Performing Test: Environmental Testi olu Inc. Comments:
Signature of Operator in Responsible Charge:
Signature of Laboratory Supervisor. Project: 10570
Sample: 150410.15
Mail Original To: North Carolina Department of Environment and Natural Resources
DWQ/ Environmental Sciences Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
North Carolina Acute Pass/Fail Toxicity Test
Collection Date: 04-09-15
Collection Time: 1012
Test Start Date: 04-10-15
Sample/Type/Duration
i
Grab Comp. Duration
3
X
o
.a
U x
Alkalinity (mg CaCO3AL)
34
Hardness (mg CaCO3/L)
42
Conductivity (µmhos/cm)
152
97
Total Residual Chlorine (mg/L)
<0.10
Sample Temp. at Receipt (°C)
2.4
Mortality
Organism Tested
48-hour - Ceriodaphina dubia
Control
7.65
7.74
pH (S.U.)
7.61
7.84
Treatment
t=
�
Control
17.8
1 7.8
D.O. (mg/L)
18.1
1 7.8
Treatment
Replicate Mean Mortality
Treatment 1 (Control) !�A B C D
V% 0%/O
Treatment 2 (Exposure) A B C D
Concentration 100% 0% 0% 0% 0%
Tested
Note: If mean control mortality exceeds 10%, the test is considered invalid.
H
H
REc
EIVED
MAY
2 2015
tDENR-!_A
D QUALITY
DRMWAT
R PERMITTING
Calculate using Arc -Sine Calculated Student's t NA PASS X
Square Root transformed Tabular Student's t NA FAIL
data. (ONE TAILED)
If the absolute value of the calculated t is less than or equal to the absolute value of the tabular t, check PASS.
If the absolute value of the calculated t is greater than the absolute value of the tabular t, check FAIL.
If all vessels within each treatment have the same response but the treatment two response is greater than the control, check fail.
DWQjorm AT-2 (M1)

• PO Box 7565
Asheville, NC 28802
0 Phone: [phone]
o777 Fax: [phone]
Environmental Testing Solutions, Inc.
Effluent Toxicity Report Form - Acute Pass/Fail Date: April 17, 2015
Facility: Enviro Chemists
Silar Labs
NPDES #: NC- S000533 Pipe #: SW005 County: Columbus
Laboratory Performing Test: Environmental
Signature of Operator in Responsible Charge:
Signature of Laboratory Supervisor: , / ry
Inc. Comments:
Project: 10570
Sample: 150410.16
Mail Original To: North Carolina Department of Environment and Natural Resources
DWQ/ Environmental Sciences Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
North Carolina Acute Pass/Fail Toxicity Test
Collection Date: 04-09-15
Collection Time: 1015
Test Start Date: 04- l 0-15
Sample/Type/Duration
Grab
Comp.
Duration
3
X
o
0
U
�
x
Alkalinity (mg CaCO3/L'
Hardness (mg CaCO3/L'
Conductivity (µmhos/cm;
Total Residual Chlorine (mg/L;
Sample Temp. at Receipt (°C;
34
42
152 P2.4
Organism Tested
48-hour - Ceriodaphina dubia
Control
7.65 7.74
PH {S.U.)
Treatment
17.2117.631
C -v
rn W
Control
7.8 7.8
D.O. (mg/L)
Treatment
18.0 1 7.9
Mortality
Replicate
Mean Mortality
Treatment 1 (Control)
A
B
C
D
0%
0%
0%
0%
H
Treatment 2 (Exposure)
A
B
C
D
70% 80%
Calculate using Arc -Sine Calculated Student's t NC PASS
Square Root transformed Tabular Student's t NC FAIL FAIL
data. (ONE TAILED)
If the absolute value of the calculated t is less than or equal to the absolute value of the tabular t, check PASS.
If the absolute value of the calculated t is greater than the absolute value of the tabular t, check FAIL.
If all vessels within each treatment have the same response but the treatment two response is greater than the control, check fail.
DWQ form AT-2 (8/91)

O
Environmental Testing Solutions, Inc.
Effluent Toxicity Report Form - Acute Pass/Fail
PO Box 7565
Asheville, NC 28802
Phone: [phone]
Fax: [phone]
Date: April 17, 2015
Facility: Enviro Chemists NPDES #: NC- S000533 Pipe #: SWO10 County: Columbus
Silar Labs
Laboratory Performing Test: Environmental Testin utio Inc. Comments:
Signature of Operator in Responsible Charge:
qesn:--a�-
Signature of Laboratory Supervisor: A Project: 10570
Sample: 150410.17
Mail Original To: North Carolina Department of Environment and Natural Resources
DWQ/ Environmental Sciences Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
North Carolina Acute Pass/Fail Toxicity Test
Collection Date: 04-09-15
Collection Time: 1013
Test Start Date: 04-10-15
Sample/Type/Duration
Grab
Comp. Duration
3
X
4
CU
U
�
k
Alkalinity (mg CaCO3/L'
Hardness (mg CaCO3/L;
Conductivity (µmhos/cm'
Total Residual Chlorine (mg/L;
Sample Temp. at Receipt (°C;
W
9.10.4
Organism Tested
48-hour - Ceriodaphina duhia
Control
7.65 7.74
pn (S.W
Treatment
16.3417.221
t= V
Control
7.8 7.8
D.O. {mg/L)
Treatment
8.0 7.9
Mortality
Replicate
Mean Mortality
Treatment 1 (Control)
A
B
C
D
0%
0%
H
Treatment 2 (Exposure)
A
B
C
D
Concentration
70%
Tested
]Vote: If mean control mortality exceeds 10%, the test is considered invalid.
80% 50%
Calculate using Arc -Sine Calculated Student's t NC PASS
Square Root transformed Tabular Student's t NC FAIL FAIL
data. (ONE TAILED)
If the absolute value of the calculated t is less than or equal to the absolute value of the tabular t, check PASS.
If the absolute value ofthe calculated t is greater than the absolute value of the tabular t, check FAIL.
If all vessels within each treatment have the same response but the treatment two response is greater than the control, check fail.
DWQ form AT-2 (8/91)

NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
April 15, 2014
Mr. William E. Oakley, Chairman
Mr. James C. Barker, President
Oak -Bark Corporation
1224 Old Hwy 87
Riegelwood, NC 28456
SUBJECT: Remedial Investigation at Wright Chemical Corporation NPL Site
Dear Mr. Oakley and Mr. Barker,
John E. Skvarla, III
Secretary
I am writing on behalf of Secretary Skvarla in response to your February 11, 2014
letter, which relates your concerns about the scope of the planned Remedial Investigation
(RI) at the Wright Chemical Corporation NPL Site in Riegelwood, Columbus County.
Like OakBark, DENR and EPA staffs consider the cleanup and restoration of areas
impacted by the lead chamber acid plant operated from the 1880's to the early 1960's as the
highest priority.at the site. Your letter questions the need for comprehensive site wide sampling
being required by EPA outside of those impacted areas, given the number of activities currently
and formerly permitted by DENR at the site.
Staff have informed me that a number of factors necessitate an RI that is both site -wide
and comprehensive, but that also meets the need to find a clear and effective path to long-term
permit compliance at your operating facility. Contaminant releases associated with more modern
chemical manufacturing operations at the site cannot be easily distinguished from those of the
lead -acid chamber plant. Sampling data indicate that the permitted units at the site, including the
20-acre spray field, the Kelly Ponds, the lined soil/sludge monofiil are a continuing source of
groundwater contamination, and the areas of their impact overlap with impact from older unlined
wastewater ponds, from the lead -acid chamber waste and with low -pH impacts from a more
modern sulfuric acid plant operated at the site until the 1980's. Also, ownership and operational
history through time is complex.
1601 Mail Service Center, Raleigh, North Carolina 27699-1601
Phone: [phone] Internet: www.ncdenr.gov
An Equal Oppatumly 1 Alfirmave Aclim Employer — 5(% Recycled 110%Posl Conswer Paper

Mr. William E. Oakley
Mr. James C. Barker
April 15, 2014
Page 2
Results of any RI are used to determine protective, cost-effective remedies. During an
April 2, 2014 meeting in Atlanta, EPA and DWM staff stated their commitment to work with the
Responsible Parties to fashion an RI work plan designed to identify those parts of the remedy
that can be conducted under state permits, and to affect the earliest achievable handoff to state
oversight for those parts of the facility. Both agencies also stated their commitment to include
appropriate DWR and DEMLR staff in RI planning, sampling and interpretation, working
alongside the Responsible Parties' consultants. Investigative work can serve both CERCLA RI
and DENR permitting functions, without duplication of effort.
Please feel free to contact me, [phone], if you have questions, or have suggestions
about how NC DENR can assist you in your efforts. Our Staff will work to achieve the goals
stated above, and to meet your desire to prevent duplication in requirements.
Sincerely,
Mitch Gillespie,
Assistant Secretary for the Environment, NC DENR
cc: Dexter Matthews, NC DWM
Jim Bateson, NC DWM
Franklin Hill, US EPA Region 4

A Pp
c��acao�or,��a�
EVALUATION OF STORMWATER OUTFALL CONDITIONS AND NPDES
DISCHARGE PERMIT STATUS
SILAR, LLC
333 NEILS EDDY ROAD
RIEGELWOOD, NORTH CAROLINA
ECS PROJECT NO. 22-17258
PREPARED FOR:
HOPPING GREEN & SAMS, P.A.
TALLAHASSEE, FL
SEPTEMBER 10, 2012
APR 15 2013
BY.

ECS CAROLINAS, LLP "Setting the Standard for Service"
. Geotechnical • Construction Materials • Environmental • Facilities NC Registered Engineering FirmF-1078
September 10, 2012
Mr. Ralph Demeo
Ms. Paula Cobb
Hopping, Green & Sams
119 South Monroe St., Suite 300
Tailahassee, Florida 32301
Reference: Evaluation of Stormwater Outfall Conditions and
NPDES Discharge Permit Status
Silar, LLC Facility
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
Dear Mr. DeMeo and Ms. Cobb:
ECS Carolinas, LLP (ECS) is pleased to provide you with the following report in regard to the
above referenced site. The services provided were conducted in accordance with the scope of
work outlined in ECS Proposal 22-15425 dated February 28, 2012. ECS appreciates the
opportunity to provide our environmental engineering services to you. If there are questions
regarding this report, or a need for further information, please contact us at [phone].
eRespectfully submitted,
ECS CAROLINAS, LLP
eRudY Smit ick, P.G.
Senior Geologist
NC License No. 866
Brian E. Maas, REM�l���
Director of Environmental Services APR
' 15 2013
BY.
7211 Ogden Business Park, Suite 201, Wilmington, NC 28411 • T: 910-686-9114 F: 910-686-9666 www.ecslimited.com
ECS Carolinas. LLP • ECS Florida, LLC • ECS Midwest, LLC • ECS Mid -Atlantic, LLC ECS Southeast, LLC ECS Texas, LLP

1
TABLE OF CONTENTS
1.0
BACKGROUND INFORMATION......................................................................1
2.0
NPDES PERMIT STATUS.................................................................................6
3.0
EVALUATION OF SILAR OUTFALLS..............................................................9
3.1
Outfall SWO01..................................................
3.2
Outfall SWO02..............................................................................................15
3.3
Outfall SWO05................................................................................................17
3.4
Outfall SW010................................................................................................19
3.5
Adjacent Outfalls and Sources.....................................................................20
3.6
Recent Stormwater Sampling Performed by Silar.....................................20
4.0
STORMWATER BMPs AND IMPROVEMENT ALTERNATIVES...............21
5.0
CONCLUSIONS................................................................................................26
6.0
RECOMMENDATIONS.......................................................................27
6.1
Monofill..........................................................................................................27
6.2
Outfall SWO06 and Momentive Duck Pond................................................28
6.3
Silar Outfall SWO02.......................................................................................29
6.4
Compliance with NPDES Permit.................................................................29
6.5
Agency Communication/Meeting with Regulators......................................30
6.6
Septic Drain Field and Outfall SW008........................................................30
6.7
Best Management Practices........................................................................
31
6.8
Additional Sampling and Analysis................................................................31
7.0
QUALIFICATIONS OF REPORT..........................................................32
FIGURES
APPENDIX
Figure 1 - Site Location Map
Figure 2 - Storm Water Map Showing Drainage and Outfall Locations
Appendix I - Copy of NPDES Permit
Appendix II - Copy of Compliance Inspection Report (NCDENR)
Appendix Ill - Copy of Staff Review and Evaluation (NCDENR)
Appendix IV -- Sampling/Analytical Results for Silar Outfalls

Evalualion of Stormwater Outfall Conditions
Silar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
1.0 BACKGROUND INFORMATION
September 10, 2012
The Silar, LLC (Silar) site is located at 333 Neils Eddy Road in Riegelwood, North Carolina
(Figure 1). The site is comprised of a 6.57 acre parcel of property leased from Oak Bark
Corporation (Oak Bark). Silar leased the current site and began operation on April 22, 2009.
The former Silar Laboratories facility (owned by Wright Chemical Corporation and later
purchased by Oak Bark Corporation) operated in this same location from 1992 until 2009. Silar,
LLC is primarily engaged in the manufacturing of organosilanes, silicones, and adhesion
promoters for use in pharmaceutical, biomedical device, electronics, industrial, and research
and development markets. The Silar manufacturing facility is ISO 9002 certified and capable of
producing gram and kilo -lab scale through multi -ton quantities at the Riegelwood plant site.
The facility is permitted to discharge stormwater to nearby surface waters under North Carolina
Department of Environment & Natural Resources (NCDENR), National Pollution Discharge
Elimination System Permit (NPDES) Permit No. NCS000533. The date of issuance of the Final
NPDES Stormwater Permit was November 1, 2010. The permit allows discharge of stormwater
into receiving waters designated as Livingston Creek (Broadwater Lake), a Class C, SW stream
in the Cape Fear River Basin. The permit authorizes discharge of stormwater associated with
industrial activity in accordance with the limitations, monitoring requirements, and other
conditions cited. The permit became effective from the date of issuance in November 2010 and
expires October 31, 2015. The NPDES permit is non -transferable.
The objective of ECS performing this review was to evaluate the general requirements and
compliance status with the NPDES permit, review of historic stormwater analytical results,
inspect the site to observe field conditions relative to each permitted outfall, and assess
reasons for degraded stormwater quality determined by routine monitoring. From this
evaluation, ECS has determined Silar's compliance status with the NPDES permit requirements
and various factors impacting stormwater quality at each outfall. Review of the NPDES permit
identifies three stormwater discharge outfalls (SDOs) in the original permit application. The
NPDES discharge permit issued November 1, 2010 identifies the three outfalls as SW001,
SW002, and SW005. It should be noted that Outfall SWO01 was re -located upstream in the
watershed in the March/April 2012 timeframe. The outfall was relocated by the facility after
discussions with NCDENR. The "new" sample location was selected to minimize runoff and
influence from discharges occurring from the adjacent Oak -Bark Monofill. This will be discussed
in more detail in the ensuing report. This evaluation focused on stormwater conditions related to
each of these outfalls in addition to one other outfall, SW010, which was added to the
monitoring network and is discussed below.
After NCDENR issued the permit in November 2010, the first facility compliance inspection was
not conducted until January 24, 2012. Ms. Linda Willis, a NCDENR Division of Water Quality
(DWQ) Engineer, performed the inspection and identified a fourth un-permitted outfall located
at the facility. The un-permitted outfall was identified in the Silar 126/Fine Chemicals area of the
site. This outfall was subsequently designated by NCDENR as SW010. As a result of the
inspection, NCDENR requested Silar to modify the Stormwater Pollution Prevention Plan
(SWP3) to include the additional outfall. The NCDENR Compliance Inspection Report
documenting the inspection further required the new outfall be monitored and sampled per the
conditions of the NPDES permit (See copy of Compliance Inspection Report in Appendix 1).

Evaluation of Stormwater Outfall Conditions September 10, 2012
Sitar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
The Compliance inspection Report further noted that NCDENR had reviewed the required
stormwater data submitted by Silar and benchmark values were found to historically exceed
permit threshold limits at Outfalls SW001, SW002, and SW005. Because of consecutive events
of benchmark value exceedance, Tier I and II sampling requirements were triggered for each
outfall. As a result of consecutive events of non-compliance at some outfalls, Tier III sampling
requirements were later triggered and required for Outfall SWO02 and SW005. Tier III sampling
was triggered by four consecutive sampling events showing benchmark exceedances. At these
two outfalls, Acute Toxicity testing was required in addition to other routine benchmark testing
required by the permit. The NCDENR Compliance Inspection report also advised the facility to
evaluate the reasons for non-compliance with stormwater benchmark values and to propose a
remedy for improving the stormwater quality discharge. The State's report advised the facility to
revise the SWP3 to include the Best Management Practices (BMPs) and identify the measures
necessary for improving stormwater quality at the outfalls. The State also suggested that Silar
test the condensate discharge from compressors proximate to the SWO05 outfall where bio-
growth was observed. The State suggested testing the condensate for Chemical Oxygen
Demand (COD).
The NCDENR Compliance Inspection Report noted that sampling/analytical results from
SWO01 shows "very high nitrogen contamination" according to Ms. Linda Willis. The inspector
' noted that "excessive and lush green grass was observed growing in the vicinity of SW001"
during the NCDENR compliance inspection. The Compliance Inspection Report requested Silar
to "please consider investigating any potential for groundwater contamination that may be
breaking out near the surface. Groundwater contamination may be contributing to high levels of
pollutants at Outfall 001." A potential source of groundwater contamination that may be
contributing to degradation of stormwater noted at Silar SWO01 is the Oak Bark Waste Monofill.
The Oak Bark Monofill abuts the Silar southern property boundary and is proximate to the
SW001 Outfall. The Waste Monofill is an earthen containment dike located approximately 200
feet upgradient of SW001. The Monofill contains a variety of nitrogen based wastes and metal
sludges that were disposed in the earthen cell according to NCDENR files. A field report
authored by Dr. Charles Stehman, P.G., former NCDENR Hydrogeological Supervisor, states
"the monofill was constructed to contain industrial process waste materials which include
hexamine and formaldehyde that were previously contained in a remote storage pond ." Dr.
Stehman further commented that "Wright Corporation is already known to have groundwater
contamination in the plant area" referring to the area adjacent to the monofill. (Record of Waste
Disposal Permit Application Review, Attached Additional Comments, Wright Corporation,
"Monofill"- authored by Dr. Charles Stehman, September 10, 2001). The high concentrations of
nitrogen -bearing compounds detected in stormwater on the Silar site can be directly correlated
to the waste disposed in the Oak Bark monofill. Groundwater on the Sitar property has likely
' been impacted as well by the waste monofill. Since the Oak Bark monofill is upgradient of Silar
and impounds over 900,000 gallons of waste water, it is most probable that impacts to Silar
groundwater, surface water, and stormwater are occurring.
Two other offsite potential sources that may be contributing to stormwater quality degradation
on the Silar site are two active chemical production plants known as Momentive Specialty
Chemicals and Oak Bark Corporation. Each facility formulates specialty chemical products with
chemical signatures that are much different from those products produced and handled by

r
Evaluation of Stormwater Outiall Conditions September 10, 2012
Sitar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
r
Sitar. Momentive Specialty Chemicals (formerly Hexion Specialty Chemicals, Inc.)
' manufactures formaldehyde by reacting acetone and methanol in an aqueous process.
Momentive also processes anhydrous ammonia to produce hexamine and other specialty
ketone -formaldehyde resin products. Momentive also produces formaldehyde derivatives.
These chemical formulations and processes integral to Momentive's operation are not used by
Sitar or associated with Sitar's processes and operation. Hexamine (a nitrogen based organic)
and formaldehyde are generated, used, and stored in significant quantities on the adjacent
Momentive site. These two compounds are not used in Sitar's processes. Because of the
volume of nitrogen -based materials and formaldehyde used on the Momentive site (and their
presence in stormwater draining from Momentive onto the Silar site), it is highly probable that
Momentive's operation is a key source of nitrogen -bearing compounds contributing to
stormwater degradation on the Silar site. This observation is further supported by review of
materials handling data provided by Sitar which shows a comparison of the volume of nitrogen -
bearing materials handled by Sitar versus that of Momentive. In that data, Momentive's
hexamine operation is shown to produce between 1,000,000 to 2,000,000 pounds (lbs) of
hexamine per month. Hexamine is a nitrogen -bearing material. In comparison, Sitar produces
less than 19 pounds of ammonia per month (also a nitrogen based material) by fugitive
Q emission. From this data, the volume of nitrogen based material produced by Silar is calculated
to be less than 0.002 % of that produced by Momentive's processes. The volume of nitrogen -
bearing material discharged by Momentive into air, surface waters, wastewater, and stormwater
' is infinitely greater than the minimal volume produced by Sitar.
The other adjacent chemical production facility potentially impacting stormwater quality on the
r Sitar site is Oak Bark Corporation. Oak Bark formerly owned the Sitar facility prior to Sitar's
acquisition of the asset in April of 2009. Oak Bark's manufacturing process has utilized a
formulation of 57% Zinc Mintrex, 27% Copper Mintrex and 16% Manganese Mintrex in
' producing an animal feed additive. Weak acid (Alimet) is reacted with these minerals and
vacuum dried and milled to a specified particle size. Oak Bark operates its facility under a
separate independent stormwater NPDES permit from Momentive and Silar. Both Oak Bark and
Momentive operate under various other State permits including wastewater, recycling, pump
and haul, and land application systems governed by NCDENR. According to the NCDENR files
reviewed by ECS, analytical results of stormwater sampled on the adjacent Momentive and Oak
Bark facilities typically detect nitrogen compounds, formaldehyde, hexamine, copper, zinc and
manganese in stormwater samples from these plants. Each of these compounds are inherent to
present or past chemical production operation on the two adjacent facilities. These same
compounds are periodically detected in Sitar's stormwater. The occurrence is attributed largely
to significant offsite sheetflow and run off entering upon the Silar site from the two adjacent
plantsites. Specifically, the Silar SWO02 and SWO05 Outfall locations are influenced by run-off
from the adjacent sites. Silar does not use zinc, copper, hexamine, or formaldehyde based
' materials in its processes, therefore is not a source for these compounds occurring in site
stormwater. These compounds are indigenous to the processes conducted now or formerly on
the Momentive and Oak Bark sites. Stormwater samples collected from each of the three
I adjacent plantsites (Sitar, Momentive, and Oak Bark) show the presence of these compounds
exceeding benchmark values. Silar communicated their concern with the impacts of
sheetflowlrun off from the adjacent plantsites with NCDENR on March 7, May 31, and October
' 20, 2011. In letters to NCDENR, Sitar notified the State that stormwater sampling was
performed to determine impacts of stormwater sheetflowing off the Momentive site onto the

Evaluation of Stormwater Outfall Conditions September 10, 2012
' Sitar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
Silar site in the SW002 Outfall vicinity. Offsite upgradient stormwater (sheetflow) from the
Momentive and Oak Bark sites was sampled and compared to stormwater quality at Silar
Outfall SW002. The analytical results of this comparison demonstrated that the upgradient
offsite stormwater entering upon Silar property into the Silar SWO02 Outfall was non -compliant
with a number of benchmark parameters. Silar's comparison demonstrated two points. First,
that offsite stormwater was entering the Silar site via- sheetflow from adjacent sites (i.e.
Momentive and Oak Bark). Secondly, the degraded quality of the offsite stormwater (sheetflow)
from the Momentive and Oak Bark was non -compliant with NPDES benchmark values and
impacting Silar stormwater quality. This evaluation concluded that stormwater sheetflow onto
the Silar site from the Momentive site was degrading stormwater quality particularly at Silar
Outfall SW002.
The offsite stormwater samples collected by Silar during the 2011 evaluation detected the
following target benchmark values exceeding permit benchmark limits:
• Total Suspended Solids (TSS),
0 Chemical Oxygen Demand (COD),
p• Biological Oxygen Demand (BOD),
• Ammonia (NH3),
* Total Kjeldahl Nitrogen (TKN),
' • Zinc (Zn),
a Formaldehyde (CH2O),
Nitrate (NO3),
• Nitrite (NO2),
Copper (Cu),
• Zinc (Zn),
• Manganese (Mn)
C Total Residual Chlorine (TRC)
Methanol and hexamine were also present in detectable concentrations at the time of sampling
though did not exceed benchmark values. Methanol and hexamine are inherent to Momentive's
former feed additive processes. Momentive presently utilizes methanol in bulk quantity and has
capacity to store several thousand gallons in six above ground storage tanks (ASTs) located
approximately 150 LF upgradient of Silar's SWO02 Outfall. The adjacent Momentive methanol
tank farm is located within the watershed that drains onto Silar's site and into the SWO02
' Outfall.
The above analytical data collected by Silar demonstrates that stormwater runoff from the two
' adjacent plantsites are adversely affecting stormwater quality within the Silar watershed. This
determination is evident due to the presence of several key signature compounds detected in
stormwater samples that are used or produced historically in high volume by Momentive and
Oak Bark. Signature compounds detected in stormwater samples sheetflowing from the
Momentive site include the nitrogen -bearing compounds total nitrogen, TKN, nitrite, and nitrate.
In addition, formaldehyde was also detected in the samples collected and is a compound that is
known to be associated with Momentive's processes. Other signature compounds detected that
Iare historically associated with Oak Bark's processes include zinc, copper, and manganese.
1

I
Evaluation of Stormwater Outfall Conditions
Silar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
September 10, 2012
None of the above signature compounds mentioned are inherent to Silar's processes therefore,
it is apparent that the adjacent operations of Oak Bark and Momentive are contributing to
degradation of stormwater quality on the Silar site. Silar submitted the findings and analytical
data to NCDENR in October 2011 and proposed that the concentrations of the signature
compounds detected be deducted from the total benchmark values detected in Silar's SDO
samples. This proposed method would effectively establish representative values of target
compounds by removing the sample interference caused from the two adjacent chemical
plants. This deduction is logical however, Linda Willis/NCDENR did not concur with the
proposal for adjusting benchmark values at SWO02 based on one set of sample results from
the adjacent sites. The DWQ requested Silar to continue with monitoring and reporting as
required by the NPDES permit. In follow up discussions between ECS and Linda Willis/DWQ on
March 25, 2012 and June 26, 2012 the findings of the NCDENR Compliance Inspection Report
was discussed. Ms. Willis acknowledges that each of the three adjacent facilities sharing a
common campus exhibit stormwater exceedances. She also states that consecutive periods of
non -compliant benchmarks values from each facility may be inter -related. Ms. Willis stated that
stormwater flow between each of these facilities is likely commingled and that it will be
important for each facility to distinguish their representative flow regimes and take measures to
address improvement. Ms. Willis further noted that the campus -wide stormwater issues are
complex and encouraged a "collaborative effort" among each facility to address improvement of
stormwater quality. Ms. Willis stated that each facility has been "required equally by DWQ to
evaluate and implement the use of Best Management Practices (BMPs) to achieve permit
compliance" with non -compliant outfalls. It was suggested by Ms. Willis that each area of the
facility contributing to stormwater contamination be evaluated thoroughly to determine whether
source controls, operational controls, or physical (structural) controls should be implemented to
improve the quality of stormwater discharging from the facilities. Ms. Willis concluded that
stormwater quality noted at each Silar outfall has been determined to be "non -compliant" during
various periods of sampling. Ms. Willis also raised a concern about whether "ongoing sources"
of contamination are present since the analytical trend does not show improvement of
stormwater quality through the permit cycle. She also pointed out that stormwater quality may
perhaps be associated with runoff from roof tops and roof drains. She suggested this be
considered in future evaluations. With regard to a deadline for achieving compliance, the
Compliance Inspection Report authored by Ms. Willis states that "whatever corrective measures
are selected to attain compliance of benchmark values must be implemented with two months
of the facility performing its Tier I inspection". ECS notes that this time period has since lapsed.
The Tier I Inspection is designed to determine what source(s) are causing non -compliant
stormwater conditions for any benchmark parameter at any outfall. Below are the five
requirements specified by the NPDES Permit for the Tier I evaluation:
Tier I Evaluation Requirements
1.
Conduct a stormwater management inspection of the facility within two weeks of
receiving sampling results.
2.
Identify and evaluate possible causes of the benchmark value exceedances
3.
Identify potential and select the specific source controls, operational controls, or
physical improvements to reduce concentrations of the parameters of concern, or to
bring concentrations within the benchmark range.
4.
Implement the selected actions within two months of this inspection.
F

r
Evaluation of Stormwater Outfall Conditions
Silar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
1
September 10, 2012
5. Record each instance of a Tier One response in the SWP3. Include the date and value
of the benchmark exceedance, the inspection date, the personnel conducting the
inspection, the selected actions and the date the selected actions were implemented.
Each of the conditions shown above in Tier I should have been addressed by the facility within
two months of the January 24, 2012 Compliance Inspection date. In addition to the Tier I
requirements shown above, Tier III has since been triggered due to benchmark exceedances
occurring on four consecutive events at Outfalls 002 and 005. Though there has been
communication between Silar and DWQ regarding site stormwater conditions, the NCDENR
files do not reflect that Tier I or Tier III requirements have been fully met. Subsequent
conversations with Linda Willis confirm that DWQ expects Silar to perform monthly
sampling/monitoring/reporting as required and also submit plans for implementing BMPs to
restore degraded stormwater quality to compliant levels. The requirements of Tier III evaluation
that should be fulfilled include the following:
Tier III Evaluation Requirements
1.
Notify DWQ Regional Supervisor in writing within 30 days of receipt of the fourth
analytical result.
2.
Frequency of monitoring may be increased or adjusted based on DWQ's review.
3.
Conduct acute toxicity testing on discharges.
4.
Install structural stormwater controls.
5.
Implement other stormwater control measures deemed necessary by DWQ.
In this evaluation, ECS has performed an initial assessment of site stormwater conditions,
potential contributing sources, offsite sheetflow, and other potential factors that may be
impacting site stormwater quality. The objective of this evaluation was not tailored to satisfying
the Tier I or Tier III requirements, however may aid Silar in identifying sources and factors
contributing to stormwater degradation on the site. This following report discusses site
stormwater conditions and compliance with the NPDES permit conditions.
2.0 NPDES PERMIT REVIEW
NPDES Permit
The facility is permitted to discharge stormwater to nearby surface waters under a National
Pollution Discharge Elimination System Permit No. NCS000533. The effective date of the
NPDES Stormwater Permit was November 1, 2010. The permit allows discharge of stormwater
into receiving waters designated as Livingston Creek (Broadwater Lake), a Class C, SW stream
in the Cape Fear River Basin. The permit authorizes discharge of stormwater associated with
industrial activity in accordance with the limitations, monitoring requirements, and other
conditions cited. The permit is in effect from the date of issuance until October 31, 2015. The
permit is also non -transferable to other parties or entities.
The objective of reviewing the NPDES permit was to evaluate the general
requirements/conditions, review stormwater analytical results, and determine the compliance
status with the NPDES permit requirements. Under the original NPDES permit, three
L

1
Evaluation of Stormwater Outfall Conditions September 10, 2012
Silar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
1
stormwater outfalls were included in the application. They are SW001, SWO02, and SWO05.
Two years after issuance of the permit, NCDENR conducted a routine facility compliance
inspection and noted a fourth unpermitted outfall during the inspection. The outfall was
identified by DWQ as SW010. It was required that the facility include the outfall in future
monitoring efforts and illustrate it's location on the Site Plan. The permit was reviewed by ECS
to determine Silar's adherence to the requirements contained in the permit. Following is a
summary of the review and possible deficiencies noted.
Compliance Evaluation and Determination
The above referenced permit was reviewed to determine adherence to the requirements in the
NPDES permit and to determine if deficiencies are present that should be addressed. The
following items of deficiency were determined during the review. Please refer to the NPDES
permit for a full description of the requirements summarized below. This review also relies of
the information reported in the January 24, 2012 NCDENR Compliance Inspection Report and
subsequent conversations with Ms. Linda Willis/NCDENR Engineer.
In general, the following benchmark parameters have been exceeded as noted from review of
the Silar stormwater monitoring data. Nitrogen bearing compounds have been associated with
stormwater routinely discharged from SW001, SWO02 and SWO05 dating back to 2000 when
Wright Chemical operated on the site. Metals including zinc and copper (along with the non-
metals; formaldehyde and manganese) have been associated with stormwater discharged from
SWO05 dating back to at least 2006. Below is a table generically illustrating the compounds
typically detected above benchmark values at each Silar outfall:
I Table 1
Stormwater Analytical Results by Outfall
OUTFALL
BENCHMARK PARAMETERS EXCEEDED
SW001
NH3,TSS,TKN,NO3}NO2,Cu,Zn
SWO02
BOD,COD,NH3,TKN,CH2O,Cu,Zn
SWO05
BOD,COD,TSS,NH3,TKN,CH2O,Cu,Zn,pH
SW010
Cu,Zn,CH2O,Mn
BOD=Biological Oxygen Demand; COD=Chemical Oxygen Demand; TSS=Total Suspended Solids; TKN=Total Kjeldahl
Nitrogen; NO3=Nitrate; NO3+NO2=Nitrate plus Nitrite; Cu=Copper;CH2O=Formaldehyde; Zn=Zinc; Mn=Manganese
Nitrogen (and derivatives) are routinely detected in stormwater samples collected form the Silar
site. Nitrogen is a naturally occurring compound and is in abundant on earth. It is also
associated with agricultural operations, fertilizer production, chemical formulation, and industrial
manufacturing processes. The relative volume of nitrogen bearing compounds handled by Silar
and released is reported to be less than 226 pounds/year. This volume is infinitely small in
comparison to the several millions of pounds of nitrogen bearing materials handled/released by
the adjacent Momentive plant site. There is a low probability that the ammonia, TKN, and total
nitrogen detected in Silar's stormwater outfall samples are associated entirely with Silar's
processes. The probability is significantly higher that these compounds are associated with
processes, emissions, or waste treatment occurring on adjacent sites, particularly Momentive.
7

1
Evaluation of Stormwater Quttall Conditions September 10, 2012
Sitar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
Below are the deficient NPDES permit conditions noted by ECS's at the time of this review. The
facility may have addressed some or all of the below deficiencies at the time of this report. The
facility should review their files and determine if the following has been adequately addressed:
identified:
1. Part II-- Monitoring, Controls, and Limitations for Permitted Discharges
Section A: Stormwater Pollution Prevention Plan
Silar should review its current SWP3 and determine if the following items have been
updated and reflect present site conditions in order to comply with the NPDES permit
conditions:
1. Site Plan
(e) certification of stormwater outfalls/annual evaluations
2. Stormwater Management Plan (SMP)-preparation and submittal
(a) Feasibility Study -review of technical/economical feasibility of BMPs
(b) Secondary Containment -records documenting quality prior to release
(c) BMP Summary -list and summary of all BMP's used or proposed
The SWP3 plan is not required to be submitted to DWQ however, is required to be updated and
maintained by the facility at all times. The facility has prepared and submitted a SWP3 plan -to
NCDENR. The content should be re-evaluated to determine that the plans content is current
and accurately reflects site conditions. If structural or non-structural BMP's have been identified
as per No. 2(c) above and accepted by NCDENR, then it is advised that such BMP's be
implemented at this time to restore each outfall location to compliant conditions. If not, then
appropriate BMPs for each outfall must be determined and implemented and documented in an
updated SWP3. Recommendations for selection of appropriate BMPs are provided in Section
6.0 of this report. The following paragraphs address the analytical monitoring deficiencies noted
from our review of the NPDES permit:
Section B: Analytical Monitoring Requirements
Table 3 Benchmark Values for Analytical Monitoring
-Perform Tier III Monitoring due to four consecutive noncompliant events
-Perform Acute Toxicity Testing
-Install Structural Stormwater Controls
-(1) develop a strategy for implementing appropriate BMP's
-(2) submit a timetable for incorporating BMP's in SWP3 Plan
A copy of the applicable NPDES permit for the Silar facility is included in Appendix I. A number
of deficiencies noted above were also cited by Linda Willis/DWQ in the January 24, 2012
Compliance Inspection Report. The Compliance Inspection Report states that a SWP3 Plan is
on file with NCDENR however, during ECSs file review, the SWP3 plan could not be located in
the file search. Regardless, in the Compliance Inspection Report, NCDENR also noted that the
facility is "compliant" on the cover page of the report. Further review of the content of the report
is conflicting with this and indicates that the sampling results show consecutive periods of
benchmark values exceeding permit limits. The Compliance Inspection Report states four
consecutive exceedances of benchmark values occurred at SWO02 and SW005, therefore
prompting Tier III acute toxicity testing. DWQ further recommended that Silar "evaluate the site
9

Evaluation of Stormweler Outfall Conditions September 10, 2012
Silar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
for all potential sources and provide their office with written plans for improvement whether
structural or non-structural." DWQ also required that the evaluation and proposed
improvements be incorporated into the SWP3 and titled as "Tiered Responses". DWQ also
indicated that it would provide Silar with an opportunity to resolve the issues before exercising
any Tier III Actions including enforcement remedies available to the agency.
Per the NPDES Permit, Section B: Analytical Monitoring Requirements, Table 3, Page 7 of 11,
a it states "the benchmark values in Table 3 are not permit limits but should be used as guidelines
for the permittee's Stormwater Pollution Prevention Plan. Exceedances of benchmark values
require the permittee to increase monitoring, increase management actions, increase record
keeping and/or install stormwater Best Management Practices in a tiered program. Page 9 of
11 of the permit states that in regard to Total Maximum Daily Loading (TMDL) additional
monitoring may be required for pollutants of concern and if so, additional BMPs may be
necessary. The permit further states that "if additional BMPs are needed to achieve the
required level of control, the permittee will be required to (1) develop a strategy for
implementing BMPs and (2) submit a timetable for incorporation of those BMPs into the
permitted Stormwater Pollution Prevention Plan".
To date, Silar has not received a Notice of Violation, Notice of Non-compliance, Consent Order,
or other form of enforcement action from NCDENR. Further enforcement action options are
available to DWQ because consecutive sampling periods exceeding benchmark values have
occurred and the facility has not engaged in implementing all Tier requirements required by the
NPDES permit. The NPDES permit specifies that the four consecutive periods of benchmark
exceedance requires action in accordance with Tier III requirements. The monitoring required
by the NPDES permit is a self -directed initiative. It is the responsibility of the facility to provide
NCDENR with sampling results and report each episode where benchmark values are
exceeded. The facility is required to evaluate the reasons for non -compliant events and
determine the measures necessary to improve stormwater quality to benchmark values or
' better. The facility is also required to implement BMP measures to restore stormwater quality to
benchmark values.
e During this period, NCDENR has the statutory authority to seek remedy if the facility fails to
take appropriate or expeditious action to implement measures that will restore stormwater
quality to compliant levels. Silar has been provided written notice by NCDENR to take steps to
' evaluate and determine the measures necessary to restore stormwater quality to benchmark
values. It is ECSs opinion that Sitar is presently in a "gray area" with DWQ. Recommendations
for complying with the NPDES permit conditions are provided in Section 6. 0.
3.0 EVALUATION OF SILAR OUTFALLS
An onsite evaluation of drainage regimes and potential factors affecting stormwater quality at
each Sitar outfall was performed by ECS. On March 2, 2012 a field reconnaissance was
performed to locate and inspect each Sitar stormwater outfall. The purpose of the
reconnaissance was to visually evaluate the physical outfall structures, observe upland
contributing drainage areas, and to observe factors that may be impacting stormwater quality at
the subject outfall locations. Several other nearby and adjacent stormwater outfalls
owned/controlled by Momentive and Oak Bark were also inspected to consider potential
impacts that these outfalls may cause on stormwater quality at the Silar outfalls. Elevation
surveying, sampling, and analytical testing of stormwater was not included in the work scope for
E

Evaluation of Stormwater Outtall Conditions September 10, 2012
Sitar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17256 A
evaluating stormwater conditions at outfalls. It should be noted from our review of available site
' topography (provided by Silar) that the accuracy of plant -wide drainage depicted from the
survey is uncertain. Topographic survey data specific to the entire 6.5 acre Silar site is needed
to determine the specific drainage regimes affecting each outfall on the Silar site. Accurate
topographical data from adjacent plant sites is also needed to determine run-on and run-off
potentially impacting Sitar outfatls.
Drainage patterns observed by ECS during the time of the field reconnaissance differs from the
drainage depicted in the topographic map shown in Figure 2. In the field,. offsite sheetflow is
observed draining onto Sitar property from the Momentive Ammonia Storage Area, Special
Projects Area, and Formaldehyde Production Area. Sheetflow from the Momentive site onto the
Silar site is obvious in the vicinity of SW002. As shown in Figure 2, Momentive constructed a
low asphalt curb/berm at the low point of the drainage area in an attempt to deflect errant
sheetflow runoff from their plantsite from entering into Silar's SWO02 outfall. Flow regimes from
the offsite sources are generalized on the Momentive Storm Water Map shown in Figure 2.
Drainage direction and patterns shown by the topography illustrated in the drawing are not
accurate with conditions observed in the field. It is important to understand the stormwater flow
regimes both on the Sitar site and from immediately adjacent sites. Addtional topographic
surveying will be needed to distinguish each facility's flow regime and confirm that sheetflow
from the Momentive and Oak Bark is contributing to degradation of stormwater quality on the
' Sitar site. The topographic survey data relied upon by ECS in this evaluation does not provide
sufficient detail for BMP design. It also does not enable an accurate determination of the extent
of offsite sheetflow from all offsite sources.
Below is summary of the relevant features and conditions of each permitted Sitar outfall.
Sampling and analytical results for each outfall beginning in March of 2011 through ,tune of
2012 are included in Appendix IV.
3.1 Outfall SWO01
Since the time ECS began this stormwater evaluation in February of 2012, Sitar re -located
SWO01 to a "new" location upstream in the same watershed. The outfall is now presently
located just north of Silar Drum Storage Area and concrete pad used for empty drum/container
storage. The outfall is located at the end of an outlet pipe conveying sheetflow from drainage
within the Silar Drum Storage watershed area. The new location of the outfall resulted from
discussions between Sitar and Linda Willis/NCDENR in the March/April time frame of 2012, The
location of SWO01 was moved to this area as it is likely more representative of site stormwater
conditions and less likely to be influenced groundwater from the Oak Bark Monofili experienced
in the former location. NCDENR concurred with Silar's decision to relocate the outfall. The
coordinates of the new outfall location have not been provided to ECS. The new location
appears to be at a topographically higher elevation than the former location of SWO01.
One period of analytical data is available for the new outfall location since the outfall location
was moved. The analytical data for the May 10, 2012 sampling event collected from the new
location of SWO01 detected three compounds above benchmark thresholds. From this data,
copper was detected at 0.128 mg1L, zinc at 0.448 mg/L and formaldehyde at 132 mg1L. The
thresholds for these compounds are 0.007 mg/L, 0.067mg/L, and 0.5 mg/L respectively. Also,
the results from this sampling event detected none of the nitrogen bearing compounds (NH3,
10

Evaluation of Stormwater Outfall Conditions
Silar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
September 10, 2012
TKN, and NO2+NO3) in concentrations above regulatory benchmark values. Additional
forthcoming sampling events and results will be necessary to establish trends associated with
the new outfall location. It is noteworthy that prior to re -location of the outfall, sampling/analysis
of the former SWO01 Outfall location routinely detected ammonia, TKN, nitrate + nitrite,
formaldehyde, copper and zinc.
The original location of the SWO01 Outfall was permitted as the easternmost outfall in the Silar
a stormwater network when the permit was issued in October of 2010. This outfall existed prior to
this date and was originally included as an outfall in Oak Bark's stormwater network. The outfall
was formerly located at 341 19' 69" and 78° 12' 2" and when Silar obtained the NPDES permit in
2010 the outfall was then referenced as the "Sitar Drum Warehouse" outfall. Historic stormwater
monitoring data from the original outfall location since Siiar's acquisition has exhibited routine
exceedances of benchmark values since at least the 1 st Quarter 2011. Prior to this date the
outfall discharged non -compliant stormwater under Wright Chemicals, Borden, and
Hexion/Momentive, and Oak Bark's ownership dating back to 2000. The table below gives the
parameters and time periods that benchmark values were exceeded since Silar assumed
permit responsibility 1 st Quarter of 2011 :
pTable 2
(Former) SW001 Outfall
Parameters
Sample Date
2012
Sample Date
2011
Benchmark Value
Exceeded
Ammonia
1st and 2nd Qtr
1st and 2naQtr
Yes
TSS
3rd Qtr
Yes
TKN
1st and 2nd Qtr
1st and 2nd Qtr
Yes
Nitrate+Nitrite
1st and 2nd Qtr
1st and 2nd Qtr
Yes
Copper
1stOtr
1 , 2nd, 3rd, and 4th Qtr
Yes
Zinc
2nd Qtr
Yes
BOD
1 st Qtr
Yes
TRC
1 st Qtr
Yes
The drainage basin feeding this former outfall encompassed a total area of 211,220 square feet
(SC=). Of that total area, 17,670 SF is reported to be impervious (NCDENR Staff Review and
Evaluation Report, NPDES Stormwater Permit dated June 7, 2010). The former SWO01 Outfall
sampling point was a stream channel that discharges through the central interior of the 6.5 acre
lease -hold parcel occupied by Silar. The former outfall had no weir, conduit, pipe, other type of
hardened structure. The sampling location of the former outfall was an arbitrary point in the
stream channel. The stream channel meanders in a sinusoidal manner through a floodplain
draining into the interior portion of the Silar site. This floodplain also receives upland surface
runoff from the Momentive and Oak Bark plant sites. From the former Outfall SWO01, the
channel flows approximately 200 ft. northward to the Silar property boundary. From there, it
flows offsite into a floodplain of Mill Creek. The stream bed is a rectangular shaped earthen
channel approximately 4 feet wide by 1 foot deep. The elevation of the former outfall is
unknown. An estimated elevation of the outfall is +10 ft. above mean sea level based on a plant
site topographic map prepared by Momentive. Adjacent topography is illustrated by the same
survey to be 21.2 ft. above mean sea level or greater according to a topographic survey
provided by Momentive (dated 10/22/08 with Revision 5, dated 1 /3/11). Review of the
11

Evaluation of Stormwaler Outfall Conditions
Silar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
1
Momentive topographic survey shows
range from 21.2 ft. to 44.5 ft. above
lower than surrounding topography
groundwater from both onsite and
Momentive and Oak Bark sites.
September 10, 2012
surrounding spot elevations on the plantsite campus to
sea level. The former Outfall SWO01 was considerably
within the watershed and received stormwater and
offsite watersheds including those on the adjacent
Upland run-off and drainage (from Momentive and Oak Bark) adjacent to the Sitar Drum
Storage Area feeds the base flow of former Outfall SW001. These upland sources of run-off
include impounded water and stormwater flowing off of the Oak Bark Monofill waste cell into the
former SWO01 watershed. Base flow of the stream where the former SWO01 Outfall is located
may be spring -fed by the shallow groundwater upwelling from the shallow water table aquifer.
Groundwater discharging upland of the outfall may account for steady stream flow conditions
observed at the former SWO01 Outfall despite seasonal drought conditions. Seasonal rainfall is
the primary source of recharge for regional stream base flows and surficial aquifers in the
region. Also, the Silar Drum Storage Area adjacent to the former SWO01. Outfall was formerly a
process pond operated by Wright Corporation until around 1993. Aerial photography reviewed
by ECS indicates the process pond was approximately one acre in size. From review of sources
of aerial photography, the pond was removed and/or closed sometime prior to 1997.
Groundwater in the vicinity of the Drum Storage Area (former pond area) likely migrates in a
northerly direction toward Mill Creels. Groundwater impacts caused by years of Wright Chemical
Corp. operating the process pond in this location may have been affecting stormwater quality
observed at the former SW001 Outfall. The subsurface impacts that may have occurred in this
location due to Wright Chemical's operations depend on the history the former industrial pond,
the substances or contaminants contained, and the contaminants released from the pond
during operation.
Another offsite contaminant source that likely affected stormwater quality in the vicinity of the
former Outfall SWO01 is the Oak Bark Monofill. This waste cell is an earthen dike impoundment
used to contain process waste generated by Wright Chemical Co. during their operation of
chemical production processes. The waste cell is located less than 150 ft. hydraulically up -
gradient of the former Silar SWO01 Outfall. Impounded waste water stored on top of the
monofill waste cell is at an elevation of approximately 42.5 ft. above sea level while surrounding
topography is on the order of 23.7 ft. above sea level. The crest of the monofill is at an
elevation of approximately 44.4 ft. above sea level. The waste cell is reported to contain a
volume of approximately 37,000 cubic yards (CY) and was constructed in the 1991 to 1992
timeframe. The waste cell is known to contain industrial wastes including sludge laden with
hexamine, formaldehyde, nitrogen derivatives, and potentially metal -based waste dredged from
Wright Corporation's process and evaporation ponds (September 24, 2001 NCDENR
Memorandum from Brian Wootton to Kim Colson and September 10, 2001 NCDENR Record of
Waste Disposal Permit Application Review by Bruce Parris). The monofill cell is approximately
500 linear feet (LF) long by 100 LF wide. From crest to toe the structure is approximately 20
feet in structural height. The monofill immediately abuts Sitar's property line. A section of the
structure's northern dike appears to encroach over the property boundary onto the Sitar parcel.
This determination is based on field -survey staking of the property line observed at the time of
ECS's field reconnaissance. The accuracy of the field staking is uncertain.
The monofill waste cell is reported by NCDENR to have been capped with a 36 mil Hypalon
liner. The liner was reportedly used only on side -slopes of the dike and covering over the top of
the structure. A leachate collection system and under -drain was included in the cell design to
dewater sludge materials placed in the impoundment from the process ponds. At the time of
12

Evaluation of Stormwater Outfall Conditions September 10, 2012
' Silar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
1
ECS's site reconnaissance, the Hypalon liner along the crest of the monofill was observed to be
' in very poor condition. The failing liner exhibited brittleness, breaches, tears, punctures, and
penetrations along the extent of northern crest. It is not certain if the ieachate collection system
originally installed beneath the monofill is operational today and whether leachate is currently
' being treated and/or disposed. The monofill impounds stormwater on the top of the structure
though it was not designed to function as an impoundment structure. At the time of inspection,
the pond pool was estimated to average 2.5 feet deep. Based on this, approximately 935,000
gallons of wastewater is being stored on top of the monofill. Review of plans show the pond
was originally designed to maintain positive drainage on the top of the waste cell to prevent
stormwater from impounding on top of the cell. Emergency spillways have been installed by
use of two 12" diameter flexible corrugated plastic slope drains. The slope drains are installed
on the top of the monofill to serve as an over -flow structure to drain the pond during periods of
high -rainfall events. The emergency slope drains are located on the northwest corner of the
monofill top -dike and drape down the face of the slope. Waste water discharging from the cell
via the slope drains is directed to the toe of the dike where it then sheetflows onto the Silar
lease hold parcel. During high rainfall events, the pond water relieved by the slope drains will
flow into the upland drainage area of the former Silar SWO01 Outfall. In addition, the
impounded stormwater accumulating on top of the monofill is suspected to be seeping through
' the earthen dike. This was noted during ECSs visual inspection of the dike structure. A number
of hydraulic seeps were observed weeping into drainage areas feeding the former Silar Outfall
SWO01. The hydraulic seeps were observed "breaking -out" on the Silar lease hold parcel
proximate to the northern toe of the monofill and immediately downgradient of the northwest
corner.
The present-day condition and integrity of the monofill liner is highly questionable. The liner
condition was questioned by Steve West/NCDENR dating back to June 14, 1999 documented
by a compliance inspection. The inspection was documented in an NPDES Compliance
Inspection Report dated July 20, 1999. In that report, Mr. West noted that "the lined landfill
pond permitted under WQ0005699 was observed to have a break in the liner in the
northernmost corner. Wright Corporation should investigate the break immediately and report
the findings to this office. The investigation should be followed up with an assessment of
groundwater impacts." Mr. West also reported that "Wright personnel should keep thorough
records of containment area stormwater disposal".
Mr. West further noted that "it is apparent from NPDES stormwater sample results that much
stormwater being discharged through sampled outfalls contain significant amounts of
pollutants." (NCDENR Letter dated July 21, 1999 from Steve West to Mike Hanes/Wright
Corporation). ECS also reviewed a 2001 NCDENR Record of Waste Disposal Permit
Application Review ranking the monofill's probability of contaminating groundwater. The
worksheet notes the Situation Rating value to be 11 which corresponds to a Probability of
Contamination as "very probable" that the monofill will contaminate groundwater. The Situation
Grade on the worksheet assigned a rank "F" with a corresponding Degree of Acceptability
being "almost certain to be unacceptable".
Considering the above statements prepared by NCDENR, it is highly probable that the quality of
the stormwater in the former Silar SWO01 Outfall location was directly affected by the existence
of the monofill due to run-off, overtopping, and seepage from the waste cell. Of greater concern
is the volume of impounded waste water that sits on top of the monofill. The impounded waste
water (and stormwater) provides a continuous source for seepage through the monofill's
earthen dike on to Silar property. This condition is also likely impacting groundwater quality in
13

1
Evaluation o f Stormwater Outfall Conditions September 10, 2012
Silar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
1
addition to stormwater quality on Silar property. During ECSs March 2012 site inspection,
visible hydraulic seeps were seen located on the Silar site immediately downgradient of the
northwest toe of the monofill dike. The hydraulic seeps found on Silar's property are
approximately 75 LF east of Momentive SWO06 Outfall. Further study may be necessary to
assess groundwater impacts that may have been caused on the Silar site by the monofill.
Installation of monitoring wells, piezometers, and/or sampling may be necessary near the
property boundary to confirm that the seepage observed originates from the monofill. This
would enable evaluation of local groundwater conditions and impacts caused by the existence
of the waste monofill located on Silar's property boundary. At the time that NCDENR permitted
Wright Corporation to operate the monofill, the DWQ Non Discharge Permit required Wright
Corporation to maintain a "compliance boundary" whereby Wright was to monitor groundwater
conditions at a point located 250 LF from the source (i.e. the monofill). The NCDENR permit
also required Wright to take remedial action if impacts were discovered at that point. A "review
boundary" was to be established at one-half the distance to the compliance boundary and if
impacts were determined at that location, the facility was required to provide a plan for
mitigating and eliminating the impacts prior to reaching the compliance boundary. From the
regulatory file reviews and public record search conducted by ECS, no evidence was disclosed
to indicate that monitoring occurred. It appears that Wright Corporation and it's successors did
Q not perform groundwater assessment to determine impacts caused by years of operating the
waste -sludge monofill. It also appears that no remedial actions and/or remedial measures were
undertaken by the owner of the facility per review of the data in the public record review. Oak
' Bark may now have a responsibility to implement remedial actions or measures to mitigate or
prevent further impacts to stormwater and groundwater if it is confirmed that such impacts are
occurring on the Silar site.
ECS also identified two other sources of potential contamination potentially affecting the Silar
site. Momentive's Outfall SWO06 and the adjacent Momentive "Duck Pond" discharge degraded
nitrogen -rich stormwater onto the Silar lease -hold parcel. From ECS's field reconnaissance
and subsequent review of a boundary survey performed by Soles & Walker, P.A., it was
determined that the actual location of the Momentive Outfall SWO06 is not on Momentive's
property. The outfali clearly encroaches on Silar's property and is positioned well inside of the
property boundary of the Silar lease -hold property boundary (see Figure 2). ECSs review did
not disclose an easement allowing this or other form of operating agreement to indicate that
Momentive has been granted rights to operate the outfall on the Silar lease -hold parcel. The
Momentive Outfall SWO06 is a 24" diameter corrugated metal pipe (CMP) that hydraulically
connects to the adjacent Momentive retention pond known as the the "Duck Pond." The Duck
Pond collects a significant volume of upland stormwater drainage from the Momentive plant
site, warehouses, and process areas. The pond then releases the water into the SWO06 Outfall
when a certain elevation is attained. The pond is approximately 550 LF long and ranges from
50 feet wide to 125 feet wide. Impounded water contained in the Duck Pond discharges nearly
continuously through the CMP including times of non -rainfall conditions. A flashboard riser
structure controls flow in the outlet -end of the Duck Pond. The flashboard riser is set at an
elevation that allows the pond -pool to drain continuously to Oufail SW006. The discharge from
the Duck Pond dumps into a narrow stream channel located on the Silar site. The narrow
receiving channel traverses through Zone AE floodplains located in the interior of the Silar
lease -hold parcel (just west of the former Silar Outfall SWO01 and east of SW002) and
discharges at the northernmost fence -line of the Silar parcel. The point of discharge to the
adjacent floodplains is approximately 200 LF east of Outfall SW005. Stormwater draining from
the Duck Pond onto the Silar site was suspected to commingle with stormwater at the former
Outfall SWO01 location which was located in the floodplains of this channel. This convergence
14

1
Evaluation of Stormwater Outfall Conditions September 10, 2012
' Silar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
of the two stormwater flows were suspected to be contributing to degradation of stormwater
' quality noted at the former Silar SWO01 Outfall. Review of the most recent stormwater quality
monitoring results for the Momentive Outfall SWO06 (February 8, 2012) shows that stormwater
quality discharging from this outfall and onto the Silar lease -hold parcel is non -compliant with
NCDENR benchmark values for a number of parameters. The February 8, 2012 sampling
results for Momentive's Outfall SWO06 shows the following parameters exceeding NPDES
benchmark values:
a • Biological Oxygen Demand (BOD)
• Chemical Oxygen Demand (COD)
• Ammonia (NH3)
• Nitrate + Nitrite Nitrogen (NO3+NO2)
• Total Kjeldahl Nitrogen (TKN)
• Formaldehyde (CH2O)
• Total Copper (Cu)
Review of Momentive's stormwater sampling results for a March 17, 2011 sampling event for
the SWO06 Outfall also detected zinc concentrations to be non -compliant with NPDES
a benchmark limits in addition to the seven parameters listed above. A "NCDENR Staff Review
and Evaluation Report-NPDES Stormwater Permit" dated June 9, 2010, states that NCDENR
acknowledges that the above cited benchmark parameters to have shown a "history of
exeedances dating back to June of 2007". Based on the long history of Momentive discharging
non -compliant stormwater onto the Silar site, it is probable that stormwater at the former Silar
SWO01 Outfall has been affected by the non -compliant stormwater flow from the Momentive
site. The quality of the non -compliant stormwater from SWO06 is generally characterized as a
nitrogen -rich effluent. Ammonia, TKN, nitrate and nitrite have been routinely detected in
elevated concentrations in the flow from this outfall which drains the adjacent Duck Pond
located on the Momentive's site. The nitrogen -rich flow from Momentive drains onto Silar's
property and exits through the interior plantsite drainage way of the Silar site. Stormwater
discharging offsite at the northern property fence -line of the Silar site enters into the floodplains
of Mill Creek. Because of this, the potential regulatory liability for Silar is great since NCDENR
e ultimately holds Silar responsible for the quality of water leaving the Silar site at the fenceline.
The boundary map shown in Figure 2 illustrates the location of Momentive's SWO06 Outfall to
be clearly on the Silar lease -hold property. Due to this, Silar does not have control nor ability to
regulate the flow of the non -compliant stormwater piped onto its property and should address
this issue immediately. Resolution will require cooperation and action by Momentive to re -locate
the pipe and/or re-route the stormwater flow from SWO06 off of Silar's property,
3.2 Outfall SWO02
Outfall SWO02 is on the southwest flank of the Silar permitted stormwater network and is
located at Northing 340 19' 71" and Easting 780 12' 8". The outfall is referred to as the "Silar Lab
and Fine Chemicals Weir" outfall. Stormwater monitoring data collected by Silar from this
Outfall historically shows BOD, COD, ammonia, TKN, formaldehyde, copper, and zinc
concentrations exceeding NPDES benchmark values. The table below gives the parameters
' and time periods that benchmark values have been exceeded at SWO02:
;1 15

I
Evaluation of Stormwater Outfall Conditions
' Silar, L L C
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
t
Table 3
SWO02 Outfall
September 10, 2012
Parameter
Sample Date
2012
Sample Date
2011
Benchmark Value
Exceeded
BOa
March
1st, 2nd, and 3rd Qtr
Yes
COD
March, May
1st, 2nd, and 3rd Qtr
Yes
Ammonia
March
1 st Qtr
Yes
TKN
March
1 st, 2nd, and 3rd Qtr
Yes
Formaldehyde
January, March, April, May,
Jul
1st, 2nd, and 3rd Qtr
Yes
Copper
January, March, April, May,
June, Juf
1 st, 2nd, 3rd, and 4th Qtr
Yes
Zinc
January, March, April, June,
Jul
1 st, 2nd, 3rd, and 4th Qtr
Yes
TSS
January, May, June
Yes
TRC
June
Yes
NCDENR reports the drainage basin feeding this outfall is estimated as 24,158 square feet (SF)
with 24,158 SF being impervious (NCDENR Staff Review and Evaluation Report, NPDES
Stormwater Permit dated June 7, 2010). Based on our field reconnaissance and review of the
Momentive Storm Water Map, it is our opinion that the volume of stormwater drainage entering
into Outfall SWO02 appears to be significantly greater than the watershed area estimated by
NCDENR or depicted by topography shown in the Momentive Storm Water Map (Figure 2).
Sheetflow onto the Sitar site from offsite adjacent sites does not appear to be included in the
NCDENR watershed area estimates. The run-on and run-off caused by the adjacent plantsite
drainage regimes is likely the single -most greatest factor contributing to the degradation of
stormwater quality noted at Silar outfalls. Review of the Momentive Storm Water Map shows
drainage leaving the Momentive site onto Silar's property. The topographic map does not
accurately represent all offsite flow noted by field observation. Areas including the Momentive
Packaging Warehouse, Ammonia Storage Area, Formaldehyde Production Area, and Special
Projects areas are known to release sheetflow which drains offsite from Momentive onto Sitar's
property and collects at the entrance to Sitar's SWO02 Outfall. Because Momentive recognizes
that sheetflow from these areas runs onto Silar's property causing flooding at the SWO02
Outfall, they have made a number of unsuccessful attempts to construct an asphalt diversion
berm in the travelway adjacent to the Formadehye Production plant. The asphalt diversion berm
was constructed by Momentive to divert sheetflow from their Formaldehyde Plant and prevent
flow from entering Sitar's SWO02 Outfall. The small berm, located approximately 75 LF
upgradient of Silar SWO02, has proven to be ineffective in eliminating offsite sheetflow from
Momentive's plant onto the Silar site. Additional hydraulic flow capture/reduction measures or
BMPs are needed in this location in order for Momentive to prevent degraded stormwater
generated on their site from entering upon Silar's site.
The outfall sampling point located at SWO02 is defined by a concrete weir structure. The weir
receives some upland drainage from the Silar Plant however receives_ a significant volume of
sheetflow from the adjacent Momentive plantsite and operations. This outfall discharges to the
16

Evaluation of Stormwater Outfall Conditions September 10, 2012
' Silar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
Sitar floodplain which terminally conveys surface runoff to the northeastern fence line and
' eventually to Livingston Creek. The elevation of the outfall was not surveyed for
horizontal/vertical control at the time of this report, however review of a facility topographic
drawing (Momentive Storm Water Map dated 10122-08) shows a spot elevation proximate to the
outfall at elevation of 23.2 ft. above sea level (asl). The elevation of the weir is likely lower than
the nearby spot elevation. Surrounding topography and upland drainage is not depicted on the
drawing either, thus precluding an accurate estimation of the drainage area contributing to flow
through the SWO02 Outfall. The source of drainage feeding this outfall stems from two areas:
(1) the Sitar Plant site and (2) runoff from several portions of the adjacent Momentive plant site.
It is our opinion that a significant portion of offsite drainage entering the SWO02 Outfall is from
the following adjacent areas: Momentive Ammonia Storage Area, Momentive Packaging
Warehouse, Momentive Hexamine Warehouse, Momentive Hexamine Production, Momentive
Formaldehyde Production, and Momentive Special Projects Warehouse areas.
Review of the Momentive topographic/drainage map (and based on ECS's field observations), it
is apparent that stormwater is flowing from the Momentive plant site onto the Silar lease -hold
parcel. During ECS's visit to the Sitar plantsite during a rainfall event, it was observed that
stormwater runoff leaving the Momentive site converges with stormwater on the Sitar site at the
confluence of Outfall SW002. Intruding stormwater runoff from the adjacent Momentive plant
site has been a significant concern to Sitar since engaging in stormwater monitoring due to the
NPDES Permit issued to Sitar in 2010. Sitar has assessed this by collecting stormwater
samples from several rainfall events from the up gradient stormwater flowing off the Momentive
site into the collection point of SW002. The analyses of up -gradient samples of both Momentive
and Oak Bark's stormwater has historically detected many benchmark parameters exceeding
threshold values. The analyses demonstrat the following benchmark parameters to be non-
compliant from stormwater on these facilities: TSS, BOD, COD, ammonia, TKN, nitrite + nitrate,
formaldehyde, copper, manganese and zinc.
In comparing the above results with Sitar's stormwater sample results from Outfall SWO02, it is
noted that TSS, BOD, COD, ammonia, TKN, formaldehyde, copper, and zinc exceed
benchmark values. The NCDENR Compliance Inspection Report states Tier III sampling
requirements have been triggered due to four consecutive periods of non-compliance. DWQ
specified in the report that Acute Toxicity testing be performed on stormwater from Outfalls
SWO02 and SW005. The Compliance Inspection Report states that "Sitar is not compliant with
the requirements to monthly monitor." From the comparative sampling performed by Sitar, we
conclude that it is highly probable that the stormwater quality occurring at Sitar Outfall SWO02 is
being greatly degraded by the stormwater being received from upgradient sources on the
Momentive site.
3.3 Outfall SWO05
' Outfall SWO05 is on the northernmost flank of the Sitar permitted stormwater network and is
located at Northing 340 19' 76" and Easting 781 12' 6". The outfall is located on the property line
and is referred to as the "North Side of Sitar Plant" outfall. Stormwater monitoring data collected
' by Sitar from this Outfall historically shows TSS, BOD, COD, ammonia, TKN, copper, zinc, and
pH concentrations exceeding NPDES benchmark values. The table below gives the parameters
and time periods that benchmark values have been exceeded at SWO05:
17

Evaluation of Stormwater Outfall Conditions
Silar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
Table 4
SWO05 Outfall
September 10, 2012
Parameter
Sample Date
2012
Sample Date
2011
Benchmark Value
Exceeded
TSS
1st Qtr
Yes
BOD
Aril
1st and 2nd Qtr
Yes
COD
Aril
1st and 2nd Qtr
Yes
Ammonia
1st Qtr
Yes
TKN
2nd Qtr
Yes
Copper
January, March, April,
May, June, Jul
1 st, 2nd, 3rd, and 4th Qtr
Yes
Zinc
January, March, April,
Ma , June
1st, 2nd, 3rd, and 4th
Qtr
Yes
Formaldehyde
March, April, May, July
ist and 2nd Qtr
Yes
pH
2nd Qtr
Yes
NCDENR estimates the drainage basin feeding this outfall to be 43,560 square feet (SF) with
15,119 SF being impervious (NCDENR Staff Review and Evaluation Report, NPDES
Stormwater Permit dated June 7, 2010). Based on ECSs field reconnaissance and review of the
Momentive Storm Water Map, it appears that drainage from the adjacent Momentive site is also
contributing to stormwater flow entering Silar's Outfall SW005. Review of the Momentive Storm
Water Map (Figure 2) shows no drainage flowing from the Momentive Tank Containment area
onto the Silar parcel. Based on our field reconnaissance, it is apparent that some volume of
stormwater is running -off from the Momentive aboveground storage tank (AST) area into the
Silar SWO05 watershed. The Momentive ASTs are used for product chemical storage and
these tanks are located inside a secondary containment wall. Drainage from the tanks and
containment structure could potentially impact stormwater quality at the Silar SWO05 Outfall.
The accuracy of adjacent topography and direction of run-off illustrated by the Momentive
Storm Water Map is questioned. Additional topographic survey to accurately determine offsite
flow from Momentive and the watershed of the Silar Outfall SWO05 may be warranted. This
would be beneficial to gain a greater understanding of whether offsite sources or flows are
affecting stormwater quality at this Silar outfall location.
Silar's Outfall SWO05 is defined by a concrete weir structure. The weir appears to receive
upland drainage primarily from the Silar Plant including the Liquid Nitrogen Storage Area, and
Hazardous Solvent Storage Tank Area. Stormwater collecting at this conveyance "cascades"
over and down an earthen embankment into" the adjacent floodplains of Mill Creek. The
elevation of the outfall could not be determined at the time of this report. Surrounding
topography and upland drainage is not clearly depicted on the drawing referenced above as no
spot elevations are shown in the drainage area feeding this outfall. Some degree of drainage
from the adjacent Momentive site appears to be entering into the SWO05 watershed.
According to the NCDENR Compliance Inspection Report, Tier 3 sampling requirements have
been triggered due to four consecutive periods of non-compliance. DWQ specified in the report
that Acute Toxicity testing be performed on stormwater from Outfall SWO05 (as well as
SW002). The Compliance Inspection report states that "Sitar is not compliant with the
requirements to monthly monitor". The report continues by stating that "failure to follow the
18

Evaluation of Stormwater Outfall Conditions
' Silar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
1
September 10, 2012
tiered requirements in the future will be addressed (by DWQ) accordingly". The DWQ further
informs that a follow-up inspection will be performed during the third quarter of this year (2012).
3.4 Outfall SW010
At the time the NPDES Stormwater Permit No. NCS000533 was issued to Silar (October 22,
2010), Outfall SWO10 did not exist and therefore was not identified by the permit. This outfall
location has since been added to the Silar stormwater monitoring network as a result of the
NCDENR Compliance Inspection conducted by DWQ on January 24, 2012. At that time, Ms.
Linda Willis/DWQ Engineer noted the unpermitted stormwater conveyance on the east side of
the Silar 126 and Fine Chemicals area of the plantsite. This outfall was named at that time as
"SW010". In this location, DWQ noted that stormwater run off pooled from the adjacent
surrounding concrete surfacing of the production facility. The stormwater eventually overtopped
the lip of the concrete pad and flowed downslope into the rip -rap lined embankment into the
primary interior drainway of the Silar site. From there, stormwater discharges northward into the
adjacent floodplains of Mill Creek.
At the time of this report, analytical results for 2012 was the only available data for review since
Outfall SW010 did not exist in 2011. The analytical results for this outfall have detected
formaldehyde, copper, zinc and manganese exceeding the NCDENR benchmark values. The
table below gives the parameters and time periods that benchmark values have been
exceeded:
Table 5
SW010 Outfall
Parameter
Sample Date
Sample Date
Benchmark Value
2012
2011
Exceeded
Formaldehyde
March, May, July
NS
Yes
March, April, May, June,
NS
Yes
Copper
July
March, April, May, June,
NS
Yes
Zinc
Jul
NS=Not Sampled ( Outfall did not exist at that time)
From the above table it is apparent that stormwater quality at this regulated outfall in the Silar
126/Fine Chemicals area of the Silar plant exhibits elevated benchmark standards. Due to the
limited history of analytical data from this outfall, it is difficult to conclude what trends are
associated with outfall flow in this location and what reasons may be attributed to the degraded
quality of stormwater exiting the outfall. In comparison to historical analytical results from other
Silar permitted outfalls, the above analytical results for SWO10 exhibit similar concentrations
and compounds. Copper, zinc, and formaldehyde are compounds that have typically been
associated with Oak Bark's Mintrex feed additive production process. Formaldehyde and
Hexamine is typically produced by Momentive and associated with production of ketone -
formaldehyde resin products.
19

1 .
Evaluation of Stormwaier Outfali Conditions September 10, 2012
Silar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
Outfalls SWO01, SWO02 and SWO05 also show non -compliant sampling events from the 2011
time period due to each of these same benchmark parameters listed in the table. It should be
noted that each of the above non -compliant benchmark parameters detected at Silar outfall
locations are also target parameters specified for sampling in Oak Bark's NPDES Stormwater
' Permit. Oak Bark is required to sample copper and zinc due to their formulation process of feed
additives which includes these metals. Silar does not use copper or zinc products in it's
processes nor does it generate waste that inherently contain these metals. The only known
source for copper and zinc on the Silar site is pipe work used for conveying liquids in their
processes. Copper and zinc have been historically been detected at each of the other
Momentive and Oak Bark outfall sample locations suggesting that a site -wide source for these
compounds may exist.
A variety of drummed raw and waste materials are stored on occasion outside in the Silar
1261Fine Chemicals area. Measures have been taken to provide permanent roof covering and
containment for the majority of materials handled in this area. Some palletized drums of raw
materials are observed in this area and are exposed to the elements and stormwater however
do not contain products with the metal -bearing compounds described above. The facility has
taken measures to minimize exposure of these materials to rainfall by providing containment
curbing and constructing shed covers to minimize exposure. The specialty organic products
produced by Silar, raw materials handled, and wastes disposed are not suspected to be
contributing to stormwater quality previously determined by sampling in the SWO10 location.
Forthcoming sampling and analytical results should be reviewed to determine the chemical
signature of contaminants detected and trends.
3.5 Adjacent Outfalls and Sources
Momentive Outfall SWO08 and a septic drain field are two potential sources located adjacent to
the southwest leg of the Silar property. These two additional potential sources may be affecting
Silar stormwater or groundwater quality. Momentive Outfall SWO08 is approximately 100 LF
east of the east -end of the Oak Bark Monofill. The septic drain field is immediately adjacent to
the outfall. These two structures are illustrated in Figure 2. Both structures are close to the
property boundary and may possibly encroach upon the Silar lease -hold property. Due to the
accuracy of the drawing and transfer of the boundary overlay, a determination of whether these
' structures are on Silar's property could not be made by ECS. Regardless, both the Momentive
Outfall and septic drain field are immediately adjacent and apparently upgradient of Silar's
property. Neither feature was located in the field by ECS at the time of the site reconnaissance.
1 These features remain potential contaminant sources of both stormwater and groundwater and
could be affecting water quality on the Silar lease -hold parcel. Though not likely a major
contributing source to stormwater degradation on the Silar site, these sources are a greater
1 concern for potential groundwater impacts.
3.6 Recent Stormwater Sampling Performed by Silar
' Silar recently performed stormwater sampling on their facility that focused on two independent
issues. This included sampling of stormwater from: 1). the new SWO01 Outfall location and 2).
sampling of ambient rainwater on the plant site near SW 002 prior to stormwater contact with
' ground surfaces. The May 10, 2012 sampling results of the new SWO01 Outfall location was

1
Evaluation of Stormwater Outfall Conditions September 10, 2012
' Silar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
discussed above in Section 3.1 and shows that copper, zinc, and formaldehyde are still present
' in stormwater above NPDES benchmark values from the sample collected at this new location.
Nitrogen containing compounds including ammonia, TKN, and nitrate+ nitrite were not detected
in concentrations exceeding NPDES benchmark values. This may suggest that groundwater
' contaminated with nitrogen compounds was the cause for the elevated nitrogen derivatives
detected in stormwater samples collected previously from SW001.
An ambient stormwater sample collected by Silar on May 10, 2012 adjacent to SWO02 was
collected in an open -top container prior to the rainwater contacting ground surfaces. The
objective of collecting the sample in this manner was to collect an ambient rainwater sample
prior to contact with ground surfacing. This would enable evaluation of ambient rainwater falling
upon the site before entering a permitted stormwater conveyance. The laboratory analysis of
the ambient rainwater sample collected adjacent to SWO02 detected copper at 0.013 mg/L, zinc
at 0.074 mg/L and ammonia at 10.0 mg/L. These results exceed the regulatory benchmark
values which are 0.007 mg/L, 0.067 mg/L and 7.2 mg/L respectively. This demonstration
suggest that ambient rainwater falling upon the Silar site near SWO02 during this stormwater
event contained background copper, zinc, and ammonia concentrations exceeding NPDES
' benchmark permit values. Additional sampling would be prudent to determine if this finding
represents plant site conditions inherent to the Silar site and in other permitted outfall locations.
Additional sampling recommendations are discussed in Section 6.8 of this report.
4.0 STORMWATER BMPs AND IMPROVEMENT ALTERNATIVES
There are a variety of structural and non-structural stormwater management alternatives,
BMPs, and strategies to consider for improving stormwater quality at the facility's non -compliant
outfall locations. Each outfall on the Silar site is unique and exhibits a spectrum of different
contaminants, concentrations, and flow regimes, therefore various alternatives may be
necessary at each outfall to provide effective treatment of stormwater. Examples of some BMP
alternatives and strategies to consider for improvement of overall stormwater quality include:
Table 6
BMP Alternatives and Strategies
BMP Method Number
Measure
Type of BMP
BMP 1
Elimination and/or Consolidation of
Outfalls
Strategy and Structural
BMP 2
Bio-Retention Cell(s)
Structural
BMP 3
Bic-Swale(s)
Structural
BMP 4
Point Source Treatment -Catch Basin
Inserts
Structural
BMP 5
Compost/Bio-Char Barriers and Filter
Strips
Structural
BMP 6
Infiltration Trenches
Structural
BMP 7
Constructed Wetlands
Structural
BMP S
Hybrid Treatment Methods
Structural
BMP 9
Wet Retention Pond
Structural
BMP 10
Dry Detention Pond
Structural
21

1
Evaluation of Stormwater Outfall Conditions September 10, 2012
Silar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
A detailed review of the applicability of each BMP shown above has not been undertaken in this
' report. There are several BMPs and strategies to consider that may prove to be "best fit"
applications in the case of the Silar site. The following strategies and alternatives are
conceptual and may necessitate more detailed engineering evaluations to arrive at a final
opinion of feasibility and effectiveness prior to selection of a particular BMP. First, Silar will
need to determine it's primary objective and the goal desired with management of stormwater at
each outfall location in order to design a comprehensive management strategy. With our
understanding of site stormwater flow conditions, it is our opinion that "BMP 1-Elimination
1 and/or Consolidation of Outfailsn should be considered regardless of the final direction that Silar
takes to achieve compliant stormwater discharges. This particular strategy will require civil
engineering design to configure a pipe system that can accommodate the anticipated flows.
Design of a consolidated piping system may be completed in a short time frame in comparison
to other more complex BMPs listed above. Implementation of the "Elimination/Consolidation"
strategy will be one of the least intensive capital cost alternatives and should yield great
benefits in return. The NPDES permit allows for elimination and/or consolidation of outfalls that
display substantially identical stormwater quality (see Section D: Monitoring and Records,
Condition 5., Representative Outfall NPDES Permit).
There are a number of benefits associated with implementing BMP Alternative No. 1 shown in
Table 2. The greatest benefit of implementing this strategy is a overall reduction in the number
of regulated sampling points within the monitoring network. This strategy alone will not
necessarily improve stormwater quality or restore non -compliant benchmark values to compliant
levels, however this strategy will reduce long term monitoring efforts required under the NPDES
permit due to a fewer number of outfalls requiring sampling. Additional evaluation of this
strategy may be necessary to fully demonstrate it's merit. In concept, this strategy may reduce
the present number of regulated outfalls from four to as few as two depending upon design and
anticipated performance obstacles. There are three variations of this strategy that may be
considered. Each variation has applicability to the outfalls displaying non -compliant discharges.
A hybrid design implementing one or more of the above variations may also be considered and
will require input from Silar before a final recommendation can be offered. The variations
related to elimination and/or consolidation of outfalls are described below:
(1) Consolidate flow- this BMP is accomplished by use of piping and connection of multiple
outfalls to reduce overall number of outfalls utiltized. Though it does not ultimately improve
stormwater quality it can reduce or eliminate the number of sampling points.
(2) Eliminate 12oint source flow by structural measures- this BMP is accomplished by
installing structural measures in present outfall locations to replace stormwater to surface water
flows with subsurface disposal/treatment measures. This strategy may eliminate or reduce the
number of regulated point source discharges by use of infiltration in the form of trenches, bio-
cells, dry wells, or other types of subsurface adsorption systems to replace presently used
existing point source outfall locations. By routing stormwater into subsurface treatment/disposal
devices, stormwater point source flow is eliminated and existing regulated outfalls would be
removed from regulation under the NPDES permit.
(3) Re-route point source flow to a central non -,point source disposal location- this BMP is
more of a comprehensive strategy for eliminating several or all point source discharge points
from the site. This strategy is accomplished by piping stormwater to interior areas of the
plantsite for disposal using subsurface treatment measures. This measure may remove a
number of regulated point source flows by routing to non -point source subsurface disposal
locations within the plant site. Outfalls incorporated into this strategy would be removed from
regulation under the NPDES permit by may require a Non -Discharge Permit by DWQ.
22

Evaluation of Stormwater Outfall Conditions September 10, 2012
Sitar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
By implementing BMP 1 above, consolidating stormwater flow from the three Silar NPDES
outfalls (SW005, SW010, and SW002) could be potentially accomplished by hard -piping the
outfalls together and connecting to a central conveyance system with one terminal outfall. If so,
then two regulated outfalls would be eliminated from the present monitoring network and a
resulting single outfall would sustain the flow volumes generated by consolidation of the three
outfalls. Implementation of this alternative would result in a substantial reduction in long term
sampling efforts and analytical costs. At the single outfall created by this strategy, a point
source treatment measure must likely be incorporated to meet NPDES discharge benchmark
limits. The cost to construct a consolidated stormwater flow system will depend largely on the
how the pipeline is engineered and the measures required to support the foundation system for
the pipe network. Also, the type of pipe, size, and length of the pipe required would also have
' to be considered in the design evaluation phase as well as existing construction obstacles and
hazards on the site_ The cost of constructing a system like this will depend on the final design,
however to give an order of magnitude estimate of cost, we assume the following:
• Three existing outfalls will be connected using 6" diameter PVC Sch 40 pipe;
• 300 feet of PVC pipe will be needed;
• Small concrete piers on 10 foot spacings will support the pipe with metal strapping
fasteners: no pilings or deep foundation support systems will be required;
' • No catch basins or drop inlets will be added;
• No trenching, excavation, cut -fill, or site grading will be required; and
• Existing weirs can be easily modified to accept flow from the pipe network.
Based on the above scenario, using a pipe network to consolidate the flow of the three outfalls
mentioned, a budgetary cost of $25,000 to $28,000 is estimated. Modification to the present
I NPDES permitted system will require approval by NCDENR and modification of the NPDES
permit prior to implementation. Consolidation of flow may require coupling with an additional
BMP(s) in order to treat the effluent and attain a compliant stormwater discharge. Point source
measures such as those described below or other BMPs such as bio-swales, bio-retention,
trenches, filter strips, and/or wetland treatment structures may also be needed to provide
adequate treatment. The additional cost of such structures will have to be considered and
factored into the overall cost of this strategy.
If consolidation of flow using an interconnected pipe system proves unfavorable, Silar should
consider using point source treatment BMPs at each of the four existing non -compliant outfall
locations. An example of low -technology effective BMP structural measure is a prefabricated
' catch basin filter insert such as the CleanWayT"' Storm CleanTM Catch Basin Filtration Insert.
The insert combined with MetalZorbTm Filtration Media fills void space to form a compact and
simple point source removal method. Technical papers/data produced by the manufacturer for
' this structural BMP show it to be effective for variety of contaminants including suspended
solids, organics, and metals. The StormCleanTM Catch Basin Filter is constructed of a rigid
three piece poly -system including a rigid filter strainer, MetalZorbTm Filter Media, and the
support structure insert. The StormCleanTM system is available in standard catch basin sizes
allowing rapid installation in typical catch basins using the grate to hold the system in place.
Stormwater flowing into the catch basin is filtered through the proprietary MetalZorbT"' filter -
sponge media. Depending on the volume of flow and contaminant concentrations, the filter
1 media requires periodic maintenance and replenishment. Periodic analytical testing is
necessary to determine when "breakthrough" occurs with the filter media. The system has been
demonstrated to be highly effective in a variety of industrial stormwater point source removal
' applications that produce high volume wastewaters laden with a variety of metal compounds.
The cost of a StormCleanTM Standard Square C/W Insert (Item SQ24FSM-II) filled with
1 23

Evaluation of Stormwater Outfall Conditions September 10, 2012
Silar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
MetalZorbTM filter media and ready to install cost approximately $1600/outfall plus labor for
installation. An existing catch basin is required and not included in the cost. The MetalZorbT"'
Filter media can be ordered in bulk quantities of up to 100 cubic feet (CF) or smaller quantities
as well. The cost of the MetalZorbTM media is the order of $375/cubic foot. To completely outfit
four outfalls with the StormCleanTM Catch Basin Inserts would cost approximately $6500 to
$7000 plus installation and fabrication of a 2 ft. x 3 ft. catch basin if needed. The total estimated
capital cost for implementing this structural point source treatment measure including the
addition of four catch basins at each of the four outfall locations is estimated to be on the order
of $15,000 to $20,000. This cost does not include civil design, engineering, or permitting
required to outfit existing catch basins. Disposal of spent MetalZorbTM filter media is not
included in the estimated capital cost.
There are other filter media available such as Mirimichi's Bio-Char® that will provide similar
treatment functions as the MetalZorbTM media. Bio-char® is an organic carbon filter media in
granular form. The granular carbon media may be used in inserts in a similar manner as the
StormCleanTM system. The effectiveness and longevity of the Bio-Char@ media would also
require pilot testing to determine the effectiveness of this product in this particular application.
The cost of the filter media is approximately $450/ CY. Technical papers produced by Mirimichi
indicate that the filter media has been effective in removing suspended solids, particulates,
dissolved organics including chlorinated/hydrocarbon contaminants, glycol, and heavy metals.
Prior to implementing any point source treatment measure, ECS recommends that a pilot study
or treatability study first be undertaken at the "worst case" outfall to evaluate the effectiveness
of the filter media and point source BMP measure being considered. If the treatability study
concludes that the StormCleanTM or Bio-Char® filtration system effectively reduces the
contaminant loads to below benchmark values, then it would be reasonable to implement this
point source structural BMP at each of the four outfall locations. The long term cost associated
with replacement/replenishment of the MetalZorbTM media will be determined by monitoring.
Each catch basin insert holds approximately 1 CF of filter media. The MetalZorbTM media cost
approximately $375/CF and the longevity of the media before change -out will depend on flow
volume and contaminant concentrations.
Concurrent with the treatability study (and prior to implementing structural BMPs to improve
stormwater discharge quality), it is recommended that further evaluation be undertaken to
define the contaminant sources responsible for each benchmark parameter detected at Silar
outfall locations during monitoring. A comprehensive evaluation of both onsite and offsite
sources must be included in the determination of contaminant sources. This is necessary to
determine if ongoing sources are present that are contributing to degradation of stormwater
quality exhibited at Silar outfalls. The evaluation would consider:
• Identification of all raw materials used, stored, produced, and disposed from onsite and
offsite sources;
• Identification of all waste products generated, stored, or disposed at onsite and offsite
sources;
• Review of onsite and offsite discrete and indiscrete wastewater sources or discharges;
• Review of offsite discrete and indiscrete wastewater discharges;
• Review of all onsite and adjacent known waste sources including those permitted and
unpermitted;
• Review of all onsite and offsite hazardous materials spill reports;
• Review of adjacent plantsite SWP3 Plans and NPDES sampling results; and
24

Evaluation of Slormwater Outfall Conditions
Silar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
September 10, 2012
• Determination of adequacy of existing site topographic mapping on and adjacent to the
Silar lease -hold property
A table of other possible BMPs that could be utilized to improve stormwater quality at the four
Silar outfalls is shown below. It is anticipated that some measures shown may be effective in
achieving compliant stormwater discharge but will result in greater capital cost, greater long
term maintenance cost, greater monitoring cost, greater difficulty in constructing, difficulty
achieving regulatory acceptance, and will experience considerable engineering challenges. The
BMP measures and strategies identified below are generic in nature and are not recommended
without performing adequate feasibility studies, hydraulic modeling, detailed hydrologic
analysis, surveying, or engineering evaluation to determine specific site conditions and design
barriers affecting the use of such BMPs on this site. The technologies selected by Silar to
achieve outfall compliance should depend on the type of contaminants present, concentrations,
hydraulic flow regimes characteristic of each of the outfall, capital costs, operation and
maintenance costs, and cost benefit realized for constructing the system.
The following table of BMP's and strategies may be applicable to Silar in developing a
comprehensive strategy for improving stormwater quality at regulated outfalls. The below table
identifies various BMPs listed from Table 2 above for application at each outfall identified:
Table 7
Specific BMPs by Outfall
OUTFALL
FLOW
BENCHMARK PARAMETERS
TYPICALLY EXCEEDED
APPLICABLE
BMP METHOD
MOW
High
NH3,TSS,TKN,NO3+No2,Cu,Zn
1,2,3,4,5,6,7,8,9
SW 002
High
BOD,COD,NH3,TKN,CH2O,Cu,Zn
1,2,4,6,9
SWO05
Moderate
BOD,COD,TSS,NH3,TKN,CH2O,Cu,Zn,pH
1,2,4,6,8,9
SW 010
Low
Cu,Zn,CH2O
1,2,4,6,9
BOD=Biological Oxygen Demand; COD=Chemical Oxygen Demand; TSS=Total Suspended Solids; TKN=Total Kjeldahl Nitrogen:
NO3=Nitrate; NO3+No2=Nitrate plus Nitrite; Cu=Cop per; CH2O=Formaldehyde: Zn=Zinc; Mn=Manganese
The use of bio-swales, bio-retention ponds and other BMPs identified above have been
universally demonstrated to be effective best management practices that will improve
stormwater quality if properly designed. Additional evaluation would required to determine if
these technologies could be applicable to improving the specific degraded stormwater noted at
this site. Measures such as bio-retention are particularly effective for nitrogen reduction which is
problematic at three of the Silar outfall locations. The capital cost for a two -bay bio-retention
pond is expected to be considerably greater than other measures suggested. Based on our
experience with constructing BMPs including bio-retention and multi -cell treatment ponds of the
size and caliber necessary for improving stormwater quality on the Silar site, it is highly
probable that the capital cost of such measures would be significantly greater than the cost of
BMP 1 and 4 suggested for consideration. Because of the relative low capital cost to implement
point source treatment systems and their near immediate results in water quality improvement,
these are considered to be effective BMPs in this application. With our present knowledge and
understanding of the site conditions and stormwater flow regimes at the Silar site, we
recommend that priority consideration be given to BMP 1 and 4 strategies with the goal being to
improve stormwater quality at each outfall to compliant NPDES benchmark values.
25

1
Evaluation of Stormwater outtall Conditions
' Silar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
5.0 CONCLUSIONS
September 10, 2012
eThere are many factors to consider when evaluating stormwater quality at the Silar site. The
stormwater flow regimes of onsite and offsite drainage critically affects stormwater quality noted
at site outfalls. Historical data reveals Outfalls SW001, SW002, SW005 and SW010 to have
displayed benchmark value exceedances for a number of required monitoring parameters.
Offsite stormwater flow from adjacent operations at the Momentive and Oak Bark sites appear
to be contributing to some degree of stormwater degradation noted in Sitar Outfall SW001
' (former and present outfall location), SW002, SW005, and possibly SW010. Offsite processes
at the adjacent Momentive plant site including wastewater treatment, cooling towers, scrubber
emissions, and/or operation of lagoons, ponds, and waste water treatment systems may also
be contributing in part to degraded stormwater quality observed at these outfalls as well.
Additional topographic survey data on the Sitar site is necessary to accurately determine run-on
and run-off regimes and the impacts of sheet flow on each Sitar outfall locations. Tier II
requirements have been triggered at each of the Sitar outfalls therefore monthly monitoring is
I required. Four consecutive events of benchmark value exceedances at SW002 and SW005
have triggered Tier III sampling requirements at these locations. The requirements for Tier III
sampling include adding Acute Toxicity testing; installing structural stormwater controls;
developing a strategy for implementing BMPs; submitting a timetable for incorporating the
BMPs into the SWP3; and implement other measures deemed necessary. Sitar has been
notified by DWQ to comply with the Tier 111 sampling requirements mentioned above and to
amend the SWP3 yearly with all amendments clearly documented.
Several adjacent sources of groundwater and stormwater contamination associated with
Momentive's and Oak Bark's manufacturing processes, physical plants, waste treatment, waste
storage/disposal structures, cooling towers, scrubbers, and grounds present probable affects
on stormwater quality noted at Sitar Outfalls. Momentive's Outfall SW006 is determined to be
located on the Sitar lease -hold parcel. Their outfall discharges dissolved nitrogen -rich effluent,
metals, and formaldehyde daily into and onto Sitar's watersheds and watercourses. The
Momentive SW006 outfall relieves the Duck Pond which is serves as a holding pond containing
nitrogen -rich runoff from various areas of the Momentive plantsite and processes. Momentive
Outfall SW006 demonstrates a history of non -compliant effluent discharge for ammonia, TKN,
nitrate+nitrite, BOD, COD, formaldehyde, copper, and zinc. The location of Momentive's Outfall
SW006 on Sitar's site is very problematic. This occurrence creates significant environmental
risk and regulatory exposure to Sitar. Ultimately, Sitar is responsible for stormwater quality
discharging through its outfalls. This source of non -compliant wastewater received from SW006
is a contributing source to water quality degradation on the Sitar site. The Duck Pond stores
stormwater that is in contact with process materials, process waters, and products from the
Momentive production facility. Momentive's should cease discharge of wastewater onto Sitar's
property immediately. This is discussed further in Section 6.0 Recommendations.
There are several other adjacent sources of contamination from adjoining sites that may be
affecting Sitar's stormwater quality. The Oak Bark Monofill is an earthen waste cell located
immediately upgradient and abutting the Sitar southern property boundary. The monofill
contains industrial sludges, metal waste, and nitrogen -rich waste that was generated by Wright
Chemical Corporation when that facility was in operation. The monofill was constructed with a
Hypalon liner however, the liner has since been severely compromised. The liner is not
M

Evaluation of Stormwater Outfall Conditions September 10, 2012
' Silar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
adequately functioning to contain waste and wastewater in the cell. In some locations, the dike
alignment of the waste monofill appears to encroach onto Silar property. The monofill is located
immediately upgradient of Silar's property boundary and leaches effluent into the Silar
watershed. Hydraulic seeps from the monofill have been documented by visual inspections
conducted along the toe of the dike structure. The seeps are located on Silar's property and
indicate that hydraulic pressure inside the waste structure is being released through the earthen
dike. Iron -rich seeps along the dike toe are evidence that seepage from the monofill is
occurring. Impacts to shallow groundwater beneath the monofill, downgradient, and adjacent to
the monofill is highly probable. It is estimated that over 900,000 gallons of
stormwater/wastewater is presently stored on top of the monofill even though the waste cell
was not designed to impound wastewater. This condition presents an imminent hazard for
' structural failure and threat to the Silar site. In the event that the monofill dike failed or were
severely breached, it would likely release the waste contents onto Silar property_ In addition,
slope drains installed on top of the monofill allow the release of stormwater/wastewater from the
pond during high rain -fall events. The slope drains direct water from the monofill pond down the
face of the dike where it sheetflows onto the Silar site.
Also, during ECS's evaluation it was noted that Momentive's Outfall SWO08 is located near the
Silar southeastern property boundary. Based on the survey plat referenced, this outfall may be
located on Silar controlled property. At a minimum, the outfall is located immediately proximate
to the Silar property boundary and stormwater may drain onto Silar property. Further evaluation
and a confirmation survey of the outfall will be necessary to confirm its location with respect to
Silar's property boundary. Review of the topographic survey for the site indicates the outfall is
likely discharging stormwater onto the Silar site. In this same location is another environmental
concern; a septic drain field is located proximate to the property line and illustrated on the
drawing referenced above. Because of the proximity of the drain field to the Silar property
boundary, it is possible the drain encroaches onto Silar property. Further evaluation of the
purpose and use of the drain field should be undertaken to determine if the feature is impacting
Silar stormwater or groundwater quality.
6.0 RECOMMENDATIONS
The following recommendations are provided to give Silar guidance in managing the various
factors that may be affecting stormwater quality on the site:
6.1 Monofill
Impounded water ontop of the monofill presently is directed by corrugated plastic slope drains
to drain the pond level and discharge the water onto Silar property. The slope drains should be
re -located and re -directed to prevent discharge of any pond water onto Silar's property.
Drainage/sheetflow running off the slopes of the monofill also discharge onto Silar property.
The run off should be collected and/or re -directed to prevent impacts to Silar's property,
groundwater, surface water, and stormwater. Remedial measures should also be implemented
at the monofill to reduce leaching and migration of contaminants contained within the structure.
Seeps originating from the monofill and discharging onto Silar property should be sampled and
analyzed to determine if impacts are occurring. If so, measures should be taken by Oak Bark to
collect and prevent leachate from seeping onto the Silar site and impacting water quality.
As recommended by NCDENR, additional assessment of groundwater conditions and
groundwater quality should be considered adjacent to the north side of the monofill, particularly
27

Evaluation of Stormwater Outfall Conditions September 10, 2012
Silar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
in the downgradient direction on Silar property. This may be necessary to determine the effects
t of leachate discharging from the monofill onto Silar's property and the affect on stormwater and
groundwater. Degraded stormwater has been observed downgradient of the monofill at Silar's
former SW001 Outfall location. Shallow monitoring wells and piezometers located between the
monofill and the former Silar SW001 Outfall would enable assessment of groundwater quality,
determination of direction of groundwater flow, and establish the relationship of groundwater
and stormwater in the area downgradient from the monofill.
Evidence of hydraulic seepage from the monofill onto Silar's property suggest the monofill's
liner system is not functioning properly. Proper closure of the monofill waste cell may not have
occurred at the time the structure was capped and closed. Closure to meet present-day
regulatory requirements may be necessary including dismantling or repair/replacing the
Hypalon liner and cap. The use of slurry walls, recovery wells, or other remedial treatment
measures may be necessary to eliminate the ongoing effects of leachate seeping from the
waste cell onto the Silar site.
Other measures that should be considered include the following:
• Perform closure of the monofill to meet current regulatory standards (includes re -lining
and/or re -capping the waste cell; OR removal and dismantlement/disposal of the waste
in an approved Subtitle C landfill;
• Re -construct drainage on the crown of the monofill structure to maintain positive
drainage that is confined to Oak Bark property;
• Capture/remove/dispose accumulated stormwater that collects on top of the monofill to
prevent future impacts to the Silar site;
• Construct diversion berms at toe of the monofill to prevent offsite runoff from entering
upon the Silar site;
• If groundwater has been impacted on the Silar site, construct a sub -terrain slurry wall
and groundwater recovery system to prevent offsite migration of any contaminant
plume leaching from the monofill onto the Silar site; and
• Survey the toe of the dike to determine if the monofill encroaches onto the Silar lease
hold property.
6.2 Outfall SW006 and Momentive Duck Pond
The Momentive Outfall SWO06 is presently designed and constructed to discharge stormwater
and surface water on a daily basis onto Silar property_ The water being discharged has been
determined to be non -compliant with State stormwater standards. The structure is located
within the Silar property boundary and should be re -located to operate upon Momentive owned
property. The storage capacity of the Duck Pond should be evaluated for adequacy and
available freeboard during routine storm events. Increasing the height of diking surrounding the
Duck Pond may be necessary to prevent overtopping of nitrogen -rich water onto Silar property
during routine and episodic storm events. It is recommended that corrective action be taken
immediately to cease the discharge of the non -compliant wastewater onto Silar's property.
The most obvious remedy is to relocate the discharge pipe off of the Silar lease -hold parcel and
onto Momentive owned/controlled property. Rerouting the flow back onto the Momentive site
will remove the non -compliant stormwater discharge that is presently entering onto Silar's
property and watercourses. The source of the non -compliant flow is stormwater and surface
water contained in the Duck Pond. The nitrogen -rich water is then piped to the SW006 outfall.
28

Evaluation of Stormwater Outtall Conditions September 10, 2012
' Sitar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
The Duck Pond maintains a minimal volume of stage -storage and is subject to overtopping.
1 The freeboard noted in the Duck Pond (less than 18"), likely provides inadequate storage to
contain the volume of nitrogen -rich stormwater yielded during high intensity rainfall events. In
this case, the Duck Pond will over -top and flood Silar property. Even during normal intensity
rainfall events (25 year-24 hour intensity rainfalls), the lack of storage and retention remains a
concern. A potential solution is to increase the height of diking around the perimeter of the
Duck Pond. This will provide additional free -board and onsite containment during storm events.
NCDENR should be contacted concerning the present manner in which the Duck Pond is
operating and their input considered in developing a design solution. If the Duck Pond is a
permitted structure under NCDENR's Non -Discharge permit program, then the permit
conditions should be evaluated and will dictate the manner in which the pond is to be designed
■ and operated.
6.3 Silar Outfall SWO02
' Stormwater discharging from the Momentive plantsite into SWO02 on Silar's site should be re-
routed and/or re -located immediately. Structural methods and BMPs to control the flow and
prevent ongoing offsite impacts due to sheetflow from Momentive should be evaluated and
implemented. Momentive has made previous attempts to construct an asphalt diversion berm to
deflect sheetflow away from the Silar Outfall SWO02 but this measure has proven inadequate.
Momentive should assume responsibility and undertake all engineering, study, and design
necessary measures that provide a runoff control system that prevents degradation of Silar's
stormwater quality at this location. The need for a cooperative effort between Silar and
Momentive seems apparent in order to develop an expeditious solution. In the event that an
amicable solution can not be reached between both parties, Silar should consider implementing
its own BMPs or structural measures that will achieve a compliant stormwater discharge from
this outfall. it is extremely important that a solution be reached quickly by Silar to rectify the
' non -compliant discharge of stormwater that is presently occurring at this outfall. It is further
recommended that a dialogue be maintained with NCDENR to apprise the agency of progress
toward development of a solution. The agency should participate in the discussions as permit
modifications will be required if any changes are made to the present outfall systems on either
Silar or Momentive's property.
6.4 Compliance with NPDES Permit
In addition to the above, Silar's SWP3 should be reviewed annually to assure the plan is up to
date and reflects the stormwater management strategies implemented by the facility. The
NPDES permit should be reviewed to assure that Tier III sampling is being implemented as
requested by DWQ and that an evaluation is underway to determine the causes of stormwater
degradation at outfalls noted. In response to DWQ, BMP measures necessary to restore storm
water quality to benchmark values, and a time table for implementation, should be submitted to
DWQ for review and acceptance. Roof drains in the Silar 126/Fine Chemicals area may also
need to be evaluated and tested to determine if discharges from these structures are
contributing to stormwater degradation in the SWO10 Outfall location. In addition, air scrubbers,
cooling towers, air strippers, and baghouses both onsite and offsite should be evaluated to
determine if stormwater is being affected by the emissions from these structures. This would
include evaluation for the presence of nitrogen bearing compounds, copper, zinc, and
formaldehyde in air emissions from such potential sources. The discharge from any other waste
treatment systems including wastewater systems and groundwater remediation systems should
29

1
Evaluation of Stormwater Outtall Conditions
Sitar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
September 10, 2012
also be evaluated to determined if discharges are affecting site stormwater quality. Other
sources that should be evaluated to assist in determining the reasons for the detection of
copper and zinc include process piping, metalwork, and pipe racks used on the Sllar site. The
piping network should be evaluated to determine the type of pipe used, the condition, and
whether leaching is occurring from contact with acidic water sources coming from onsite or
either offsite sources.
Sampling is an integral part of complying with the NPDES Permit. Quality control, adherence to
sampling protocol, sample handling, and sample conveyance to the laboratory is governed by
EPA methods and protocols and important in assuring that samples are not compromised in the
process. It is critical that the samples collected and analyzed represent site conditions. Sitar is
presently relying upon Momentive through a service agreement to collect their stormwater
outfall samples and subsequently for generating laboratory results. Lab reports are issued in
Momentive's name and reference the results of Silar's outfalls and Momentive's outfalls on the
same report. It is advisable in light of recent interest of the site by various regulatory agencies,
that Silar generate their data independent of Momentive. If a qualified third party is utilized for
sample collection, that party should be unrelated to the environmental issues that presently may
have a connection with Momentive or Oak Bark. Silar's legal counsel is more qualified to
elaborate on this point and should be consulted for direction.
6.5 Agency Communication/Meeting with Regulators
Silar is presently not compliant with all terms and conditions of the NPDES permit. Though no
formal enforcement action has been initiated by DWQ to date, there are regulatory options
available to DWQ (and EPA) that could greatly accelerate Sitar's schedule in completing the
evaluative actions described above. To prevent an agency directed action, it is recommended
that a meeting be scheduled in the near -term with Ms. Linda Lewis/DWQ to discuss the status
of the facility with respect to the NPDES permit. It is advised that the meeting be coordinated in
the very near future to demonstrate that Silar is committed in their effort to comply with the
agency's earlier request. As stated in Section 6.3 above, implementation of new BMPs or
changes to the existing stormwater management system will require modification of the existing
NPDES permit. NCDENR should be apprised of proposed plans or intentions to modify any
component of the presently permitted system in advance of doing so.
6.6 Septic Drain Field and Outfall SW008
ECS recommends that both the septic drain field and SWO08 Outfall be located by a licensed
surveyor with respect to the Silar property boundary. A determination should also be made by
the surveyor whether either structure encroaches onto Silar property. ECS also recommends
that analytical data for SWO08 be acquired and reviewed to determine the quality of stormwater
being discharged at this outfall location. If non -compliant discharge of stormwater is noted from
the data review, further evaluation may be necessary to determine the need and type of remedy
to eliminate future discharge. The direction of stormwater flow leaving the outfall is unknown at
this time and should be also be determined.
The septic drain field identified at the site is a recognized environmental condition (REC) that
could impact groundwater, soil, or stormwater on the Silar site. ECS recommends further
evaluation of this structure. The owner of the system should be confirmed and details
concerning the typical use of the system should be ascertained. The type of system, design
30

Evaluation of Stormwater Outfall Conditions September 10, 2012
Silar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 R
details, schematics, drawings, waste character and typical flow volumes should be determined.
' Depending on the findings, additional evaluation or assessment including soil, stormwater, and
groundwater sampling may be necessary to determine if the feature presents significant
environmental risk to the Silar property.
6.7 Best Management Practices
It is recommended that Silar evaluate and consider BMP's for managing stormwater at each
outfall location exhibiting benchmark exceedances. Silar should consider in it's development of
a comprehensive management strategy whether to address non compliant outfalls on a point
source basis using structural BMP's or whether to develop a more comprehensive approach
that would utilize a centrally located BMP such as a bio-retention pond designed to contain all
plantsite stormwater. Regardless of the BMP strategy or structures proposed, additional
topographic survey of the Silar watershed is necessary to accurately determine stormwater run-
on and run-off regimes affecting stormwater quality on the Silar site. In the course of this
process, it is advised that Silar engage in an open dialogue with DWQ to inform the agency of
the specific steps and a time table that will be undertaken to manage the stormwater program.
Potential BMPs that may be used at this site have been identified in Section 4.0 of this report.
The BMPs identified will provide point source treatment technology for improving degraded
stormwater effluent. These point source structural BMPs have been successfully implemented
in various US locations and on a variety of other types of industrial sites. Treatability
study/evaluation and pilot testing of any point source BMP under consideration is recommended
prior to full implementation.
6.8 Additional Stormwater Sampling and Evaluation
In addition to the above recommendations, it would benefit Silar to undertake additional
stormwater sampling to target and determine the sources for the 1) nitrogen bearing
compounds, 2) formaldehyde, and 2) metallic compounds copper and zinc. Even though it is
suspected that formaldehyde, zinc, copper, and nitrogen compounds are associated with the
processes of the adjacent Oak Bark and Momentive operations, Silar may have to perform
sampling to demonstrate this occurrence. A sampling program designed to demonstrate that
these compounds are not indigenous to Silar's operation would support this assumption. This
may include a multi -faceted sampling program to characterize both onsite ambient and offsite
stormwater quality where such stormwater does not contact ground surfaces. Ambient
stormwater sampling of airborne stormwater prior to contact with ground surfacing would aid in
determining the reasons for the presence of the contaminants that have been detected long
term in the stormwater samples collected from the Silar site. The sampling program should also
target nearby sources that are likely contributing to onsite stormwater degradation from
adjacent plant sites including cooling tower waters, scrubbers, air -strippers, bag houses, pipe
racks/metal work, and water/waste treatment systems (onsite and adjacent sites). Emissions of
any other potential air sources in the local area, onsite or nearby should also be considered in
developing the sampling program.
Limited sampling and analytical data is available for the newly relocated Outfall SWO01 since
this outfall was just established in March/April of 2012. Sampling, observation, and review of
stormwater data related to the new outfall location should continue with future efforts. Once a
sufficient level of data has been generated, (at least 3 periods), review of the data should occur.
31

Evaluation of Stormwater Outfall Conditions
Silar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
September 10, 2012
Observable trends and findings from the data can be considered in developing applicable BMPs
or management strategies for this outfall.
7.0 QUALIFICATIONS OF REPORT
The methods and evaluative approaches used in this report of findings are consistent with
those normally employed in the environmental engineering industry in performing waste water,
stormwater, surface water, and groundwater assessment projects. Our evaluation and
conclusions of site stormwater conditions has been based on information available in the public
record, information and data provided by the facility, and data derived during our field activities.
Additional data, monitoring, or information relevant to stormwater conditions at the site may
' exist that ECS has not been privy to and could alter the opinions and recommendations cited in
this report.
The BMPs identified by ECS for consideration have been identified without performing pre-
emptive feasibility study, modeling, surveying, or engineering evaluation to fully qualify each
BMP for this application. Design or performance barriers affecting the use of such structural
BMPs may exist and would require consideration. Additional hydraulic evaluation or study may
also be necessary to determine the factors that will affect the use of these BMPs as applicable
measures to remediate stormwater at non -compliant outfalls. The technologies that are
selected by Silar for implementation will depend on the type of contaminants, concentrations,
and hydraulic flow regimes characteristic of stormwater at each outfall location. Additional
feasibility study and pilot testing may be necessary to qualify BMPs under consideration.
32

,•
so
ACM CEMWAM Ma
• �4y'`
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i...
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d
" " i L L C
Approximate
Site Location C0L ux��UKWS`ULAY'ioa
GRAPHIC SCALE
Iwt�)a
R 1FlpMp-MYCp4S
DEED BOOK 799 - PAGE 929
PARCEL ONE - TRACT ONE
PARCEL ONE - TRACT TWO
PARCEL ONE - TRACT THREE
PARCEL ONE _ TRACT SEVEN
SEX ARTICLE OF MERGER
CORPORATE BOOK e - PAGE 7
COLUMM COUNTY REGISTRY
6.570 AGES +/- IN TOTAL OU9YET
0-Ma A +/- QI 8A 1818 R!f
SAW ACM +/- NET
w. r.
Jok
49 *At
PARCEL m (EEC6Pi DR)
_ ••BREAEROOY/Iie" HITIILgIG• _ z '
16" 2 0= ACRIS ►/- l9n sq. MI 1N.VOTAL•• SiMfti _, '-
4.4
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4
KETCH � � ' �¢ "```.. � �,r!► � Sa A,..
N
LEGEND:
� Approximate Parcel Boundary
SOURCE
Soles & Walker, P.A., PLS
Project No. 080660
BKIPB 87; PG 94-94
Scale V = 100 ft
W
Figure 1
Silar
333 Neils Eddy Road
Riegelwood, Columbus County, North
Carolina
ECS PROJECT NO. 22-17258
E

Forest Products
MOMENTIYE- ACME OPERATION`ssion
333 Neils Eddy Road
Riegelwood, NC 28456-9570
February 8, 2012
Division of Water Quality
Wilmington Regional Office
127 Cardinal Drive Extension
Wilmington, NC 28405
RE: 2011 Annual Summary Monitoring Report
To Whom It May Concern:
Please find enclosed with this cover letter Momentive — Acme Facility's annual summary monitoring
report for the four designated stormwater outfalls.
If you have any questions regarding this submittal, please contact Ronald Bazinet at 910-655-2263,
extension 5257.
Regards,
OMENTIVE SPECIALTY CHEMICALS INC.
tote
Ronald Bazinet
Site Leader
RECEIVED
FEB 10 2012
BY:_�

STORMWATER DISCHARGE OUTFALL (SDO)
ANNUAL SUMMARY DATA MONITORING REPORT (DMR)
Calendar Year 2011
Individual NPDES Permit No. NCS000156 or
Certificate of Coverage (COC) No. NCG❑❑❑❑❑❑
This monitoring report summary of the calendar year is due to the DWQ Regional Office no later than March 1"t of the following year.
Facility Name: Momentive Specialty Chemicals, Inc.
County: Columbus
Phone Number: [phone] Total no. of SDOs monitored: 4
Outfall No. 003
Is this outfall currently in Tier 2 (monitored monthly)? Yes ® No ❑
Was this outfall ever in Tier 2 (monitored monthly) during the past year? Yes ® No ❑
If this outfall was in Tier 2 last year, why was monthly monitoring discontinued?
Enough consecutive samples below benchmarks to decrease frequency ❑
Received approval from DWQ to reduce monitoring frequency ❑
Other ❑
Was this SDO monitored because of vehicle maintenance activities? Yes ❑ No
Total
Rainfall,
inches
Parameter, (units)
TSS
(Mg/1)
BOD
(Mg/1)
COD
(Mg/1)
NH3
(mg/1)
TKN
(mg/1)
NO3+NO2
(mg/1)
Total
Phosphorus
(Mg/1)
Methanol
(Mg/1)
Benchmark
N/A
1 100
30
120
7.2
20
10
2
7,700
01 /17111
0.31
<2.7
31
157
119
139
10.4
0.23
<10
04/05/11
0.33
53.2
39
136
89.3
79.1
8.94
0.28
12.9
09/20/11
1.35
52.5
22
200
13.5
62.0
9.06
0.24
<10
11/29111
1.4
13.7
16
78
12.0
19.9
11.4
1 0.06
<10
12/27/11
0.33
8.4
5
62
20.2
22.6
3.97
1 0.19
<10
SWU-264-Generic-25May2010

Outfall No. 003 Continued
Total
Rainfall,
inches
Parameter, (units)
TRC
(mg")
Hexamine
(mg/1)
Formaldehyde
(mg/1)
Total Co Copper
pp
(mg/1)
Total Zinc
(mg/1)
Total Lead
(mg11)
Non -Polar
08G
(m911)
p H
(s.u.)
Benchmark
N/A
0.028
25,000
0.5
0.007
0.067
0.03
15
6-9
01/17/11
0.31
0
33.0
2.05
0.099
0.618
<0.010
<5
7.62
04/05/11
0.33
0
<10
1.38
1.31
0.565
<0.010
<5
7.33
09/20/11
1.35
0
27.6
4.25
0.425
0.230
<0.010
<5
7.60
11/29/11
1.4
0
<10
0.425
0.318
0.219
<0.010
<5
6.80
12127/11
0.33
0
<10
0.330
0.101
0.217
<0.010
<5
7.23
Outfall No. 004
Is this outfall currently in Tier 2 (monitored monthly)?
Was this outfall ever in Tier 2 (monitored monthly) during the past year?
If this outfall was in Tier 2 last year, why was monthly monitoring discontinued?
Enough consecutive samples below benchmarks to decrease frequency ❑
Received approval from DWQ to reduce monitoring frequency ❑
Other ❑
Was this SDO monitored because of vehicle maintenance activities?
Yes ® No ❑
Yes ® No ❑
Yes ❑ No
Total
Rainfall,
inches
Parameter, (units)
TSS
(mg/1)
BOD
(mg/1)
COD
(mg/1)
)
NH3
(mg/1)
TKN
(mg/1)
NO3+NO2
(mg/1)
Total
Phosphorus
(mg/1)
Methanol
(mg/1)
Benchmark
N/A
100
30
120
7.2
20
10
2
7,700
01117111
0.31
170
362
2,180
476
975
15.4
1.2
96.6
04/05111
0.33
146
248
523
1.0
81
9.94
0.56
26.7
09/20111
1.35
46.7
24
108
1.9
15.6
8.41
0.06
<10
11/29/11
1.4
19.4
>66
1,270
1.1
386
11.8
0.05
<10
12/27/11
0.33
69.0
59
313
27.7
72.7
3.96
0.64
<10
SWU-264-Generic-251Vlay2010

Outfall No. 004 continued
Parameter, (units)
Total
Rainfall,
inches
TRC
(Mgt[)
Hexamine
(mg/1)
Formaldehyde
(mg/1)
Total Copper
(mg/1)
Total Zinc
(mg/1)
Total Lead
(mg/1)
Non -Polar
O&G
(mg1l)
pH
(s.u.)
Benchmark
N/A
0.028
25,000
0.5
0.007
0.067
0.03
15
6-9
01/17/11
0.31
0
858
41.2
0.490
0.897
<0.010
<5
7.86
04/05111
0.33
0
52
107
0.525
0.999
0.014
<5
7.07
09/20/11
1.35
0.005
<10
17.5
0.093
0.217
<0.010
<5
7.43
11/29/11
1.4
0
<10
23
0.062
0.243
<0.010
<5
7.03
12/27/11
0.33
0
<10
3.6
0.113
0.376
<0.010
<5
7.37
Outfall No. 006
Is this outfall currently in Tier 2 (monitored monthly)?
Was this outfall ever in Tier 2 (monitored monthly) during the past year?
If this outfall was in Tier 2 last year, why was monthly monitoring discontinued?
Enough consecutive samples below benchmarks to decrease frequency ❑
Received approval from DWQ to reduce monitoring frequency ❑
Other ❑
Was this SDO monitored because of vehicle maintenance activities?
Yes ® No ❑
Yes® No❑
Yes ❑ No
Parameter, (units)
Total
Rainfall,
inches
TSS
(mg/1)
BOD
(mg/1)
COD
(mg/1)
NH3
(mgll)
TKN
(Mg/1)
NO3+NO2
(mg/1)
Total
Phosphorus
(mg/1)
Methanol
(mg/1)
Benchmark
N/A
100
30
120
7.2
20
10
2
7,700
01117/11
0.31
16.7
45
121
26.9
30.6
7.41
0.27
<10
04/05/11
0.33
30
100
222
54.2
65.4
1.66
0.32
<10
09/20/11
1.35
16.8
9.0
89
5.5
15.7
3.93
0.17
<10
11129/11
1.4
15.4
7
84
5.0
11.4
5.44
<0.04
<10
12/27111
.033
15.6
8
66
5.6
9.2
12.50
0.5
<10
SW U-264-Generic-25May2010

Outfall No. 006 continued
Total
Rainfall,
inches
Parameter, (units)
TRC
(mg/1)
Hexamine
(mg11)
Formaldehyde
(mg/1)
Total Copper
(mg/1)
Total Zinc
(mg/1)
Total Lead
(mg/1)
Non -Polar
O&G
(mg/1)
pH
(s.u.)
Benchmark
IV/A
0.028
25,000
0.5
0.007
0.067
0.03
15
6-9
01/17/11
0.31
0.005
14.8
1.88
<0.010
0.142
<0.010
<5
7.41
04/05/11
0.33
0.009
<10
5.18
0.012
0.041
<0.010
<5
7.33
09/20/11
1.35
0.018
<10
1.43
0.018
0.046
<0.010
<5
7.75
11/29/11
1.4
0.018
<10
0.550
<0.007
0.027
<0.010
<5
6.96
12/27111
0.33
0.022
<10
0.294
<0.007
0.026
<0.010
<5
7.26
Outfall No. 009
Is this outfall currently in Tier 2 (monitored monthly)?
Was this outfall ever in Tier 2 (monitored monthly) during the past year?
If this outfall was in Tier 2 last year, why was monthly monitoring discontinued?
Enough consecutive samples below benchmarks to decrease frequency ❑
Received approval from DWQ to reduce monitoring frequency ❑
Other ❑
Was this SDO monitored because of vehicle maintenance activities?
Yes ® No ❑
Yes® No El
Yes ❑ No
Total
Rainfall,
inches
Parameter, (units)
TSS
(mgll)
BOD
(mg/1)
COD
(mg/1)
NH3
(mg/1)
TKN
(mg/1)
NO3+NO2
(mg/1)
Total
Phosphorus
(mg11)
Methanol
(mg/1)
Benchmark
N/A
100
30
120
7.2
20
10
2
7,700
01117/11
0.31
252
51
428
11.2
14.6
1.04
0.57
<10
04105/11
0.33
161
32
140
1.8
9.4
1.16
0.17
<10
09120/11
1.35
22.4
2.0
32
4.5
5.0
0.42
0.07
<10
11/29111
1.4
6.1
<2
<20
<0.2
<0.5
0.16
<0.04
<10
12127111
0.33
16.0
2
<20
<0.2
1.0
0.24
0.16
<10
SW U-264-Generic-25 May2010

Outfall No. 009 continued
Parameter, (units)
Total
Rainfall,
inches
TRC
(mg/1)
Hexamine
(mg/1)
Formaldehyde
(mg/1)
Total Copper
(mg/1)
Total Zinc
(mg/1)
Total Lead
(mgll)
Non -Polar
O&G
(mg/1)
pH
(s.u.)
Benchmark
N/A
0.028
25,000
0.5
0.007
0.067
0.03
15
6-9
01/17/11
0.31
0.001
<10
1.48
0.136
0.717
0.016
<5
7.42
04/05/11
0.33
0
<10
2.13
0.151
0.324
0.01
<5
7.00
09/20/11
1.35
0.018
<10
0.140
0.018
0.124
<0.010
<5
7.23
11 /29/11
1.4
0.002
<10
<5
0.007
0.045
<0.010
<5
6.73
12/27/11
0.33
0
<10
0.039
0.016
0.096
<0.010
<5
7.04
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a
system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person
or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the
best of my knowledge and belief, true, accurate, and complete. 1 am aware that there are significant penalties for submitting false information,
including the possibility
Signature
�
Date _ IIW `'
fines and imprisonment for knowing violations."
SWU-264-Generic-25May2010

Mail Annual DMR Summary Reports to:
DWQ Regional Office Contact Information;
ASHEVILLE REGIONAL OFFICE
FAYETTEVILLE REGIONAL OFFICE
MOORESVILLE REGIONAL OFFICE
2090 US Highway 70
225 Green Street
610 East Center Avenue/Suite 301
Swannanoa, NC 28778
Systel Building Suite 714
Mooresville, NC 28115
[phone]
Fayetteville, NC 28301-5043
[phone]
[phone]
RALEIGH REGIONAL OFFICE,
WASHINGTON REGIONAL OFFICE
,WILMINGTON REGIONALOFFIC9
3800 Barrett Drive
943 Washington Square Mall
127 Cardinal Drive Extension
Raleigh, NC 27609
Washington, NC 27889
Wilmington, NC 28405-2845
[phone]
[phone]
[phone]
------...............
WINSTON-SALEM REGIONAL OFFICE'
CENTRAL OFFICE
1617 Mail Service Center
"To preserve, protect
585 Waughtown Street
Winston-Salem, NC 27107
Raleigh, NC 27699-1617
and enhance
[phone]
[phone]
worth Carolina's water..."
SW U-264-Generic-25 May2010

rr NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles WakiId, P.E.
Governor
Director
February 13, 2012
Dee Freeman
Secretary
John Shibley
Silar, LLC
333 Neils Eddy Road
Riegelwood, NC 28456
Subject: NPDES Compliance Evaluation Inspection
Silar, LLC
NPDES Permit No. NGS000533
Dear Mr. Shibley,
A compliance evaluation inspection was conducted at the Silar, LLC facility by Linda Willis and Jean
Conway on January 24, 2012. The inspection was conducted to determine compliance with the
NPDES permit NCS000533. Enclosed is a copy of the inspection report. Please address the items
discussed in the summary section of the inspection report prior to the next inspection that will be
scheduled during the third quarter of this year. Any deficiencies noted should be addressed in
accordance with the permit requirements.
Should you have any questions concerning the enclosed compliance evaluation inspection report,
please contact Linda Willis or Jean Conway at 910-796-7215.
Sincerely,
4ingto
egson
n Regional Supervisor
Division of Water Quality
Surface Water Protection Section
S:WQS:NPDES:NCG/NCS Inspections/NCS/2011-2012
CC: DWQ WiRO NCS000533
DWQ CO Fifes
Wilmington Regional Office
127 Cardinal drive Extension Wilmington, NC 28405
Phone[phone] / FAX: [phone]
Internet: www.ncwaterquality.org
NorthCarolina
Naturally
An Equal Opportunity/Affirmative Action Employer
50% Recycled/10% Post Consumer Paper

Compliance Inspection Report
Permit: NCS000533 Effective: 11/01/10 Expiration: 10/31/15 Owner, Silar LLC.
SOC: Effective: Expiration: Facility: Silar LLC -Riegelwood
County: Columbus
333 Neils Eddy Rd
Region: Wilmington
Riegelwood NC 28456
Contact Person: Peter Yurgel Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Certification: Phone:
Inspection Date: 01/24/2012 Entry Time: �01:00 PM Exit Time: 05:00 PM
Primary Inspector: Linda Willis Phone: [phone]
Secondary Inspector(s):
Jean Conway �.�,__ �,,ts�sLy( Phone:
Reason for Inspection: Routine JV! Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ■ Compliant Q Not Compliant
Question Areas:
® storm Water
(See attachment summary)
Page: 1

Permit- NGS000533 Owner -Facility: Silar LLC
Inspection Date: 01/2412012 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Data review:
Sitar is experiencing high concentrations of contaminants at several of the outfalls. Sitar believes stormwater from the
Momentive and Oakbark facilities are contributory. Sitar is responsible for Outfalls 001, 002, and 005. Quarterly
monitoring was conducted throughout 2011 for all 3 outfalls. Benchmark exceedances at 001 are as follows: NH3
(1st&2nd 0), TKN (1st&2nd 0), NO3+NO2 (1st&2nd Q), Copper (2nd,3rd&4th Q), and Zinc (2nd Q). Outfall 002
exceedances are: BOD (1,20 Q), COD (1,2&3 Q), NH3 (1st Q), TKN (1,2&3 Q), Formaldehyde (1,20 Q), Copper (all 4),
Zinc (all 4). Outfall 005 eceedances are: TSS (1st Q), BOD (1&2 Q), COD (1&2 Q), NH3 (1st Q), TKN (2nd Q),
Formaldehyde (1&2 0), Copper (all 4 Q), Zinc (all 4 Q) and pH (2nd Q). It is possible that outfalls 002 and 005 can
receive runoff from Momentive site located upgradient. A review of the raw materials/products used/produced by Sitar
does not include formaldehyde or hexamine. A large number of chemicals are used by Sitar and some chemical
compositions include nitrogen bearing compounds. It is uncertain if any of the compounds utilized by Sitar could
dissociate/decompose to form hexamine or formaldehyde. Tier 2 requirements have been triggered at each outfall,
therefore monthly monitoring is required at all three. Four consecutive exceedances have occurred at Outfall 002 and
Outfall 005 and will require acute toxicity testing at these two outfalls. Should more recent data for Outfall 001 result in 4
consecutive exceedances of any benchmark, acute toxicity testing at that outfall will need to be implemented as well.
Please follow the instructions provided in Appendix A accordingly.
SWP3 Review:
A feasibility study should be included in the SWP3, see the requirements of the SWP3 on page 2 of 11 in Part II of your
permit. Employee training and facility inspections are being performed and documented in accordance with the
requirements of the permit. The SWP3 should be amended yearly and the amendments clearly documented. Please
ensure that all good housekeeping measures and BMPs. that are implemented be documented.
Site Map: Please include the following information on the site map: latitude/longitude for each outfall (including the new
outfall discovered); structural divides in the drainage area such as curbs, drop stormwater inlets, pervious surfaces,
existing structural BMPs and swales; buildings, tanks, secondary containment structures, haul roads, process areas,
staging, -storage or loading areas for chemical/waste/product/raw materials (with a key that indicates the specific/potential
contents of such); arrows that indicate drainage directions in each stormwater outfall drainage area; and property
boundary lines. The accuracy of site elevations from ground survey rather than aerial survey would likely be more
precise.
Site Inspection:
The condensate discharge from the compressor appears to support bio-growth. Permittee should consider testing the
condensate for COD. The condensate discharges via outfall 005.
The equipment in the area noted as "Sitar 126" was leaking caustic but was contained. This equipment should be fixed
since rain events could contribute volumes in excess of the containment basin and cause an overflow to surface waters.
Please provide adequate maintenance for that equipment to resolve the leaks and clean up and dispose of the caustic
accordingly.
The inspector noted excessive and lush green grass growing in the vicinity of Stormwater Outfall 001 which also shows
very high nitrogen contamination. Please consider investigating any potential for groundwater contamination in this area
that may be breaking out near the surface. Groundwater contamination may be contributing to high levels of pollutants at
Outfal 1001.
Page: 2

Permit: NCS000533 Owner - Facility: Sitar LLC
Inspection Date: 01/24/2012 inspection Type: Compliance Evaluation Reason for Visit: Routine
Momentive off loads wastewater to the large storage tanks adjacent to Outfall 005. The pavement appeared to have
stains from leaks/spills. There is no containment provided at this location for the activity and any spill can be conveyed
directly to surface waters via Outfall 005. The offloading area should have secondary containment. Personnel should be
present during the entire off loading activity and each event should be documented.
There is a stormdrain drop inlet near the compressor room that had a build up of solids in it and appeared to have some
contaminants that were decomposing as evidenced by off gassing when disturbed. These stormwater drop inlets need to
be cleaned out regularly and the contents disposed of properly on a frequent basis to eliminate the build up of pollutants.
A clean out schedule for all drop catch basins should be included in the facility inspection/good housekeeping areas.
Stains from spilled wastes were noted on the concrete near the chemical disposal receptacles located adjacent to the fine
chemicals and Silar 026 buildings. There is containment provided for the storage receptacles, however better
housekeeping and careful disposal practices should be implemented. include regular inspections for the secondary
containment receptacles.
Unrinsed drums are located within the hazardous waste storage secondary containment area. Many were tipped over
with bungs and lids not in place which can allow the contents to comingle with stormwater collected inside the
containment area. The drums should always have lids and bungs in place until the drums are able to be rinsed at the
rinsing station. Any spillage of listed waste comingled with stormwater becomes all wastewater and therefore cannot be
released from the containment area but disposed of properly in accordance with waste management regulations_
An outfali was located between the Silar 126 and Fine Chemicals area that needs to be included in the SWP3 and
monitored in accordance with the NPDES permit requirements.
Concluding comments:
The NPDES permit requires actions be taken when sampling results exceed benchmarks. Tier 1 actions include a
thorough inspection of the facility within two weeks of receiving sampling results. Each area of the facility that can
possibly contribute contamination to stormwater must be evaluated thoroughly to determine whether source controls,
operational controls, or physical improvements (structural controls) should be implemented to improve the quality of the
stormwater discharges. Whichever action is deemed adequate must be implemented within two months of the
inspection. A record of who conducted the inspection and the selected actions must be clearly documented by the
permittee. Tier 2 requires that monthly monitoring be implemented if the results from three consecutive monitoring
periods are above the benchmarks. Tier 3 requires notification in writing to the Supervisor of DWQ Surface Water
Protection Section that stormwater exceeded benchmarks on four occasions. DWQ should then provide guidance such
as requiring revised monitoring schedules on a more frequent or less frequent schedule, require the permittee to conduct
acute toxicity testing, require structural stormwater controls, require the permittee to implement other stormwater control
measures or require the permittee to implement site modifications to qualify for a no exposure exclusion.
This facility has triggered tier 3 response and therefore DWQ is requiring toxicity testing at outfalls 002 and 005. DWQ is
recommending that Silar evaluate the site for all potential sources and provide to this office in writing any improvements
whether structural or non structural that should help improve the characteristics of the run off from the site. It should
include a revised site map with all bulk tanks and chemical/raw material/product/waste storage areas numbered and
provide a key that describes the chemicals used or stored in those areas. Your evaluation and proposed improvements
should also be incorporated into the SWP3 under a section entitled Tiered Responses. Various areas of concern have
been identified in this inspection report. Silar personnel knows the site and the activities therein far better than DWQ
inspectors and can therefore provide the best recommendations for solutions to the stormwater problems. DWQ would
like to provide Silar an opportunity to resolve their issues and identify the issues posed from the adjacent facilities
(Momentive and Oakbark) before exercising any of the other tier three actions at our disposal. Silar is not compliant with
the requirement to monitor monthly, however, since Silar requested relief from monthly monitoring due to runoff from
Oakbark and Momentive, DWQ will not deem the facility non compliant with that requirement for 2011, however, any
failure to follow the tiered requirements in the future will be addressed accordingly. A follow up inspection will be
conducted during the third quarter of this year.
In October, 2011, you had proposed a subtraction of contaminant concentrations found at outfalls located on
Oakbark/Momentive site from the concentrations of contaminants found at your outfalls. DWQ does not believe there is
enough information to support this method for reporting purposes. You should continue to monitor and report the outfalls
in accordance with the data provided by the laboratory. DWQ will be receiving monitoring data from Oakbark and
Momentive for their respective outfalls and therefore will have data that can be referenced.
Page: 3

Permit: NCS000533 Owner - Facility: Silar LLC
Inspection Date: 01/24/2012 inspection Type: Compliance Evaluation
Reason for Visit:
Routine
Stormwater Pollution Prevention Plan
Yes
No
NA NE
Does the site have a Stormwater Pollution Prevention Plan?
■
❑
❑ ❑
# Does the Plan include a General Location (USGS) map?
■
❑
❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
■
❑
❑ ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■
❑
❑ ❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
■
❑
❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
■
❑
❑ ❑
# Does the facility provide all necessary secondary containment?
■
❑
❑ ❑
# Does the Plan include a BMP summary?
■
❑
❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■
❑
❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
■
❑
❑ ❑
# Does the facility provide and document Employee Training?
■
❑
❑ ❑
# Does the Plan include a list of Responsible Party(s)?
■
❑
❑ ❑
# Is the Plan reviewed and updated annually?
■
Cl
❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
■
❑
❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
■
❑
❑ ❑
Comment:
Qualitative Monitoring
Has the facility conducted its Qualitative Monitoring semi-annually?
Comment:
Analytical Monitoring
Has the facility conducted its Analytical monitoring?
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
Comment:
Permit and Outfalls
# Is a copy of the Permit and the Certificate of Coverage available at the site?
# Were all outfalls observed during the inspection?
# If the facility has representative outfall status, is it properly documented by the Division?
# Has the facility evaluated all illicit (non stormwater) discharges?
Yes No NA NE
■ ❑ ❑ ❑
Yes No NA NE
■❑❑❑
❑ ❑ ■ ❑
Yes No NA NE
■ ❑ ❑ ❑
■ ❑ ❑ ❑
❑ ❑ ■ ❑
■ ❑ ❑ ❑
Page: 5

00
Permit: NCS000533 Owner -Facility: Sitar LLC
Inspection Date. 01/24/2012 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Comment: One outfall was located between the Silar 126 and Fine Chemicals areas
(noted by the reference as "drain pipe" on the Silar site map). This outfall will need to
be added to the site map, identified in the SWP3 and monitored in accordance with the
permit requirements.
Page: 6

E
�� United States OSW ERIOSRTI
�' Environmental Protection Washington, RC 20460
�,
Agency
***Final Site*** March 2011
NVRIC1-TTCHEIt'UC,-U,CORPOR�VIIO\T Riegelwood, North Carolina
Columbus County
(�) Site Location:
The Wright Chemical Corporation site is located outside of the City of Riegelwood along the banks of Livingston Creek.
The area of concern for the purposes of NPL listing is approximately 80 acres where fertilizer manufacturing operations
formerly occurred.
a Site History:
From the 1880s through the 1960s, Acme Manufacturing Company operated a fertilizer manufacturing facility on the
southern parcel and operated a lead chamber sulfuric acid plant across the railroad tracks on the northern parcel. Acme
merged with Wright Chemical Corporation in 1968. Wright Chemical Corporation continued operation of the acid plant
and constructed a second acid plant just to the cast, which operated until 1991.
d Site Contamination/Contaminants:
Arsenic; lead; mercury, and the pesticides dieldrin and gamma -chlordane have been detected in soil between the former
acid plant and a surface water pathway. De -vegetation is evident down gradient from the former acid plant due to low pi-1
of the soils. This source area drains to Livingston Creek and the Cape Fear River approximately 2 miles from the site.
Metals and pesticide contamination is present in Livingston Creek sediments; as well as in clam and fish tissue samples.
rid± Potential Impacts on Surrounding Community/Environment:
Livingston Creek is a freshwater creek containing a fishery and wetlands. Downriver is a brackish estuary also containing a
fishery and wetlands. Sediment in Livingston Creels, a documented fishery containing a federally endangered fish species,
contain an observed release of arsenic, lead and other metals as well as pesticides at levels exceeding the Probable Effects
Level (PEL) for freshwater sediment as set forth by the National Oceanic and Atmospheric .Administration. Clam and fish
tissues sampled in 2004 shored that concentrations of these constituents exceeded their respective recommended
concentration range. Arsenic and lead were also found in the wetlands of Livingston Creek.
`A Response Activities (to date):
EPA has completed assessment activities at the site. The Expanded Site Inspection was completed in June 2008,
recommending listing of the site on the NPL.
E--j Need for NPL Listing:
The State of North Carolina referred the site to EPA because of widespread contamination on the property. Other federal
and state cleanup programs were evaluated, but are not viable at this time. EPA received a letter of support for placing this
site on the NPII from the state.
(The description of the site (release) is based on information available at the time the site was evaluated with the HRS. The description maychange
cis additional in formation is gathered on the sources and extent of contamination.]
For more information about the hazardous substances identified in this narrative summary, including general information regarding the effects of exposure to these
substances on human health, please see she Agency for Toxic Substances and Disease Registry (ATSDR) ToxFAQs. ATSDR '1'ox1,AQs can be found on the Internet
at htt :/h+uu.atsdr.cdc. ne/toxfat.hnnl or by telephone at 1-888-42-A'I'SDR or 1-888-422-8737.

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Vlxlv-�J'�
of wATr- 1 -"` s�j
r. "`N Michael F. Easley, Governor
William G. Ross Jr., secretary
North Carolina Department of Environment and Natural Resources
� Alan W. Klimek, P.E. Director
Division of Water Quality
Certified Mail # 7003 1010 0000 0030 1923
Return Receipt Requested
May 3, 2005
Mr. Anthony D. Smith
Wright Corporation
333 Neils Eddy Road
Riegelwood, NC 28456
Subject: NPDES Compliance Inspection Report
Wright Corporation
NPDES Permit No. NCS000156
Columbus County
Dear Mr. Smith:
The North Carolina Division of Water Quality conducted a recent inspection of the Wright
Corporation Wastewater Treatment Facility on March 16, 2005. This inspection was conducted to
verify that the facility is operating in compliance with the conditions and limitations specified in
NPDES Permit No. NCS000156.
A sunimary of the findings and comments noted during this inspection is provided in Section D on
Page 2 of the attached copy of the complete inspection report entitled "Water Compliance inspection
Report".
1f you have any questions concerning this report, please contact me at [phone] Ext. 215 in
the Wilmington Regional Office.
Sincerely,
inda L. Willis
Environmental Chemist It
Attachments
Cc: Wilmington Regional Office -- Yellow File
Aisha Lau (DWQ / NPDES Storniwater Unit — Raleigh)
127 Cardinal Drive Extension, Wilmington, North Carolina 28405 One
Phone: [phone] / Fax: M-350-2004 I Internet: h2o.enr.state.nc.us North Ca+roh na
An Equal OpportunitylAffirmaI ve Action Employer - 50% Recyctedll0% Posl Consumer Paper / atuL all ff

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040.0057
Water Compliancefl
Approval expires B-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yrlmolday Inspection Type Inspector Fac Type
1 Ivl 2 !_[ 31 NCSouOiS6 111 12� 05/011/16 117
lJ LJ
1$Ir i 191c1 20f i
LJ U U
Remarks
211 1 1_ I I I I I 1 1 1 I I 1 i I I II I I I I I I...I I I I I
I II..I 1 I I I I I I I I 1166
_I
Inspection Work Days Facility Self-[Lloniloring Evaluation Rating 81 OA
,I_
------------------- Reserved-------------
67 1 1 69 70 U 71 U 72 Lj
73 W 74 751_ 1 1 1 1 1 1 180
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry TimelOate
Permit Effective Date
POTW name and NPDES permit Number)
Wri.g':L. Cc,rporacion WWTY
10:00 Ar-I I35/03/25
Oil/C?/OS
Exit Time/Dale
Permit Expiration Dale
333 Niels Edav Rd
01:30 PM 05%03/16
05/0./'8
Name(s) of Onsite Representative(s)ITitles(spPhone and Fax Number(s)
Other Facility Data
Anthony D Smicn/03C/910-655-22n3/
Name, Address of Responsible OfficiaMille/Phone and Fax Number
Anthony D Smita. PF.,333 Niels Eddy Rd 29456//910-655-5253/ Contacted
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit s Self -Monitoring Program ® Facility Site Review
® Storm Water
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspeclof(s) Agencyt'OKcelPhone and Fax Numbers Dale
Linda Willis L r Ki+'4 CKt/2�J WTRo WQ//%
//
J X. /G3
Tom Moose I.JIRQ WQ1//
SJG/o 5
Signature of Management O A Reviewer AgencylOfficelPhone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.

Section D: Summary of Find ingslComments
(Attach additional sheets of narrative and checklists as necessary)
1. Permit:
Your permit became effective February 4, 2000 and expired on February 28, 2005
The permit is currently in the renewal process and is udder review. The Wilmington Regional
Office conducted this inspection in conjunction with the permit renewal review.
The permittee is reminded to read, understand and comply with all of the terms and conditions
contained in the permit. If you have questions concerning your responsibilities, call the
Wilmington Regional Office to speak to a Division of Water Quality staff member.
'. Facility Site Re -view:
The overall condition of the plant site was satisfactory. The appearance of the facility was in
acceptable condition indicating that the current housekeeping practices are fair.
Upon inspection of the monitoring results for storrnwater discharge front Outfalls 002, 003 and
005, the concentration of pollutants discharging through the storrnwater outfalls are excessive
and significantly higher than should be expected (See attached "Summary of Storin Event
Alonitoring'). The data presented in the "Summary of Storm Event Monitoring" indicates
concentrations of BOD, COD, TSS, NHj, TKN, Fornialdehvde and Hexamine are excessive for
stormivater- discharges. The facility indicated that it was difficult to control the accidental
transport of dry chemicals by personnel 's feet and forklift wheels in areas where dry chemical is
being stored and handled. As specified in the current permit, this monitoring data is evaluated
against the "cutoff levels" presented in the permit. The concentrations of various pollutants
were significantly higher than the corresponding "cut-off level" which indicates that substantial
irnpr•ovein ents in housekeeping, material handling, and containment are needed.
The facility should review the Storiwater Pollution Prevention Plan and current standard
operating procedures in these areas to identify anv areas that may be improved. The facility
should implement the appropriate changes in an effort to improve current practices and reduce
storm water pollution. These analytical results do raise concern regarding the potential impacts
to surrounding surface ivaters. Therefore, it is recommended that the facility take ininnediate
steps to identify and improve facility operations and practices that contribute to the excessive
sto,nivater pollution discharges.
3. Adequacy of Stormwater Pollution Prevention Plan (SWPPP):
The STYPPP was complete and contained the necessary elements for storrnwater
pollution prevention. All storrnwater outfalls were identified in the SWPPP and were
adequately documented on a sire map. Otrfalls 001, 004, 006 and 007 are not currently
rrnornito-ed individually as they have representative status with other designated outfalls.
These outfalls with representative statics should be specifically identified with the
appropriate analytical data to support the representative outfall designation.
The facility should provide the Division of Water Quality with such information for
verification of representative outfall status. Should such information not be available,
the facility should conduct the appropriate analttical testing of these outfalls and subinit
all results to the Division of TVater• Quality.

4. VehiclelEquipment Maintenance Area:
Not Applicable_
5. Vehicle/Equipment Wish Area:
Not Applicable.
6. Temporary Storage of Waste Materials:
Waste materials appeared to have secondary containment. Please be sure to check all
secondray containment areas daily far possible over situations. During the
inspection, one of the secondary containment structures in the silane production area
associaled with one of the boilers was close to overflowing. The facility addressed this
issue at time of visit to have the area pumped immediately.
7. Outdoor Storaee of Materials:
Materials stored outside appeared to be in poly totes with reinforced cages. There did not
appear to be any evidence of leaking containers. Dry materials are stored in buildings to
prevent exposure to the elements.
8. Spill_ Response and_Cleanup Program:
Adequately addressed.
9. Erosion Control on Site:
There were areas that need to be looked at for erosion control such as the area up gradient
from the chemical storage area_ Runoff from. up gradient seeps through the wall surrounding
the chemical storage area and rums across the storage pad floor. The facility indicated the area
located up gradient fronn the storage area would be re -graded to eliminate runoff collecting in
the storage pad area. Areas around the Duck -Pond are also graded to reduce the effects of
erosion.
10. Illicit Discharge Elimination:
Not Applicable.
11. Wastewater Treatment Facili
Wastewater treatment is not required at this time.
12. Stream Impacts/Results of Sampling:
Compliance sampling was not conducted during the inspection.
13. Sammarv:
The SPVPPP was complete and contained the necessary elements for storrnwater
pollution prevention.
The Division has two concerns however that needs to be addressed imrnedicrtely:
1. Provide the Division with analytical results that support the represenlatis,e status
designation for Stormwater Outfalls 001, 004, 006 and 00.

Z. The facility should review the Storrntiti-ater Pollution Prevention Plan and current standard
operating procedures in all areas, especially areas involving materials handling operations,
to identify arty areas that may be improved. The facility should implement the appropriate
changes in an effort to improve current practices and reduce sto-nz►vater pollution. The
"Stunmary ol'Stornz Event Monitoring" data indicates concentrations of BOD, COD, TSS,
NH3, TKN, Formaldehyde and Hexamine are excessive for stormwater discharges. In manly
instances throughout the monitoring periods 1-20, the .storrnwater pollutant levels far
exceeded the "cutoff levels" specified in the slorrnivater general permit.
The Division of Water may consider evaluating whether this discharge should be permitted
under an individual ivastewater discharge permit, which would require treatment to achieve
acceptable concentrations of pollutants for discharge to surface waters.
Name and Sionatnre of Inspectors:
�-
Thr6rias F. Moore
Surface Water Protection Section
Wilmington Regional Office
Lin a . Willis
Surface Water Protection Section
Wilmington Regional Office
Y 0 -5
Date
M&j
---
Date

W F U CAH-r C C>F1R C>F1,AT 1 C>N
December 29, 2004
Rick Shiver
NCDENR — Division of Water Quality
127 Cardinal Drive Extension
Wilmington, NC 28405�
Reference: Wright Corporation
Permit No. NC000339_5 C110
Permit No. NCSOOOISG -- ��
Dear Mr. Shiver:
ISO 9002 Certified
This letter is to formally announce that Thomas H. Wright, III (one of five share holders of
Wright Corporation) has retired from Wright Corporation (Wright). Bill Oakley and Jim Barker,
the former President and Vice President of the company, have purchased all of Mr. Wright's
shares of stock. Mr. Oakley is now the Chairman of the Board and Mr. Barker is the President of
Wright, respectively. Mr. Oakley and Mr. Barker wish to continue the good working
relationship Wright has previously had with the North Carolina Department of Environment and
Natural Resources (NCDENR). The Wright facility has remained in tact and as we discussed by
telephone there are no changes needed for the two (2) permits (NCO003395 and NCSOOO156) the
facility currently holds with your division of NCDENR.
Please contact me at [phone], Ext. 5204 if you have any questions, comments, or desire
further information. You can also contact Mr. Oakley at [phone], Ext. 121 or Mr. Barker
at [phone] Ext. 119.
Sincerely,
Anthony D. mith, P.E.
Regulatory Affairs Officer
333 NEILS EDDY FORD + RIEGELWOOD, N.C. 28456 • TELEPHONE [phone] • FAX: [phone] t

Michael F. Easley, Governor
o��� w A r�Rpt:
Anthony D. Smith, P.E.
Regulatory Affairs Officer
Wright Corporation
333 Niels Eddy Road
Riegelwood, North Carolina 28456
Dear Mr. Smith:
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
December 7, 2004
DEC v 9 2004
BY:
Subject: NPDES Permit Renewal Application
Permit Number NCS000156
Individual Stormwater Permit
Columbus County
The Division of Water Quality's Stormwater Permitting Unit hereby acknowledges receipt of your
renewal application for coverage under NPDES Permit Number NCS000156 on August 3, 2004. We
apologize for the delay in addressing your submittal and will make every effort to review your permit
renewal as expeditiously as possible. The submitted renewal package contained the following items:
Signed application
Site map
i Analytical monitoring results summary
Qualitative monitoring results summary
Y Best Management Practices summary
Narrative describing significant changes at the pennitted facility
➢ Signed Stormwater Pollution Prevention Plan certification
We have conducted a preliminary review of the renewal application and supplemental information, and
the package appears to be complete. No additional information is required at this time. If you have any
questions about the renewal process or would like to discuss this letter, please contact me at (919) 733-
5083, extension 529.
Sin
• i
cerely,Aleorgoulias7
° Environmental Engineer
cc: "Wilmington Regional Office
Stormwater Permitting Unit Files
Central Files
One
NCarolina
)Naturally
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: h2o,enr.state.nc.us 512 N, Salisbury St. Raleigh, NC 27604 FAX [phone]
An Equal OpportuMylAfrirmative Action Employer — 50% Rocycledf 10% Post Consumer Paper

Georgoulias, Bethany
From: Conway, Jean
Sent: Wednesday, April 09, 2014 8:49 AM
To: Georgoulias, Bethany
Subject: RE: Conference Call about old Wright Chem Site (Sitar, Oak Bark, Momentive, Hexion... ?)
Bethany, I will be in Dan's office 910-796-7326 so here is some recent data as well as 2011 data along with a map of the site
EJ
You should have copies of everything we have but let me know if there is anything else you need.
Jean
From: Georgoulias, Bethany
Sent: Wednesday, April 09, 2014 8:34 AM
To: Conway, Jean; Sams, Dan
Cc: Bennett, Bradley; Pickle, Ken
Subject: RE: Conference Call about old Wright Chem Site (Sitar, Oak Bark, Momentive, Hexion... ?)
Jean and Dan,
What's the best number to reach you all for this call later this morning?
Bethuny Georgoulias, Environmeutcrl Engineer
NCDENR / Division of Energy. Mineral, and Land Resources
Stormwater Permitting Program
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury Street, Raleigh, NC 27604
9191 807-6372 (phone); 919 / 807-6494 (fax)
Website: http://portal.ncdeilr.orWwob/Ir/storinwater
E-mail correspondence to crud from this address nap he subiect to the :Numb C:arohm 11nhlic Records lair and may he disclosed io third parties.
-----Original Appointment -----
From: Georgoulias, Bethany
Sent: Wednesday, March 05, 2014 11:23 AM
To: Georgoulias, Bethany; Conway, Jean; Sams, Dan; Bennett, Bradley; Pickle, Ken; Gregson, Jim
Subject: Conference Call about old Wright Chem Site (Sitar, Oak Bark, Momentive, Hexion... ?)
When: Wednesday, April 09, 2014 9:00 AM-10:00 AM (UTC-05:00) Eastern Time (US & Canada).
Where: 7th FCR
Hi Jim G.,
Do you think you can join us for this conference call for some background and perspective on this site?
All, I just spoke with Dave Matthison in DWM's Superfund Program, and I'll share that information tomorrow morning.
EPA is the lead agency on a remedial investigation out there right now, but DENR DWM is working to help manage

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Georqoulias, Bethan
From: Bennett, Bradley
Sent: Monday, March 03, 2014 3:20 PM
To: Georgoulias, Bethany
Subject: FW: Wright Chemical Corporation, Riegelwood NC
1] D D 0 SI (zr-
Bethany, dLS Q(1d 532- a,-qGL?zr..L-
nIGS
Could you help me get these permits and other information to send to David.
F.F.
Bradley Bennett
Stormwater Permitting Program Phone: [phone]
NC Division of Energy, Mineral and Land Resources j Fax: [phone]
1612 Mail Service Center Email: bradleY.ben nett(ftodenr.gov
Raleigh, NC 27699-1612 Web: hfp:llaortal.ncdenr.org/webAr/stormwater
Email correspondence to and from this address may be subject to public records laws
From: Mattison, David
Sent: Monday, March 03, 2014 2:49 PM
To: Bennett, Bradley; Kegley, Geoff
Cc: Bateson, James; Lown, David; Zimmerman, Jay; Risgaard, Jon
Subject: Wright Chemical Corporation, Riegelwood NC
Bradley & Geoff,
Jay Zimmerman and -Jon Risgaard indicated that I should contact you so that I could get a copy of any stormwater or
NPDES permit for the Oak -Bark Corporation/Momentive/Silar facility (formerly known as the Wright Chemical
;Corporation) -located in Riegelwood NC as well as any monitoring results and compliance history. I am the project
manager for the Wright Chemical Corporation NPL (Superfund) Site. I have been tasked to assess the Site to best
determine the scope of the remedial investigation without infringing upon other program's jurisdiction. Please feel free
to contact me if you have any questions or concerns.
Thanks,
Dave
David B. Mattison
Environmental Engineer
NC DENR Superfund Section
ffj'�A'4
NC®ENR
Phvsical Address:
Cubicle 3104F

is
DENR Office Building
Green Square Complex
217 W Jones Street
Raleigh NC 27603
Mailing Address:
1646 Mail Service Center
Raleigh, NC 27699-1646
Office Phone/Fax: [phone]
Mobile: [phone]
david.matt ison Rncdenr.gov
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statute or other regulation.

Hopping Green & Sams
Attorneys and Counselors
March 29, 2013
Mr. Charles Wakild
Division of Water Quality Director
N.C. Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: RE: Sitar, LLC, Riegelwood, North Carolina
Dear Mr. Wakild:
As your Division is aware, Silar, LLC ("Silar") leases property from Oak -Bark
Corporation ("Oak Bark"), located at 333 Neils Eddy Road, Riegelwood, North Carolina, for its
operations. At Sitar's request, Rudy Smithwick. P.G., ECS Carolinas, LLP recently prepared a
Report titled "Evaluation of Stormwater Outfall Conditions and NPDES Discharge Permit
Status" ("Report"), a copy of which is included for your records.
Copies of the Report have been provided to Oak -Bark and another business in the vicinity
of Oak-Bark's and Sitar's operations, Momentive Specialty Chemicals, Inc. Please do not
hesitate to contact me if you have any questions regarding this Report. Thank you for your
attention to this matter.
Sincerely,
HOPPING GREEN & SAMS
Ralph A. DeMeo
cc: Brian Miller, Silar
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V,
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Post Office Box 6526 Tallahassee, Florida 32314 119 S. Monroe Street, Suite 300 (32301) 850.222J500 850.224.8551 fax www,hgslaw.com

EVALUATION OF STORMWATER OUTFALL- CONDITIONS AND NPDES;
DISCHARGE PERMIT STATUS
SILAR, LLC-
333 NEILS EDDY ROAD
RIEGELWOOD, NORTH CAROLINA
ECS PROJECT NO. 22-17258
PREPARED FOR:
HOPPING GREEN & SAMS, P.A.
TALLAHASSEE, FL
SEPTEMBER 10, 2012

i
` _Mali
ROL IN ' S iILP� ySefting the Standard for Service"
',,Geotechnical • Construction Materials --Environmental - Facilities "CF!-I_EncAhat FkmF 072
.A September 10, 2012
Mr. Ralph Demeo
Ms. Paula Cobb
Hopping, Green & Sams
119 South Monroe St., Suite 300
Tallahassee, Florida 32301
Reference: Evaluation -of Stormwater Outfall Conditions and
NPDES Discharge Permit Status
Silar, LLC Facility
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
Dear Mr. DeMeo and Ms. Cobb:
ECS Carolinas, LLP (ECS)is pleased to provide you with the following "report in regard to the
above referenced site. The services provided were'oonducted in accordance with the scope of
work outlined in ECS Proposal 22-15425 dated February 28, 2012. ECS appreciates the
opportunity to provide our environmental engineering services to you. If there are questions
regarding this report, or a need for further information, please contact us at [phone].
Respectfully submitted,
ECSCAROLINAS, LLP
Rudy Sm' wick, P.G':
Senior Geologist
NC License No. 866
Brian E. Maas, REM
Director of Environmental Services
7211 Ogden Business Park, Suite 201 , Wilmington, NC 28411.- A T: 910-686-9114. • F. 910-686-9666. - urvrJi.ecsiimited.com
ECS Carolinas; LLP . ECS Florida, LLC ECS Midwest, LLC - ECS Mid-Atiantic, LLC ECS Southeast, LLG'�'-' ECS Texas, LLP

TABLE OF CONTENTS
' ,0
BACKGROUND INFORMATION......................................................................1
2.0
NPDES PERMIT STATUS.................................................................................6
3.0
EVALUATION OF SILAR OUTFALLS..............................................................9
3.1
Outfall SWO01................................................................................................10
3.2
Outfall SWO02..............................................................................................15•
3.3
Outfall SWO05................................................................................................17
3.4
Outfall SWO10................................................................................................19
3.5
Adjacent Outfalls and Sources.....................................................................20
3.6
Recent Stormwater Sampling Performed by Silar.....................................20
4.0
STORMWATER BMPs AND IMPROVEMENT ALTERNATIVES...............21
5.0
CONCLUSIONS................................................................................................26
6.0
RECOMMENDATIONS.......................................................................27
6.1
Monofill..........................................................................................................27
6.2
Outfall SWO06 and Momentive Duck Pond................................................28
6.3
Silar Outfall SW002.......................................................................................
29
6.4
Compliance with NPDES Permit.................................................................29
6.5
Agency Communication/Meeting with Regulators......................................30
6.6
Septic Drain Field and Outfall SWO08 ................................... .....................30
6.7
Best Management Practices........................................................................
31
6.8
Additional Sampling and Analysis................................................................31
7.0
QUALIFICATIONS OF REPORT..........................................................32
FIGURES
APPENDIX
Figure 1 - Site Location Map
Figure 2 - Storm Water Map Showing Drainage and Outfall Locations
Appendix I - Copy of NPDES Permit
Appendix II - Copy of Compliance Inspection Report (NCDENR)
Appendix III - Copy of Staff Review and Evaluation (NCDENR)
Appendix IV — Sampling/Analytical Results for Silar Outfalls

Evaluation of Stormwater Cutfell Conditions September 10, 2012
Sllar, LLC
333 Neils Eddy Road
Rleolwood, North Cwullns
ECS Project Number 22-17258 A
1.0 BACKGROUND INFORMATION'
The Silar, LLC (Sitar) site is located at 333 Neils Eddy Road in Riegelwood; North Carolina
(Figure 1). The site is comprised of a 6.57 acre parcel of property leased from Oak Bark
Corporation (Oak Bark). Silar leased the current site and began operation on April 22, 2009.
The former Silar Laboratories facility (owned by Wright Chemical Corporation and later
purchased by Oak Bark Corporation) operated in this same location from 1992 until 2009. Silar,
LLC is primarily engaged in the manufacturing of organosilanes� silicones, and adhesion
promoters for use in pharmaceutical, biomedical device, electronics, industrial, and research
and development markets. The Silar manufacturing facility is ISO 9002 certified and capable of
producing gram and kilo -lab scale through multi -ton quantities at the Riegelwood plant site.
The facility is permitted to discharge stormwater to nearby surface waters under North Carolina
Department of Environment & Natural Resources (NCDENR), National Pollution Discharge
Elimination System Permit (NPDES) Permit No. NCS000533. The date of issuance of the Final
NPDES Stormwater Permit was November 1, 2010. The permit allows discharge of stormwater
into receiving waters designated as Livingston Creek (Broadwater Lake), a Class C, SW stream
in the Cape Fear River Basin. The permit authorizes discharge of stormwaterassociated with
industrial activity in accordance with the limitations, monitorings requirements, and other
conditions cited. The permit became effective from the date of issuance in November 2010 and
expires October 31, 2015. The NPDES permit is non -transferable.
The objective of ECS performing this review was to evaluate the general requirements and
compliance status with the NPDES permit, review of historic stormwater analytical results,
inspect the site to observe field conditions relative to each permitted outfall, and assess
reasons for degraded stormwater quality determined by routine monitoring. From this
evaluation, ECS has determined Silar's compliance status with the NPDES permit requirements
and various factors impacting stormwater quality at each outfall: Review of the NPDES permit
identifies three stormwater discharge outfalls (SDOs) in the original permit application. The
NPDES discharge permit issued November 1, 2010 identifies the three outfalls as SW001,
SW002, and SW005. It should be noted that Outfali SWO01 was re -located upstream in the
watershed in the March/April 2012 timeframe. The outfall was relocated by the facility after
discussions with NCDENR. The "new' sample location was selected to minimize runoff and
influence from discharges occurring from the adjacent Oak-Bark-Monofill This will be discussed
in more detail in the ensuing report. This evaluation focused on stormwater conditions related to
each of these outfalls in addition to one other outfall, SW010, which was added to the
monitoring network and is discussed below.
After NCDENR issued the permit in November 2010, the first facility compliance inspection was
not conducted until January 24, 2012. Ms. Linda Willis, a NCDENR Division of Water Quality
(DWQ) Engineer, performed the inspection and identified a fourth un-permitted outfall located:
at the facility. The un-permitted outfall was identified in the Silar 126/Fine Chemicals area of the
site. This outfall was subsequently designated by NCDENR as SW010. As a result of the
inspection, !NCDENR requested Silar to modify the Stormwater Pollution Prevention Plan
(SWP3) to include the additional outfall. The NCDENR Compliance Inspection Report
documenting the inspection further required the new outfall be monitored and sampled per the
conditions of the NPDES permit (See copy of Compliance Inspection Report in Appendix 1).

Evehinfion of Stormwater Qutfaff Conditions
Silar, LLC
333 Neils Eddy Road
Rlegelwood, North Carolina
ECS Prefect Number 22-17256 A
September 10, 2012'
The Compliance Inspection Report further noted that NCDENR had reviewed the required
stormwater data submitted by Silar and benchmark values were found to historically exceed
permit threshold limits at Outfalls SW001, SW002, and SW005. Because of consecutive events
of benchmark value exceedance, Tier I and Ii sampling requirements were triggered for each
outfall. As a result of consecutive events of non-compliance at some outfalls, Tier III sampling
requirements were later triggered and required for Outfall SWO02 and SW005. Tier iII sampling
was triggered by four consecutive sampling events showing benchmark exceedances. At these
two outfalls, Acute Toxicity testing was required in addition to other routine benchmark testing
required by the permit The NCDENR Compliance Inspection report also advised the facility to
evaluate the reasons for non-compliance with stormwater benchmark values and to propose a
remedy for improving the stormwater quality discharge. The State's report advised the facility to
revise the SWP3 to include the Best Management Practices (BMPs) and identify the measures
necessary for improving stormwater quality at the outfalls. The State also suggested that Silar
test the condensate discharge from compressors proximate to the SWO05 outfall where bio-
growth was observed. The State suggested testing the condensate for Chemical Oxygen
Demand (COD).
The NCDENR Compliance Inspection Report noted that sampling/analytical results from
SWO01 shows "very high nitrogen contamination" according to Ms. Linda Willis. The inspector
noted that "excessive and lush green grass was observed growing in the vicinity of SW001°
during the NCDENR compliance inspection. The Compliance inspection Report requested Silar
to "please consider investigating any potential for groundwater contamination that may be
breaking out near the surface. Groundwater contamination may be contributing to high levels of
pollutants at Outfall 00V A potential source of groundwater contamination that may be
contributing to degradation of stormwater noted at Silar SW001 is the Oak Bark Waste Monofill.
The Oak Bark Monofill abuts the Silar southern property boundary and is proximate to the
SW001 Outfall. The Waste Monofill is an earthen containment dike located approximately 200
feet upgradient of. SWO01. The Monofill contains a variety of nitrogen based wastes and metal
sludges that were disposed in the earthen cell according to NCDENR files. A field report
authored by far. Charles Stehman, P.G., former NCDENR Hydrogeological Supervisor, states
"the monofill was constructed to contain industrial process waste materials which include
hexamine and formaldehyde that were previously contained in a remote storage pond Dr.
Stehman further commented that "Wright Corporation is already known to have groundwater
contamination in the plant area" referring to the area adjacent to the monofill. (Record of Waste
Disposal. Permit Application Review, Attached Additional Comments, Wright Corporation,
"Monofill- authored by Dr. Charles Stehman, September 10, 2001). The high concentrations of
nitrogen -bearing compounds detected in stormwater on the:Silar site can be directly correlated
to the waste disposed in the Oak Bark monofill. Groundwater on the Silar property has likely
been impacted as well by the waste monofill. Since the Oak Bark monofill is upgradient of Silar
and impounds over 900,000 gallons of waste water, it is most probable that impacts to Silar
groundwater, surface water, and stormwater are occurring.
Two other offsite potential sources that may be contributing to stormwater quality degradation
on the Silar site are two active chemical production plants known as Momentive Specialty
Chemicals and Oak Bark Corporation. Each facility formulates specialty chemical products with
chemical signatures that are much different from those products produced and handled by
2

Evaluation of Stormwater Outfell Conditions
Sitar, LLC
333 Neils Eddy Road
Riegelwood. North Carolina
ECS Project Number 22-17258 A
September 10, 2012
Sitar. Momentive Specialty Chemicals (formerly Hexion Specialty Chemicals, Inc.)
manufactures formaldehyde by reacting acetone and methanol in an aqueous process.
Momentive also processes anhydrous ammonia to produce, hexamine and other specialty
ketone -formaldehyde resin products. Momentive: also produces formaldehyde derivatives.
These chemical formulations and processes integral to Momentive's operation are not used by
Silar or associated with Silar's processes and operation. Hexamine (a nitrogen based organic)
and formaldehyde are generated, used, and stored in significant quantities on the adjacent
Momentive site. These two compounds are not used in Silar's processes. Because of the
volume of nitrogen -based materials and formaldehyde used on the Momentive site (and their
presence in stormwater draining from Momentive onto the Silar site), it is highly probable that
Momentive's operation is a key source of nitrogen -bearing compounds contributing to
stormwater degradation on the Silar site. This observation is further supported by review of
materials handling data provided by Silar which shows a comparison of the volume of nitrogen -
bearing materials handled by Silar versus that. of Momentive. in that data, Momentive's
hexamine operation is shown to produce between 1,000,000 to 2,000,000 pounds (lbs) of
hexamine per month. Hexamine is a nitrogen -bearing material. In comparison, Silar produces
less than 19 pounds of ammonia per month (also a nitrogen based material) by fugitive
emission. From this data, the volume of nitrogen based material produced by Silar is calculated
to be less than 0.002 % of that produced by Momentive's processes. The volume of nitrogen -
bearing material discharged by Momentive into air, surface waters, wastewater, and stormwater
is infinitely greater than the minimal volume produced by Silar.
The other adjacent chemical production facility potentially impacting stormwater quality on the
Silar site is Oak Bark Corporation. Oak Bark formerly owned the Silar facility prior to Silar's
acquisition of the asset in April of 2009. Oak Bark's manufacturing process has utilized a
formulation of 57°% Zinc Mintrex, 27% Copper Mintrex and 16% Manganese Mintrex in
producing an animal feed additive. Weak acid (Alimet) is reacted with these minerals and
vacuum dried and milled to a specified particle size. Oak Bark operates its facility under a
separate independent stormwater NPDES permit from Momentive and Silar. Both Oak Bark and
Momentive operate under various other State permits including wastewater, recycling, pump
and haul, and land application systems governed by NCDENR. According to the NCDENR files
reviewed by ECS, analytical results of stormwater sampled on the adjacent Momentive and Oak
Bark facilities typically detect nitrogen compounds, formaldehyde, hexamine, copper, zinc and
manganese in stormwater samples from these plants. Each of these compounds are inherent to
present or past chemical production operation on. the two adjacent facilities. These same
compounds are periodically detected in Silar's stormwater. The occurrence is attributed largely
to significant offsite sheetflow and run off entering upon the Silar site from the two adjacent
plantsites. Specifically, the Silar SWO02 and SWO05 Outfall locations are influenced by run-off
from the adjacent sites. Sitar does not use zinc, copper, hexamine, or formaldehyde based
materials in its processes, therefore is not a source for these compounds occurring in site
stormwater. These compounds are indigenous to the processes conducted now or formerly on
the Momentive and Oak Bark sites: Stormwater samples collected from each of the three
adjacent plantsites (Silar, Momentive, and Oak Bark) show the presence of these compounds
exceeding benchmark values. Silar communicated their concern with the impacts of
sheetflow/run off from the adjacent plantsites with NCDENR on March 7, May 31, and October
20, 2011. In letters to NCDENR, Silar notified the State that stormwater sampling was
performed to determine impacts of stormwater sheetilowing off the Momentive site onto the
3

Evaluation of Stormwater Outfall Conditions
Silar, LLC
333 Neils Eddy Road
Riegelwood, North Caroline
ECS Project Number 22-17258 A
September 10, 2012
Silar site in the SWO02 Outfall vicinity. Ofssite upgradient stormwater (sheettlow) from the
Momentive and Oak Bark sites was sampled and compared to stormwater quality at Silar
Outfall SW002. The analytical results of this comparison demonstrated that the upgradient
offsite stormwater entering upon Sitar property into the Silar SWO02 Outfall was non -compliant
with a number of benchmark parameters. Silar's comparison demonstrated two points. First,
that offsite stormwater was entering the Sitar site via' sheetflow from adjacent sites (i.e.
Momentive and Oak Bark). Secondly, the degraded quality of the offsite stormwater (sheetfiow)
from the Momentive and Oak Bark was non-compiiant with NPDES benchmark values and
impacting Sitar stormwater quality. This evaluation concluded that stormwater sheetflow onto
the Sitar site from the Momentive site was degrading stormwater quality particularly at. Slier
Outfall SW002.
The offsite stormwater samples collected by Silar during the 2011 evaluation detected the
following target benchmark values exceeding permit benchmark limits:
• Total Suspended Solids (TSS),
• Chemical Oxygen Demand (COD),
ij•' Biological Oxygen Demand (BOD),
Ammonia (NH3),
• Total Kjeldahl Nitrogen (TKN),
f•; Zinc (Zn),
• Formaldehyde (CH2O),
• Nitrate (NO3),
• Nitrite (NO2),
• Copper (Cu),
• Zinc (Zn),
*j Manganese (Mn)
• , Total Residual Chlorine (TRC)
Methanol and hexamine were also present in detectable concentrations at the time of sampling
though did not exceed benchmark values. Methanol and hexamine are inherent to Momentive's
former feed additive processes. Momentive presently utilizes methanol in bulk quantity and has
capacity to store several thousand gallons in six above ground storage tanks (ASTs) located
approximately 154 LF upgradient of Sitar's SWO02 Outfall. The adjacent Momentive methanol
tank faun is located within the watershed that drains onto Silar's, site and into the SWO02
Outfall.
The above analytical data collected by Silar demonstrates that stormwater runoff from the two
adjacent piantsites are adversely affecting stormwater quality within the Sitar, watershed. This
determination is evident due to the presence of several key signature compounds detected in
stormwater samples that are used or produced historically in high volume by Momentive and
Oak Bark. Signature compounds detected in stormwater samples sheetflowing from the
Momentive site include the nitrogen -bearing compounds total nitrogen, TKN, nitrite, and nitrate.
In addition, formaldehyde was also detected in the samples collected and is a compound that is
known to be associated with Momentive's processes. Other signature compounds detected that
are historically associated with Oak Bark's processes include zinc, copper, and manganese.
4

Evaluation of Stormweter Qutfell Condltlons
Silar, LLC
333 Neils Eddy Road
Aegahvood, North Caroline
ECS ft ect Number 22-17268 A
September 10, 2012
None of the above signature compounds mentioned are inherent to Silar's processes therefore,
it is apparent that the adjacent operations of OaVBark and Momentive are contributing to
degradation of stormwater quality on the Silar site. Silar submitted the findings and analytical
data to NCDENR in October 2011 and. proposed that tl�q__concentratioj3s_of—the_sigriature
compounds detected be deducted from the -total bench ma_rkc values detected in_Silaes SDO
saml�§s. Thiss p sed method wou a actively establish representative values of target
compounds by removing the sample. interference caused from the two adjacent chemical
Xplants. Thisdeduction is logical however, Linda Willis/NCDENR did not concur with the
proposal for adj­u­­stin—benchmark values at SWO02 based on one set of sample results from
the adjacent sites. The DWQ requested Silar to continue with monitoring and reporting as
required �y the NPDES permit. In follow up discussions between ECS and Linda Willis/DWQ on
March 25, 2012 and June 26, 2012 the findings of the NCDENR Compliance Inspection Report
was discussed. Ms. Willis acknowledges that each of the three adjacent facilities sharing a
common campus exhibit stormwater exceedences. She also states that consecutive periods of
non -compliant benchmarks values from each facility may be inter -related. Ms. Willis stated that
stormwater flow between each of these facilities is likely commingled and that it will be
important for each facility to distinguish their representative flow regimes and take measures to
address improvement. Ms. Willis further noted that the campus -wide stormwater issues are -
complex and encouraged a "collaborative effort" among each facility to address improvement of,
stormwater quality: Ms. Willis stated that each facility has been "required equally by DWQ to
evaluate and Implement the use of Best Management Practices (BMPs) to achieve pennif
compliance" with non -compliant outfalls. It was suggested by Ms; Willis that each area of the
facility contributing to stormwater contamination be evaluated thoroughly to determine whether
source controls, operational controls, or physical (structural) controls should be implemented to
improve the quality of stormwater discharging from the facilities. Ms. Willis concluded that
stormwater quality noted at each Silar outfall has been determined to be "non -compliant" during
various periods of sampling, Ms. Willis also raised a concern about whether "ongoing sources"
of contamination are present sincer the analytical trend does not show improvement of
stormwater quality through the permit cycle. She also pointed out that stormwater quality may
perhaps be associated with runoff from roof tops and roof drains. She suggested this be
considered in future evaluations. With regard to a deadline for achieving compliance, the
Compliance Inspection Report authored by Ms. Willis states that "whatever corrective measures
are selected to attain compliance of benchmark values must be implemented with two months
of the facility performing its Tier I inspection'. ECS notes that this time period has since lapsed.
The Tier 1 Inspection is designed to determine wliaf 5ource(sj are causing non -compliant
stormwater conditions for any benchmark parameter at any outfall. Below are the five
requirements specified by the NPDES Permit for the Tier I evaluation:
Tier I Evaluation Requirements
1.
Conduct a stormwater management inspection of the facility within two weeks of
receiving sampling results.
2.
Identify and evaluate possible causes of the benchmark value exceedances
3.
Identify potential and select the specific source controls, operational controls, or
physical improvements to reduce concentrations of the parameters of concern, or to
bring concentrations within the benchmark range.
4. I
Implement the selected actions within two months of this inspection.
5

Evaluation of Stormwater Outfell Conditions
Sllar, UC
333 Neils Eddy Road
RiVetwood, North Carolina
EC5 Pnolect Number 22-17258 A
September 10, 2012
5. Record each instance of'a Tier One response in the SWP3. Include the date and value
of the benchmark exceedance, the inspection date, the personnel conducting the
inspectlon, the selected actions and the date the selected actions were implemented.
Each of the conditions shown above in Tier i should have been addressed by the facility within
two months of the January 24, 2012 Compliance Inspection date. in addition to the Tier I
requirements shown above, Tier ill has since been triggered due to benchmark exceedances
occurring on four consecutive events at Outfalls 002 and 005. Though there has been
communication between Silar and DWQ regarding site stormwater conditions, the NCDENR
files do not reflect that Tier I or Tier iII requirements have been fully met. Subsequent
conversations with Linda Willis confirm that DWQ expects Silar to perform monthly
sampling/monitoring/reporting as required and also submit plans for implementing BMPs to
restore degraded stormwater quality to compliant levels. The requirements of Tier III evaluation
that should be fulfilled include the following;
Tier III Evaluation Requirements
1.
Notify DWQ Regional Supervisor in writing within 30 days of receipt of the fourth
analytical result.
2.
Frequency of monitoring may be increased or ad"usted based on DWQ's review.
3.
Conduct acute toxicity testing on discharges.
4.
Install structural stormwater controls.
5.
Implement other stormwater control measures deemed necessary by DWQ.
In this evaluation, ECS has performed an initial assessment of site stormwater conditions,
potential contributing sources, offsite sheetFlow, and other potential factors that may be
impacting site stormwater quality. The objective of this evaluation was not tailored to satisfying
the Tier I or Tier III requirements, however may aid Silar in identifying sources and factors
contributing to stormwater degradation on the site. This following report diiscusses site
stormwater_conditions_andcomence-,vith ihNP_DI=$permit conditions,
2.0 NPDES PERMIT REVIEW
NPDES Permit
The facility is permitted to discharge stormwater to nearby surface waters under a National
Pollution Discharge Elimination System Permit No. NCS000533. The effective date of the
NPDES Stormwater Permit was November 1, 2010. The permit allows discharge of stormwater
into receiving waters designated as Livingston Creek (Broadwater Lake), a Class C, SW stream
in the Cape Fear River Basin. The permit authorizes discharge of stormwater associated with
industrial activity in accordance with the limitations, monitoring requirements, and other
conditions cited. The permit is in effect from the date of issuance until October 31, 2015. The
permit is also non -transferable to other parties or entities.
The objective of reviewing the NPDES permit was to evaluate the general
requirements/conditions, review stormwater analytical results, and determine the compliance
status with the NPDES permit requirements. Under the original NPDES permit, three
l:.1

Evaluation of Stormweter Outfall Conditions
Slier, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
September 10, 2012
stormwater outfalls were included in the application. They are SW001, SWO02, and SW005.
Two years after issuance of the permit; NCDENR conducted a routine facility compliance
inspection and noted a fourth unpermitted outfall during, the inspection. The outfall, was
identified by DWQ as SW010. It was required that the facility include the outfall in future
monitoring efforts and illustrate it's location on the Site Plan. The permit was reviewed by ECS
to determine. Silar's adherence to the: requirements contained in the permit. Following is a
summary of the review and possible deficiencies noted.
Compliance Evaluation and Determination
The above referenced permit was reviewed to determine adherence to the requirements in the
NPDES permit and to determine if deficiencies are present that should be addressed. The
following items of deficiency were determined during the review. Please refer to the NPDES
permit for a full description of the requirements summarized below. This review also relies of
the information reported in the January 24, 2012 NCDENR Compliance Inspection Report and
subsequent conversations with Ms. Linda Willls/NCDENR Engineer.
In general, the following benchmark parameters have been exceeded as noted from review of
the Silar stormwater monitoring. data. Nitrogen bearing compounds have been associated with
stormwater routinely discharged from SW001, SWO02 and SWO05 dating back to 2000 when
Wright Chemical operated on the site: Metals including zinc and copper (along with the non-
metals; formaldehyde and manganese) have been associated with stormwater discharged from
SWO05 dating back to at least 2006. Below is a table generically illustrating the compounds
typically detected above benchmark values at each Silar outfall:
Table 1
Stormwater Analytical Results by Outfall
OUTFALL
BENCHMARK PARAMETERS EXCEEDED
SW001
NH3,TSS,TKN,NO3+NO2,Cu,Zn
SWO02
B0D,C0D,NH3,TKN,CH20,Cu Zn
SWO05
BOD,COD,TSS,NH3,TKN,CH20,Cu,Zn, H
SW010
Cu,Zn,CH20,Mn
800=81ologleal Oxygen Demand; COD=Chemlcal oxygen Demand; TSS=Total Suspended Solids; TKN=Total KJeldahl
Nitrogen; NO3=Nitrate; NO3+NO2 =1Vitrate plus Nitrite; Cu=CopWCH2o=Fo maidehWe; Zn=Zinc: Mn=Manganese
Nitrogen (and derivatives) are routinely detected in stormwater samples collected form the Sitar
site. Nitrogen is a naturally occurring compound and is in abundant on earth. it is also
associated with agricultural operations; fertilizer production, chemical formulation, and industrial
manufacturing processes. -The relative volume of nitrogen bearing compounds handled by Silar
and released is reported to be less than 226 pounds/year. This volume is infinitely small in
comparison to the several millions of pounds of nitrogen bearing materials handled/released by
the adjacent Momentive plant site. There is a low probability that the ammonia, TKN, and total
nitrogen detected in Silar's stormwater outfall samples are associated entirely with Silar's
processes. The probability is significantly higher that these compounds are associated with
processes, emissions, or waste treatment occurring on adjacent sites, particularly Momentive.
7

Evaluation of Stormwater Outfall Conditions
Siler, UC
333 Neils Eddy Road
Riegelwood North Carolina
ECS Project Number 22-17258 A
September 10, 2012
Below are the deficient NPDES permit conditions noted by ECS's at the time of this review. The
facility may have addressed some or all of the below deficiencies at the time of this report. The
facility should review their files and determine if the following has been adequately addressed:
identified:
1. Part II— Monitoring, Controls, and Limitations for Permitted Discharges
Section A: Stormwater Pollution Prevention Plan
Silar should review its current SWP3 and determine if the following items have been
updated and reflect present site conditions in order to comply with the NPDES permit
conditions:
1. Site Plan
(e) certification of stormwater outfalls/annual evaluations
2. Stormwater Management Plan (SMP)-preparation and submittal
(a) Feasibility Study -review of technical/economical feasibility of BMPs
(b) Secondary Containment -records documenting quality prior to release
(c) BMP Summary -list and summary of all BMP's used or proposed
The SWP3 plan is not required to be submitted to DWQ however, is required to be updated and
maintained by.the facility at allAimes. The facility has prepared and submitted a SWP3 plan -to
NCDENR. The contents should be re-evaluated to, determine that the plans content is current
and accurately reflects site conditions. If structural or non-structural BMP's have been identified
as per No. 2(c) above and accepted by NCDENR, then it is advised that such BMP's be
implemented at this time to restore each outfall location to compliant conditions. If not, then
appropriate BMPs for each outfall must be determined and implemented and documented in an
updated SWP3: Recommendations for selection of appropriate BMPs are provided in Section
6.0 of this report. The following paragraphs address the analytical monitoring deficiencies noted
from our review of the NPDES permit:
Section B: Analytical Monitoring Requirements
Table 3 Benchmark Values for Analytical Monitoring
-Perform Tier III Monitoring due to four consecutive noncompliant events
-Perform Acute Toxicity Testing
-install Structural Stormwater Controls
-(1) develop a strategy for implementing appropriate BMP's
-(2) submit a timetable for incorporating BMP's in SWP3 Plan
A copy of the applicable NPDES permit for the Silar facility is included in Appendix I. A number
of deficiencies noted above were also cited by Linda WiIIWDWQ in the January 24, 2012
Compliance inspection Report. The Compliance Inspection Report states that a SWP3 Plan is
on file with NCDENR however, during ECSs.file review, the SWP3 plan could not be located in
the file search. Regardless, in the Compliance inspection Report, NCDENR also noted that the
facility is "compliant' on the cover page of the report. Further review of the content of the report
is conflicting with this and indicates that the sampling results show consecutive periods of
benchmark values exceeding permit limits. The Compliance Inspection Report states four
consecutive exceedances of benchmark values occurred at SWO02 and SW005, therefore
prompting Tier III acute toxicity testing. DWQ further recommended that Silar "evaluate the site
11

Evaluation of Stomnvater Cutfall Conditions
Silar, LLC
333 Neils Eddy Road
Riegelwood North Carolina:
ECS Project Number 22-17258 A
September 10, 2012
for all potential sources and provide their office with written plans for improvement whether
structural or non-structural." DWQ also required that the evaluation and proposed
improvements be incorporated into the SWP3 and titled as: "Tiered; Responses". DWQ also
indicated that it would provide Silar with an opportunity to resolve the issues before exercising
any Tier IIi Actions including enforcement remedies available to the agency.
Per the NPDES Permit, Section B: Analytical Monitoring Requirements, Table,3, Page 7 of 11,
it states "the benchmark values in Table 3 are not permit limits but should be used as guidelines
for the permittee's Stormwater. Pollution Prevention Plan. Exceedanaes of benchmark values
require the permittee to increase monitoring, increase management actions, increase record
keeping and/or install stormwater Best Management Practices in a tiered program. Page 9 of
11 of the permit states that in regard to Total Maximum Daily Loading (TMDL) additional
monitoring may be required for pollutants of concern and if so, additional BMPs may be
necessary. The permit further states that "if additional BMPs are needed to achieve the
required level of control, the permittee will be required to (1) develop a strategy for
implementing BMPs and (2) submit a timetable for incorporation of those BMPs into the
permitted Stormwater Pollution Prevention Plan".
To date, Silar has not received a Notice of Violation, Notice of Non-compliance, Consent Order,
or other form of enforcement action from NCDENR. Further enforcement action options are
available to DWQ because consecutive samplingW_ periods- exceeding benchmark values have
occurred and the facility has not engaged in implementing all Tier requirements required by the
NPDES permit. The NPDES permit specifies that the four consecutive periods of benchmark
exceedance requires action in accordance with Tier III requirements. The monitoring required
by the NPDES permit is a self -directed initiative. it is the responsibility of the facility to provide
NCDENR with sampling results and report each episode where benchmark values are
exceeded. The facility is required to evaluate the reasons for non -compliant events and
determine the measures necessary to improve stormwater quality to benchmark values, or
better. The facility is also required to implement BMP measures to restore stormwater quality to
benchmark values.
During this period, NCDENR has the statutory authority to seek remedy if the facility fails to
take appropriate or.expeditious action to implement measures that will restore stormwater
quality to compliant levels. Silar has been provided written notice by NCDENR to take steps to
evaluate and determine the measures necessary to restore stormwater quality to benchmark
values. It is ECSs opinion that Silar is presently in a "gray area" with DWQ. Recommendations
for complying with the NPDES permit conditions are provided in Section 6. 0.
3.0 EVALUATION OF StLAR OUTFALLS
An onsite evaluation of drainage regimes and potential factors affecting stormwater quality at
each Silar outfail was performed by ECS. On March 2, 2012 a field reconnaissance was
performed to locate and inspect each Silar stormwater outfall. The purpose of the
reconnaissance was to visually evaluate the physical outfall structures, observe upland
contributing drainage areas, and to observe factors that may be impacting stormwater quality at
the subject outfall locations. Several other nearby and adjacent stormwater outfalls
owned/controlled by Momentive and Oak Banc were also inspected to consider potential
impacts that these outfalls may cause on stormwater quality at the Silar outfalls. Elevation
surveying, sampling, and analytical testing of stormwater was not included in the work scope for
9

Evaluation of Sta mwater Ouffal) Conditions
Sitar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
September 10, 2012
evaluating stormwater conditions at outfalls. It should be noted from our review of available site,
topography (provided by Silar) that the accuracy of plant -wide drainage depicted from the,
survey Is uncertain. Topographic survey data specific to the entire 6.5 acre Sitar site is needed
to determine the specific drainage regimes affecting each outfall on the Silar site. Accurate
topographical data from adjacent plant sites is also needed to determine run-on and run-off
potentially impacting Sitar outfalis.
Drainage patterns observed by ECS during the time of the field reconnaissance differs from the
drainage depicted in the topographic map shown in Figure 2. In the field, offsite sheeiflow is
observed draining onto Silar property from the Momentive Ammonia Storage Area, Special
Projects Area, and Formaldehyde Production Area. Sheetflow from the Momentive site onto the
Silar site is obvious in the vicinity of SW002. As shown in Figure 2, Momentive constructed a
low asphalt curb/berm at the low point of the drainage area in an attempt to deflect errant
sheetflow runoff from their plantsite from entering into Silar's SWO02 outfall. Flow regimes from
the offsite sources are generalized on the Momentive Storm Water Map shown in Figure 2.
Drainage direction and patterns shown by the topography illustrated in the drawing are not
accurate with conditions observed in the field. It is important to understand the stormwater flow
regimes both on the Silar site and: from immediately adjacent sites. Addtional topographic
surveying will be needed to distinguish each facility's flow regime and confirm that sheetflow
from the Momentive and Oak Bark is contributing, to degradation of stormwater quality on the
Sitar site. The topographic survey data relied upon by ECS in this evaluation does not provide
sufficient detail for BMP design. It also does not enable an accurate determination of the extent
of offsite sheetflow from all offsite sources.
Below is summary of the relevant features and.. conditions of each permitted Silar outfall.
Sampling and analytical results for each outfall beginning in March of 2011 through June of
2012 are included in Appendix IV.
3.1 Outfall SW001
Since the time ECS began this stormwater evaluation in February of 2012, Silar re -located
SW001 to a "new° location upstream in the same watershed. The outfall is now presently
located just north of Sitar Drum Storage Area and concrete pad used for empty drum/container
storage. The outfall is located at the end of an outlet pipe conveying sheetflow from drainage
within the Silar Drum Storage watershed area. The new location of the outfall resulted from
discussions between Silar and Linda Willis/NCDENR in the March/April time frame of 2012. The
location of SW001 was moved to this area as it is likely more representative of site stormwater
conditions and less likely to be influenced groundwater from the Oak Bark Monofill experienced
in the former location. NCDENR concurred with Silar'& decision to relocate the outfall. The
coordinates of the new. outfall location have not been provided to ECS_ The new location
appears to be at a topographically higher elevation than the former location of SWO01.
One period of analytical data is available for the new outfalt location since the outfall location
was moved: The analytical data for the May 10, 2012 sampling event collected from the new:
location of SW001 detected three compounds above benchmark thresholds. From this data,
copper was detected at 0.128 mg/L, zinc at 0.448 mg/L and formaldehyde at 132 mg/L. The
thresholds for these compounds are 0.007 mg/L, 0.067mg/I_, and 0.5 mg1L respectively. Also,
the results from this sampling event detected none of the nitrogen bearing compounds (NH3,
10

Evaluation of Sformwator Outfall Conditions
Sitar, LLC
333 Nells Eddy Road
Riegelwood, North Carolina
ECS Rgect Number 22-17268 A
September 10, 2012
TKN, and NO2+NO3)in concentrations above regulatory benchmark values. Additional
forthcoming sampling events and results will be necessary to establish trends associated with
the new outfall location. It is noteworthy that prior to re -location of the outfall, sampling/analysis
of the former SW001 Outfali location routinely detected ammonia, TKN; nitrate + nitrite,
formaldehyde, copper and zinc.
The original location of the SW001 Outfall was permitted as the easternmost outfall in the Silar
stormwater network when the permit was issued in October of 2010. This outfall existed prior to
this date and was originally included as an outfall in Oak Bark's stormwater network. The outfall
was formerly located at 340 19' 69° and 780' 12' 2° and when Silar obtained the NPDES permit in
2010 the outfall was then referenced as the "Sitar Drum Warehouse" outfall. Historic stormwater
monitoring data from the original outfall location since Silar's acquisition has exhibited routine
exceedances of- benchmark values since at least the 1st Quarter 2011. Prior to this date the
outfall discharged non -compliant stormwater under Wright Chemicals, Borden, and
Hexion/Momentive, and Oak Bark's ownership dating back to 2000. The table below gives the
parameters and time periods that benchmark values were exceeded since Silar assumed
permit responsibility 1st Quarter of 2011 :
Table 2
(Former) SW001 Outfall
Parameters
Sample Date
2012
Sample Date
2011
Benchmark Value
Exceeded
Ammonia
1st and 2nd Qtr
1st and 2 Qtr
Yes
TSS
3rd Qtr
Yes
TKN
let and 2nd Qtr
1st and 2nd Qtr
Yes
Nft ate+Nftrtte
1 st and 2nd Otr
1 stand 2nd Qtr
Yes
Copper
1 st Qtr
1 , 2nd, 3rd, and 4th Qtr
Yes
Zinc
2nd Qtr
Yes
BOD
1 st Qtr
Yes
TRC
1 st Qtr
Yes
The drainage basin feeding this former outfall encompassed a total area of 211,220 square feet
(SF). Of that total area, 17,670 SF is reported to be impervious (NCDENR Staff Review and
Evaluation Report, NPDES Stormwater Permit dated June 7, 2010). The former SW001 Outfall
sampling point was a stream channel that discharges through the central interior of the 6.5 acre
lease -hold parcel occupied by Silar. The former outfall had no weir, conduit, pipe, other type of
hardened structure. The sampling location of the former outfall was an arbitrary point in the
stream channel. The stream channel meanders in a sinusoidal manner through a floodplain
draining into the interior portion of the Silar site. This floodplain also receives upland surface
runoff from the Momentive and Oak Bark plant sites. From the former Outfall SW001, the
channel flows approximately 200 ft. northward to the Silar property boundary. From there, it
flows offsite into a floodplain of Mill Creek. The stream bed is a rectangular shaped earthen
charnel approximately 4 feet wide by 1 foot deep. The elevation of the former outfall is
unknown. An estimated elevation of the outfall is ±10 ft. above mean sea level based on a plant
site topographic map prepared by Momentive. Adjacent topography is illustrated by the same
survey to be 21.2 ft. above mean sea level or greater according to a topographic survey
provided by Momentive (dated 10/22108 with Revision 5, dated 1/3/11). Review of the
11

Evaluation of Ston»water 0"I Conditions
Silar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
September 10, 2012
Momentive topographic survey shows surrounding spot elevations on the plantsite campus to
range from 21.2 ft. to 44.5 ft, above sea level. The former Outfall SW001 was considerably
lower than surrounding topography within the watershed and received, stormwater and
groundwater from both onsite and offsite watersheds including those on the adjacent
Momentive and Oak Bark sites.
Upland run-off and drainage (from Momentive and Oak Bark) adjacent to the Sitar Drum
Storage Area feeds the base flow of former Outfall SW001. These upland sources of run-off
include impounded water and stormwater flowing off of the Oak Bark Monofill waste cell into the
former SWO01 watershed. Base flow of the stream where the former SW001 Outfall is located
may be spring -fed by the shallow groundwater upwelling from the shallow water table aquifer.
Groundwater discharging upland of the outfall may account for steady stream flow conditions
observed at the former SWO01 Outfall despite seasonal drought conditions. Seasonal rainfall is,
the primary source of recharge for regional stream base flows and surficial aquifers in the
region. Also, the Sitar Drum Storage Area adjacent to the former SW001.Outfall was formerly a,
process pond operated by Wright Corporation until around 1993. Aerial photography reviewed
by ECS indicates the process pond was approximately one acre in size. From review of sources
of aerial photography, the pond was removed and/or closed sometime prior to 1997.
Groundwater in the vicinity of the Drum Storage Area (former pond area) likely migrates in a
northerly direction toward Mill Creek. Groundwater impacts caused by years of Wright Chemical
Corp. operating the process.pond_in this location may have been affecting stormwater quality
observed at the -former SWO01 Outfall. The subsurface impacts that may have occurred in this
location due to Wright Chemical's operations depend on the history the former industrial pond,
the substances or contaminants contained, and the contaminants released from the pond
during operation.
Another offsite contaminant source that likely affected stormwater quality in the vicinity of the
former Outfall SW001 is the Oak Bark Monofill. This waste cell is an earthen dike impoundment
used to contain process waste generated by Wright Chemical Co. during their operation of
chemical production processes. The waste cell is located less than 150 ft: hydraulically up -
gradient of the former Silar SWO01 Outfall. Impounded waste water stored. on top of the
monofill waste cell is at an elevation of approximately 42.5 ft. above sea level while surrounding
topography is on the order of 23.7 ft. above sea level. The crest of the monofill is at an
elevation of approximately 44.4 ft. above sea level. The waste cell is reported to contain a
volume of approximately 37,000 cubic yards (CY) and was constructed in the 1991 to 1992
timeframe. The waste cell is known to contain industrial` wastes including sludge laden with
hexamine, formaldehyde, nitrogen derivatives, and potentially metal -based waste dredged from
Wright Corporation's process and evaporation ponds (September 24, 2001 NCDENR
Memorandum from Brian Wootton to Kim Colson and September 10, 2001 NCDENR Record of
Waste Disposal Permit Application Review by Bruce Parris). The monofill cell is approximately
500 linear feet (LF) long by 100 LF wide. From crest to toe the structure is approximately 20
feet in structural height. The monofill immediately abuts Sitar's property line. A section of the
structure's northern dike appears to encroach over the property boundary onto the Sitar parcel.
This determination is based on field -survey staking of the property line observed at the time of
ECS's field reconnaissance. The accuracy of the field staking is uncertain.
The monofill waste cell is reported by NCDENR to have been capped with a 36 roil Hypalon
liner. The liner was reportedly used only on side -slopes of the dike and covering over the top of
the structure. A leachate collection system and under -drain was included in the cell design to
dewater sludge materials placed in the impoundment from the process ponds. At the time of
12

Eveluatlon of Stormweter Outfall Conditions
Sitar, LLC
333 Neils Eddy Road
Rl"eMood, North Caroilna
ECS Project Number 22-17258 A
September 10, 2012
ECS's site reconnaissance, the Hypalon liner along the crest of the monofill was observed to be
in very poor condition. The failing liner exhibited brittleness, breaches, tears, punctures, and
penetrations along the extent of northern crest. It is not certain if the leachate collection system
originally installed beneath the monofill is operational today and whether leachate is currently
being treated and/or disposed. The monofill impounds stormwater on the top of the structure
though it was not designed to function as an impoundment structure: At the time of inspection,
the pond pool was estimated to average 2.5 feet deep. Based on this, approximately 935,000
gallons of wastewater is being stored on top of the monofill. Review of plans show the pond
was: originally designed to maintain positive drainage on the top of: the waste cell to prevent
stormwater from impounding on top of the cell. Emergency spillways have been installed by
use of two 12" diameter flexible corrugated plastic slope drains. The slope drains are installed
on the top of the monofill to serve as an over -flow structure to drain the pond during periods of
high -rainfall events. The emergency slope drains are located on the northwest comer of the
monofill top -dike and drape down the face of the slope. Waste water discharging from the cell
via the slope drains is directed to the toe of the dike where it then sheeiflows onto the Silar
lease hold parcel; During high rainfall events, the pond water relieved by the slope drains will
flow into the upland drainage area of the former Silar SWO01 Outfall. In addition, the
impounded stormwater accumulating on top of the monofill is suspected to be seeping through
the earthen dike. This was noted during ECSs visual inspection of the dike structure. A number
of hydraulic seeps were, observed weeping into drainage areas feeding the former Silar Outfall,
SWO01. The hydraulic seeps, were observed "breaking -out" on the Silar lease hold parcel
proximate to the northern toe of the monofill and immediately downgradient of the northwest
comer.
The present-day condition and integrity of the monofill liner is highly questionable. The liner
condition was questioned by Steve WesttNCDENR dating back to June 14, 1999 documented
by a compliance inspection. The inspection was documented in an NPDES Compliance
Inspection Report dated July 20, 1999. in that report, Mr. West noted that "the lined landfill
pond; permitted under W00005699 was observed to have a break in the liner in the
northernmost comer. Wright Corporation should investigate the break immediately and report
the findings to this office. The investigation should be followed up with an assessment of
groundwater impacts." Mr. West also reported that "Wright personnel should keep thorough
records of containment area stormwater disposal".
Mr. West further rioted that 'it is apparent from NPDES stormwater sample results that much
stormwater being discharged through sampled outfells contain significant amounts of
pollutants." (NCDENR Letter dated July 21, 1999 from Steve West to Mike Hanes/Wright
Corporation). ECS also reviewed a 2001 NCDENR Record of Waste Disposal Permit
Application Review ranking the monafill's probability of contaminating groundwater. The
worksheet notes the Situation Rating value to be 11 which corresponds to a Probability of
Contamination as 'very probable" that the monofill will contaminate groundwater. The Situation
Grade on the worksheet assigned a rank "F' with a corresponding Degree of Acceptability
being. "almost certain to be unacceptable".
Considering the above statements prepared by NCDENR, it is highly probable that the quality of
the stormwater in the former Silar SWO01 Outfall location was directly affected by the existence
of the monofill due to run-off, overtopping, and seepage from the waste cell. Of greater concern
is the volume of impounded waste water that sits on top of the monofill. The impounded waste
water (and stormwater) provides a continuous source for seepage through the monofill's
earthen dike on to Silar property. This condition is also likely impacting groundwater quality in
13

Evaluation of Stormwater Outlall Conditions
Silar, LLC
333 Neils Eddy Road
Riegahvood, North Carolina
ECS Protect Number 22-17258 A
September 10, 2012
addition to stormwater quality. on Sitar property. During ECSs March 2012 site inspection,
visible hydraulic seeps were seen located on the Sitar site immediately downgradlent of the
northwest toe of the monofill dike. The hydraulic seeps found on Silar's property are
approximately 75 LF east of Momentive SWO06 Outfall. Further study may be necessary to
assess groundwater impacts that- may have been caused on the Silar sit& by the monofill.
Installation of monitoring wells, piezomeiers, and/or sampling may be necessary near the
property boundary to confirm that the seepage observed originates from the monofill. This
would enable evaluation of local groundwater conditions and impacts caused by the existence
of the waste monofill located on Silar's property boundary. At the time that NCDENR permitted
Wright Corporation to operate the monofill, the DWO Non -Discharge Permit required Wright
Corporation to maintain a "compliance boundary" whereby Wright was to monitor groundwater
conditions at a point located 250 LF from the source (i.e. the monofill). The NCDENR permit
also required Wright to take remedial action if impacts were discovered at that point. A "review
boundary° was to be established at one-half the distance to the compliance boundary and if
impacts were determined at that location, the facility was required to provide a plan for
mitigating and eliminating the impacts prior to reaching; the compliance boundary. From the
regulatory file reviews and public record search conducted by ECS, no evidence was disclosed
to indicate that monitoring occurred. It appears that Wright Corporation and it's successors did;
not perform groundwater assessment to determine impacts caused by years of operating the
waste -sludge monofill. It also appears that no remedial actions and/or remedial measures were)
undertaken by the owner of the facility per review of the data in the public record review. Oak
Bark may now have a responsibility to: implement remedial actions or measures to mitigate or
prevent further impacts to Stormwater and groundwater if it is confirmed that such impacts are
occurring on the Sitar site.
ECS also identified two other sources of potential contamination potentially affecting the Silar
site. Momentive's Outfall SWO06 and the adjacent Momentive "Duck Pond" discharge degraded
nitrogen -rich stormwater onto the Silar lease -hold parcel. From ECS's field reconnaissance
and subsequent review of a boundary survey performed by Sales $ Walker, P.A., it was
determined that the actual location of the Momentive Outfall SWO06 is not on Momentive's
property. The outfall clearly encroaches on Sitar's property and is positioned well inside of the
property boundary of the Sitar lease -hold property boundary (see Figure 2). ECSs review did
not disclose an easement allowing this or other form of operating agreement to indicate that
Momentive has been granted rights to operate the outfall on the Sitar lease -hold parcel. The
Momentive Outfall SWO06 is a 24" diameter corrugated metal pipe (CMP) that hydraulically
connects to the adjacent Momentive retention pond known as the the "Duck Pond." The Duck
Pond collects a significant volume of upland Stormwater drainage from the Momentive plant
site, warehouses, and process areas. The pond then releases the water into the SWO06 Outfall
when a certain elevation is attained. The pond is approximately 550 LF long and ranges from
50 feet wide to 125 feet wide. Impounded water contained in the Duck Pond discharges nearly
continuously through the CMP including times of non -rainfall conditions. A flashboard riser
structure controls flow in the outlet -end of the Duck Pond. The flashboard riser is set at: an
elevation that allows the pond -pool to drain continuously to Oufall SW006. The discharge from
the Duck Pond dumps into a narrow stream channel located on the Silar site. The narrow.
receiving channel traverses through Zone AE floodplains located in the interior of the Sitar
lease -hold parcel (just west of the former Sitar Outfall SWO01 and east of SW002) and
discharges at the northemmost fence -line of the Silar parcel. The point of discharge to the
adjacent floodplains is approximately 200 LF east of Outfall SW005. Stormwater draining from
the Duck Pond onto the Silar site was suspected to commingle with Stormwater at the former
Outfall SW001 location which was located in the floodplains of this channel. This convergence
14

Evaluation of Stormwater Outfall Conditions
Sitar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
September 10, 2012
of the two stormwater flows were suspected to be contributing to degradation of stormwater-
quality noted at the former Silar SWO01 Outfall. Review of the most recent stormwater quality
monitoring results for the Momentive Outfall SWO06 (February 8, 2012) shows that stormwater
quality discharging from this outfall and onto the Silar lease -hold parcel is non -compliant with
NCDENR benchmark values for a number of parameters. The February 8, 2012 sampling
results for Momentive's Outfall SWO06 shows the following parameters exceeding NPDES
benchmark values:
Biological Oxygen Demand (BOD)
• Chemical Oxygen Demand (COD)
• Ammonia (NH3)
• Nitrate + Nitrite Nitrogen (NO3+NO2)
• Total Kjeldahl Nitrogen (TKN)
• Formaldehyde (CH2O),
• Total Copper (Cu)
Review of Momentive's stormwater sampling results for a March 17, 2011 sampling event for
the SWO06 Outfall also detected zinc concentrations: to be non -compliant with NPDES
benchmark limits in addition to the seven parameters listed above. A 'NCDENR Staff Review -
and Evaluation Report NPDES Stormwater, Permit" dated ,tune 9, 2010, states that-NCDENR
acknowledges that the above cited benchmark parameters to have shown a °history of
exeedances dating back to June of 2007°. Based on the long history of Momentive discharging
non-com pliant _ stormwater onto the Silar site, it is probable that stormwater at the former Silar
SWO01 Outfall has been affected by the non -compliant stormwater flow from the Momentive
site. The quality of the non -compliant stormwater from SWO06 is generally characterized as a
nitrogen -rich effluent. Ammonia, TKN, nitrate and nitrite have been routinely detected in
elevated concentrations in the flow from this outfall which drains the adjacent Duck Pond
located on. the Momentive's site. The nitrogen -rich flow from Momentive drains onto Silar's
property and exits through the interior plantsite drainage way of the Silar site. Stormwater
discharging offshe at the northern property fence -line of the Silar site enters into the floodplains
of Mill Creek. Because of this, the potential regulatory liability for Sllar is great since NCDENR
ultimately holds Silar responsible for the quality of water leaving the Silar site at the fenceline.
The boundary map shown in Figure 2 illustrates the location of Momentive's SWO06 Outfall to
be clearly on the Silar lease -hold property. Due to this, Silar does not have control nor ability to
regulate the flow of the non -compliant stormwater piped onto its- property and should address
this issue immediately. Resolution will require cooperation and action by Momentive to re -locate
the pipe and/or re-route the stormwater flow from SWO06 off of Silar's property.
3.2 Outfall SWO02
Outfall SWO02 is on the southwest flank of the Silar permitted stormwater network and is
located at Northing 340 19' 7V and Easting 78012' 8'. The outfall is referred to as the "Silar Lab
and Fine Chemicals Weir" outfall. Stormwater monitoring data collected by Silar from this
Outfall historically shows BOD, COD, ammonia, TKN, formaldehyde, copper, and zinc
concentrations exceeding NPDES benchmark values. The table below gives the parameters
and time periods that benchmark values have been exceeded at SWO02,
15

Evaluation of Stormymter Oaftil Conditions
Sitar, t1C
333 Neils Eddy Road
Riegshvood, North Carolina
ECS Protect Number 22-17258 A
Table 3
SWO02 Outfall
September 10, 2012
Parameter
Sample Date
2012
Sample Date
2011
Benchmark Value
Exceeded
800
March
14 2nd and 3rd CXr
Yes
COD
March May
1st 2nd and 3rd Qtr
Yes
Ammonia
March
1st Qtr
Yes
TKN
March
7 st, 2nd and 3rd Qtr
Yes
Formaldehyde
January, March, April, May,
July -
1st, 2nd, and 3rd Qtr
Yes
Copper
January, March, April, May,
June uly
1 st, 2nd, 3rd, and 4th Qtr
Yes
ZJnc
January, March, April, June,
July
1 st, 2nd, 3rd, and 4th Qtr
Yes
TSS
January, May, June
Yes
TRC
June
Yes
NCDENR reports the drainage basin feeding this outfall is estimated as 24,158 square feet (SF)
with 24,158 SF being impervious (NCDENR- Staff Review and Evaluation Report, NPDES'
Stormwater Permit dated June 7, 2010). Based on our field reconnaissance and review of the
Momentive Storm Water Map, it is our opinion that the volume of stormwater drainage entering
into Outfall SWO02 appears to be significantly greater than the watershed area estimated by
NC©ENR or depicted by .topography shown in the Momentive Storm Water Map (Figure 2).
Sheetflow onto the Silar site from offsite adjacent sites does not appear to be included in the
NCDENR watershed area estimates. The runon and run-off caused by the adjacent plantsite
drainage regimes is likely the single -most greatest factor contributing to the degradation of
stormwater quality noted at Silar outfalls. Review of the Momentive Storm Water Map shows
drainage leaving the Momentive site onto Silar's property. The topographic map does not
accurately represent all offsite flow noted by field observation. Areas including the Momentive
Packaging Warehouse, Ammonia Storage Area, Formaldehyde Production Area, and Special
Projects areas are known to release sheetflow which drains offsite from Momentive onto Silar's
property and collects at the entrance to Sitar's SWO02 Outfall. Because Momentive recognizes
that sheetflow from these areas runs onto Silar's property causing flooding at the SWO02
Outfall, they have made a number of unsuccessful attempts to construct an asphalt diversion
berm in the travelway adjacent to the Formadehye Production plant. The asphalt diversion berm
was constructed by Momentive to divert sheetflow from their Formaldehyde Plant and prevent
flow from entering Silar's SWO02 Outfall.' The small berm, located approximately 75 LF
upgradient of Silar SWO02, has proven to be ineffective in eliminating offsite sheetflow from
Momentive's plant onto the Silar site: Additional hydraulic flow capture/reduction measures or
BMPs are needed in this location in order for Momentive to prevent degraded stormwater
generated on their site from entering upon Silar's site.
The outfall sampling point located at SWO02 is defined by a concrete -weir structure. The weir
receives some upland drainage from the Sitar Plant however receives a significant volume of
sheetflow from the adjacent Momentive plantsite and operations. This outfall discharges to the
16

Evaluation of Stormwater Outfell Conditions
Sitar, UC
333 Neils Eddy Road
Rleph ood, North Carolina
ECS Project Number 22-17258 A
September 10, 2012
Silar floodplain which terminally conveys surface runoff to the northeastern fence line and
eventually to Livingston Creek. The elevation of the outfall was not surveyed for
horizontal/vertical control at the time of this report, however review of a facility topographic
drawing (Momentive Storm Water Map dated 10/22-08) shows a spot elevation proximate to the
outfall at elevation of 23.2 ft. above sea level (asl). The elevation of the weir is likely lower than
the nearby spot elevation. Surrounding topography and upland drainage is not depicted on the
drawing either, thus precluding an accurate estimation of the drainage area contributing to flow
through the SW002 Outfall. The source of drainage feeding this outfall stems from two areas:
(1) the Silar Plant site and (2) runoff from several portions of the adjacent Momentive plant site.
It is our opinion that a significant portion of offsite drainage entering the SWO02 Outfall is from
the following adjacent areas: Momentive Ammonia Storage Area, Momentive Packaging
Warehouse, Momentive Hexamine Warehouse, Momentive Hexamine Production, Momentive
Formaldehyde Production, and Momentive Special Projects Warehouse areas.
Review of the Momentive topographictdrainage map (and based on ECS's field observations), it.
is apparent that stormwater is flowing from the Momentive plant site onto the Sitar lease -hold
parcel. During ECS's visit to the Silar plantsite during a rainfall event, it was observed that
stormwater runoff leaving the Momentive site converges with stormwater on the Silar site at the
confluence of Outfall SW002. Intruding stormwater runoff from the adjacent Momentive plant
site has been a significant concern to Silar since engaging in stormwater monitoring due to the
NPDES Permit issued to Silar in 2010. Silar has assessed this by collecting stormwater
samples from several rainfall events from the up gradient stormwater flowing off the Momentive
site into the collection point of SW002. The analyses of up -gradient samples of both Momentive
and Oak Bark's stormwater has historically detected many benchmark parameters exceeding
threshold values. The analyses demonstrat the following benchmark parameters to be non-
compliant from stormwater on these facilities: TSS, BOD, COD, ammonia, TKN, nitrite + nitrate,
formaldehyde, copper, manganese and zinc:
in comparing the above results with Silar's stormwater sample results from Outfall SW002, it is
noted that TSS, BOD, COD, ammonia, TKN, formaldehyde, copper, and zinc exceed
benchmark values: The NCDENR Compliance Inspection Report states Tier iII sampling
requirements have been triggered due to four consecutive periods of non-compliance. DWQ
specified in the report that Acute Toxicity testing be performed on stormwater from Outfalls
SWO02 and SW005. The Compliance Inspection Report states that 'Silar is not compliant with
the requirements to monthly monitor." From the comparative sampling performed by Silar, we
conclude that it is highly probable that the stormwater quality occurring at Silar Outfall SWO02 is
being greatly degraded by the stormwater being received from upgradient sources on the
Momentive site.
3.3 Outfall SW005
Outfall SW005 is on the northernmost flank of the Silar permitted stormwater network and is
located at Northing 340 19' 76" and Easting 780 12' 6'. The outfall is located on the property line
and is referred to as the "North Side of Silar Plant" outfall. Stormwater monitoring data collected
by Silar from this Outfall historically shows TSS, BOD, COD, ammonia, TKN, copper, zinc, and
pH concentrations exceeding NPDES benchmark values. The table below gives the parameters
and time periods that benchmark values have been exceeded at SWO05:
17

Evaluation of Stormwater Oulfall CondlNons
Sitar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
Table 4
SWO05 Outfall
SePlember 10, 2012
Parameter
Sample Date
2012
Sample Date
2011
Benchmark Value
Exceeded
TSS
1st Qtr
Yes
eOD
Aprif
1 st and 2nd Qtr
Yes
COD
Aril
1 st and 2nd Qtr
Yes
Ammonia
1st Qtr
I Yes
TKN
2nd Qtr
Yes
Copper
January, March, April,
MaX, June Jul
1st, 2nd, 3rd, and 4th Otr
Yes
Zinc
January, March, April,
May, June
1st, 2nd, 3rd, and 4th
Qtr
Yes
Formaldehyde
March, April, May, July
1st and 2nd Qtr
Yes
pH
I
2nd Qtr I
Yes
NCDENR estimates the drainage basin feeding. this outfall to be 43,560 square feet (SF) with
15.119 SF being impervious (NCDENR Staff Review and; Evaluation Report, NPDES
Stormwater Permit dated June 7, 2010). Based on ECSs field reconnaissance and review of the
Momentive Storm Water Map, it appears that drainage from the adjacent Momentive site is also
contributing to stormwater flow entering Silar's Outfall SWO05. Review of the Momentive Stone
Water Map (Figure 2) shows no drainage flowing from the Momentive Tank Containment area
onto the Silar parcel. Based on our field reconnaissance, it is apparent that some volume of
stormwater is running -off from the Momentive aboveground storage tank (AST) area into the
Silar SWO05 watershed. The Momentive ASTs are used for product chemical storage and
these tanks are located inside a secondary. containment wall_ Drainage from the tanks and
containment structure could potentially impact stormwater quality at the Silar SWO05 Outfall.
The accuracy of adjacent topography and direction of run-off illustrated by the Momentive
Storm Water Map is questioned. Additional topographic survey to accurately determine offsite
flow from Momentive and the watershed of the Silar Outfall SWO05 may be warranted. This
would be beneficial to gain a greater understanding of whether offsite sources or flows are
affecting stormwater quality at this Silar outfall location.
Silar's Outfall SWO05 is defined by a concrete weir structure. The weir appears to receive
upland drainage primarily from the Silar Plant including the Liquid Nitrogen Storage Area, and
Hazardous Solvent Storage Tank Area. Stormwater collecting at this conveyance "cascades"
over and down an earthen embankment into the adjacent floodplains of Mill Creek. The
elevation of the outfall' could not be determined at the time of this report. Surrounding
topography and upland drainage is not clearly depicted on the drawing referenced above as no
spot elevations are shown in the drainage area feeding this outfall. Some degree of drainage
from the adjacent Momentive,site appears to be entering into the SWO05 watershed.
According to the NCDENR Compiiance- Inspection Report, Tier 3 sampling requirements have
been triggered due to four consecutive periods of non-compliance. DWO specified in the report
that Acute Toxicity testing be performed on stormwater from Outfall SWO05 (as well as
SW002). The Compliance Inspection report states that °Silar is not compliant with the
requirements to monthly monitor". The report continues by stating that "failure to follow the
18

Ulu
Evaluation of Stormwater Outfall Conditions
Silar, LLC
323 Neils Eddy Road
Riegelwood, NwM Caroline
ECS Project Number 22-17258 A
September 10, 2012
tiered requirements in the future will be addressed (by DWQ) accordingly'. The DWQ further
informs that a follow-up inspection will be performed during the third quarter of this year (2012).
3.4 Outfall SW010
At the time the NPDES Stormwater Permit No. 1 CS000533 was issued to Silar (October 22;
2010), Outfall SW010 did not exist and therefore was not identified by the permit. This outfall
location has since been added to the Silar stormwater monitoring network as a result of the
NCDENR Compliance Inspection conducted by DWQ on January 24, 2012. At that time, Ms.
Linda Willis/DWQ Engineer noted the unpermitted stormwater conveyance on the east side of
the Silar 126 and Fine Chemicals area of the plantsite. This outfall was named at that lime as
"SW010". In this location, DWQ noted that stormwater: run off pooled from the adjacent
surrounding concrete surfacing of the production facility. The stormwater eventually overtopped
the lip of the concrete pad and flowed downslope into the rip -rap lined embankment into the
primary interior drainway of the Silar site. From there, stormwater discharges northward into the
adjacent floodplains of Mill Creek.
At the time of this report, analytical results for 2012 was the only available data for review since
Outfall SWO10 did not exist in 2011. The analytical results, for this outfall have detected
formaldehyde, copper, zinc and manganese exceeding the NCDENR' benchmark values. The
table below gives the parameters and time periods- that benchmark values have been
exceeded:
Table 5
SW010 Outfall
Parameter
Sample Date
Sample Date
Benchmark Value
2012
2011
Exceeded
Formaldehyde
March; May, July
NS
Yeas
March, April, May, June,
NS
Yea
Copper
July
March, April, May, June,
NS
Yes
Zinc
July
NS=Not Sampled ( Outfall did not exist at that time).
From the above table it is apparent that stormwater quality at this regulated outfall in the Silar
126/Fine Chemicals area of the Silar plant exhibits elevated benchmark standards. Due to the
limited history of analytical data from this outfall, it is difficult to conclude what trends are
associated with outfall flow in this location and what reasons may be attributed to the degraded
quality of stormwater exiting the outfall. In comparison to historical analytical results from other
Silar permitted outfalls, the above analytical results for SW010 exhibit similar concentrations
and compounds. Copper, zinc, and formaldehyde are compounds that have typically been
associated with Oak Bark's Mintrex feed additive production process. Formaldehyde and
Hexamine is typically produced by Momentive and associated with production of ketone -
formaldehyde resin products.
19

Evaluation of Stormwater Outfall CondlHons
Slier, LLC
333 Neils Eddy Road
R ftehvood, Noah Caroline
ECS Project Number 22-172W A
September 10, 2012
Outfalls SW001, SWO02 and SWO05 also show non -compliant sampling events from the 2011
time period due to each of these same benchmark parameters listed in the table. It should be
noted that each of the above non -compliant benchmark parameters detected at Silar outfall
locations are also target parameters specked for sampling in Oak Bark's NPDES Stormwater
Permit. Oak Bark is required to sample copper and zinc due to their formulation process of feed
additives which includes these metals. Silar does not use copper or zinc products in it's
processes nor does it generate waste that inherently contain these metals. The only known
source for copper and zinc on the Silar site is pipe work used for conveying liquids in their
processes. Copper and zinc have been historically been detected at each of the other
Momentive and Oak Bark outfall sample locations suggesting that a site -wide source for these
compounds may exist.
A variety of drummed raw and waste materials are stored on occasion outside in the Silar
126/Fine Chemicals area. Measures have been taken to provide permanent roof covering and
containment for the majority of materials handled in this area. Some palletized drums of raw
materials are observed in this area and are exposed to the elements and stormwater however
do not contain products with the metal -bearing compounds described above. The facility has.
taken measures to minimize exposure of these materials to rainfall by providing containment
curbing and constructing shed covers to minimize exposure. The specialty organic products
produced by Silar, raw materials handled, and wastes disposed are not suspected to be
contributing to stormwater quality previously determined by sampling. in the SW010 location.
Forthcoming sampling and analytical results should be reviewed to determine the chemical
signature of contaminants detected and trends.
3.5 Adjacent Outfalls and Sources
Momentive Outfall SWO08 and a septic drain field are two potential sources located adjacent to
the southwest leg of the Silar property. These two additional potential sources may be affecting
Sitar stormwater or groundwater quality. Momentive Outfall .SW008 is. approximately 100 LF
east of the east -end of the Oak Bark Monofill. The septic drain field is immediately adjacent to
the outfall. These two structures are illustrated in Figure 2. Both structures are close to the
property boundary and may possibly encroach upon the Silar lease -hold property. Due to the
accuracy of the drawing and transfer of the boundary overlay, a determination of whether these
structures are on Silar's property could not be made by ECS. Regardless, both the Momentive
Outfall and septic drain field are immediately adjacent and apparently upgradient of Silar's
property. Neither feature was located in the field by ECS at the time of the site reconnaissance.
These features remain potential contaminant sources of both stormwater and groundwater and
could be affecting water quality on the Silar lease -hold parcel. Though not likely a major
contributing source to stormwater degradation on the Silar site, these sources are a greater
concern for potential groundwater impacts:
3.6 Recent Stormwater Sampling Performed by Silar
Sitar recently performed stormwater sampling on their facility that focused on two independent
issues. This included sampling of Stormwater from: 1). the new SWO01 Outfall' location and 2).
sampling of ambient rainwater on the plant site near SW 002 prior to stormwater contact with
ground surfaces. The May 10, 2012 sampling results of the new SW001 Outfall location was
20

Eveluehon of Stormwater Outfall Conditions
Silar, LLC
333 Neils Eddy Road
Riege&ood, North Carolina
ECS Prefect Number 22-17258 A
September 10, 2012
discussed above in Section 3.1- and shows that copper, zinc, and formaldehyde are still present
in stormwater above NPDES benchmark values from the sample collected at this new location.
Nitrogen containing compounds including ammonia, TKN, and nitrate+ nitrite were not detected
in concentrations exceeding NPDES benchmark values: This. may suggest that groundwater
contaminated with nitrogen compounds was the cause for the elevated nitrogen derivatives
detected in stormwater samples collected previously from SW001.
An ambient stormwater sample collected: by Silar on May 101 2012 adjacent to SWO02 was
collected in an open -top container prior to the rainwater contacting ground surfaces. The
objective of collecting the sample in this manner was to collect an ambient rainwater sample
prior to contact with ground surfacing, This would enable evaluation of ambient rainwater falling
upon the site before entering a permitted stormwater conveyance. The laboratory analysis of
the ambient rainwater sample collected adjacent to SWO02 detected copper at 0.013 mg/L, zinc
at 0.074 mg/L and ammonia at 10.0 mg/L. These results exceed the regulatory benchmark
values which are 0.007 mg/L, 0.067 mg/L and 7.2 mg/L respectively. This demonstration
suggest that ambient rainwater failing upon the Silar site near SWO02 during; this stormwater
event contained background copper, zinc, and ammonia concentrations exceeding NPDES
benchmark permit values, Additional sampling would be prudent to determine if this finding
represents plant site conditions inherent to the Silar site and in other permitted outfall locations.
Additional sampling recommendations are discussed in Section 6.8 of this report.
4.0 STORMWATER BMPs AND IMPROVEMENT ALTERNATIVES
There are a. variety of structural and non-structural stormwater management alternatives,
BMPs, and strategies to consider for improving stormwater quality at the facility's non -compliant
outfall locations. Each outfall on the Silar site is unique and exhibits a spectrum of different
contaminants, concentrations, and flow regimes, therefore various alternatives may be
necessary at each outfall to provide effective treatment of stormwater. Examples of some BMP
alternatives and strategies to consider for improvement of overall stormwater quality include:
Table 6
BMP Altematives and Strategies
BMP Method Number
Measure
Type of BMP
BMP i
Elimination and/or Consolidation of
outfalls
Strategy and Structural
BMP 2
Blo-Retention Cells
Structural
BMP 3
plo-Swale s
Structural
BMP 4
Point Source Treatment -Catch Basin
Inserts
Structural
BMP 5
Compost/Bio-Char Barriers and Filter
Strl
Structural
BMP 8
Infiltration Trenches
Structural
BMP 7
Constructed Wetlands
Structural
BMP 8
Hybrid Treatment Methods
Structural
BMP S
Wet Detention Pond
Structural
BMP ID
Dry Detention Pond
Structural
21

Evaluation of Stonnwater Outfall Conditions
Silar, LLC
333 Neils Eddy Road
RiegehvoW, North Caroline
ECS Project Number 22-17256 A
September 10, 2012
A detailed review of the applicability of each BMP shown above has not been undertaken in this
report. There are several BMPs and strategies to consider that may prove to be "best fit"
applications in the case of the Silar site. The following strategies and alternatives are
conceptual and may necessitate more detailed engineering evaluations to arrive at a final
opinion of feasibility and effectiveness prior to selection of a particular BMP. First, Silar will
need to determine it's primary objective and the goal desired with management of stormwater at
each outfall location in order to design a comprehensive management strategy. With our
understanding of site stormwater flow conditions, it Is our opinion that "BMP 1-Elimination
and/or Consolidation of Outfalls" should be considered regardless of the final direction that Silar
takes to achieve compliant stormwater discharges. This particular strategy will require civil
engineering design to configure a pipe system that can accommodate the anticipated flows.
Design of a consolidated piping system may be completed in a short time frame in comparison
to other more complex BMPs listed above. Implementation of the 'Elimination/Consolidation°
strategy will be one of the least intensive capital cost alternatives and should yield great
benefits in return. The NPDES permit allows for elimination and/or consolidation of outfalls that
display substantially identical stormwater quality (see Section D: Monitoring and Records,
Condition 5., Representative Outfall NPDES Permit).
There are a number of benefits associated with implementing BMP Alternative No. 1 shown in
Table 2. The greatest benefit of implementing this strategy is a overall reduction in the number
of regulated sampling. points within the monitoring network. This strategy alone will not
necessarily improve stormwater quality,or restore non -compliant benchmark values to compliant
levels, however this strategy will reduce longterm monitoring efforts required under the NPDES:
permit due to a fewer number of outfalls requiring sampling: Additional evaluation of this
strategy may be necessary to fully demonstrate it's merit. In concept, this strategy may reduce
the present number of regulated outfalls from four to as few as two depending upon design and
anticipated performance obstacles. There are three variations of this strategy that may be
considered. Each variation has applicability to the outfalls displaying non -compliant discharges.
A hybrid design implementing one or more of the above variations may also be considered and
will require input from Silar before a final recommendation can be offered. The variations
related to elimination and/or consolidation of outfalls are described below:
(1) Consolidate flow- this BMP is accomplished by use of piping and connection of multiple
outfalls to reduce overall number of outfalls utiltized. Though it does not ultimately improve
stormwater quality it can reduce or eliminate the number of sampling points,
(2) Eliminate oolnt source flow by structural_ measures- this BMP is accomplished by
installing structural measures in present outfall locations to replace stormwater to surface water
flows with subsurface disposal/treatment measures. This strategy may eliminate or reduce the
number of regulated point source discharges by use of infiltration in the form of trenches, bio-
cells, dry wells, or other types of subsurface adsorption systems to replace presently used
existing point source outfatl locations. By routing stormwater into subsurface treatment/disposal
devices; stormwater point source flow is eliminated and existing regulated outfalls would be
removed from regulation under the NPDES permit.
(3) Re-route mint gource flow to a central non -point source & al location- this BMP is
more of a comprehensive strategy for eliminating several or all point source discharge points
from the site. This strategy is accomplished by piping stormwater to interior areas of thel
plantsite for disposal using subsurface treatment measures. This measure may remove a
number of regulated point source flows by, routing to non -point source subsurface disposal
locations within the plant site. Outfalis incorporated into this strategy would be removed from
regulation under the NPDES permit by may require a Non -Discharge Permit by DWO.
22

Evaluation of Sto mwater OWN Conditions
Sitar, LLC
323 Neils Eddy Road
Riegelwood, North Caroline
ECS Protect Number 22-17258 A
September 10, 2012
By implementing BMP 1 above, consolidating, stormwater flow from the three Silar NPDES
outfalls (SWO05 SWO10, and SWO02) could be potentially accomplished by hard -piping the
outfalls together and connecting to a central conveyance system with one terminal outfall. If so,
then two regulated outfalls would be eliminated from the present monitoring network and a
resulting single outfall would sustain the flow volumes generated by consolidation of the three
outfalls. Implementation of this alternative would result in a substantial reduction in long term
sampling efforts and analytical costs. At the single outfall. created by this strategy, a point
source treatment measure must likely be incorporated to meet, NPDES discharge benchmark
limits. The cost to construct a consolidated stormwater flow system will depend largely on the
how the pipeline is engineered and the measures required to support the foundation system for
the pipe network. Also, the type of pipe, size, and length of the pipe required would also have
to be considered in the design evaluation phase as well as existing construction obstacles and
hazards on the site. The cost of constructing a system like this will depend on the final design,
however to give an order of magnitude estimate of cost, we assume the following:
• Three existing outfalls will be connected using 6" diameter PVC Sch 40 pipe;
300 feet of PVC pipe will be needed;
-• Small concrete piers on 10 foot spacings will support the pipe with metal strapping:
fasteners: no pilings or deep foundation support systems will be required;
• No catch basins or drop inlets will be added;
• No trenching, excavation, cut fill, or site grading will be required; and
• Existing weirs can be easily modified to accept flow from the pipe network.
Based on the above scenario, using a pipe network to consolidate the flow of the three outfalls
mentioned, a budgetary cost. of $25,000 to $28,000 is estimated. Modification to the present
NPDES permitted system will require approval by NCDENR and modification of the NPDES
permit prior to implementation. Consolidation of flow may require coupling with an additional
BMP(s) in order to treat the effluent and attain a compliant stormwater discharge. Point source
measures such as those described below or other BMPs such as bio-swales, bio-retention,
trenches, filter strips, and/or wetland treatment structures may also be needed to provide
adequate treatment. The additional cost of such structures will have to be considered and
factored into the overall cost of this strategy.
If consolidation of flow using an interconnected pipe system proves unfavorable, Silar should
consider using point source treatment BMPs at each of the four existing non -compliant outfall
locations. An example of low -technology effective BMP structural measure is a prefabricated
catch basin filter insert such as the CleanWayTm Storm CleanTm Catch Basin Filtration Insert.
The insert combined with MetalZorbTm Filtration Media fills void space to form a compact and
simple point source removal method. Technical papers/data produced by the manufacturer for
this structural BMP show it to be effective for variety of contaminants including suspended
solids, organics; and metals. The StarmCleanTm Catch Basin Filter is constructed of a rigid
three piece poly -system including a rigid filter strainer, MetalZorbTM Filter Media, and the
support structure insert. The StormCleanTm system is available in standard catch basin sizes
allowing rapid installation in typical catch basins using the grate to hold the system in place.
Stormwater flowing into the catch basin is filtered through the proprietary MetalZorbTm filter -
sponge media. Depending on the volume of flow and contaminant concentrations, the filler
media requires periodic maintenance and replenishment. Periodic analytical testing is
necessary to•determine when 'breakthrough" occurs with the filter media. The system has been
demonstrated to be highly effective in a variety of industrial stormwater point source removal
applications that produce high volume wastewaters laden with a variety of metal compounds.
The cost of a StormCleanT" Standard Square C/W Insert (item SQ24FSM-II) filled with
23

l=valuatlon of Stormwater Outfall Conditions
Sitar, LL C
333 Neils Eddy Road
Rlege&ood, North Carolina
ECS Project Number22-17258 A
September 10, 2012
MetalZorbl filter media and: ready to install cost approximately $1600/outfall plus labor for
installation. An existing catch basin is required and not included in the cost. The MetalZorbTm
Filter media can be ordered in bulk quantities of up to 100 cubic feet (CF) or smaller quantities
as well. The cost of the MetalZorb"m media is the order of $375/cubic foot To completely outfit
four outfalls with the StormCleanT'" Catch Basin Inserts would cost approximately $6500 to
$7000 plus installation and fabrication of a 2 ft. x 3 ft. catch basin if needed. The total estimated
capital cost for implementing this structural point source treatment measure including the
addition of four catch basins at each of the four outfall locations is estimated to be on the order
of $15,000 to- $20,000. This= cost does not include civil design, engineering, or permitting
required to outfit existing catch basins. Disposal of spent MetalZorbTM filter media is not
included in the estimated capital cost.
There are other filter media available such as Mirimichi's Bio-Char® that will provide similar
treatment functions as the MetalZorbTm media. Bio-charO is an organic carbon filter media in
granular form. The granular carbon media may be used in inserts in a similar manner as the
StormClean TM system. The effectiveness and longevity of the Bio-Char® media would also
require pilot testing to determine the effectiveness of this product in this particular application.
The cost of the filter media is approximately $4501 CY. Technical papers produced by Mlrimichi!
indicate that the filter media has been effective in removing suspended solids, particulates,
dissolved organics including chlorinated/hydrocarbon contaminants, glycol, and heavy metals.
Prior to implementing any point source. treatment measure, ECS recommends that a pilot study
or treatability study first be undertaken at the 'worst case" outfall to evaluate the effectiveness
of the filter media and point source BMP measure being considered. If the treatability study
concludes than the StormCleanT"4 or Bio-CharQD filtration system effectively reduces the
contaminant loads to below benchmark values, then it would be reasonable to implement this
point source structural BMP at each of the four outfall locations. The long term cost associated
with replacement/replenishmeht of the MetalZorbTm media will be determined by monitoring.
Each catch basin insert holds approximately 1 CF of filter media. The MetalZorbTm media cost
approximately $375/CF and the longevity. of the media before -change -out will depend on flow
volume and contaminant concentrations.
Concurrent with the treatability study (and prior to implementing structural BMPs to improve.
stormwater discharge quality), it is recommended that further evaluation be undertaken to
define the contaminant sources responsible for each benchmark parameter detected at Silar
outfall locations during monitoring. A comprehensive evaluation 'of both onsite and offslte
sources must be included in the determination of contaminant sources. This is necessary to.
determine if ongoing sources are present that are contributing to degradation of stormwater
quality exhibited at Silar outfalls. The evaluation would consider:
• Identification of all raw materials used, stored, produced; and disposed from onsite and
offsite sources;
• Identification of all waste products generated, stored, or disposed at onsite and offsite
sources;
• Review of onsite and offsite discrete and indiscrete wastewater sources or discharges;
• Review of offsite discrete and indiscrete wastewater discharges;
• Review of all onsite and adjacent known waste sources including those permitted and
unpermitted;
• Review of all onsite and offsite hazardous materials spill reports;
10 Review of adjacent plantsite SWP3 Plans and NPDES sampling results; and
24

Evaluation of Stormwater Outfall Conditions
Silar, LLC
333 Neils Eddy Road
Riegelwood, Narth Carolina
ECS Project Number 22-17258 A
September 10, 2012
• Determination of adequacy of existing site topographic mapping on and adjacent to the
Sitar lease -hold property
A table of other possible BMPs that could be utilized to improve stormwater quality at the four
Sitar outfalls is shown below. It is anticipated that some measures shown may be effective in
achieving compliant stormwater discharge but will result in greater capital cost, greater long
term maintenance cost, greater monitoring cost, greater difficulty in constructing; difficulty
achieving regulatory acceptance, and will experience considerable engineering challenges. The
BMP measures and strategies identified below are generic in nature and are not recommended
without performing adequate feasibility studies, hydraulic modeling, detailed hydrologic
analysis, surveying; or engineering evaluation to determine specific site conditions and design
barriers affecting the use of such BMPson this site. The technologies selected by Sitar to
achieve outfall compliance should. depend on the type of contaminants present, concentrations,
hydraulic flow regimes characteristic- of each of the outfall, capital costs, operation and
maintenance costs, and cost benefit realized for constructing the system.
The following table of BMP's and strategies may be applicable to Sitar in developing a
comprehensive strategy for improving stormwater quality at regulated outfalls. The below table
identities various BMPs listed from Table 2 above for application at each outfall identified:
Table 7
Specific BMPs by Outfall
OUTFALL
FLOW
BENCHMARK PARAMETERS
TYPICALLY EXCEEDED
APPLICABLE
BMP METHOD
SWO01
High
NH3,TSS,TKN,NO3+NO2,Cu,Zn
1,2,3,4,5,6,7,8,9
SWO02
High
BOD,COD,NH3,TKN,CH2O,Cu,Zn
1,2,4,6,9
SW005
Moderate
BOD,COD,TSS,NH3,TKN,CH20,Cu,Zn, H
1,2,4,6,6,9
S W010
Low
CU,Zn,CH2O
12,4,6,9
BOD=Biological Oxygen Demand; COD=Chemical Oxygen Demand; TSS=Total Suspended Solids; TKN=Total K]eldahl Nitrogen;
NO3=Nitrate; NO3+NO2=Nitrate plus Nitrite; Cu=CopperCH2O=Formaldehyde; Zn=Zinc; Mn-Manganese
The use of bto-swales, bio-retention ponds and other BMPs identified above have been
universally demonstrated to be effective best management practices that wIIU improve
stormwater quality if properly designed. Additional evaluation would required to determine if
these technologies could be applicable to improving the specific degraded stormwater noted at
this site. Measures such as bio-retention are particularly effective for nitrogen reduction which is
problematic at three of the Sitar outfall locations. The capital cost for a two -bay bio-retention
pond is expected to be considerably greater than other measures suggested. Based on our
experience with constructing BMPs including bio-retention and multi -cell treatment ponds of the
size and caliber necessary for improving stormwater quality on the Sitar site, it is highly
probable that the capital cost of such measures would be significantly greater than the cost of
BMP 1 and 4 suggested for consideration. Because of the relative low capital cost to implement
point source treatment systems and their near immediate results in water quality improvement,
these are considered to be effective BMPs in this application. With our present knowledge and
understanding of the site conditions and stormwater flow regimes at the Sitar site, we
recommend that priority consideration be given to BMP 1 and 4 strategies with the goal being to
improve stormwater quality at each outfall to compliant NPDES benchmark values.
25

Evaluation of Stormweter OutfaN Conditions
Sitar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
5.0 CONCLUSIONS
September 10, 2012
There are many factors to consider when evaluating stormwater quality at the Sitar site. The
stormwater flow regimes of onsite and offslte drainage critically affects stormwater quality noted
at site outfalls. Historical data reveals Outfalls SWO01, SWO02, SWO05 and SW010 to have
displayed benchmark value exceedances for a number of required monitoring parameters.
Offsite stormwater flow from adjacent operations at the Momentive and Oak Bark sites appear
to be contributing to some degree of stormwater degradation noted in Silar Outfall SWC01
(former and present outfall location), SWO02, SWO05, and possibly SWO10. Offsite processes
at the adjacent MomenWe plant site including wastewater treatment, cooling towers, scrubber
emissions, and/or operation of lagoons, ponds, and waste water treatment systems may also
be contributing in part to degradedstormwater quality observed at these outfalls as well.
Additional topographic survey data on the Sitar site is necessary to accurately determine run-on
and run-off regimes and the impacts of sheet flow on each Sitar outfall locations. Tier II
requirements have been triggered at each of the Sitar outfalls therefore monthly monitoring is.
required. Four consecutive events of benchmark value exceedances at SWO02 and MOD&
have triggered Tier III sampling requirements at these locations. The requirements for Tier III
sampling include adding Acute Toxicity testing; installing structural stormwater controls;
developing a strategy for implementing BMPs; submitting a timetable- for incorporating: the
BMPs into the SWP3; and implement other measures deemed necessary. Sitar has been
notified by DWQ to comply with the Tier III sampling requirements mentioned above and to
amend the SWP3 yearly with all amendments clearly documented.
Several adjacent sources of groundwater and stormwater contamination associated with
Momentive's and Oak Bark's manufacturing processes, physical plants, waste treatment, waste
storage/disposal structures, cooling towers, scrubbers, and grounds present probable affects
on stormwater quality noted at Sitar Outfalls. Momentive's Outfall SWO06 is determined to be
located on the Sitar lease -hold parcel. Their outfall discharges dissolved nitrogen -rich effluent;
metals, and formaldehyde daily into and onto Sitar's watersheds and: watercourses. The
Momentive SWO06 outfall relieves the Duck Pond which is serves as a holding pond containing
nitrogen -rich runoff from various areas of the Momentive plantsite and processes. Momentive
Outfall SWO06 demonstrates a history of non -compliant effluent discharge for ammonia, TKN,
nitrate+nitrite, SOD, COD, formaldehyde, copper, and zinc. The location of Momentive's Outfall
SWO06 on Silar's site is very problematic. This occurrence creates significant environmental
risk and regulatory exposure to Sitar. Ultimately, Sitar is responsible for stormwater quality
discharging through its outfalls. This source of non -compliant wastewater received from SW006'
is a contributing source to water quality degradation on the Sitar site. The Duck Pond stores
stormwater that is in contact with process materials, process waters, and products from the
Momentive production facility. Momentive's should cease discharge of wastewater onto Sitar's
property immediately. This is discussed further in Section 6.0 Recommendations.
There are several other adjacent sources of contamination from adjoining sites that may be
affecting Silar's stormwater quality. The Oak Bark Monofill is an earthen waste cell located
immediately upgradient and abutting, the Sitar, southern property boundary. The monofill
contains industrial sludges, metal waste, and nitrogen -rich waste that was generated by Wright
Chemical Corporation when that facility was in operation. The monofrll was constructed with a
Hypalon liner however, the liner has since been severely compromised. The liner is not
26

Evaluation of Storrnwater Outfall Conditions
Stlar, LLC
333 Neils Eddy Road
Mageiwood, North Carolina
ECS Project Number 22-17258 A
September 10, 2012
adequately functioning to contain waste and wastewater in the cell. 'in some locations, the dike
alignment of the waste monofill appears to encroach onto Silar property. The ronofill is located
immediately upgradient of Sitar's property boundary and leaches effluent into the Sitar
watershed. Hydraulic seeps from the monofill have been documented by visual inspections
conducted along the toe of the dike structure. The seeps are located on Sitar's property and
indicate that hydraulic pressure inside the waste structure is being released through the earthen
dike. Iron -rich seeps along the dike toe are evidence that seepage from the monofill is
occurring. Impacts to shallow groundwater beneath the monofill, downgradient, and adjacent to
the monofill is highly probable. It is estimated that over 900,000 gallons: of
stormwater/wastewater is presently stored on top of the monofill even though the waste cell
was not designed to impound wastewater. This condition presents an imminent hazard for
structural failure and threat to the Sitar site. In the event that the monofill dike failed or were
severely breached, it would likely release the waste contents onto Sitar property. In addition,
slope drains installed on top of the monofill allow the release of stormwater/wastewater from the
pond during high rain -fall events. The slope drains direct water from the monofill pond down the
face of the dike where it sheetflows onto the Silar site. 'J,
Also; during ECS's evaluation it was noted that Momentive's Outfall SWO08 is located near the
Sitar southeastern property boundary. Based on the survey plat referenced, this outfall may be;
located on Sitar controlled property. At a minimum, the outfall is located immediately proximate,
to the Sitar property boundary and stormwater may drain onto Sitar property. Further evaluation
and a confirmation survey of the outfall will be necessary to confirm its location with respect to
Sitar's property boundary. Review of the topographic survey for the site indicates the outfall is
likely discharging stormwater onto the Sitar site. In this same location is another environmental
concern; a septic drain field is located proximate to the property line and illustrated on the
drawing referenced above. Because of the proximity of the drain field to the Sitar property
boundary, it is possible the drain encroaches onto Sitar property. Further evaluation of the
purpose and use of the drain field should be undertaken to determine if the feature is impacting
Sitar stormwater or groundwater quality.
6.0 RECOMMENDATIONS'
The following recommendations are provided to give Silar guidance in managing the various
factors that may be affecting stormwater quality on the site:
6.1 Monoflll
Impounded water ontop of the monofill presently is directed by corrugated plastic slope drains
to drain the pond level and discharge the water onto Sitar property. The slope drains should be
relocated: and re -directed to prevent discharge of any pond water onto Sitar's property.
Drainage/sheetflow running off the slopes of the monofill also discharge onto Silar property.
The run off should be collected and/or re -directed to prevent impacts to Sitar's property,
groundwater, surface water, and stormwater. Remedial measures should also be implemented
at the monofill to reduce leaching and migration of contaminants contained within the structure.
Seeps originating from the monofill and discharging onto Sitar property should be sampled and
analyzed to determine if impacts are occurring. If so, measures should be taken by Oak Bark to
collect and prevent leachate from seeping onto the Sitar site and impacting water quality.
As recommended by NCDENR, additional assessment of groundwater conditions and
groundwater quality should be considered adjacent to the north side of the monofill, particularly
27

Evaluation of Stormwater Outfall Conditions
Silar, LLC
333 Neils Eddy Road
Riegelwood, North Carolina
ECS Project Number 22-17258 A
September 10, 2012
in the downgradient direction on Silar property. This may be necessary to determine the effects
of leachate discharging,from the monofill onto Silar's property and the affect on stormwater and
groundwater. Degraded. stormwater has been observed downgradient of the monofill at Silar's
former SWO01 Outfall location. Shallow monitoring wells and piezometers located between the
monofill and the former Silar SWO01 Outfall would enable assessment of groundwater quality,
determination of direction of groundwater flow, and establish the relationship of groundwater
and stormwater in the area downgradient from the monofill.
Evidence of hydraulic seepage from the monofill onto Silar's. property suggest the monofll's
liner system is not functioning properly. Proper closure of the monofill waste: cell may not have
occurred at the time the structure was capped and closed. Closure to meet present-day
regulatory requirements may be necessary including: dismantling or repairlreplacing the
Hypalon liner and cap. The! use of slurry walls. recovery wells, or. other remedial treatment
measures may be necessary to eliminate the ongoing effects of leachate seeping from the
waste cell onto the Silar site.
Other measures that should be considered include the following:
• Perform closure of the monofill to meet current regulatory standards (includes re -lining
and/or re -capping the waste cell; OR removal:and dismantlement/disposal of the waste
'in an approvetf Si.fbtide C landfill;
Rey -construct drainage on the crown; of the monofill structure to maintain positive
drainage that is confined to Oak Bark property;
• Capture/remove/dispose accumulated stormwater that collects on top of the monofill to
prevent future impacts to the Silar site;
• Construct diversion berms at toe of the' monofill to prevent offsite runoff from entering
upon the Silar site;
• If groundwater has been impacted on the Silar site, constrict a sub -terrain slurry wall
and groundwater recovery system to prevent offsite migration of any contaminant
plume leaching from the monofill onto the Sitar site; ands
+' Survey the toe of the dike to determine if the monofill encroaches onto the Silar lease
hold property.
6.2 Outfall SWO06 and Momentive Duck Pond
The Momentive Outfall SWO06 is presently designed: and constructed to discharge stormwater
and surface water on a, daily basis onto Silar property. The water being discharged has been
determined: to be non -compliant with State stormwater standards. The structure is located
within the Silar property boundary and should be re -located to operate upon Momentive owned
property. The storage: capacity of the Duck Pond should ° be evaluated for adequacy- and
available freeboard during routine storm events. Increasing the height of°diking surroundiing.the
Duck Pond may be necessary to prevent overtopping of nitrogen -rich water onto Silar property,
during routine and episodic storm events. It is recommended.that corrective action be taken
immediately to cease the discharge of the non -compliant wastewater onto Silar's property.
The most obvious remedy is to relocate the discharge pipe off of the Silar lease -hold parcel and.
onto Momentive owned/controlled property. Rerouting .the flow back onto the Momentive site
will remove the non -compliant stormwater discharge that is presently entering onto Silar's
property and: watercourses. The. source of the non -compliant flow is stormwater and surface
water contained in the Duck Pond. The nitrogen -rich water is then piped to the SWO06 outfall.
28

Evaluation of Starmwater OuftY Conditions
Silar, LLC
333 Neils Eddy Road
RlegeAvaod, North Carolina
ECS Pmject Number 22-17258 A
September 10, 2012
The Duck Pond maintains &-minimal volume of stage -storage. and: is subject to overtopping.
The freeboard noted in the Duck Pond: (less than 18"), likely- provides inadequate storage to
contain the volume of nitrogen -rich stormwater yielded '-during high intensity rainfall events. In
this: case; the Duck: Pond will over -top and flood Silar property. Even during normal intensity
rainfall events (25 year-24 hour intensity rainfalls), the lack of storage and retention remains a
concern. A potential solution is to inerease'the heig ht of diking around the perimeter of the
Duck Pond. Thi&will provide additional free -board and onsite containment during storm events.
NCDENR' should be contacted concerning; the present manner in which the Duck Pond is
operating and their input considered in developing a design solution: If the Duck: Pond is a
permitted structure under NCDENR's Non -Discharge permit program, then the permit
conditions should be evaluated and will dictate the manner in which the pond is to be designed
and operated.
6.3 Silar Outrall SWO02
Stormwater discharging from the Momentive plantsite into SWO02 on Silar's site should be re-
routed and/or re -located immediately. Structuralmethods and BMPs to control the flow. and
prevent ongoing offsite impacts due to sheetflow from Momentive should be evaluated- ands
implemented. Momentive has made previous attempts to construct an asphalt diversion berm to
defiect.sheetflow away from the Silar:Outfall SWO02 but this measure has proven inadequate.
Momentive should assume- responsibility and undertake all engineering, study, and design
necessary measures that provide a runoff control system that prevents degradation of Silar's
stormwater quality at this location. The need for a cooperative effort between Silar and
Momentive seems apparent in order to develop an expeditious solution. in the event that an
amicable solution can not be reached between both parties; Silar should consider implementing
its -own BMPs. or structural measures that --will achieve a compliant stormwater discharge from
this outfall. It is extremely important that a solution be reached quickly by Sitar to rectify the
non -compliant discharge of stormwater that is presently occurring at this outfall. It is further
recommended that a dialogue be maintained with NCDENR to apprise the agency of progress
toward development of a solution. The agency should participate in the discussions as permit
modifications will be required if any change_ s are made to the presentoutfall systems on _either
Silar or Momentive's.property.
6.4 Compliance with NPDES Penmlt
In addition to the above, Silar's SWP3 should be reviewed annually to assure the plan is up to
date and reflects the stormwater- management strategies implemented by the facility.. The
NPDES permit should be reviewed to assure that Tier III sampling is being implemented as
requested by DWQ-.and that an evaluation is underway to determine the causes of stormwater
degradation at outfalls noted. In response to DWQ, BMP measures necessary to restore storm
water quality to benchmark values, and a time table for implementation, should be submitted to
DWQ for review and acceptance. Roof drains in the Zilar 126/Fine Chemicals area may also
need to be evaluated and tested to determine if discharges from these structures: are
contributing to stormwater degradation in the SW010 Qutfall location, in addition, air scrubbers,
cooling towers, air strippers, and baghouse's both onsite and offsite should be evaluated to
determine if stormwater is being affected by the emissions from. these structures. This would
include evaluation for the presence of nitrogen bearing compounds, copper, zinc, and
formaldehyde in air emissions from such potential sources. The discharge from any other waste
treatment systems including wastewater systems and groundwater remediation systems should
29

Evaluation of 5tormwater 4utfall Conditions
Silar, LLC
333 Neils Eddy Road
Rlegehrood, North Carolina
ECS Project Number 22-17258 A
September 10, 2012
also be evaluated to determined if discharges are affecting site stormwater quality. Other
sources that should be evaluated to assist in determining the reasons for the detection of
copper and zinc include process piping, metalwork, and pipe racks used on the Sitar site. The
piping network should be evaluated to determine the type of pipe used, the condition, and
whether leaching is occurring from contact with acidic water sources coming from onsite or
either offske sources.
Sampling is an integral part of complying with the NPDES Permit. Quality control, adherence to
sampling protocol, sample handling, and sample conveyance to the laboratory is governed by
EPA methods and protocols and important in assuring that samples are not compromised in the
process. It is critical that the samples collected and analyzed represent site conditions. Silar is
presently relying upon Momentive through a service agreement to collect their stormwater
outfall samples and subsequently for generating laboratory results. Lab reports are issued in
Momentive's name and reference the results of Sitar's outfalis and Momenttve's outfalls on the
same report. It is advisable in light of recent interest of the site by various regulatory agencies,
that Silar generate their data independent of Momentive. if a qualified third party is utilized for
sample collection, that party should be unrelated to the environmental issues that presently may
have a connection with Momentive or Oak Bark. Silar's legal counsel is more qualified to
elaborate on this point and should be consulted for direction.
6.5 Agency Communication/Meeting with Regulators
Silar is presently not compliant with all terms and conditions of the NPDES permit. Though no
formal enforcement action has, been initiated by DWQ, to date, there are regulatory options
available to DWQ (and EPA) that could greatly accelerate Silar's schedule in completing the
evaluative actions described above. To prevent an agency directed action, it is recommended
that a meeting be scheduled in the near -term with Ms. Linda Lewis/DWQ to discuss the status
of the facility with respect to the NPDES permit. It is advised that the meeting be coordinated in
the very near future to demonstrate that Silar is committed in their effort to comply with the
agency's earlier request. As stated in Section 6.3 above, implementation of new, SMPs: or
changes to the existing stormwater management system will require modification of the existing
NPDES permit. NCDENR' should be apprised of proposed plans or intentions to modify any
component of the presently permitted system in advance of doing: so.
6.6 Septic Drain Field and Outfall SW008
ECS recommends that both the septic drain field and SWO08 Outfall be located by a licensed
surveyor with respect to the Silar property boundary. A determination should also be made by
the surveyor whether either structure encroaches onto Silar property. ECS also recommends
that analytical data for SW008 be acquired and reviewed to determine the quality of stormwater
being discharged at this outfall location. If non -compliant discharge of stormwater is noted from
the data review, further evaluation may be necessary to determine the need and type of remedy
to eliminate future discharge. The direction of stormwater flow leaving the outfall is unknown at -
this time and should be also be determined.
The septic drain field identified at the site is a recognized environmental condition (REC) that
could impact groundwater, soil, or stormwater on the Sitar site. ECS recommends further
evaluation of this structure. The owner of the system should be confirmed and details
concerning the typical use of the system should be ascertained. The type of system, design
30

Evaluedon of Stormweter Outfall Conditions
Silar, LLC
333 Neils Eddy Road
Riegelwood, North CaraUna
ECS Project Number 22-17258 A
September 10, 2012
details, schematics, drawings, waste character and typical flow volumes should be determined.
Depending on the findings, additional evaluation or assessment including soil; stormwater, and
groundwater sampling may be necessary, to determine if the feature presents signiflicant
environmental risk to the Silar property.
6.7 Beat Management Practices
it is recommended that Silar evaluate and consider 8MP's for managing stormwater at each
outfall location exhibiting benchmark exceedances. Silar should consider in it's development of
a comprehensive management strategy whether to address non -compliant outfalls on a point
source basis using structural BMP's or whether to develop a more comprehensive approach
that would utilize a centrally located BMP such as a bio-retention pond designed to contain all
plantsite stormwater. Regardless of the BMP strategy or structures proposed, additional
topographic survey of the Silar watershed is necessary to accurately determine stormwater run-
on and run-off regimes affecting stormwater quality on the Silar site: In the course: of this
process, it is advised that Silar engage in an open dialogue with DWQ to inform the agency of
the specific steps and a time table that will be undertaken to manage the stormwater program.
Potential BMPs that may be used at this site have been identified in Section 4.0 of this report.
The BMPs identified will provide: point source treatment technology for improving degraded
stormwater effluent. These point source structural BMPs have been successfully implemented
in various US locations and on a variety of other types of industrial sites. Treatability
study/evaluation and pilot testing of any point source BMP under consideration is recommended
prior to full implementation.
6.8 Additional Stormwater Sampling and Evaluation
In addition to the above recommendations, it would benefit Silar to undertake additional
stormwater sampling to target and determine the sources for the 1) nitrogen bearing
compounds, 2) formaldehyde, and 2) metallic compounds copper and zinc. Even though it is
suspected that formaldehyde, zinc, copper, and nitrogen compounds are associated with the
processes of the adjacent Oak Bark and Momentive operations, Silar may have to perform
sampling to demonstrate this occurrence. A sampling program designed to demonstrate that
these compounds are not indigenous to Silar's operation would support this assumption. This
may include a multi -faceted sampling program to characterize both onsite ambient and offsite
stormwater quality where such stormwater does not contact ground surfaces. Ambient
stormwater sampling of airborne stormwater prior to contact with ground surfacing would aid in
determining the reasons for the presence of the contaminants that have been detected long
tern in the stormwater samples collected from the Silar site: The sampling program should also
target nearby sources that are likely contributing to onsite stormwater degradation from
adjacent plant sites including cooling tower waters; scrubbers; air -strippers, bag houses, pipe
racks/metal work, and water/waste treatment systems (onsite and adjacent sites). Emissions of
any other potential air sources in the local area, onsite or nearby should also be considered in
developing the sampling program.
Limited sampling and analytical data is available for the newly relocated Outfall SWO01 since
this outfall was just established in March/April of 2012. Sampling, observation, and review of
stormwater data related to the new outfall location should continue with future efforts. Once a
sufficient level of data has been generated, (at least 3 periods), review of the data should occur.
31

Evaluation of stormwater Outfall Conditions
Silar, LLC
333 Nells Eddy Road
RlegeA&ood, North Carolina
ECS Project Number 22-17258 A
September 10, 2012
Observable trends and findings from the data can be considered in developing applicable BMPs
or management strategies for this outfall.
7.0 QUALIFICATIONS OF REPORT
The methods and evaluative approaches used in this report of findings are consistent with
those normally employed in the environmental engineering industry in performing waste water,
stormwater, surface water, and groundwater assessment projects. Our evaluation and
conclusions of site stormwater conditions has been based on information available in the public
record, information and data provided by the facility, and data derived during our field activities.
Additional data, monitoring, or information relevant to stormwater conditions at the site may
exist that ECS has not been privy to and could alter the opinions and recommendations cited in
this report.
The BMPs identified by ECS for consideration have been identified without performing pre-
emptive feasibility study, modeling, surveying, or engineering evaluation to fully qualify each
BMP for this application. Design or performance barriers affecting the use of such structural
BMPs may exist and would require consideration. Additional hydraulic evaluation or study may
also be necessary to determine the factors thai will affect the use of these BMPs as applicable
measures to remediate stormwater at non -compliant outfells. 'The technologies that are
selected by Silar for implementation will depend on the type of contaminants, concentrations,
and hydraulic flow regimes characteristic of stormwater at each outfall location. Additional
feasibility study and pilot testing may be necessary to qualify BMPs under consideration.
32

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f EC.S PROJECT NO: 22-17256

MAY-02-2011 MON 09:2:7 AM HEXION/ACME FAX NO. 9106554749
AK4 5A , 'I "t
North Cardina Department of Environmeflt and Natural Resources
P. 02
_. Division of Water Quality
QeVer1r Ems Perdue Coleen H. Suft Deefreemari
Governor Director Secretary
October M 2MO
Mr_ Peter Yurgel
S11= LLC
333 Neils Eddy Rd.
Rlegeiwood: NC 2W6
33=
4 Subject Final NPDO Stor nwater Permit
Permit No. N(S00053.3
Slur LLC
Columbus County
Dear Mr. YurgeL-
In response to your rmawal application for continued coverage wider NPDES stormwater permit NC500=,
the Division of Water Quality (Division) is forwarding herewith the subject state - NF'DES permit. This permit is
issued pursuant to the requirements of North Carolina General Swate 143.215.1 and the Memorandum of
Agreement between North Carolina and due US. Environmental Pratecfion Agency dated fiber 15, 2007 (or as
subsequently amended).
This finial permit includes no major rbanges from the draft permit sent to you oil August 23, ZMIL We
received comments by email from Silaes President John L.. Slribley on September 24, 2010 and from Silar's Plant
Manager Petry Ywrgei on September l7, 2010. The comments were focused on conoft-ris on responsible of
contansitiation that is beyond their control. A meeting was held on October 14, 2010 in Wilmington with Sitar in
order to adc1mm these concerns. The final permit is consistent with permits for Hendon Specialty Chemicals, Inc
and Oak -Bark Corporation.
The qualitative monit6ring strategy is quarterly. Please note that quarterly analytical monitoring is also required
in this permit Fa Dure to.cormplete the inonitoting as required is i violation of the permit and any,permit.
noncompliance constitutes a violation of the Clean Water Act Reference Part III, Section A, Item 2"Duty to
Comply', Item 9 "Penalties for Tampering" and Item 10 'Penalties for Fi si6eation of ReporW of your permit for
further information.
if any part, measurement frequencies or sampling requirements contained in arts permit are -unacceptable to
you, you have the right to an adjudicatory hearing upon written request within thirty (30)1days following receipt
of this letter. This request must be in the -form of a written petition, conforming to Chnpter550H of the North
Carolina General Statutes, and filed with the Offm of Administrative Hearings, Post Office Drawer 27447,
Raleigh, North Carolina 276117447. Unless such demand is made, tlui+ decision shall be final and .bhui ng.
r
DWQ would like to have an updated site plan far our files. Please send DWQ Central Office and DWQ
Wilmington Regional Office (attn. Linda Willis); r:�sito plbn (earh) including topographical lines and property
boundaries. if War LLC owns or operates any areas, atcrages fgc3lfties or odw facih es that are pat withtw
Silas s property boundary, please label these as well.
is
16177 Mal SuM CUW, Ram NnM Camara 2700417 a i'�TIcpr !'�
Lwadotk 8t2 K S&bb" SL RW*I,NoM CarolkM 27604 : �C��r/y8i�� lla
Phow 919�OG/4= t FAX 919.8U4494 t Cust ow So[b 1.87742"748 S, �j K� s st����
Irt&iroero�wwnor6�quslitr,o+4
.. cam.,. n...�Mu...w....n.: a..... c,�.+....

HAY-02-2011 HON 09: 27 AK HEX ION/ACHE FAX M. 9106554749 ., P,; 03
1`
Mr. Peter Yurgel �.
War L,%C
Permit No. NC5000533 x,
Please take notice dds permit is not transferable. PartM B3 addresses the requirements to be faliowed in case
4 of change in ownership or control of &is discharge. This permit does not affect the legal requirements to Obtain
other permits which may be required by the Division of Water Quality or permits required by the Division of
Land Resource9, Coastal Area Mari agernent Act or any other Federal or Local governmental permit that may be
required.
If you have any questions or comments concerning this permit; contact Briars Lowther at (919)SW-6368 or at
kiarLloynbercdenr. ov.
h! Sincerely,
1•
for Coheen H. Sunins, Dbector
re Wilmington Regional Office, Water Quality Section
Mike Mitchell EPA Region N
DWQ Environmenbd Science Secdom. Cindy Moore
Stormwater Permitting Unit
Central Files
Attachments
A
I

b KAY-02-2011 MON 09:27 AK REXION/ACME FAX M 9108554749 R 04
5
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
" k,
TO DISCHARGE STORMWATER UNDER THE
NATXONAL POLLUTANT DI,SCHARGE ELBMkTION SYSTEM'
In compliance with the provisions ofNorth Carolina General Statute 143-21 S.1, other lawfiA
standards and regulations promulgated and adopted by the North Carolina Envumnental
Management Conttmission, and the Federal Water Pollution Control Act, as amended,
�n Si1�r.LLC'
is hereby authorized to'diseharge stormwater from a facility located at
Silar, LL.0
333 Neils Eddy Road
r.
Riegel vood, NC
Columbus County ,
EE
to receiving waters designated as Livingston Creek (Broadwater Uke), a class Q Sw stream in
the Cape Fear River Basin, in accordance with the disebarge limitations, monit©riog., �-
nquirements, and other condidans set forth inaParts l; II, a IV, V and VI bereof 'f
This permit shall become effective November 1, 2010.
This gcrhiit and the authorization to discharge shall expire at midnight on October.3l, 2015.
Signed this day October 22, 2010.
4
for Colew H. Sullins Director
Division ofWatcr•.Quality
By the Authority of the Bnvironmaatid'Minagemeut Commission
R

�f
MAY--02-2011 MON 09:27 AM HEXION/ACNE
PART I INTRODUCTION
Vi
Section A: individual Permit Coverage
Section B: Permitted Activities 't
si=don C: Location Map
FAX NO. 9106554749 a P;r 05
�
Peznut No. NCS000533
PART li MONITORING, CONTROLS, AND L[WrATIONS FOR PERMITTED
DISCHARGES
Section A: Stormwater Pollution Prevention Plan
Section B: Analytical Monitoring Requirements
Section C: Qualitative Monitoring Requirements
Section D: On -Site Vehicle Maintenance M-onitoring Requirements
PART III STANDARD CONDITIONS FOR NPDES STORM'WATER IND'f'VIDUAL
PERMUS
Section A: Compliaaae and Liability
1,
Compliance Schedule
2.
Duty to Comply
3.
Duty to Mitigate
4.
Cavil and Criminal Liability
S.;,
Oil and Hazardous Substsace Liability T
b.
Property Rights
.7:
Scvcrability
S.
Duty to Provide Infomaation
9:
Penalties for Tampez-iag
10.
Penalties for Falsification of Reports
Section B. General Conditions
1.
Individual Permit Expiration
2.
Transfers
T
Signatory Requirements
Im
3

MAY-02-2011 MON 09,28 AM HEXIOVACME FAX NO. 9106554749 P„ 06
• - Permit No. NCS000533
b. 4. Individual Permit Modification, Re"eatian FmA Reissua M or
T«mination
5. Permit Actions
Section C: Operation and Maintenance o0ollution Controls
1. Proper Operation and Maintenance
2. Need to Halt or Reduce Not a Defense
3. Bypassing of Storwwatcr Control Facilities
Sermon D: Monitoring and Records
1. Representative Sampling
2. Recording Results
3. Flow Measurements
4. Test Procedures
S. Representative Outifall
,a
d. Records' Retention
7. Inspection and Entry
Section E: ReporOg Requiremenp:
1. •Dischar& Monitoring Rdpo ts;
2: Submitting Reports
3. Availability of Reports .
4:' Nan-Stormwater.Discharges
S. Planned Changes -�
b. � 'Anticipated Noncompliance.
7. Spills
8: Bypass,
f== 9: Twenty-four I.1©ur Reporting
10. Other N0neompBance
11. Other Information
PART TV LIMITATIONS�kEOPENER
PART V ADNIhii3' ERi G AN'I :CON&PLIAN'CE MON1TOK NG FEE
REQUi1tEi�iI'S _ _.
PART VI DEFINITIONS
4,1
Sl

. �..: M-02-2011 MON W 28 AM HEX I OWACME
TART, I IN M-
SEC'TIDN A: JTW' iVbUAI PERMir CtivERAGE'
FAX N0, 9106554749 R 07
Pewit No. NCSON533'
During the period beginning on the effecrive date of the permit and lasting until crgirat'6n. the
permitter is authorized to discharge stottnwater associated with industral activity. Such
discharges shall be controlled., limited and monitored as specified in this peEWt.
'If indusftW materials and activities are not exposed to precipitation ornmoffas descabed in 40
CFR § i n-26(g), the facility may qualify for a tdo Exposure Exclusion from NPDES stormwater
discharge peraut re quu=ents. Any owner or operator wisbing to obtain a No Exposure
Certification must su%rait a No Exposure Cerdfication NCI form to the Division; must receive
approval by the Division; must maarttaiu do exposure conditions unless authorized to discharge
under a valid NPDES stormwater permit; and must reapply for the No Exposure Exclusion once
every five (5) years.
i
Until dtis permit expires or is modified or revoked, ttie permituc is authorized to discharge
' stormwater to the surface water; of North Carolina or separate st66 sewer syst m that has been ' a
adequately treated and managed is accordance with the terms and conditions of this individual
permit All stormwater discharges shall be in accordance with the conditions of this permit.
Any other point source dischwge to sur6ace waters of the state is prohibited unless it is en
allowable non-stormwatcr discharge or is ro- e4,6d by another permit, authorization, or approval.
The stornawater discharges allowed by this individual perrrxit shaWnot cause or contribute to
violations of Water Quality 5taMtr & ,
This permit does not relieve the permitlee from responsZility for compliance with any other
applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or decree. -
�, A
�h
rt
4
Part I Pale 1 of 2
. t
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MAY-02-201110 NJ"09: 28 AM HEX JON/ACME FAX NO. 9106554749 po.- 08
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Part I ftp 2'of 2

11AY-02-2011_ 0 09:28 All HEXION/ACME
sB
FAX NO. 9106554749
Permit No. N6000S33
SECnb?4-A: STORMWATER-P,OLL11MONFPREVENTION PLAN'
3>
The Petmittee shall develop a Stormwater Pollution Prevention Plan, limim after referred to as
the Plan. This Plan shall be considered public information in accordance with Part III, Standard
Conditions, Section E, Paragraph 3 of this individual permit_ The Plan sba11 it:clude; al a
minimwn, the following items:
1. Site Plan. The site plan sW provide a description of the physical, facility and the
potential pollutant sources which may be expected to contribute to contamination of
stormwater discharges. The site plan shall contain the following:
(a) A general location map ((3SGS quadrangle map or appropriately drafted
equivalent trap), showing the facility's location in relation to hmnsportation routes
and surface waters, the name of the receiving water(s) to which the stormwater
outfall(s) discharges, or if the discharge is to a municipal separate storm sewer
system, the name of the municipality and the ultimate receiving waters, and
accurate latitude and longitude of the poiat(s�of discharge. The general location
map (or alternatively the site map) shall identify whethce each receiving water. is
Ampaired (on the state's 303(d) list of impaired waters) or is located in a
watershed for which a''I'M16i has :fern established, and what the pammerer(s)
of concern are. r �•
(b) . A narrative description of storage practices, loaning atxl unloading activities,
outdoor process Areas, dust or particulate generating or control processes, and
waste disposal practices. A narrative description of the potential pollutants which
could he expected to be present in the starmwatex discharge from each outfall.
a, .,
(c) A site map drawn to scab, (including s distapcc legend) showing: the site property
boundary, the stormwater discharge outtfeMs, all on -situ and adjacent surface
waters and wctlandn, industrial activity area (uncluding storage ofmatcrials,
disposal areas, pros arras, loading and unloading areas, and haul roads), site
topography, all drainage features and structuws, drainage areas for each outfall,
direction of flow in each drainage area, indusd W activities occurring in each
drainage area, buildings, existing HMPs, acid impervious surfaces. The site map
must indicate the percentage of each drainage area that is impervious.
(d) A list of significant spills or leaks of pollutants that have occurred at the facility
during the ftee (3) prmous years and stay eve actiams taken to mitigate
spill. impacts.
(e) `Ca lifieation that the stormwater autfa.ls have been evaluated for the preswee of
hoa-stormwater discharges.. The certification statement will be signed in
accordance with the requirements found in Part DL standard Conditions, Section
Pot lt;?page S of it
P.: 09

MAY-02-2011 MON 09:28 Ali HEX ION/ACHE FAX NO. 9106554749
P=dtNo. NCS000533
B, Paragraph S. The permittec shall re -certify annually the the: stormwati r
outfails have been evaluated for the presanco of non-stormwater diwIargea.
2. Stormwater Management Plan. The stormwater mansgeatent plan shall contain a
narrative description of the materials maaagatnent prscticm a 4fted which control or
minimize the akposu m of significant materials th stormwatcr, including structural and
nonstructural measures. The swrmwatcr management plan, at a minimum, shall
incorporate tho following:
(a) l;eastbility Study. A review of the technical and economic feasibility of cb angina
the method8 of operations and/or storage ptacticm to climinue or reduce exposure
of materials and processes to stormwaur. Wherever practical, the permittee sW
prevent exposure of all storage areas, material handling operations, and
manufacunriug or fueling operations. In areas wEhaze alknination of expw= is
not pracdcal, the stormwater management plan shall document the feasibility of
divatitig the stormwater runoff away from areas of potmfW contamination.
(b) Secondary Containment Requircmcnts and Records. Secondary containment is
required for. bulk storage of liquid rnattxials, storage in any amount of Section
313 of Title III of the Superhind Amcaftents and Reautt mization-act (SARA)
�! water priority chemicals;. and storage in arty. argeuut of hamdous mhibstancces, in
- order to prevent leaks and spills from Contaminating stonnwaterrulof, A table
or su=ary of all such tanks and stored materials and their associated secondary
containment areas shall be maintained. If the secondary containment devices are
connected to stotm�water conveyance systarhs, the connection shall be controlled
by manually acavated valves or other similar devices -(which shall be secured
closed .with a locking mechanism), and any a=watei that acc=iulatcs in the
containment area shaft }seat a minigl=_visually observed for color. foam, outfall
staining, visible theens and dry weadw flow, prior to release of the accumulated
stormwater. Aoeimhula s shall eased if bo
uaconiarninated by any_matelial. Records docnrnentingthe individual maldng the,
o servationy the description of the accumulated stormwater, and the date and amie,
F .of the release shall be kept for a period of five years:
(c) ShO Summary. A listing of site struchaal and non-structual Best Maaagement
Practices (BMP) shall be provided: The itsstanauon and Implementation ofBMPs
shall be based on t miuessment of the potential for sources to contribute
significant quantities of pollutants to stormwater discharges and data collected
through monitoring of storaiwaur discharges. ne BMP Summary shall include a
viritten record of the specific ratioiWe for installation and implementaiien of the
selected site Bt++ft The BW Sumn a y shalt be reviewed and updated annually.
3. Spill Prevention and Response Plan. The Spill Prevention and Response Plant (SPRP)
shall incorporatc an assessment of potential pollutant solaces based on a materials
inventory of the facility. Facility personnel (or the team) respansi'ble for implementing the
SPRP shall be identified in a written list uhcerpasetcd into the SPRP and signed and dated
by each individual acknowledging their responsibilities for the plan. A responsible.
Pars II Pega � of 11

MAY-02-2011 AEON 09:29 Ali HEXIWACi E
4.
FAX Na 9108554749 P. 11
Permit No. NCSONS33
person shall be on -site at.all tintcs during facility operations that have the potential to
contaminate stormwater =off through spills or exposure of materials associated with the
facility operations. The SPRP must be site stormwater specific- Therefore, an oil Spill
Prevention Control and Countermeasure plan (SPCC) may be a component of the SPRP,
but may not be sulEcirnt to completely address the stormwater aspects of the SPRP. The
common elements of the SPCC with the SPRP may be incorporated by refermce into the
SPRP.
Preventative Maintenanoe and Good Housekeeping Program. A preventative;
maintenance and good housekeeping program shall be developed. The program shall list
till stormwater control systems stormwater discharge outfalls, all ou-site and adjacent
surface waters and wetland&% industrial activity areas (including material storage areas, . .
material handling areas, disposal areas, process areas, loading and unloading areas, and .:
haul roads), all drainW features and structures, and existing smwtural BMPs. The
program shall establish schedules ofinspections, maintenance, and housekeeping
activities of stoanwater control systems, as well as facility equipmeat, facility areas, and
facility systems that present a potential for stormwater exposure or stornawater pollution.
Inspection of materiel handling arras and regular cleaning schedules of these areas shal!
be incorporated into the program. Timely compliance with the established schedules for
inspections, maintenance, and housekeeping shall be recorded in writing and maintained
in the SPPP:
w, •
Employee Training. Training programs shall be developed and training provided at a
minimum on an annual basis• for facility personnel with responsibilities for. spill rrsponse
and cleanup, preventative maintenance activities, and for anyof the facilitys operations
that have the potential to cognate stormwater runoff Facility personnel (or team)
responsible for implementing the training shall be identified., and their annual training
shall be documented by the sigrsatum of each employce trained.
Responsible Party. 'The Stormwater Pollution Prevention Plan shall ide dfy a specific
position(s) responsible far the overall coordination, development, implementation, and
revision to the Plan. Responsibilities for all components of the Plan sttihll be documented
and position assigmnents provided. ;!
Plan Amendment The permittee shall amend the Plan whenever there is a change in
design, construction, operation, or maintenance which has a significant effect on the
potential for the. discharge of pollutants to surface watem. aspects fif t3he
Storrnwater gollutdan Prevention Plan stem be revimed and updated an an•anns�sii
!Uds. Me annual update shall 'include an updated list of significant spills or leaks of
pollutants for the pmvious three years, or the notation that no spills have occurred. The
annual update shall include writer recertification that the stormwater outfalls have been
evaluated far the presence of non-stormwater discharges. Each annual update shell
include a documented re-evaluation of the effectiveness of the BNQ9 listed in the 13NT
Summary of the Stocmwatrr Management Plan.
The i}irector may notify the pemuttec when the Plan does not meet one or more of the
suinimwn requirements of the gamut: Within 30 days of such notice, the permittce shall
Part 11 Page 3 of 1 l
V

. MAY--02-2011 MON 09 , 29 All HEX 1QNlACHE
FAX N0. 9106554749 P. 12
we" i-c ti
Permit No. NCS000533
submit a time schedule to the Dkvdor for rio4&ng the Plan to meet minimum
requiretne=: The.perra aft shall provide eerdficuion in writing (in aoaandance with
Part A.I, Standard Conditions, Section B, Paragraph 5) to the Dha for that the changes
have beta made. - � If
8. Facility Inspections, Inspections of the facility and all 4tmmwater systems shall occur as
part of the Preventive Maintenance =&Good Housekeeping Program at a minimum on
a semi-annual schedule, once during the first half of the year (January to June), and once
during the second bAlf (July to Dwxmbar), with at least 60 dayg separating inspectona
dates (unless performed more fiegttently than stint -annually). These facility inspections
are different from, and in addition to, the stotmtwater discharge characteristic monitoring
required in Part II B and C. of this permit. cy
W
9. Implementation. The permittee shall implememr the Plan. Lmplcuicotation of the Plan
.-shall include documentation of all rnoniUming, meal cats, inspections, maintenance
activities, and.training provided to ea4Anyees, including the log of the sampling data and
- of actions taken to implement BMPs associated with the industrial activities, including
vehicle maintenance activities. Such docu meatation shall be kept on -site for a period of
five years and made available to the Direcwr or the Dimctar's anthoriied representative
r immediately upon n4uem. " .-
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Part U Page 4 of 11
i
E} '
4

."PI
MAY-02-2011 MON 09:29 AM HEXION/ACHE
FAX NO, 9108554749 P.., 13'
cp
Permit No. NCSO=33
SECTION Bz ANALYTICALMONITOMGREQUIREMENTS
Analytical monitoring of stormwater discharges dW1 be performed as specified in Table I. All
analytical monibming shall be performed dming a representalive stoup event. The reqtfired,
monitoring will resWt in a minhnwn of 20 analytical samplings being cmdue" over the term of
the permit at mb stortnwater discharge outfiLU (SDO);
A representative stomp event is a storm cvmt that mcamw z=w tban, 0.1 incites of rainfall. The time
betwam this storm emt and the prmaw stom event measurkqgmwer than 0.1 iw1a must be at least
72 hours. A single norm event may have a period of no precipitation of up to 10 hours. For example, if
it rains,but stops before producing any collectable discharge, a sample may be collected if the next rfam
,P a &schaiga begins within 10 hours:
Table 1, AkatAcal Monitoring Requlrefiwau_
Characteristics
Vnits
messumment.
Vriquengi
SaMPIP
Simple
Locadon3
Total Suspended Solids ITSS I
mg/L
quwtmiy
Crab
SDO
Biochemical QUAen Demand (BOD5),
mg/L
qWwtedY
Grab
SDO
Chemical Px en Demand COD)
mr/L.
quwtedy
Cmib
SDO
Ammottn
sa as Ni!E3-nm
ai
quarty
�Giab
SDO
Total Kj6dahl Nitrogen Mo
uag/L
quatterly
Grab
SDO
Nitrate +-Nitrite Nitro an
quarteriy
Grab
SDO
Total _Lhospiim ,
mWL.
quarterly
Grab
SDO
Methnnol4rag/L
quarterly
Grab
SDO.
Total Residual Chlorine 4
MR/L
quarbmly
Grab—
SDO
i1examine,
MWL,
qua=)Y
Chmb
SDO
Formaldehyde
mg(L
q=Wy
Grab
SDO
,Total Recoverable
'Cqqxr
nkWL
quartefly.
Grab.
SDO
Zino, Total Recoverable
M
q=Wy
Grab
SDO
Total Recoverable:
mg/L
quarterly
;Grab
SDO
Lead, Total Repovcrabj04
mA(L
quartegiy
Grab
SDO
EPA giethoJ, -1664 (S'GT_1 i:im) —
Non -polar O&GVTPH
mg/L
v.a . rta'y
Chzb'
SDO
L
pis
standard
quawdy
Grab
SDO, 005
Part II Page 5 of I I

MAY-02-2011 HON 09c29 Ali HEXfON/ACHE FAX NQ 9106554749 P._r 14
Pe mitNo, NC-SO00533
Dissolved Oxygen
Grab
005 Effluent,
me/L
q1Y
..I]owp5tre;atn,
Upstream
Acton Toxicity7
A>m=Uy
Grab
SDO
Tatal Rainfall8
inches
q=tmiY
e
-
l Mea=et Wt Flftpneacy. Fomr times per Year &UUS a rgMtff ative storm n=
2 drab samples alma bo oollwW wid4n. do first 30 minutes of diseharIPL
3 S ample Location: Sat Pkd shall be caIlecmd at eaah stmmwatar disc wt p oor&n (SDO) vat reptexcuaative ou&U
stabs has beep .4 -
4 May ducarnd= moniwring thin paraatt w fbr the remasstder oftbe peam aEizx Stet eight (9) sampling if all
mmi is are below the beau values
S The pH at each WO *bell not be Irw than 6.0 standard units nor greater than 4.0 stmdard units fbr fi-c* water
clA&vI=tw= The in stream samples are from swan* waters and may have a pH vahm m .low as 4.3 if it is the
result ofnatural condidom :+
6 Water Quality. Standard for Dissolved or$A= not less than 6.0 mg/1 Em trout wawa; for non-trout'vratem not
leas than a daily average of 5.0 mgn with a miaimm iw antameot9 vahte of not less than 4A mgll; 9W=P wate m
lalec coves or b&CkWRter3, =d lake bottom waters tray have lower vahtea if caused by rnadaal conditions.
7 Acute toxicity shall be: performed in accordance with Appcadix A. Special Couditiam at the end of this p=it
9 For each u=plad repces=mdve storm event the Dotal psocipstat= mug be wear&& An on -site rain gorge or local trait`
Szug'e madinA tnum bt sande&
the permittee shall complete the minimum 20 analytical saml?Ungs in a =rdance with the
schedule specified below in Table.;L A mi ihnum of 30 days must separate Period lF stid�;
'ericd;2 sample dates unless monthly Monitoring has been instituted under a ter Two
response. R
Table 2. Mnnnoria Schedule:
Monitoring pe dodi,% $tom Ead
All.Years -- Quax = 1 Jae I March 31
6
Ali Years — Qttatter, 2 April 1 June 30 '.
All Years -- Qttartear 3 July 1 5eptemiier 30
A?I Yews -- QuarW 4 October 1 Dcx=ber 31
` ' 1 Maintain rtue udy monitoring d=4 Permit renewal nroee m, [f at tltt eXpuwian of this petmdt,` eta
penes =e has sahmimd su application i4t rasewal of ravemgt befbte the aubmittal deadlitsa, the partattee
wM be oomaidered for renewed coverage. QdwWly monimring &hall be done all years of rho permit bad the
applicant must contra= quart aly mordtanng until the r=wed pars* is issued:
2 ff no diadwv octets dudU the "mPlsng period, the peanitteo ttwst suhadt a =Ait0r" report ladicating
"No Fkmi" within 30 days of the end of the three-month samphe period.
r.
permittee sban report the analytical results fmm the first sample with valid results within the
mor4toting period. The permittee shall compare monitoldlW results to the bench`-=* values in
r

I
MAY-02-2011 LION 09:30 AM HEXION/ACME FAX NO. 9106554749
P., 16
ws
Permit No. NCS0005,33
Table 3; The benchmark values in Table 3 m not pet-mit limits but should be used as guidelines for
the permittee's Stormwater Pollution Prevention Plan-(SPPP). Ewcodances of bend mark values
reqfike the pennime to h=usc monitoring, marease marmSesnimt actions, increase record keeping,
and/or install stormwater Had Management Practices (BWs) in a tiered program See below the
descriptions of Tier One and Tier Two. :41
TahliL I VIAMAMaAr tr.t-.&
Dim Cbsracteristics
Units
Benchmark
Total Solids MS)
100
Biochemical Oxygen Demand (SODS)
mg/L
30
Chemical Oxygm Demand (COD)
MWL
120
Ammonia as Nitrogen (NHrM)
mg/L
72,
Total KjcWsW Nitrogen (TK:t4)
20
Nitrate + Nitrite Nitrogen
mg,
10'
Total Phosphorus
mg/L
Methanol a
Ing(L
7,700
Total Residual Chlorine (IRC)
mg/L
0.028
mg/L
25,000
Formaldehyde
MWL
0.5
Copper Total Recoverable
Tug&
0.007
Zinc, Total Recoverable
ICA
0.067
Manganese, Total Recoverable
N/A
Lead, Total Recoverable
mg/L
.0,03
EPA Method 1664 (SGT-HEM) —
Non-pokr O&al?H
-
45
PH
stmulard
6-9
Acute Toxicity
See
Appendix A.
special
Set Appendix
A: Special
Conditions
W
P67, 11 Page 7 of I I
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MAY-02-2011 MON 09:30 AM HEXIONIACME FAX W-- 9106564749 R 1s
E-
N
3 •.
w
M
Permit No. NCS000533
Tier One"'
U.- -The lust valid sampling results are shove a benchmark value, or outside of the benchmark range, for any
Then: The permiuee shall:
I. Conduct a stormwater managa=nt inspectian of the facility withiri'tiro weeks of receiving
sampling resuks.
2. Identify and evahsate possible caw= of the benohsnark value axceedence. s
3. Identify potential and select the specific: sou -ce controls, opeorst�, controls, orphysical
improvements to reduce conceutrstions of the parncaatcrs of canrent, or to bring concentrations
within the benchmark range.
4. Implement the selected actions within two moa#lm of the insptrtlon.
5. Record each kmzace of a Tier Ona ragpoase in the Stortnmattr Pollution Prevention Plan. Include
the date and value of the benchmark exceedence, the inspactlon date, the parsunnrl conducting the
in Lion, the selected action., and the date the selected actions wens ' lemeated
�. ;. Mer.Twp
If: During the term of Ws peunik the first valid gaznpling results from three camecutive monitoring periods
are above the benchmark values, or outside of thB benchmark range, rdr any specific .pararrteterat a
Cqiflc dq24g Igg otitfall;
Pen; -The permiUm shall:
1. Repeat all the required actions outlined above in Tier One.
2. Immediately institute monthly monitoring for all parametest at every oud4l1.whem a.a gLng resulr
s exeecded the bcathnrark value for two'consaeutivt: samples. Montfify (analytical and qualitative)
monitoring shall coptjnue until three consecutive sample results are below the benclrrnark values or
i within the benchmark range. 4
3. If no discharge ooctirs during the sampling perioatbe pctxr►ittte is required.to submit a monrhiy
S monitoring.report indicating "No Plow' to comply with reporting requirements.
4.. Maintain a rwArrd of.tbzlie; TWo msp, - "ia tha Stormwater Pollution Pmveution Plan:
lMrThree
r.
During the term of this permit, if the valid sampling rc ults required fdr the permitamonitohR periods
txce.A the benchmark value, or. are outside the bewlu= lr range, for any specific tiara Dew at any specific
out#rli on four oecaslomu% the pennittee Shall notify the. DWQ Regional Office Supervisor in writing witliln
30 days of receipt of the fourth. analytical results: DWQ may but is not limited to::
n require that the prim_ ittee rev=, ic►ereast, or decrease the niaaiLotirrg frequtsacy for the remainder j
of the poste%[;;
• regaim the permittee to conduct acute toxicity testing on disc arges;.
•` require the pmmittee to install smieturd itormwater controls;-
require tha permittee to impimnew other stoimwawx controil measwcs;.ar
a re that the ittee." lemt:tst site moditieadons to M4M for dhe N, 'E. saga Exclusion. .
put T1. Papa of [ t
14
T

MAY-02-2011 KON 09:30 AM HEXION/AcmE FAX H0, 9106564749 P. 1'7
L,
tirraft Na. NCS000533
This site discharges to impaired waters'experiencing problems with turbidity. If a Total.
Maximum Daily Load ('I'MI]L)is approved for this segment of. Livingston Crcelc, the pennittee
may be required. to monitor for the pollutant(s) of cones rn in the future and subunit results to the
Division of Water Quality. The Division will consider the monitoring results in detmmaining
whether afttional'BMPs are needed to control dt.pollutant(s) of concern to the maximum
extent practicable.
If additional HMPs are needed to achieve the required level of control, the permittee will be
required.to (1) develop a strategy foriq*cmenting approprWe 13%9 , and (2) submit a timetable
fur incorporation of those M09 into the pe:niitted Stormwater Pollution Prevention Plan,
SECTION C. QUALITATIVE MONITORING REQUIREMENTS
Qualitative monitoring requires a visual inspection of each stormwater outfall regardless of
representative out6ill status and shall be performed as specified is Table 4, during the analytical
monitoring event. [If artalytecal monitoring is not required, the pe mittee still trust conduct.
quarterly qualitative monitoring,]Qualitative monitoring is for the purpose of evuluating the
effectiveness of the Stormwater Pollution Prevention Platt (SPPP) and assessing new sources of.
stonnwater pollution.
a -
In the event an atypical condition is noted at a stormwater discharge outfall, the permitted shall
document the "suspected cause of tho. condition and any actions taken in response to the
discovery. This documentation will be maintained with the SM.
T2hle•4_ . Owkiftirtive Mnnttorine.Reanfrentents..,
Oischarje Characteiistics
frequenol
Monitoring
Locilti=2
Color
quarterly
SDO
Odor
1
SI)O
Lg,ari ="_
SDO
F1Aah Solids
t.lo _"'.._
' Siis,'i"sicd Solids
uarteri
SDO
y
tlstteri
SDa
Foam
Mnntiy
ADO
Oil 5hren _r
erl
SDO
tosimi or deposition at the outfail
nauxerl
SDO
3D0
"^Other obvious indicators!
of stormrratcr pollution
—
SDO
•s
"
1 Measvt,emea Frequency: F a= times 1= yw ding i teM=n1airn stotta "ME, Sod MCb year vndi either
anotLa permit is ix. for thine Wity err unat this permit is revoked or ms,_in� If at the end of this
p=njtring cycle the perraitrtre hag submitted the APprapriatt Paperamo* fli a ttnewal permit befom tho m miad
dead'iue, the permitw will bo cowidUed for renewed coverage. The app desist must due quartCrlY
Para 11 Page 9 of t l
I
M

MAY-02-201 l _MON 09:30 AID HEX i0N/ACME FAX Na 9106554749 P. 18
Y' ICI
Permit No. NCS000533
mm ttft until the renewed permit is &ff=cL See Table 2 for wbed:rk of mvnit&r periods through the and of
2 Wnitoriog Locatim Qa&U%thm monitoring sball be perforaaM'ett each &== am &Whsrge cut$all (SDO)
mprdiew of repres=mlive oatfall am
i7 '
SECnOYA; ON -SITE VEHICLE MAINTENANCE MONUOMG REQEilR1✓MOi'I'S
y
Facilities which have tmy vehicle mWnterranca activity occurring on -site which uses more thaw 55
gallons of new motor oil per month whets averaged over the calendar y="pe fwro
analytical monitoring as specified below in Table 5. This monitoring sha11 be performed at all
storxmwatet discharge outUb which tiischargc slo mwater runoff from vehicle maintanm=
areas, and in accordance troth the schedule presented in Table 2 (Section B). AU analytical
monitoring shall be performed fitting a tepmentative storm evelm
Table 5. Analytical Monitoring Requirements for On-81te Vehide Malatenmce
Discharge Cbae arftristles
units
Me' u rer=t
SXEVle
� Sample
a
,-lire uenc I
T eZ
``3rocatlan3`F
standard
quarteriy
Grab
SDO 4
Total Petroleum Hydrocarbons
Mg/1
quarterly
Arab
SDO j
LEPA Me Mod 1 bush gT--HEM)
Total `S ended Solids
ilarterl
GrabSDO
Total RainfaU4
inches
Rahn all
-
New Motor Oil Usage I
gallons/month-1uartttrly
Estimate
14taLurem= Frequency: Four times par year during a repnxmtative stemr event, far each year anal either
another perrait is lasted for this facility or until thb permit is revoked or, reaciadrd. If at the and of this —
pexmirtinng cycle the penmttec has submitted the appropriate paperwork for a ten wal permit befa= the nanistal
deadlina, the pe rmittee will be cnnsidercd for renewed coverega. The applicant must contirnre quarterly
monitoring entail dw renewrd permit is issued. Son Table 2 for schedule of monitoriag periods through the: end of
d rs'permittirag dycle. „� _
:t
2 If the stt] mwater nmoff is contmIled by a stormwatnr detention pond a g ub sample of the dtacharge from the
pond shall be collected within the first 30 mimLtcs of disahsrge fry the perm:
3 Satuple Location; Samples shall be collected at each stnrmwater discharge outfall (SDO) that discharges
stormwat o ntaoff from asea(s) where vehicle maintenance aclivides Occur.
ns .
4 i' r each sampled repreaevwt m am= event the total precip&tim meat br rworde& An ea -arse or local ruin
gauge reading man be recorded:
Mani" results shall be compared to the benchmark values in ' i-xile d. The bmcl�taric
values in Table b are not permit limits but should be used as guidelines for the pamittee's
Stonnwater'Polhition Prevention plan (SPPP). Eaweedences Ofbe:uchmMA-valuer require the
permi�,tea to increase monitoring, increase management actions, in� record keeping, and/or
install stormwater Best Management Practices (BMPs) as provided'in Part II Section B.
Part II Page to of f l

HAY-02-2011 MON 09:31 AM HEXIONYACHE FAX Ha 9106554749 P. 19
rq
Permit No. NCSOODS33
TablcI& 'AtAchmark Vdues fh*rVehide Maintenance An cal Monitoring
Dlsch�!tc CL=acteribfici Bejichink*
PH
stwuLud
6-9
Total Petralem Hyftcarbons (TPM
[EPA Merha 1664 i'SGT-HE*]
Total S!Mended Solids (rSS) - -- — -1m
IDD
44
is
bm
PaR II Page I Of 11
0

.m�
ttAY-02-2011 t10N 09:31 AM HEXION/ACKE
FAX NO, 9106654749
P. 20
?anWt No. NCSOW533
PART III S'TANDwRD COiNDMONSIFOR NMES STORMVATER WIV' UAL PO MM
SEMON A: COAOU414CE AO LMRILiTY
't
1. Ccanalianee Schedule a R
The parmittm shall coarply with LimWitions and Conerala v=ficd for atwm'% er diseha rges iar
ttccartinrrcm with hC follawing scbr&de:
i;
•;, Existing Faes'lities already qwx&g but applying for permit eovmp for tbt: first tote: T& Starm>avatar
POMM Prcvold= Platt dO! be devr� and Wplemcated wi&612 ItrOnl i of the cficedva date of the
initial permit sad updated the an in annusl basis. Sec=dary coaminmdst, as Waci5ed in Part H,
S-alim A, Faxsgraph 2(b) of this ptxmk, Shall ire aoeovaplithed widfin 12 mans of &e eft-u-tive date of
the moral l ssetraLOCe.
Neav Fari#itiea applying for coverap for tiro first titno and existing fkades pc+ &uslypei=ned and
applying fr r r+erteaval under this permit The Staffiwates Polltdon Pmvtm ion Plan shall be &veioped and
bnpkn *d prior to dh& beginning of discharges from the operation of ttse iti&ft W andvity aM be
updated dwea$rr on an annuat basis. Secondary cones as specified in Pert II, Secrirm.A, Paragraph
` 2(b) of this permit sball be acccmplixW prior to die be&m ng of durdtarges form dw operation of the
industrial eotivity. :
E
Tho permimm must camply with all conditions of this individual ptumit Any permit aaucau�iiaaee
constituter a violation of the Clears Water Act and is groaada for enforcement action; far permit
%=xinatiou, revocation and raissaauce, or ndifieaaon; or denial of a permit upon renewal application.
A. The perntitme sh4 comply with alludods or prohibitions esta U6M tmdcr section 307(a) of die
C i-= Wittier A= for toxic poilutaats WidIin the tftmc ptnvWad in the regstlagtms that e+tabliah these
studards or p vhibitlons, even if fhe permit hag not yet been modified to incorpozam the
�a
b. The Cleats Wsttr Act provides dW arty peraoa %vbn viola= a permit taa Ati m rk subject m a civil a
p=Ry tot to exceed $25.OW per day for csch violation. Any pasm who uegllgmtly vioWW any
permit condition is st*joct to criminal petaslties of S2,5W to 25,000 per day of violation, or
zmpriaonment for not more than 1 year, or bodt. Any.peautt who lawwingly violates permit
eonMoaa is sab3tat to crinsnal perWdes of $5.0W to $50,i100 per day of violation, or
imprisoament for riot more than 3 years, or botp. Also, anypetsaa who violetrca a permit condition
rstaybo &wcswd so adutiaisttativc penalty not to exceed S 10,000 por violation with the maatimam
amount net to exceed $125.OW. [Reef Section. 309 of the Fodeml Act 33 USC 1319 and 40 CPR
122AI(e).) #•
C. Under atate law. a daily civil penalty of not mare than tea thouaand dollars (910,000) per violation
may be wed against Say person who violates or fails to act in accordance with the tetu►s,
coa itiow, or regniremum of a permit [Ref'. NC Crowd Statuto 143-215.6A].
d. Any person tu3y be anosaed an arixninistrative penalty by the Director for violating Sestina 301,
302, 34fi, 307, 309, 319 or 405 of thb Act, or any permit condition or EW4dah ►mplemendng any
of such sermons in a permit iwuod tinder sectkm 402 of the Act. Add%Wiwu ve penalties for Clan,
I violations are not to c uxmd $10,000 pet violation, Wah the mumium amount of any Class l
penalty agassaed not to exceed S?S,{14t0. P4as)sios for Clas:r iI vfolatioas era taxi m tbccecd
1( Part lu per 1 of s
s�
9

MAY--02-2011 HON 09 : 3I Am HER ION/ACCIE FAX HQ 9106554799
Permit No. NCS000533
$I0,000 per day for =h day during which the violation eoabnass: witl► the utexi=Mn amount of
any ClNse 11 penalty not to exceed S125,000.
3. or to Mnwnoe
t
The permittee el;all taloc all reasonable steps to minimize or prevent any disclaige in vinlatioa of &j.,
individual pert which has a rt mwbla MaLi3tood of adveraeelLyr a$ectiag htrsaan healtb or the cavirom tent.
V
4. Civil and Criminal fiahilitir
Except as provided in Pats III. Section C ofthis pemtit regarding bypassipg of 5ttgnrm ' control fact7itice,
nothing h this individual permit shall be coastroad to relieve the permium from any ts5gensib3iitiea,
° liablidb% or penshies for nnmompi>antae pursuant to NiCGS 143-2153,143..215.6A.143-215.65,143-
215.6C or Section 309 of the Federal Act, 33 USC 1319. Furmet mwvr the permiitee is respo=''ble for
consequmtial damages, such as fish kills, oven though tlse respoaubility for efflw&e compliance essay be
tempotmy a
S. OR and HaR dpas Subetzw= Liability
Nothing in thin individual permit sM0 be construed to proelude die institution of any legal action of relieve
the permitter from airy rcspoastbiUdw, tiabUizies, or penahies ro which the permivae is or may be subject to
{ under.NCGS 143-21� 73 at sect. or Section 311 of the Federal Act', 33 USC 1321.
6. ProwaRiuha�
;,. A
t' The issuance of this individuul permit does not couvcy any property rights in either teal or peravual
` property, or auy exclusive privileges, nor does it authorize any i4ury to privam ptoperty or any invasion of
personatrights. nor any infriII o[Fcdcral, State or local laws or regulations.
The provulans of this indMdwd permit set severable. and if any providotr of d& Individual petit, or the
applicado of auy.ptovision of this individual permit to any circimutancelk U bd1d ►mMIK. the application
of stub provision to oldest circumstmices, apd the remainder of this individual permit, shall not be wetted
t: tlxrr�y :.
Ma pwruittee shall fisuish to the Director, within a icasozsable time, eny 1doxvisdou which the Director
may request to determine whether cause exists for mcK ifying, revoking aid reis ,or M=inating the
.yfsaited punt aant to this individual permit or to determine compliance wide this individual permit Th
eses e
r; n Perm ittee shall also fiimish to the Director upon, request, eppics of rwards requred to be kept by title
individual pectait.
9. 1�eoaltles for�i�g: :�
s* _ he Ctrm Wrier Act provides that any person who falsifies, tampers with, of imowwgly ret>dan inaccurate.
any monitoring device or method required to be mainudned under this u divldual permit shale upOA
eonviedust, be punished by a fine of not more than $10,000 per violation, or by imprisonment fen• WE morn
than two years per violation, or by both. 1f a conviction of a person of i_%r a violation ooMmimed afar a first
' conviction of each person under this paragraph, pum�Ld=cnt is ai' Hue not mote dial S20 M Per day of
vitslation, or by i rgwisomnent of not more than 4 years, or both.
Fart M PAO 2 of a
9

f1AY-02-2011 MON 09:31 AM HEXION/ACHE FAR K 9106554749 P. 22
Permit No. NCSOMS33
10. Em&Lfim It Falsification of Rc>sorta �„
The Clean Water Act pmvldm that any person who bwwwgly maims any false smwaaea4'rrp�ti= or S.
cettiificetion in record or other document submitted or any rtogrtired ur ba maintainod coda this individual
permit. iochtding mauitoring reports or reports of compliance or null== duA spore conination, be
punished by a floc of not mono than $W,000 �a violadoa, or by imptisocroew lbr not morn than two years
per vint fts, or by both. rz'
N �
s craoxB: GENERAL. CONUMNS
ell
1. Imiivi�ailtral Pet�icF.gr�t�on ,
The petmittes d not atst wdzed to du dtasga after the expirotiama date. rn order to receive automatic
eiuluon=don to dnehwga beyond the expfrar m cube, tie per dmw fileu sebmit forms aced face as ate
required try the agmcy wftrkad to raster pamits no later thin 180 deA prior to tie cxpiratiptt dace. Any
permutes that has not rrxpm and renewal at least 180 days prier to exp mdoa, or my permidee fiat does not
have a permit attar the expi rarkm and bag not rcquiested nmmuval nt test 180 days prior to esgimdoA wUbe
subjected to cnfcwvmew prc cvdurea as provided its NCGS. j 143-2153.6 and 33 USC 1251 et s*
„1
1.�.C�IfS -F ,..
This permit is not transfimb' le to any-pacm except after notice to and approval by the Dirmwr. The
DuwWrmay require modification or rm=tion and rciiwanCe of dw permit to change dia name and
incorporate such other rurairments as may be necessary under the C om Water Act. 'The Permittee iz i
required to notify the Divialon iniwritinll in the event the ptrmltted facaity is wld�cr cl mw&
Si�natoru.#�eniranent4. 'r: ;i ;w;
All applications, reports, of information submitted to the Dhrc pw steal! be signed awl certified
a. All applications "to be coveted tinder this individual pettttit shall be Lived as follot*;s
;; 'i ,+,.
{1) in this case of a corponttiow by a principal executive offiaec of at leid the level of rice-
L+. prvsidznt, or ha duly mtlxmixad represen=ve, if such represotative is respondble far +.
&a Overall opomrion of the facility from wltisb the diW arfla describrd,iu the permit
applicadon form originates; ; ;►'
(2) • in din case of a parbncsshiy or limited partnership: by a •Feral par=r,,
(3) in Hte case of a, solo propriatombip: by the propriety,
(4) in die can of a mimiccipal, state, or other pnblie amity. by tr prmeipai Omcutiv6 officer,
rrdlangtiactrd official, or other duly autl►oriecd employe J ti
b- ;J1 reports regtdmd by the individual permit and other inibtmstion regtxstod by the Va=tor sba11
be signed by a person deacttibed above or by Is duty anthadaed reprem mtstive of that penou. A
person is a. duly nulhot reprewrative mly if
(1) The atuhorizaihon is made in writing by a peasaio did above;r
(2) The at dwrization specified eid= an individual at a position !raving mwoosrbUity for the
overall opw4aua of the regulated Sscility or ac&ity, such as the position ofplant
M=nW, operator era Welt of well held, sttprrinEr:ndmat; a pogititrn of equNalwt
Part M Page 3 of It 6 ,
31

^ i MAY-02-2011 MON 09 : 31 M NEX i 0N/ACHE FAX N0, 9106554749 2;; 23
• Perinit No. NCS000533
`r! C
Ct
tespansibilrty, ar an individual or poAtion hnvids overall rmpomiitaty for eavirowmente
;t mamen for tlte'conwarty. (A dulY audborimA repreunmva may dw 6e either a named �.
individual or auy.icdi WvW occupying a terned position.); and
(3) -The tytict n mWmintion is mibmimd to thin Director.
"r a. Any person siMN a dpcuzn= under paragraph+ a. or b. of this section shall make the follow
catti$catidn:
'T auft anA& penmW of law, that this docu neat and all atmbmmm we, prepnod Dnder tint
direction or Pq=vision is accordance with a vj%Wm designed to amsm that qualifiled pessatmd
properly gorier and evaluate dm inft=tior vAnnitted Bayed on my inquisy of the perttau or
pemms who saanage do ggWm, or &on persona dirmAy ter xnmble lbr gatberm& to
k&rn mWoo, the mf=iadost submitted ia, to dw best of my knowirdge sad belief; true, axwmte,
and catnpletr. I an swats that du= are sipAcant p=tddea for submitting W= infmmatioa,
mclndittg the posit-rMw of &a and unprisomu=1 for ]mowing vinlatioas "
4. vi ca s.
`t The im ace of this individual permk does hot prolutat the Director frets reopeWng and modifying the
>: individual permit, mvolang aced reiesaing the individual permit, or tenmmadvi the individual permit as
r
a, tliowed by dw lawh rules, and rqp adona conmined in Title 40, Coda of Federal Regolatiotte, Farts 122
and 123; Title 15A of die North Carolina Adminia rative Code, Subebapter 29.0100, and North Carolina
General Statute 143-215.1 et aL 4;
a! a 5. .POWix'...Q
i t ; The permit may be modified, mwokod mod xeWuod, or tumimated for caw& The notification of p,anaed
e 17 changes or and6pamd. nonmmpli=e loco not stay any individual permit Condition.
=•t
SEMOY.Q_- OPEMaTION AND MAIMNANCE OF POLY.dMON CONTROLS
7 1. •OD r.s
.. " The persnifto shall at all times ptopmiy opmW and makitain all fttcilidw and syst m Of treatment U d
;3 control (amd related app crs) which are installed or umd by the perurittee to 4cme cntsspliame with
tie {OQdWOM of this individual pemmit. Proper operation sad mainwm nce also inctudrs adequate
laboratory coatrais and appmp use quality ash ptnoadurae. T1tis provision requires die op«ation of
back-4 or tuxgiuy tbciW4m or similar sysrmm# which are mam ed by a pertm= Oa1y when the operation
i3 noOesrary to achieve compU"= with'the maditione.bf this individual permit.
€ a
2. Need to I Rcduca Not a Def nae f� a
It sbail eat bo a defense for a permittee is an enforcement amino hear it would lurve been necessary to halt or
roduce the permitted activity m order to mmnbm compliance wuh the -.=die = of this wdividuat pemia
3. 13yREU&S-of S=ag= QaQ=I_EWIitiezy
Bypass is prohibited and the Di%=W may take aaforcem*nt action against a perrais ce for bypass uakas:
fx
A. Bypass was-unavoidahk to pmvemt loss of li#b, personal injury or severe grapettY d maga; sad
a
part III Pep 4 of 8
ff
I

KAY-02--2011 PION 09: 32 AM HEX ION/ACME
FAX N0, 9106554749
P. 24
Permit No. NCSO00533
b. Them wcro na feWbta aitarae" to the bm wa. zwh w the use of at tWky eaatrol fatalides,
rab=don of RM=wster or msi rteusnee during nonnel paid& of equkmwd downd= or dry
weather: This coudition is not 9&49 ed if adequate btt darpvm&als shoWd have been•installed'in
file exercise of rtasonable engineering judgment to pmvaata bypass which occurred *zmg rwrmal
prioda of cgvWumt downtime or ptevendve raairtteman= and
c. Tlta permitter su6ma and notices as required trades, Part M Section S of ft penait.
If &o X)h+actor dca w mhm diet it will meet the tuft were dow liaded shave. dle Diromor may approve as
anticipated bypass ai w considering its advem eff6AL
SIMON D: MONFi OMG AND RIPCORDS ~:3
L R==C4Qdbffl so"
Steles courted sad meannemeas mien, at required hat in, a mll he char a rkde of the volume and
nature of the permim:d discharge. Analytical uaapling sball be pet4htmed daring a rcpxtise dWve swan
event Samples shall be talmn on a day and time that is chamCtmisdc oftbn dLwlm m All semplo9 shall be
taken &fbm the discharge jofna or is diiluted by any other wears stream, body of water, or substance.
Monitoring points as spe tified in thin paxm -"I not be changed without notificakon to and approval of
the Director.
2. etordins lSe F' Y.
3.
4.
For tech remeat, sample, inspection or roiintenaace activity patmued or eoAected pursuant to the
rcquiLe is of rhia in4Mdual perrair, the perraiteee Shall record the following information:
a. The date, exact place, and time of sampling, zowsllfemanns im-pection of ilraiatenanee scdvit ,,
b. Tbz individual(s) who performed the sampling, mtmunn=%, nupwtion or maintm=ce activity,
() petfarmed; C. The dares anabmex were
a
d. The individual(s) vrh9 perforated the saalyoea;
f "sJ
e. The attah6aM techmClu or tnetirads sled; and
E The resolm of such anslysm-
M
Wh"a rognu4 cpWapsiate flow mamw mmt devices and mad3oda cc-,, east whir accepted scientMe .
pmam= aball be selwwd and used to onsets the acctusry and reliability of meesuti atenm of tfre vahne of
waidtored diacbarges.
Test procadtues for fire analysis of polhrtmwb shall conforor to tut EMC rogt Pions published p+ttstrara to
NCGS 143-215.63 et. scq, the Werner and Air Quality Reponiug Ate, and to regulations published purauurt
to Section 304(g), 33 LiSC 1314, of the Pedwal Waw PoMon Cancol Arm as Amet Arad RxO lotion
40 CFR 136,
Piirt m . Pare S of 8

MAY-02-2411 MON 03:32 AM HEXION/ACME FAX N0, 91013554T43 P. 25
_ �. .�
�: ry
Permit Ida NCS0005]3
To moet the inflect of the monlearing required by this individnalgermit, all teat ptnot duns must pmdura
minimum detection and reparting levels sad all data glaciated must be rgxrtcd down to the trim urn
dateaina or lower cepotti level of the FWO&&-
S. AMSMAKNe QQ fWl '
If a fimiliry has nmultiplC dire brtgo ineationg with aubafantiaily identical stntasw4ter,disebarge9 that are
rcVaired to be ampled, the prrmatee luny petition the Dmactor for rcymsmawa otuflsll atwua, if it is
eMblished that the etatmweter discharges are sabatautislly identical and the penbitme is S=wd
rcpMeMbe otstfdil BU Ws, d= tuunplWk t 'may bo partumad at a reduced numbw of outAdb.
6. Reco"Ja Ratrrttinn ;r
t d
Visual monitoring shall W documenttd and retards tnaiataiaed at the &cilky along with the Stormwatnr
Pallutlon Prevenflon Pisa. Copies of analytical monitoring results shall also be masnmiued on- w. The
peottattee shall mtaia roeards of ail monitoring ioafbreaadon, including all calibration and maintenance
records and all original strip chart reca *no fbr aontinuaw amaitorfmg in tiara. and copies of all
reports required bythis wdividual permit fur &period of at least 3 yam $ram the date of the sample,
E�
mt&suretnant, report or appiicarka. This period may be axiendm by request of the Director at any trine.
7. [Are,SMM andFntrg „
The per=aw slush allow the Director, or an suthosized repreaaatativa rumbidiug an authorized contractor
acting as a nVr=ntWvc of tba Dimctor). or in the ear of a facility which divlarges d rougls a municiyal
separate storm sewer syst= an autisorized rcpwxer&tive of a tmm%ipal aperaflor or the separate atom
,j scwtr syatmn oweiving the d v1wgec, upon the praftation of cRdrstbala and other documattts as any be
reguirad by law, to;
a. Eutrr upon the permit'teda pramum where a regulated hcilsty i activity is located or conducted,
or wl= records must be kept urxkr the condition of ibis huRvidual permit;
b. Have eeeatm tp sad copy, et treasonable tines, any reeorda that mud be kept undcr the conditions of 4
this iedivi ml permit;
;.
C. -inspect at reasonable tines any f aiim% equipment (including monimring and cou)xol equipmMI),
practices, or opmtiona regulated or mquued tinder this indM&W permit sad
' d. Sample or monitor at raesanable times, for df w pvrpom of assmmg individual permit conVItaace
or as otherwise authorimd by the Clan Wales Act, =y'subatances or parameters at any location.
:z
SECTIONE: R�POliT1NGAEQVI"MN;YI<'S
I. Dt_gc�ygrlfottitiriaQ ReeQrts
Samples aaAyzM in accordance with the tarns of this permit shall be rnbmittad to the Division as
Disciwge Monitoring Report forms provided by the Dire& tcr. St dmU be delivered to the Division
aj no later than 30 days from the date the facility rwxivea the asmpling resuhs from the laborstary.
Thepermxae shall submit an Annual summary Dan Monitoring Report to rite appropriate DWQ RzSional
Office by Mardi 1 of each year that munmari.zas data Pram the ptCviaus calendar ycar. Tile vabmittai shall
be on 5ortas supplied by the Division.
Part III Page 6 of a

MAY-02-2011 MM 09:32 AM HERION/ACME FAX Na 9106554749
P. 26
Pennif No. NCS000533
VAen-aD &schaga has occurred ftm the fiw4trty during tim iepm period, the pen=tM U required to
submit a diwimme mouitming repent within 30 days of the end of do We&a=*s=Qpft period, giving
all nquired inibzmarioa and indicating "NO FLOW" as paNCAC T11A MB.0506.
The pmudifts shall it eord the roqubvd Va=w monitoring obsovatiaw an the SDO Qualitative
Mmutanng Rapml form provided by the Divalm and shall rettiza ffic comVkW fima an sate. V1mW
amdWring results Should not be submitted to the DivixiM except tq= DWQ's specific requb=ent to do
as
2. SEbmigWalwom
Two signed capita of Discharge MnaitoxiAg Reports (DMR-S) shall bcs -brabW M:
Carad PRO
Division of Water Quality
1617 Ma Service Cmrjw
Rakigk Worth Carolina 27699-1617
51
Io additioN a sqwaft signed Annual Summary DMR copy than be submitted to the IDW DWQ Regional
Offic:6 (RD) by March I ofeaeb year (Ste 1. abova)..
Addresics for each RO and dx coundes covered by mch RO can be 1bund hm
Tbt permitme A4 retain the completed origimb
on site: Visual monitoring molts should not be nftmiftd to ft R000gml Offim or QmtW Rk3 nnlam
v--if=4kY-rCqUWV5d by DWQ-
ExmV far,data determirted w be confidential wider NCrrS 143-2153(a)(2) or Section 3(2'ef the Federal
Act, 33 USC 1318, all reports prapzred-in axardanoe With the W" shall be available for . PUbgG bapoCtiML
at the offim of tie Division of Waxer Quality. As required by dw Aix. anablical d&% shell not be
considered confidential. Knowiney making ztry.fflsv swment an any arch report may result in the
imposition of =ininA venaltim as provided Er in NCOS 143-245.6B or in Section 309 of din Fedwal Act-
4. XMSMMM=j)•VLh_qW
Tf the stom ev=t monitored in no0oulanct with this Individual Permit coinckke with a norb-ItonrAntrr
diNharrthc pmmifttea shag separately monitor all panime" n rwAimcl wider the non-StormwaW
dWIar,p pmat and provide this information with the normvnier diachmW monitoring report
5. PU=4 Qm=
TbC Pennijue 9)an give noffne to tho I)ife=r as BGM as Possible of any plenued ebanges at the parnotted
tcinly which could zignificw* alter the nature or qw6ty ofpoliamnty discharged. TbU uod&=�"n
requircomentincludes pollutants which are not specifically hittd in the Individual Permit or subject to
notij5wioo regisireweats imder 40CFELPert j22.42(4
jk penwittm Shau give nodoo to the Director U SWU 03 passible of any planned Ahagms 81 the pwMitted
facility which MRY rOSUft in nQVC4WMP1WWC with the IfAVi&d FMV11it rGqUWCMCM-
Z
rmt M Pap 7 of 8

MAY-02-2011 MON 09:32 AM HEXION/ACM£ FAX N0. 9106554749 P, 27
Permit No. NCS000533 "
x.
it
7. t1 .� F•;
The peimittee mall report to the lord! DWQ Raooaal office, with 34 >ourt. all dgnifcant spills as
de&ned is Part VI of this permit. Additionally, the pe:mitten Shell report spills mchk tlg: any oil spill of 1S
gallons or mom any spill ragardJass of anent that causes a abeen on mrf m waters, uW oil spill
regardless of amount oo=uiag within 100 that o€surthce vv4tcre, and any oil spill less than 2S gallons that
y . t: cannot be cle ancd up within 24 bo=.., -
a. Anticipated bypass, If the pemil ax itnovus iu advance of the need fof a byp&04 it ahali gubmit
prior nodco, if pom-blc at !asset ten days befnrn the dare of the bypass; including an evaluation of
the anticipated quality and affect of the bypass.
b. Unanticipated bypass. The penaittae shall submitnotica within 24 how ofbacomiag awars of as g=
Unanticipated bypass,
9�
Y The pernoiwm shall report to the cents! office or the Appropriate regional. office any ooncomplLme which
may endanger health or tho environment. Any information shall be provided orally wid& 24 hours from
Ow time the permittee became aware of the cimumstancas. A written si& shall also be provided
widufn 5 days of the. tirua the perauttee bacon= swam of the chmumstanco.
e°.
The written std=imion shall contain a description of the poncomplianee, sad its esusca; tEte period of
nnacompheace, mcludias a act dates and tires, and if the noncompliance has act been corrected. dta
anticipated titre compliance is=Weated to continue: and stain talttau or planned to re tue, dirninate, and xa
prevent reoccurrence of the nonconWliance. }"
The Director may waive the vrd*n report on a case-by-com basis if tiro oral report has been received
within 24 hours.
10. 1' r!
The petmittee shall reportaU instances of aoncampliance not reporrcd under 24 hoar rtportiag at the rands
mounting reports are subraittt:d
11, Other infnnajm
Where the permittee becomes aware that it famed to submit any mlavant faces in a Notice of intent to be
_covered +miler this Individual Permit or is any report to the Direemr, it shall proatpdy gubmit such flea or
0 fnrmatiou.
Partin Page 8 of 8

MAY-02-2011 MON 0912 AN HEX ION/ACHE
-FAX NO. 9106564749 28
NCS000533
PAATrV :LDMATIONS REOPEN= 6
This individual permit "I.be modified or alumnativciy, revoked and reisoad. to comply with any zpplicabla
affluent Sukkime or water quality &andad kmwd or approved under Secdm 30*) (2) (q}, and (d). 304(b) (2) and
307(a) of the Cleat WAW_ Act, if the effluent guidelim or watm qualiry sundard so iss=d or approved:
a. Contains diffarent conditiom or is &dmwise mare stringent dLan any effl ft individual
perraw. at
b. Controls any Pollutant not Rotted ift the imfivid permit.
Tile individualpermit as modified OT ro&qu;[ under this pwigmh'ihall Also contain any o0weqiremeab in the
Act ditid aMU=bh,-
PART V ADUMMTKMCm AND COMPLUNCE 140NMORMG PER
RXQUMEMZNTS
The pe=ftc must pay the adminisu ring =6 compliance monitoring fee within 30 (thirty) days after being billed by
thaDivision. Failure'to pay the fee in timely manner mi accordance with 15,kNCAC 214.0105(b)(4) may Cauie this
Division to initiate action 10 MWkC the Individual Permit.
PMM VIt DEUark1NS
&NO
See Clean Water Act ..Z
2.
This pama regw*m stormwater discharges. Won-stormwast disctwgos which shall be allowed In the
stormwater emveywce Sys*= are:
All other discharges that am authorized by A non-storrawaum NPDES peanit
(b) T.Ta=ntsaninated groundwater, ftidatiop drains, air -conditioner condensate without 4d&d
eheznjcals, springs, discharges of uncontaminated potable vmm wm=rm snd fire hydrant
fluablaM water from footing drUns, flows from riparian balm Cats and wetlands.
(c). Discharges resulting from Ste-fi&M or fire-flOdno training
3. Bw MMA8M=EMgkM. aws)
Measurts or proctim used to redow the amount of pollution entming Surfim MW& IDWs way tako the
i`orm of a process, activity, Or Phymai structure,Morc itformadw on MOs can be fbund au
A bypau is the known chverajon of atormwawr from any portion of a starmwatu control %M&Y including
the collection tystem. which is not a designed or established bperafte mode for dw facilicy-
S. 819k Sto QWg Err
- - 4sts - _?
Liquid raw MnMTWS, Mnu&CW.,sd products, weave MAWizk or by,, �_- wiffi a single above ground
storage container having a capacity of wester than 660 OJIms Or wi2h =16PIt Above 001md SOMIP
conmims loomed in close proximity W each whar having a mW combined starap capacity of greater than
1,320 CW1w.
Appendix A: Pigs Vof 4

MAY-02-2011 MOH 09:33 AM HEXIOH/ACME
FAX NO, 9106554749
Permit No. NCSO005.)3
6. cemr
The Certificate of Coverage (COC) is the cover Am= whicb wconipanks the IndwwW P== won
fssuanceand lists the bciftname, kwAdm ree6viag st=mo, river basin, effective date of coveter wider
dw permit and is signed by the Djwtor.
7. Q= 3W—A= Act
The Fed"W WftterPoMon Control AM also known as the Clean Water Mt (CWA), asamen" 33 USC
12S I, et Saoq.
8. DW193an or DM
TU Division of Water Quality. DeparWwmt of Environmont and Noftind Resourcu.
9. DiM=
The Diroctar of the Division of Water Quality, the pemift issuing authority.
Thor North Carolina Etrvironm=ral Mansounew Commission.
gab SA=l
Aniudividualsample coLloctedinseam' =usly. drab samples that will be analyzed (quantitatively CW
qafiMti y) moat be taken within ffie. MV 30 minutai of discharM
12.
Any substma deWgnated under 40 C7R Part 116 pursuant to Station 311 of tare Clean Water Aa,
13.
A disposal ftciliry or part of a disposal facility whom waste is placed in or an brid and which is not a land
treatment facility, a surface impoundment, an injwtlm wrIL a hanu4ous wane long-term Starzv fiwilfty or
awraze 5"a &cility. LI)
14. kw9gipAl SON= Storm Sgava Us=
A stosmwater collection system wid& an incorporated area of local self gavanax= S=b as a city or town
:7
I.A, is. NgjjuQ=
A condition of no aqpowm means drat all induawW mwzrWa and activities are prometed by a storm
renstaut shcUtr or ammphihk n=gc conunifts to p=vtnt expasore to rain. snow, snowmek or =OfE
IndutriiLL mamiala or activities inchAe, but are pot limited to, matcrW handling equipment or activities,
mdui*W mwll=y, raw mawriaK intermediate products, by-products, &W prod=m or wasto prodxwm
DWQ may Vans a No Ezpomt ExcWon &-= IRDES Swrmwatcr Pennining requirement& only if a
twingy complies with the urtm and oawdiimu des=ibed m 40 CM § I 22-26(g)
16.: Notice of
The suft VpUzaaon form which, wben submitted to the Dr. WON officially wAtcates the fuiliO wtLOe Of
itgent to seek coverage under an ln&vibd Permit
17. Nimitm
The owner or operaWf issued &Cartjfi&j6 Of 00VtMgC VDISUMa to this IndiVidUAl PeMiL
Appendix A: Pap 2 Of* PaPi
P.-�. 29
Ej

MAY02-2011 MOM 09:33 AM HEX 10N/ACID FAX N0, 9108554749 F;, 30
(% C' 1 Permit No.NCSOM533
18. 'r: Point q tare. Dirc, [m of tonm�ntrr s�
Ally diseet7 Ile, d: a6 wd and that zm conveyance iMcb:dW& but not specifically limited to, any piper ditch,
141"wJ, tamnel, condtait, arch, or d e reft fimm &mn which srarn watw is or may be discharged to waters
of the st" H
19. m
A atom eve; that maamrd greater than 0.1 mcheS of rainfall. The time bctwcm this smrat evrar and the previoaa
storm event mumning greater tuna 0.1 iacbes must be at least 72 hoaM A Single stout event may Lave a period of
no precipitation of up to 10 bout.. For example. if it rains but stops bef= ptoduoing nay collectable discharge, a
sample may be collected if the nW rant producing a diadwrgc begs wioin 10 hount
€: 20. -g stdve �fito
Men it is esnibliahed that the dixcharye ofsmtmwater runnff from a ei¢g1e otufall is reMaentative of the
discharges st multiple outfalls, the DWQ may pant representative autfall starve. Repmmtawe outfali
status allows the pertnittee to pe f= analytical mouimaing or a ceduced mttal w of outfidU.
21. •
Spill caotai>uume fbr ulna coatterats of the single largest tank within the containment smrctive plus WHicicut
6rxboard to allow for the 25year, 24-hour storm evm
}W • �E
22. Socting 313 Eam priority
A chemical or chernicsal eategory which-- 'o :
a. Is listed in 40 CFR 372.65 pursuant to S action 313 of"I"ide III of the Superfm4 Ar a Wments and
Rcia&osizatioa Act (SARA) of 1986, also titled the Emergency Pluming and CovA unity Right -
to -Know Act of 1986;
b. is present at or above dnsbold'levels at a facility subject to SARA title UL Sectaen 313 repovi6r.
requirements; and
C. Meets at least fine of the following criteria: -
(1) Is listed in apperdbr D of40 CFR part 122 on Table 11(orpoic pAoritypotiutants), Table
M (certain metals, cymides, zhd phaools) or Table IV {cercaitt pia pollutants and
hazardous substances); ti
(2) Is listed as Machw subswim pau5taant to section 3 f l(b)(2)(A) of the CWA at 40
CFR 116.4; or
(3) is a pollutant ibr which EPA has pubWhad actor chronic wator quality criteria
23. �SeverePmecrlS►Damagg is r; .� -t R
Mmw suUsatial pluy6ad damage to property, damage to the control faciiitiea which undies &M to
become .nop mble, or su>bstatalial and panissneat loss of natural resources which can n motlably be .
emoted to aoc= in the sbunce of a bypass. Seven property damn¢a does not inm econo,nic lose caused
by delays in production. `s
24. Sianificaat_Mamrials :
Inchxka, but is not limited to taw mate ULS: fuels; mattxiAls such as wdvmts, dt: M-11ta, xrs:f plastic
pellcM fl aished moon -ilia such as metallic pwducta; raw materials used in food proccasleg nr production;
hazudouu substances designated under seodon 10104) of CERCiA; any chemical the facility is requited to
report paxsuant to reedou 313 of Title III of SARA. £ertillzaa; peslcides; and waett producm such as ashes,
slag and ahzdgo that bare the pa atrial to be released with zwnnwA=. dlsrbarjes. :•
25. Sialr0cant SDBU
Includes, but is not limited to: releases of 00 of ha=rdoua subaad= incwl= of RPQrtable quand6es
under anodes 311 of the Clean Wwor Aix (RcE 40 CFIL 110.10 and cFR 117.21) or section 102 of:
CERCLA (RE 40 CFdt 302.41 , + ti
Appendix A: Page 3 of 4 Pages

Im
MAY-02-2nil MON 0913 AM HEX IOWACME
FAX No. 9106554749 P. 31
Permit No. NCS000S33
2 & SWMn=j)iKhAM Og*H-tSDOI
Die point of departure of stmmnvatar ftm a dicemibla, confiocd, at discim o=vey=rA Wchding but not
IfTniteA to, gCKM SCM pipm drainage ditchm dxa=*N spillways, or chanulized eellection arena from
which stotmwaw Bova di eq* or hullrectly into wnftm of the State of North CuolftL
27. SWMRWMRIW
The flow of crater WWA I=Wts from pm*itadw and Aiich omm fmmedid* following rainfall or as &
V%Wt OfMOWnek.
29.,
gMMm=&ff9dfiQ with Lnbadal.
The discbamp fi= my point soww which is used for collecting and conveying atormwatcr and vgiich is
directly relmed to mam, cWrtq& processing or taw mawziAl storage arms at an WdusuW sits Facilities
considered to be wppd in "industrial activities" ivohide ftm activities defined in 40 CFR 122.26(b)(14).
The term does not lachtdo ftchn" tram faciRties or activities e=fudod fi= did N?DES progmm
29. SWDMkI b24120 PIM ,t
A - compreham-dve sa&q�ecilic plan which detWs measum and practices to reduce aairmwwr palbstion and
is bawd on an avakmtion of the polhition pot=dnl of the afte,
30.
31.
,32.
33.
TcCAMaimuci PAW Load MKD-L-)
I'NMI4 are valtum plans fair amtioing and mabitaini.g water quality standards, in all seasons, for a specifir
water body and polhimt, CA list of appinved TMDLa for dw mate of North Carolina can be fiawd at
Toxic P'6
..-;kny pollutant UsW as bxdc undc7 Section 307(a)(1) of the Claw Watez ACL
YAi&k MalUtme= Activity
Vehicle rchs6ilftadoA mechanical repairs, painting. fixEug, lubricadon, vehicle ckaWas operations, or
airpao 6iclng opwaion&
A V*S awk S2&9=192
Solid particulate mow, both mineral ead organic, that has bm or is be* transported by wxter• air,
gravity,. or ioa from its she of origin which can be x= with The wWded eye.
34-,',� 25:=L 21 how- Om
The max ' imarn 24-hour pmcipitWon,event expected to be equaled or exceeded, an the everam once is 25
YMM.
9
Appendix A.- Pap 4 of4 I'x9m
a

HAY-02 2011 HON.09 33 AN HE1{1DFt/AN FAX M 9106554749 py 32
NCSo00S33
TES
ss
APpE15TDL A: ACiJTE TDICiT Y TIl`dG F]R S ORMEAT R OU i"FAl1:LS
I. ANNUAL TF.ST.f1 VG _(PASS/F A'r"i1TE TOJl�IC1;C'lP MM5LGjC ,r,
The per>a lace. shall conduct atatte ta%Wty tests an a Yearly leads using pratocols defined in the North
Carolina Procedure Document entided "Pass/Fail Methodology for Determining Acuto Toxicity in a 4i,
Single Effluent Cov=tradW (Revised -July, 1992 at subsequaut versions). The monitoring shall be
performed as a "wster floc" (CerkmEvAn a dubia) 494 nur static teat
Stotmwater samples Shall be collected as a single grab smnoc. Samples for self-monitorkg purposes
mist be obtained darmg a rep tine storm event. 71m tests will be performed during the first six
monttu of the year (January -June).
If at any time there is sipificans mortality at a sWMwatcr CATUC ti conzentration of IF / the results
will be oonsidemd as a bcrbmarir cxecedanea of toxk*.
Vs
t:
All toxicity testing results required as pate of this pa=it condition will be cared on the Stormwater
Discharge MoWtodug Form (DMR) for the mount in which it was performed, siting the parameter code
TGA3D. One copy shall be submitted to Central Files, and one copy shall be submitted to the
Storsnwater Ptimitting Unitas fallows:
y Attention: Central Files o •, .' }'' �:� :�,o
Division of Water Quality +i
lf>17 Mail Service Center
Raleigh, North Carolina 27699-1611
Attention: 'Stotinwater Pcrmtttin unit
Division of Water Quality
1617 Mail Service Centel ti
41 1t.aleighr North Carolina 27699-1617
Additionally, DWQ Fornt AT-2 four Acute Pass/Fail Tests (original} is to be sent to the following
address:
Attention: �N D$NR / DIVQ I Emirotsmentsl,Sdeam Section
1621 Mail Service Penter
Raleigh, Notch Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be sent and postmarked to the Environmental Sciences
Section and Central Ftlas no later than 30 days after the end of the month in which the test was
conducted
Test data shall 'be complete and accurate and include all supporting chemicaVPhYsioal mcasurertients
perforated in association with Ehe toxicity tests, as well as all dosehcsponsz data- Total msi&4 chlorine
of the stanaswater toxicity sample must be measured and reported if chlorine is employed for disinfection
of the stormwatter discharge. q
If there is no stortawater discharge from the facility during the moults which toxicity monitoring is
requited, the permittee will complete the information located at both the top of the aquatic toxicity (AT)
AMeafc A: Page n of 4
e

MAY-02-2011 MON 09:33 AM 11EXION/ACE
FAX NO. 9106554749 P. 33
-r::l
Permit No. NCS0005-33
lest farm and DMR indicating the facility namo,.penait to znber, starmwater outfall number, county, and
the month/year of the report with the notation of "No FkW in the comat►ent area of the form. The
perm ittee shall subunit three (3) "no flow" reports; one deport sh;&T1 be submitted to the lrnvironmewd
W .� Sciences Section, one to the Stormwater Permitting Unit (SPU) Cement Office, and one report &pall be
sent to Central Files at the address cited abom. Zhepermittee shalt submit acute twricity monitoring as
outlined abaves, at the new available repnesentatiw ftorm event.
ff.: A CUDa FQAEzd&M1L
Should any single scheduled monitoring Indicate a &ilnre to meet todeily benchma* levels, a
series of measures dM occur.
tt
I} Within 30 calendar days'from availability of the test results, the peratittee shah! confect the
Division SPU Central Office and the Rtegiond Office Supa viswin MVLh]N,.
a.#,odrer stormwwter Monitoring parameter have eraceaded btenchnuark vetoes, the
itegianal Office may exam" pt the permittee from additional acute toxicity monitoring
'= (others rhea regularly achcdtticd test periods), at the Regfonal 0 cg's discretion.
7p per' ee shall coudauc ID
Add=gAl other 9grmata_ amrterbucinGhwlirk
�. t.
b. it dw permittee has not exegaded other benchmark Values, pj if the Regional Office
does•not exempt the permitt<ee fro' fiddfNoaa] fsronitotrlug, the peunitt4e sheath
�'.
kq; immediately institute ►nanthly acute tonicity monitoring. with a 4$-hour multiple dilution
test per U.S. EPA Method 2002.0. "Methods for Measuring the Acute Toxicity. Of'
Muents to Freshwater and Marine Organisms," EPA 821/R-02/012 (October 2002).
Alt
IIL ACTIONS LFMQ&TRZ F;'J" 0AUTURJNG IS ffSS"'R'Zrrx' n LB -
If monthly acute to=ielty monitoring is institated pet Section,H above, the permitted shell.PeOorm
the tests per the fallowingeondidoas:
.1) An LC50 greater than 100% shall'be heed as a benchma k passing ondpol= Stormwatec
Permitting Unit (SPil) Central Office may deiertnirto alternative endpoints as ;`poring" on a --
case -try -case bests, depending on the specific characteristics of the facility's storrnwater
discharge. Multiple dilution tests wr'fl ba_rin at 100%, 50%, 25%.13.5%, 6.25% and 0%
stormwater tm.kess other test concentrations are determined vpropmte by the Stormwater
Permitting Unit (SPU) Central Office.
2) Multiple Dilution Test Results shallbesubmitted on form AT-1 for Acute Multiple Dilution
Tests. The parawAw code is ai , '71M perrnittee shall:
a.:-. Submit form AT-1 (odginal) to the DWQ EnvhmmeG W Scicooas Section:
b. Send a completed a Stotrawates DMR farm (original) with an a mcW farm AT-1
(original) to DWQ Central Files:
C. Sand a completed a Stormwater DMR farm (copy) with an emchod farm AT-1 (copy) to
the DWQ StormwwerPesmiitting Unit
0
Appendix A Page 2 of 4 Pages
:I
m

.%.
_HAY-02_2011 MON 09:34 AM HEXION/ACHE FAR NO, 3106554749 P. 34
Pamdt No. NCS000533
3) The petmittee shall perfmm monddy acute toxicity monitoring gW ape of tfwfailaAb
gaNLt condi "ons er.
'+n
n. THREE`CONSECUrM MUTIPLE-DELUTION TESTS PASS. No further tests '
need to be performed until next regularly scleduIed test period.
-OR-
b. METER OF THE FOLLOWING OCCURS: 13
i. A XaZIL M LTIPLE-DILLMON TESTS FAM,,
-OR-
ii. THREE C0IYSLCl7iTl MULTIPLE-D1 Un0N TESTS Fall..
If either of the above occurs, farther actions ore necessary. See lW below.
4) The permittre then submit a suiaznary of all test results for the riiultiple dihttion test series
along with complete copies of the test repose as received firm the tab� to the RegimW
Office Supervisor, to DWQ Ceubzl Files and to SPLL These shah be st=u and poste ,cd within
30 calendar days of reccipt of the last failed or pascal multiple-aution test (as described above
in LT 3)). '• •`
I i . ACTIONS FOR f A.IL ITRE OF)W UL ITIP.L,E DU MON TEATS aRE TRr aP'O7HER
If the peranittee. fails eWker A TOTALOFTWE rmu)41--'-dilution testa or THE THMD
COM,CfilmAltlpl"iludoa teat as descriNA in Section, M 3) b, the permittee shall execute
the fallowing:"
1) A toxicity redution. evaluation CiRE) shall be automatically instituted. Within 30 calendar days
from availability of the test result&, the permittee &ball contact the Division. SPU Central Office
and the Regional Office Supervisor in writing.
a. 1,he permittee shall submit one copy of a plan for conducting a THE to the DWQ SM.
and one copy to the DWQ Enviromnental Sciences' Sbaiou. T hwe copies shall be
submitted within' 60 calendar days of the data of DWQ SPTYs direction to perform the
TRP— ,..
b_ This plan, must be approved by DWQ SPU before the TIRE is begun. A schedule for
,., compkting the T11E shall be established in the plan approval. A Toxicity Idaatification,
Evaluation (M) may be a oanq ostcot of the TRE.
c. Upon DWQ's approval, the THE schedule may be modified if toxicity is intermittent
duaittg the M investigations: A revised WET teat schedule may be established by
DWQ for this period.
r:
2) Additionally after the first year that THE results have been collected and submitted, depending
rert,ke the R aril Office may (among options):
:E Require the permittee to install structural stnnawates controls;
0" Require the permittee to implement other stor=rtwater cantrol measures or AMPS;
"e, Requite the permittee to collect and treat the discharge andlor eliminate the
f� discharge; 14
' ys� Require that tho permiuce implement site moftficnticros to qualify for the No
Exposure Exclusion; or.
�Appendnc A: Page 3 of 4 Papes
4:-

MAY-02-201 i KoN 09, 34 An HEX I ON/AGME
FAX NO. 9106554749 p;;. 35
: Pexmit No. NCS000553
rh fe Require Ow the permitt& perform up -stream and downstream biological assessment
in the receiving water.
!! wISiTRES,a�m T&,44_TfirSrn
Ail acute toritity test rasnits :hail be submitted in a concise summary 0 the end of the five year
permit term. One copy of this report dean be sent to thaRegionai Office Supervisor, one copy to the
SPU Ceiatral Office, and one copy to the DWQ Environmental Scicaicas Scodon.
Should any test data from either these monitoring r equi me ats or teats performed by the North Carolina
Division of Water Quality indicate potential impacts to the t=civing stream, this permit may be re-
opened and modified to include alternate monitoring requirements.
If the Permitter monitors any pollutant more frequently than required by this permik the results of such
. monitoring shall be included in the calculation & reporting of the data submitted on the DMR & all
Acute Toxicity Fornis submitted.
NOTE: failure to achieve test conditions as specified in the cited dolt, such as minimum control
organism survival and appropriate environmental controls, shall constitute an invalid test and will require
., imawdiato follow-up testing to be completed no later than the last day.of the month following the month
`s of the initial monitoring.
�f
r�-
.'h
i1 • • i a e
T
12
,*Vpendix A: Page 4 of 4 Papo

Compliance Inspection Report
Permit: NCS000533 Efiectivs: � 11/01/10 Expiration: 10f31/15 Owner: &liar LLC
SOC: Effective:. Expiration-. Facilttyc Silar t1C - RlegehNood
County: Columbus 333 Neils Eddy Rd
Region: Wilmington
Riegelwood NC 28456
Contact Person: Peter Yurgsi Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC-
Secondary ORC(s):
On -Site Representadve(s):
Related Permits:
Inspection Date: 01/2402012 Entry lime: 01:00 PM
Primary Inspector. Unda Willis
Secondary Inspector(s):
Jean Conway
Reason for Inspection: Routine
Permit Inspection Type: 5tcrmwater Discharge, Individual
Facility Status: ■ Compliant 0 Not Compliant
Question Areas:
i Storm Water
(See attachment summary)
Certification: Phone:
`R
Exit lime: 05:00.PM:
Phone: [phone]
Phone:
Inspection Type: Comp once Evaluation
Page: 1

PWm1t: NCS000633 Owner- Facilfty: Sitar LL.G
inspection Date; 01124120t2 inspection Type: Cornpffanoe Evaluation Reason for Ylsft: Roulim
Inspection Summary:
Data review:
Silar Is experiencing high concentrations of contaminants at several of the outfalls. Sher believes stormwater from the
Momentive and Oakbark facilities are contributory. Silar is responsible for Outfalis 001,.002, and 005. Quarterly
monitoring was conducted throughout 2011 for all 3 outfalls. Benchmark exceedances at 001 are as follows: NH3
(1st&2nd Q), TKN (1st&2nd Q), NO3+NO2 (1st&2nd 0), Copper (2nd,3rd&4th Q), and Zinc (2nd Q). Outfall 002
exceedances are: SOD (1,2&3 Q), COD (1,2&3 Q), NH3 (1st a), TKN (1,2&3 Q), Formaldehyde (1,2&3 Q), Copper tall 4),
Zinc (a114). Outfall 005 eceedanc es are: TSS (1st Q), SOD (1&2 Q), COD (1 &2 Q). NH3 (1st Q), TKN (2nd Q),
Formaldehyde (1 &2 Q), Copper (all 4 Q), Zinc (ail 4 Q) and pH (2nd Q). It is possible that outfalls 002 and 005 can
receive runoff from Momentive site located upgradient. A review of the raw matedals/products used/produced by Silar
does not include formaldehyde or hexamine. A large number of chemicals are used by Silar and some chemical
compositions include nitrogen bearing compounds. it is uncertain if any of the compounds utilized by Silar could
dissociate/decompose to form hexamine or formaldehyde. Tier 2 requirements have been triggered at each outfall,
therefore monthly monitoring is required at all three. Four consecutive exceedances have occurred at Outfall 002 and
Oudall 005 and will require acute toxicity testing at these two outfalls. Should more recent data for Outfall 001 result in 4
consecutive exceedances of any benchmark, acute toxicity testing at that outfall will need to be implemented as well.
Please follow the instructions provided in Appendix A accordingly.
SWP3 Review:
A feasibility study should be Included in the SWP3, see the requirements of the SWP3 on page 2 of 11 in Part II of your
permit Employee training and facility inspections are being performed and documented in accordance with the
requirements of the permit The SWP3 should be amended yearly and the amendments clearly documented. Please
ensure that all good housekeeping measures and BMPs that are implemented be documented.
Site Map: Please include the following Information on the site map: Iatitude/longitude.tor each outfall (including the new
outfall discovered); structural divides in the drainage area such as curbs, drop stormwater inlets, pervious surfaces,
existing stnuctural BMPs and swales; buildings, tanks, secondary containment structures, haul roads, process areas,
staging, storage or loading areas for chemical/waste/product/raw materials (with a key that indicates thespecific/potential
contents of such); arrows that indicate drainage directions in each stormwater outfall drainage area; and property
boundarylines. The accuracy of site elevations from ground survey ratherthanaerial survey woufd likely be more
precise.
Site Inspection:
The condensate discharge from the compressor appears to support bio-growth. Permittee should consider testing the
condensate for COD. The condensate discharges via outfall 005.
The equipment in the area noted as "Sitar 126" was leaking caustic but was contained. This equipment should be fixed
since rain events could contribute volumes In excess of the containment basin and cause an overflow to surface waters.
Please provide adequate maintenance for that equipment to resolve the leaks and dean up and dispose of the caustic
accordingly.
The inspector noted excessive and lush green grass growing in the vicinity of Stormwater Outfall 001 which also shows
very high nitrogen contamination. Please consider investigating any potential for groundwater contamination in this area
that may be breaking out near the surface. Groundwater contamination may be contributing to high levels of pollutants at
Outfall 001,
Page: 2

Owner - FagiMr. Mar LLO
h�apectlon Date. 0MMM12 WpeWon Type- CompUnce Evaktation Reason for Vielt: Rardw
Momentive off loads wastewater to the large storage tanks adjacent to Outfafl 005. The pavement appeared to have
stains from leaks/spills. There Is no containment provided at this location for the activity and any split can be conveyed
directly to surface waters via'Outfall 005. The offloading area should have secondary containment. Personnel should be
present during the entire off loading activity and each event should be documented.
There Is a storm drain drop inlet near the compressdr room that had a build up of solids In it and appeared to have some
contaminants that were decomposing as evidenced by off gassing when disturbed. These stormwater drop inlets need to
be cleaned out regularly and the contents disposed of property on a frequent basis tD eliminate the build up of pollutants.
A dean out schedule for all drop catch basins should be €ncluded in the facility Inspection/good housekeeping areas.
Stains from spilled wastes were noted on the concrete near the chemical disposal receptacles located adjacent to the fine
chemicals and Sitar 026 buildings. There Is containment provided for the storage receptacles, however batter
housekeeping and careful disposal practices should be implemented. Include regular Inspections for the secondary
containment receptacles.
Unrinsed drums are located within the hazardous waste storage secondary containment area. Many were tipped over
with bungs and lids not in place which can allow the contents to comingle with stormwater collected inside the
containment area. The drums should always have lids and bungs in place until the drums are able to be rinsed at the
rinsing station. Any spillage of listed waste comingled with stormwater becomes all wastewater and therefore cannot be
released from the containment area but disposed of property in accordance with waste management regulations.
An outfall was located between the Sitar 126 and Fine Chemicals area that needs to be included in the SWP3 and
monitored In accordance with the NPDES permit requirements.
Concluding comments:
The NPDES permit requires actions be taken when sampling results exceed benchmarks. Tier 1 actions include a
thorough inspection of the facility within two weeks of receiving sampling results. Each area of the facility that can
possibly contribute contamination to stormwater must be evaluated thoroughly to determine whether source controls,
operational controls, or physical improvements (structural controls) should be implemented to improve the qualityof the
stormwater discharges. Whichever action is deemed adequate must be implemented within two months of the
inspection. A record of who conducted the Inspection and the selected actions must be dearly documented by the
permittee. Tier 2 requires that monthly monitoring be implemented if the results from three consecutive monitoring
periods are above the benchmarks. Tier 3 requires notification in writing to the Supervisor of DWQ Surface Water
Protection Section that skxi, ter exceeded benchmarks on four occasions. DWQ.should then provide guidance such
as requiring revised monitoring schedules on a more frequent or less frequent schedule, require the permittee to conduct
acute toxicity testing, require structural stormwater controls, rewire the permittee to implement other stormwater control
measures or require the permittee to implement site modifications to qualify for a no exposure exclusion.
This facility has triggered tier 3 response and therefore DWO Is requiring toxicity testing at outfalls 002 and 005. DWQ is
recommending that Sitar evaluate the site for all potential sources and provide to this office In writing any improvements
whether structural or non structural that should help improve the characteristics of the run off from the site. it should
include a revised site map with all bulk tanks and chemlcaVmw matedal/product/waste storage areas numbered and
provide a key that describes the chemicals used or stored in those areas. Your evaluation and proposed improvements
should also be incorporated into the SWP3 under a section entitled tiered Responses. Various areas of concern have
been identified in this inspection report. Sitar personnel knows the site and the activities therein far better than DWO
inspectors and can therefore provide the best recommendations for solutions to the stormwater problems. DWO would
like to provide Sitar an opportunity to resolve their issues and Identify the issues posed from the adjacent facilities
(Momentive and Oakbark) before exercising any of the other tier three actions at our disposal. Sitar is not compliant with
the requirement to monitor monthly, however, since Sitar requested relief from monthly monitoring due to runoff from
Oakbark and Momentva, DWO will not deem the facility non compliant with that requirement for 2011, however, any
failure to follow the tiered requirements in the future will be addressed accordingly. A follow up inspection will be
conducted during the third quarter of this year.
In October, 2011, you had proposed a subtraction of contaminant concentrations found at outfalls located on
Oakbark/Momentive site from the concentrations of contaminants found at your outfalls. DWO does not believe there is
enough information to support this method for reporting purposes. You should continue to monitor and report the outfalls
in accordance with the data provided by the laboratory. DWO will be receiving monitoring data from Oakbark and
Momentive for their respective ouftafls and therefore will have data that can be referenced.
Page: 3

Parmlt: NCS000533 Owner - FeeiAty: Slhir LLC
Inspection Data 0112412012 Inspecton Typm ComplWm Evatuatlorr Reason for Vbft: Routine
Page: 4

Perrrr:t: NCSOODS33 Oww - Fe ity: SlIar LLC
Umpntlon Date: 01l2OMV tnspeedon Type: Compliarm Evaluation
Roast n for Vtalt: Routine_
Stormwater Pollutlon Prevention Plan
Ym No NA NE __
Does the site have a Stormwater Polkitim Prevention Plan?
0111311
# Does the Plan Include a General Location (USGS) map?
■ : ❑ ❑. ❑
# Does the Plan include a'Narrative Description of Practices'?
■ ©❑- ❑
# Does the Plan include a detailed site map including outfall iocations and drainage areas?
■ ❑ ❑- ❑
# Does the Plan include a lid of signftwt spills occurring during the past 3 years?
■- ❑ ❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
■ 0 ❑ ❑
# Does the facility provide all necessary secondary containment?
■ ❑ 130
# Does the Plan include a BMP summary?
■ ❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■ ❑' ❑ 0
# Does the Plan Include a Preventative Maintenance and Good Housekeeping Plan?
■ ❑ ❑ ❑
# Does the facility provide and document Employee Training?
■ ❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
■ ❑ ❑ ❑:
# is the Plan reviewed and updated annually?
■ ©❑ ❑.
# Does the Plan include a Stormwater Facility Inspection Program?
■ 0 ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
■ ❑ ❑ ❑
Comment:
Qualitative Monitoring
Yes No NA NE
Has the facility conducted Its ChWita5ve Monitoring semi-annually?
■ ❑ ❑ 0
Comment:
Analytical Monitoring:
Yes No NA NE
Has the facility conducted its Analytical monitoring?
■ ❑ ❑ ❑
# Has the facility conducted its AnaN*W monitoring from Vehicle Maintenance areas?
❑ ❑ ■ ❑
Comment:
Permit and Outfalls
Yee Ne NA HE
# Is a copy of the Permit and the Certificate of Coverage available at the site?
■; ❑ ❑ ❑
# Were all outfalls observed during the irrspection?
■ ❑ ❑ ❑
# If the facility has representative outtal♦ status, is it properly documented by the DKftion?
000 0
# Has the facility evaluated all flit (non stormwater) discharges?
■ ❑ ❑ ❑
IN
Page: 5

Penult_ NCS000533 Owner. - Feclltty: Soar LLC
Inspection batm 01/241W12 Inspection Type; Compliance Evaluatlon Reason Mr Visit Routim
Comment: One outfall was located between the Silar 126 and Fine Chemicals areas
(noted by the reference as 'drain pipe" on the Silar site map). This outfall will need to
be added to the site map, identified In the SWP3 and monitored in accordance with the
permit requirements.
Page. 6

NGSOOM 3
i g
- NCDEN
North Carolina Department of Environment and Natural Resources
'Division of Water, Quality,
Beverly Eaves Perdue- Coleen H. Sullins, Dee Freeman
Govemor, Director. Secretary.
STAFF REVIEW AND EVALUATION ..
NPIDES Stormwa#er Permit
Facility Name:
NPDES Permit Number: rm
Facility Location:
Type of Activity:
SIC Code:
Receiving Streams:
River Basin:
Stream Classification:
Proposed:Permit Requirements:
Mon itoringData:
Response Requested by (Date):
Central Offise-Staff Contact:
Special Issues:
Silar, LLC
2.
F: NC500001
333 Neils Eddy Rd Riegelwood, NC (Columbus County):
-
CHEMICAL MANLIFACfURING
2859
See.Figurel., g,
Cape Fear River Basin, Sub -basin 03-06-17
C; SW
See attached draft permit.
See Table 1
Return to: Brian I,ovvther, [phone] f rp
Issue •
Ridin Scale: ] ea to-10 r
Co Hance histo ,
6
Benchmark ezceedance
7:
Location (TMUL, TEE
etc
5;
Other Challenges: •
•' - Acute Tox-
8
-
Di Ratio` .
26144 .
I
Specal, Issues Explanation:: 4
n,
• Tl is.sfte fs part of a larger site which was owned by Wright Corporation. In December 2006 a major---
portion was sold to Hexion.Specialty Chemical: The -sale transferred part of the facility to Hexion and the:
remaining part became Oak -Bark Corporation: This remaining part included Silar.=-Hexion originally asked
to: -transfer the permit with all of the stormwater outfalls. In November,2008, Hexion applied fora
dBC sold Se which raft out 4 ezisiing ouffalls (5W001; SW002,.SW005, and 5W007) On April 22, 2009
ilar� to.Monoine� Polymers which has outfalls SW001„SW002- and SW005:; .
:. o Outfalls-and responsibilities and permits need to be..defihed:for-each company., -
q
■ Hexion�s'stormwater outfalls are 003; 004, 006. 008,.and f?Q9 (from 2(]f}8 application)::
- Oak -Bark Corp. manufacturing area drains to stormwater outfall 007
,¢ 8
Paged of 8'
LE

NCS000533 p +
Silar areas drain to stormwater outfalls 002, 002, and 005.
o 3 Permits wilt be issued for Hexion, OakrBark and Silar. ; A
o The site has had past problems with SW and'WW issues.
Description of Onsite Activities:
• . Sitar LLC (a division of MPD HdWings) manufactures Organosilicon compounds and Fine organics
using batch processes.' m
�e
• The Silar production facilities in Acme, NC�and Scotia, NY are primarily engaged in the manufacture
of organbsilanes; silicones and adhesion promoters for use.in pharmaceutical, biomedical devices,
electronics, industrial and R&D markets. Sitar`s manufacturing facilities are 150 9D02 certified and capable
of producing gram and kilo -lab scale thro4gh multi;ton at the Acme facility. (From www.silar.corn)
Documents Reviewed: e:
NPDES Stormwater Permit Application Materials
• National Heritage Program (NHP) Threaten_ed_.and Endangered Species Database
• Central Files
r�
• EPA Sector -Specific Permit, 2008' ..
• -; 2010 303(d) List, 2008 draft'._
• 2005 Cape Fear Basinwide Plan
e' TRl databaseOV
` m
a History:
June 5, 2009:Application received`
x4
N
ffi
2£ wh
a -.e m m '� S• 0
- L
4 &
���Page 2 of 8 =

NCS000533
m
--NCS0005j
ifkd
'n w
ReciP
Figute.l:- Map of Facility
40
Page 36f 8
� v
.1

NCS000533.
Central Office Review Summary:
1. '6wnees other Permits: No other permits for Sitar LLC were in RIMS. However, on the same site Hexion
Specialty Ch6mi6Is,,0ak-8ark Corporationi and Wright Corporation exist.
• Nexion-;NCS000156Stormwater—UpiresNCO00339swastewaterWQ0022324PUMPLand Haul
'Oak- arks NC5=532 Stormwater in review, WQ0003361 Wastewater Recycling, WQ0005699
.:S6ft:e,DWpoialtbf Residual Solids-
Cdrp— SW8000928 StatiF.Stormwater, WQ0001771 Surface Irrigation- Inactive, WQW15551
Land Application of Residual Solids- Inactive
2. General Observations:
Three Outfalls:
a 001- 3419`69P-7912'2"—.211, 220sq ft with 17,670 sq ft impervious. Silas Drum Warehouse:
treatment is housekeeping training and Mori ftaudits by EHS.
0 002' k-IT 7V -7912'8- — 24,158 sq Ft with 24,159 sq ft.impervious. Silarand Fine Chern'ical-Lab.
treatment is housekeeping training and monthly audits by EHS
0 66S= 3C14' 76' -79 12'6" —, 43,560 sq ft with 15, 119 sq ft impervious. North Side of Silar Plant: treatment
is hodi"ek-e4e"ping training and monthly audits -by EHS. Rel6cated Drum Rinse Station to a contained Area.
-;N6, hificant, spills or lealtiomrred in the -last three years.
Poteiitijl'Pollutants:-�Chlorine, Maghetiu_m, Chloroform, Methylene Chloriclk Tetrachlaroethylene,
Toluene; Allyfthloride, Diethylamine, DimOthylamine, Styrene, Triethylarnine, Trimethylamine, Vinyl
acetate; he .4,
3. Impairment Ijving"iton Creek is not on the 2010 303(d) list but it wai,on the 2008 dr'aft list for turbidity.
Basinwi'di, Plin-lisdILiviingkon Creek as have low dissolved oxygen as.a stresso"e. The Basinwide Plan has no
I . � 7
re_ com6indatichsfob 'Wngston Creek.
4. Threatened iitd.6daoig ; ered. The natural heritage virtual. Workroom shows there two federally protected
iiclius of the facility: AcipeKier br6virostru'(Shortnose (Shonose Sturgeon) and Lysimachia
species within4two mile -
asperufifofia`("g�'h!-Leaf Lobie'strife).
5. Location, C- Sw -
6. Ana lytical . MoriltA- g. 'Notes: SedTable 1. Data submitted with application, ,,7-- A
B06, Cd6,-TS9 Ammonia, TKN'Total Nitrogen, and Formaldehy0e.were over the benchmarks.
• T' Based on"the SIC& 2869 the industry is 6veted.in the EPA Multi -Sector General Permit under Sector C
-d "
Chem Ical,and Allied Pioducts Manufacturing, an Aefining. The sector does not recommend any specific
monitoring.;'
S,
• The r e'werrecoinmendti2ndudingE�Op,'COP,'�-T-S Ammonia, TKN, Total Nitrogen, and Formaldehyde
into. the renewed permit because they are potential pollutants and previous samples in the application
were above.our current benchmarks.
• The reviewer recommends including acute toxicity monitoring. This recommendation is based on the site
having 'many potential pollutants and poor housekeeping by the former owners as well as being requested
by the'regicinal . office. See attached rationale document Ac'ute Toxicity for'more details.
. . . -. .. I.,. u
7. Qualitative Monitoring Notes: Visual observations were done at OutfallsO02,005 and 001 three different.
times.jw6titnies there no rain ¢ut no. other outfalls were identified. That last time was done during rain
_
and it was nota&thafthere was no outfall from this source. All runoff was retained in the small retention"
pond south ofthe outfall. it was observed there was no oil sheen.
Page 4 of 8

i1
_F
- Tabled: Analytical Monitoring •
r a
r,
Sf �
Sample Date
4Egtal'
P,reci llation
P -p
�Dusatlon'
�..,_
P H
BOD,
COD
TSS ,
i ENH3
7KN
Nfl3 + NO2
Total N
Lead
FosrrtelONO
Hexam ne
Total P.
Flow •
(in) z4
{hours}
�f I= i�
�' =
i"
1
.,'
= Barrchinark
Saitchinark
Benchmark
°.
,`.yi�y�`f
.8.9 su
SOm L
�10
7100 -
7.2
20 mglt-
ie.;mgll� �.
30 mglL
0.03
•0.5 mglt,76.00OmgIL
mgiL
m 11.E
to 1L-
er !L
f
inlglL
Bf 1212007 .
„ 0,083 0,$i
1,1.0.87
;
87
' 49
: 4.2 •
8.5 �
5.8 • `
12.3
.` 0.012
0.368
<1'0
0.82
•°
1.
4, - -
'fir- - e
;r .� S(�s
yv r }�Ar'\vu6an Uu z. Lao vvuir
3121/2006 '
It 0,023
& OT
0.487.'
1
+' 2
"OA _
235
4/312006
1 0018
0,92
0:3T
&35-%1'
1.=<;
.39 "
t'4:007
217
8/812006
`0.;052
1,42
11.1
T.07,, ._�
48r
1A.
1 2F1 S`
O'004r
_
` 0095"`",
3
11I1612008''
0;02
0:75
U.STc
t 7.56
B:149
1.3
.003.°
22-.5
2M12007
0.04
9.08
ZZ-
1.02i
xf7.44'�l f
`'$8
1 8�' I..
r Q:005=
24:8
6f12i2007'
0,04
0:67
0,97 ,
' 6.5 ,;
!!
13 ,
K{0:0091
0.17
':
�'
'_ �*;�;pietfidl',QuS.l�itaiw;Welr.�=�=:
- `�+ �-
, • -
r„ .... ... .
'3121 i2006
OD29 '
A 0.83
0.48 `
7.71 ; _
-1.1
ii'0;011'E''
46
4I372006
01022
0,92
0.373
5.96'. f?
23 =
2 3 "
"25 3
' Q.003"
.•t
44
818/2006 '
0�06 5
1:42. -
{IT,% :
t_.'a`B.58'��j�t
'�Nr38"�
0�5
20.6
0.005
= .'0:06� )
2.
11liSlZDOS,
0,034
'. 0,75_�
0.57
:t24: '•'(; 141:..'sz
1S"•t 1'=
1.7'
11.8.
eO.003i
3.98
2/112007 '
, , 0...061
k08''
:1:02 '
"7° 86»-jj�-'
16„= ': 60.
28 " 10.6.
1.1
2/1/2007 "
01061
8 08
1.02
8.6 t.: ,
" 18 'I ' 71
,, 26 1 9 42
3.7, '
13:1
0.004 i
4,51
0:18'
W1212007
(r�,05.
0.67
09SE1 ".
t '=.848�
'' 9,68
4 6:S:r 6.3
2.3
11.8
0.007::
- 8.15
0.54
Over Current Benchmark
f
�.
911a Not Codectltad
I
u ..
v_MY
�6
�
•�
`
�
�
l
1� L
J.
E•
- ._
Page 5 of 8
R

NC-SO0053 3 r
Revised Permit Recommendations: Analytical Monitoring:
1. SOD, COD, TSS, Ammonia, TKN, Total Nitrogen, Formaldehyde and pH have been added to the permit because
they are potential pollutants and were above the benchmarks in the data submitted with the application.
Parameters in this permit include all chemicals reported by the applicant for the May 2009 sampling event,
exceptfor lead.
BOO and COD are a ppropriate`for-theyanous organic chemicals stored and used at the facility, and the
zi ti-,,site.as a while tas had numerous;insta ees of Qlevated levels In the stormwater discharge (Outfalis 002,
aA' r
003, 004, 91, 5, & 006).:
• T55 is indica .ve of housekeeping oc other problems. Tss is -also appropriate for a discharge to receiving
. waters plagues with turbidity problems. u
• Ammonla, TXN (rarganic nitrogen), and Nitrate/Nitrite are above benchmarks in the subrnitted'analysis
;a and are pies^nt with this industrial activity. Nitrate/NV rite3was.rrot above in'the submitted data but in
data from the Hexion file: E
Total Lead is not proposed in the monitoring scheme because levels were well below the 0.03 mg/I
benchmark, and it does not appear to'be present'in the materials here. Noted that there were very few f
= benchmark exceedances in data collected from other outfalls at this site between 2000-09.
o Total Copper, Zinc, and Manganese included because the. potential pollutants and want to be consistent
with Hexion and oak Bark. . : t
r Hexamine and formaldehyde are included in:the permit because they are potential pollutants. Samples
" for formaldehyde are above benchmarks in ttie'submitted;analysis:., i=
« pH is included because of its use as a genefal`and im,mn diate indicator of.probfems (especially With acid;
storage at this faalityL as well as"its im"`portance in interpreting a&idata-such as metals.:
"t, ff. -x �r ',, ;
• Total Petroleum Hydrocatbons (TPliris:induded because -several ails are stored at this site, and fork-lift
traffic may introduce such materials into the discharge:'An alternative to Just oil and Grease (O&G), TPH
can be measurer) with the same method EPA has approved for O&G Vethod 1664, but using Silica Gel.
Treated N-Hexane Extractable Material(SGT-H€M) and an.additionaI step that removes polar/fatty non-
petroleum based material from the sample. This metf b'd is noi_eampound-specific but is less costly, and
still provides an estimate of petroleum hydrocarbon concentration.°This parameter is better targeted_ for
petroleum based materials than O&G, which�c4F;include-animalibased.fats and oils. ,•
• Acute Toxicity has been included for this siti duetto coocernstiaboutmultiple toxic sourtes,as•weli'as
onsite-unknown chemical mixing and resultantunknoyvrrenvironmental toxicity. The ACUTE TOXICITY -
APPENDIX A: -ACUTE TOXICITY.TESTiNG:FOR STORMWATER OUTFALL-S has been include at.the end of the
a
permit text. (See— a<} d�.eo Tax {-�t - Y-Mtmr.a- Cti.►..e-...�
2. All analytical monitoring is quarterlK during a representative storm event as defined in Part ll Section B. this
frequency is higher than the standard temi-annual, but is consistent with,proposed monitoring in draft -
� r i� i
w permits for the other manufacturers at this site (Hexion°and.silar). The frequency is also appropriate given
DWgs elevated concern about stormwater'contaminatinn from past activities. Because the retention pond
discharges more rarely, Oak -Bark will probably not see flow from its one outfall,for many of -those quarters.
3. Benchrre Mr for analytical monitoring are included with this draft permit. Exceedances of benchmark values
require the permittee to increase monitoring; Increase management actions, increase record keeping, and/or
install storrnwater Best Management i?raetices` Smps)in:atiered •program. If sampling.results are above a'
benchmark value, or outside of the benchmark range, for any parameter at any outfall then the facility should
n- . follow the Tiered response guidelines.* 4- i
4. The permittee is required to collect all of the analytical and qualitative monitoring samples during a
representative storm event as defined in Part II Section B. Qualitative monitoring is required to coincide.
5. The flow reporting requirement is not included, per DWQ revised strategy. Total rainfall is in the permit,
d,
however, andcan be used with'impervious area information to estimate flow. Impervious area detail is
� 4 1
1
Page 6 of 8
,i�

s -NCS000533
;y
'required to be documented in the.permittee s SPPP_ L'
6. VehOe maintenance monitoring included, if ever applicable at this site (proposed quarterly to be consistent
.. with other monitoring, which would occur at the same outfall).
Discussions with permittee: Peter Yurgelf Plant Manager, 910-655-6980,.9/22/2009 °
o
1. Visual observations in the application describe the only outfalls as 002, 005, and 007 but the outfalls are listed
as 001, 002, and;005.. Are these the same outfalls? Outfalls are 001, 002 and 005. 007 is on the Oak -Bark
Facility.
2. Outfall 007 drains to a small retention pond. Does the pond ever discharge? it is an Oak -Bark Facility.
I Ttie application says.samples will be taken for pollutants from EPA Form 2F, tables 2F-2, 2F-3 and-2F-4. Have
those been forwarded to us yet? Samples for all these parameters have not been taken. Samples are taken for
I parameters in the.old Hexion permit. They are working with Linda Willis on this.
4. Do you have vehicle maintenance onsite?.No.
- t
S. What is your SIC code? ?869
.e
A
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a G
Ef Page 7 of 8 f.

NCS000533 A :."
n
Recommendations: Based on the documents reviewed, the application information submitted on June 5, 2003
sufficient to issue an Individual Stormwater Permit
Prepared by (Signature) Date 4:,-/z X
St6rrhwater Permitting Unit Supervi;��- Date SAMP
fodridleyaenn;it
Concurrence by Regio.rial 0 ceC�!� 1. 0'.1 DateF-,—j"&, J7, �an/o
RO Water Quality SupeMsor C,./I- Date Cj 4j
Regional Office Staff Comm'ents (attach additional par; s as necessary)
U
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7
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a-0, wa*-
Page 8 of 9
13

Ir
Rationale for Using Acute Toxicity as a Stormwater Test Parameter for Permitting
NC DWQ Stormwater Permitting Unit ='
I.
NC DWC� Regional Offices had inquired about adding an acute toxicity testing parameter to some
individual stormwater permits due to concerns about multiple toxic sources, onsite unknown chemical
mixing and resultant unknown environmental toxicity, and chemical sources that may not have an
appropriate benchmark available.
After speaking with DWQ central office staff, regional office staff, environmental laboratory staff, and
stormwater staff at other US states, DWQ SPU CO staff made the decision that adding acute toxicity'may
be appropriate as a test parameter in some cases. '
Rationale for Acute Toxicity Testini[ & Appropriateness of use: ; A
Other states such as CT, SC, MO, and CA are using Ac'uie -toxicity Testing (usually Whole'lffluent
Toxicity (WET) Tests)' in stormwater individual (and some general) permits as a test parameter
and have.found it to be useful parameter for a number of reasons (detailed below).
a
• Some states (CT) have hound that using Acute Toxicity is also a useful parameter to educate
permittees and the public on the concerns of contaminants on the impact on aquatic life. rn
this way the permittee understands the correlation between release of contaminants and
aquatic toxicity more clearly rather than calling levels "bad."
==�.Y NC DWQ also believes it could be a useful parameter in cases where:
o DWQ cannot feasibly include all test parameters in apermit or ask the permittee to test
specific cheriticals stored on site (because of financial concerns, large numbers of
parameters, or other concerns), even if we know what all the chemicals are;
o DWQ may not have benchmarks available for all parameters that maybe discharged
from the site;
o DWQ may not be able to predict environmental effects from mixed chemicals or
chemicals produced by reactions when mixed that may be discharged from the site; ,
o DWQ may notbe able to know all chemicals that may be discharged from the site or
these chemicals, or information about them, may be proprietary in nature;;
o DWQ may be concerned that the toxicity of some parameiers (such as copper or other
metals) may be difficult to predict due to variable environmental influences such as
hardness, p'H, etc.
(A
DWQ feels that the use of both a 48-hour pass/fail test and a 48-hour-multi-dilution test is more
conservative and will provide more in _
o DWQ feels that although it is unlikely the organisms would-be exposed to 100%
stormwater for more than 24 hours, organisms may be exposed to dilute stormwater for `&
longer than 24 hours. We feel that we would obtain more useful information using 48-
hour tests,*
o After data are collected, if runoff is passing at 24 hours but is. failing at 48 hours, the
permit can. be reassessed to see If a 24-hour exposure. better reflects exposure at that
particular site.
o Neither the NC acute pass/fail procedure nor the EPA mufti -concentration procedure
requires that organism mortality be checked at 24 hours during a 48-hour test; however,
DWQ may easily request labs to perform this:
s7 _

e
o As the NE DWQ toxicity testing relies on benchmark screening (for stormwater
discharges -rather than a limit, use of a more conservative test with benchmarks does
not have the same impacts as a test with limits. '
o, EPA Region 6 (including•TX) uses a 24-hour LCSQ (multi -concentration) and Washington
sate uses a 24-hour test(with Hjidlletrl, not Ceriodaphnia). However, SC, CT, NJ, and
MO all use a 48-hour test. = :�
Method: K
!0 . Organism: Ceriadaphina dubia _
r,
• Frequency: Once per year. testing is recommended:
• Dilution: Initial test is test of 100% stormwater effluent. Any subsequent follow'up tests a"'
�.
more specific multiple dilution tests. Both tests are.48-hour tests. See Acute toxrcity permit
language Appendix A for more details. = ;l k:E L: ; m
• Control: Specified in'the methods.
• Ache Test Type: See Acute toxicity permit language Appendix A for more details.
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Attachment A SWQ01, SWO02 & SWO05 E
EPA Farm 2F — Item IV-B
The following materials are or have been stored within the affected area of Oak-Bark's Storm Water Outfali SWOO2. The storage
areas are either covered, with built in secondary containment or uncovered with secondary'�containment. Containme� are -managed to
prevent overflows and are tested before any rainwater is released.( See attachment "E")
r:
Material
State
Category
Primary
Best..
Material Handling
"
Containment
Management
Practice
Acetic Anhydride
Liquid
Raw
Drum
Stored in
Delivered by van;
material
warehouse
transported to plant
via fork truck- i a
Acetone
Liquid
Cleaning
DrumNote
Stored in
Delivered .by van;
solvent
warehouse
transported to plant
via fork truck
Allyl Amine
Liquid
Raw
Cylinder
Stored in
Delivered by van;
Material
warehouse
transported to plant
via fork truck
Allyl Bromide
Liquid
Raw
Cylinder
Stored in
Delivered by van; L
Material
warehouse
transported to plant .
via fork truck
Allyl Chloride
Liquid
Raw
Cylinder
Stored in
Delivered by -van;
Material
warehouse
transported to"plant
via fork truck s
Allylehloroformate
Liquid
Raw
Drum
Stored in
Delivered by van;
Material
warehouse
transported to plant "
via fork
Mlylcyanide
Liquid
Raw
Drum
Stored in
Delivered -by van;
Material
warehouse
transported to giant
via fork truck._
Allylglyddylether
Liquid
I Raw
Drum
Stored in
I Delivered-4 van; ;
a8
ry
h

Attachment A SW001, SWOOZ & SW005•
EPA Form 2F — Item IV-B
Ej
I
material
warehouse
transported to plant
via fork track
Aminophenol
Powder
Raw
Carboy
Stored in
Delivered by van;
Material
warehouse
transported to plant'
via fork truck
Benzaldehyde
Liquid
Raw
Drum
Stored in
Delivered -by van; --
Material
warehouse
transported to plant
via fork truck
Benzylmagnesiumchlofide in THE
Liquid
Raw
Drum
Stored in
Delivered -by van;
q
Material
wareh6use
transported to plant
via fork track
n-Butyl Alcohol
Liquid
Raw
Drum
Stored in
Delivered by van;
Material
warehouse
transported to' plant
via fork•
I -Butene
Gas
Raw
Cylinder
Stored in
Delivered by van;
Material
cylinder rack .
transported td-p-lant
via fork truck
Caustic Soda
Liquid
Raw
Tote/Drum'
Stored in
Delivered'bvv*.
Material
warehouse
transportedto;.Plant'
via fork -truck
Chlorine
Gas
Raw
Cylinder
Stored in
Delivered by van;
Material
Oxidizer rack
transported.to plant
via fork truck
Diallyknaleate
Liquid
Raw
Dnnn
Stored in
Delivered by van,
material
wareh6usa
transported to'.Plant .
via fork truck
j

3
Attachment A SW001, SWO02 & SWO05
EPA Form 2F—,Item IV-B
Diethylatnine Liquid Raw
Drum
Stored in
Delivered by van;
Material
warehouse
transported to plant
via fork truck
Dimethylamine Gas Raw
Cylinder
Stored in
Delivered byvan
material
cyfinderrack
transported to -plant
via fork truck
Dimethylfarmamide Liquid Solvent
Drum
Stored in
Delivered"by van;.
warehouse
transparted to plant
`via fork truck
Dodecene Liquid Raw
Drum i
Stored in
Delivered by van;
ry Material
warehouse
transported to.plant '.
via fork uuck{ .
Dodecylamine I Liquid Raw
Drum
Stored in
Delivered by
Material
tr orte& -
Ethanol Liquid Raw
Drum -
Stored in
Delivered'by.yari;
material
_
warekionse
transpoted•to plant, .
via Park -truck,
Ethyl ether Liquid Raw
Drum
Stored in .
Delivered by -van,
Material
warehouse
transported.t'o plant
via fork truck ;
Ethyleyanoacetate Liquid Raw
Drum
Stored in
Delivered by van;
Material
warehouse
transported , to plant
via1brk`truck L-,
Glacial Acetic Acid Liquid Raw
q
Drum
Stored in.., .
Delivered b jan :,.
Material
warehouse
-.transported i�plant IJ
via fork truck t.:
Heptanes ... Liquid Raw
Drum
Stored n] E
Dehvered,by Van —
Material
warehouse
transported to plant '
xexa�nes Li uid Xtaw
Drum ,
Stored in
Delivered b van;
y
a �.E

M
m
Attachment A SWOOI, SWO02 & SWOOS
EPA Form 2F — Item IV-B
71,
Material
warehouse
transporte&tq. plant
via fork truck''
Rexene
Liquid Raw
Drum
Stored in
Delivered by van;
Material
warehouse'
transported to'plant
via fork truck
Isopropanol
Liquid---. Raw
Drum
Stored in
Delivered by vaa,
material
warehouse
transported to,plant
via fork truck
Isopropylamine
Liquid Raw
Drum
Stored in
I3elivered'bv van;
Material
n
warehouse
tra.nsported.to plant
via fork truck ,
Magnesium Chips
Solid Raw
Drum
Stored in
Delivered,by van;
Material
• warehouse
transported to .plant
via fork truck.
Magnesium Sulfate
Powder Raw
Bag
Stored in
Dcli, e&ed b van;,,
Material
warehouse
transported=to plant
via fork track-",
MesityIene
Liquid Raw
Drum
Stored in
Delivered' -by van; .'
Material
warehouse'
transported ta'plant
g
via fork truck'
Methacrylic Anhydride.
Liquid - Raw
Drum
Stored in
Delivered by van;-
Material
!'
warehouse
transported to- plant '
via fork truck .
Methacrylic Acid
Liquid Raw.
Drum
Stored in
Delivered by van;
Material
warehouse
tran'sported.to plant
via fork truck
Methanesulfonylchloride
Liquid ' Raw
Drum
Stored in.
Delivered by van;.
Material
warehouse
transported to .plant
via fork truck
Methanol
Liquid Raw
Toteldrum'I
Stored in
Delivere0y.van;t:-
ry
Y-�
9

a
Attachment A SWOOI, SWO02 & SWOON
EPA Form 2F -'Item IV-B
Material
warehouse
transported IO.Plaut
via fork thick",
Methyl-t-Butylether
Liquid
Raw
druiu
stored in
Delivered'.by
Material
warehouse
transported toplay t
-via-fork truck,,..
Methylene Chloride
Liquid
Raw
drum
Stored in
:-Deliveied, by-*46;1
Material
warehouse
transported`toa: pleat
via fork truck
n-Decene
Liquid
Raw
drum
Stored in
Pefivered;bjy van-,
Material
warehouse
transported to plant
k
via fork -truck'
n-Octene
Liquid
Raw
drum
Stored in
Delivered by.varC,
Material
warehouse
transportedto plant
via fbrk�truck
n-Octadecene
Liquid
Raw
drum
'Stored in
Delivered by var4,'
material
warehouse'
trarisported to plant
via flo-rk,truk'it!
2-Octanol
Liquid
Raw
dmm
Stor6d in
Delivered by van;
Material
warehouse
trensported'"t6plant
via foil Ctruck
Octylamine
Liquid
Raw
drum
Stored -in
D.efivered'6y van;
Material
warehouse
transported to, plant
via fork -truck
p-MethoxybenzylcWoride
Liquid
Raw
drum
Stored in
Delivered by van;
Material
warehouse
transported to,plant
via fork truck
ia
_Pentane
Liquid
Raw
drum
Stored in
D04vered. ,y b - yan;�an;�
Material
warehouse
tr-axisported,to,plant,
vii, fork truck
Pero acetic Acid
Liquid
Raw
Drum
Stored in
Delivered -by van,.
IQ

i•
t
Attachment A Sw001, SW002 & SWOOS
EPA Form 2F Item IV-B
Material
warehouse
transported to plarn
via fork truck
Perfluorooctylethylene
Liquid
Raw
Drum
Stored in
Delivered by van;
Material
warehouse
transported to plant
Via fork truck
Pbenylmagnesiumchloride in TH F
Liquid
Raw
Drum
Stored in,
Delivered by van;
Material
warehouse
transported to plant
via fork truck
Phosphorouspentachloride
Solid
Raw
Drum
Stored in
Delivered by van;
Material
warehouse
transported•to plant
via fork truck,-.
Potassium Methylate 25% in Methanol
Liquid
Raw
Drum
Stored in
Delivered by van;
Material
warehouse
transported to plant,
via fork.truck
Silicone Fluid
Liquid
Raw
Drum
Stoned in
Delivered by van;
Material
warehouse
transported to plant -
via fork truck
Soy Bean Oil (epoxidated)
Liquid
Raw
Drum
Stored in
Delivered by •v_ah
Material .
warehouse
transported to plant
via, fork truck
Sodium Methylate 25% in Methanol
Liquid
Raw
Drum
Stored in'
Delivered byvvan;
Material
warehouse
transported to plant
via �&k truck -
Tetrachloroethane
Liquid
Raw
Drum
Stored in
Delivered by van; D
material
warehouse
transported to.plant
via fork truck
Tetrabydrofuran
Liquid
Raw
Drum
Stored in
Delivered by van;
material
warehouse
transported to plant
via fork truck
Thion ichloride
Li uid
Raw
Drum
Stored in
Delivered b vas;
'A f,
le

Attachment A SWOQI, SWO02 & SWOOS
EPA Form 2F — Item IV-t
material
warehouse
transported to^I
­P ant
via fork truck
Toluene
Liquid
Raw —
Drum
—Stored in
Delivered by van;
material
warehouse
transported to plant
via fork truck
Triethylamine
Liquid
Raw
Drum
Stored in
Delivered by van;
material
warehouse
tramportCd tq,
plant
via fork Mick"
Triethylorthoformate
Liquid
Raw
Drum
Stored in
Delivered
material
warehouse
transported W:plani
via fork truck`
Trimethylorthoformate
Liquid
Raw
Drum
Stored in
Delivered by van;
material
warehouse
transport v
' transported to plan
via fork truck
Xyl6nes
Liquid
Raw
Dnun
-Stored in
Delivered by yl ari;,
material
warehouse-
transported to plant
via fork truek-, -
Ethylacetate
Liquid
Raw
_Drum
Stored in
Delivered by, van;
material
warehouse
transported to plant -,-
via fork :ftruck.
Viny1chloroformate
'Liquid
'Raw
Bottle
Stored in'
Delivered, by pan;
material
warehouse
transported:,t6 plant,
via fork truck
Allylbenzamidine
Liquid
Raw
Cylinder
Stored in
Delivered by V'an;
Mae"
warehouse
transported to plant
via fork truck
Axfinopropyltriethoxysilane
Liquid
'Raw
Drum
Stored in
Delivered by van;
Material
warehouse
transpofted to plant,
via fork truck`
Amino propyltris(t4methylsdox y)silane
Liquid
t
I Product
Drum
T
warehouse
M..fitu,.d
z
ON
n
E
M

19
I
Attachment A SW001,-SW002 & SWO05
EPA Form 2F — item. IV-B
a
V
Bisaninopropyltetrainekidisiloxane
Liquid Product
—Liquid
Drum
warehouse Manufactured
Bistrimetho sil I ro lfumarate
Product
Drum
warehouse Manufactured
Bu ldimeth lchlorosilane
Li uid Product
Drum
warehouse . Manufactured
Chlorometh Itrimeth lsilane
Liquid Product
Drum
warehouse Delivered by van
Chloro ro ltrimetho silane
Liquid Product
Drum
warehouse Delivered van
Decameth ltetrasHoxane
Liquid Product
Drum
warehouse Delivered by van
Dributy1dichlorosilane
Liquid Product
Drum
warehouse Manufactured
DibujI&nethoxy0ane
Liquid Product
Drum
warehouse Manufactured
Dieth laminotrimeth lsilane
Liquid Product
Drum
warehouse Manufactured
Diiso ro laminodimeth Wiane
Li 'd Product
Drum
warehouse Manufactured
Dimeth lchlorosilane
Liquid Product
Cylinder
warehouse Delivered -by van'
Dimeth ldichlorosilane
Liquid Product
C under
warehouse Delivered by van
Dio idichiorosilane
Li uid Product
Drum
warehouse Manufactured'
Di hn
Manufactwed
Divin ltetrameth ldisiloxane
Li uid Product
Drum
warehouse Defivere4by van
Dodec lmethyldichlorosilane
Liquid Product
Drum
warehouse Manufactured
Eth ltrichlorosilane
Liquid Product
Cylinder r
warehouse Delivered.b van
He tadecafluorde ltrichlorosilane
Liquid -Product
Bottle
warehouse Manufactured
Heptadecafluordecylttimethoxy0ane
Li uid Product
Bottle
warehouse. Manufactured
He tameth ltrisiloxane
Liquid Product
Drum
warehouse Delivered by van
Hexameth ldisilane
Liquid Product
Drum
warehouse Delivered ty van
Hexameth ldisilazane
Li uid Product
Drum
warehouse Delivered by_ van
Hexameth ldisHoxane
Liquid Product
Drum
warehouse Delivered by van
Hex lmeth ldichlorosilane
Liquid Product
Drum
warehouse Manufactured
Linear Phos honitril Chloride in Siloxanes
Liquid Product
Drum
warehouse Manufactured
Methac to ro ltristrimeth lsil silane
Liquid Product
Drum
warehouse Manufactured'
Metb
y1dichlorosilane
Li uid Product
C under
warehouse Delivered 13 "van -
Meth ltrichlorosilane
Li uid Product
Cylinder
warehouse Delivered: van
Odoeqddivn2Lhylchlorosflane
Liquid Product
Dntm =
warehouse Manufactured
Octad meth ldiohlorosilazae
Liquid Product•.
Drum
warehouse Manufactured
I
e�

Attachment A SW001, SW002 & SWQ05
EPA Form 2F — Item iV-B
LB
Octadec itriehlorosilane
Liquid
Product
Drum
warehouse
Manufactured
Octamethylcyclotetrasifoxane
solid
Product
Drum
warehouse
Delivered van
Octamet ltrisiloxane :
Liquid
Product
Drum'
warehouse
Delivered vari'
Oetylevanoacetate 2
Liquid
Product
Drum
warehouse
Manufactured ,
ldim lchlorosilane
Liquid
Product
Drum
warehouse
Manufactured
Octy1metticlichlorosilane
Liquid
Product
Drum
warehouse
Manufactured,;
Oct ltrichlorosilane
-Liquid
Product
Drum
warehouse
Mamifactured
Phen ldimeth lchlorosilane
Liquid
Product
Drum,
warehouse
Manufact'uredf.
-Metho be ltriehlorosilane 50% in Toluene
-Liquid •
, Product
Drum
warehouse
Manufactured
Tetrachlorosilane
Liquid
Product
C finder
warehouse
Delivered by van
Tetrameth ldisiioxane
Liquid
Product
Drum
warehouse
Delivered b van '
Trichlorosilane
Liquid
Product
Cylinder
warehouse
Delivered by van
Trietbylchlorosilane
Liquid
Product
Drum
warehouse
Manulkctured ,
Triethyjagane
Li uid
Product
Drum
warehouse
1 Defivered'by van
Trilsopropylsilane
jtjuid
Product
Drum
warehouse
Delivered by van
Trimeth lchlorosdane
Li id'
Product
Cylinder
warehouse
DerjynLby van
Vin ldirngh :lchlorosilane
Liquid
Product
Drum
warehouse
Delivered by van
Vin lmet tdichlorosilane
Li uid
Product
Drum
warehouse
Delivered by van
Vin Itrichlorosilane
Li id
1 Product
C under
warehouse
Delivered by van
Polyphosphoric Acid
Liquid
Raw
Material
Drum
warehouse,
Delivered by van
Hexafluoroisopropanol
Liquid
Raw
material
Drum
warehouse
Delivered"*Ivan ";
BishexafluoroisopflMhLtaconate
Liquid
Product
Drum
warehouse
Manufactured
V' o carbon ro ftristrirneth lsilo silane
Li d
Product
Bottle i
warehouse
M►iifactured
Therminol D12
Liquid
HW
Drum/plant
s stems;+
Warehous&plaat
Delivered by:,vari
Propylene Glycol
Liquid
HU
Drum/Plant
3 Btms
Warehousq/plaM
Delivered by van
1
L
J
,,

Attachment A SW001, SW002 & SW005
EPA Form 2F -- Item N-B
HE-200 Oil Liquid Vacuum Drumlab Warehouse/Lab Delivered by van
Pumps
n
p
i
1
t
3

ftch" 'Er
EPA From 2F SW, Vll, Part A
Odtlaall 001
TOW IF
WD
COO
T33
Pills
TKN
�+W2 calciilaliOn
TOW lead FormAldehyde
Kexa111fne
TQt81 P Event Yota# Event
Date
(Mt3)
PH
(mom)
(n►g1L)
(mglL)
(myL)
(m9n-1
#-1 ()
(m$81 (> I
{n+ptL)
(m9�1 Duration (h) Preetpltmtlan (in)
611 n
6-3
8
9
4,2
g
12.
O.0 .3�
e
. 0.820.8 91
Odilall DOZ. Lab weir
Data
Total Flow
(MC)
pH
800
(m(lL)
COD
(mglL)
TSS
(rnwL)
NHS
MOM
TKN
(►nWL)
N%+NOr
(m9n.)
TOW N
oak,ulatlen
(rng/w
Total Lead
(m91L)
Porm Wehyde
(ffw'W
Hexamine
(mglL)
Trial P
(milt)
Event
Duration (h)
Tatai Evart
=.PreMpktatxlan (►n)
312 r2
00-2
53
19
146
.0
.0
0.010
_.-0.48
warlmi0,
91
68
69,9
MOD7
1
1
0
•4 0.37
V&2008
O.
07
62
183
48
27
1.1
28.1
0.004
OE5
3
1.42
1.1
12008
E
0027
7,_
51
245
48
30.8
38.1
1.3
39.4
0.Ow
17.4
22.5
0.75
" 05i1200T
0,048
7,44
102
281
48
47,7
1.8
493
0.005
131
24.8
•
08
:- 1-..02
611212
1 O.D011.51
7601
8710L
1
1
IM,31
7.1
D.
4
M-"bmm
5311
TP4
7331
37331
1172T7
01
1854
.9
m5,31
OA4
17.4
3750
0.1
8.08
1A
Awe
0.035
2 •f
1 8 .33
.32
3
4.90
.7O
0.011
.Si
708.
0.17
1.781
0.74
Out>1rl100d: silent wwr
Date
TataE NOW
(MG)
PH
80D
(MWL)
COD
(MOIJ
T88
(MiN
NFIa
(0)w)
TKPI
(Mg1t.)
NOt+trOy
(me&)
oalaulalion
(Mgr)
Tara! Lead
(MWL)
FortnrlMehyde
POL) •
Haxamina
(mglt,)
Total p:
(mg1L)#
Event
Dundion(h),
Total Event
Mr 1plblttcn#n A
3121/2006
OJIM
T.71
es
447
1 4
41
i.1
i 13
II 48
' _ LO,48
4rlI"
0422
5.96
123
184
28
23
23
7.3
25.5
0.003
1
44
.02
0.
0.08
9.
52
38
20
0.6
20.6
0.
"; 0;
2
1:42
;:> • Vv W
11t1
4.034
24
13
8.1
10.
1.7
11.8
QO.(M
3.20
328
;
0.
:= 0.57
211MM
0.081
8.8
18
80
28
8.
10.8
IA
11.7
0.
eA
6.63
6,
1.02
1 a
0.08i
B.8
46
71
9 a
44
.7
13,1
0.004
7.07
4.51
0. 8
6.
1:02
12f2007
0,
88
4
81
8.
T3
11.8
0.007
3.
8.1
.M4
-
1
Msxln�um
O.Wj
8.8
i23t
447
'1141
411
461
3.691
47.11
0,0111
i3
481
C5418,08
1.1
A►+ers1
0.0471
1 46.571
140.861
35141
16.10
18.37
I.Nj
20.21
0,01
11 4.92f....16.46
0.36
" 2.39
0,7E
r�
6
b. si
a
[
rr�
1 «
,4
I
u

Attachment "C"
EPA Form 2F, Sect_ C, part C
e
The pollutants from EPA Fonn 2F, tables 2F-2, 2F3 &2F-4 have not been analyzed for.
Samples will be pulled during the next storm water event and the results will be
forwarded to NCDENR
A.+
�t
xf
w�
�s
is
.L
�5.
r
p
l�
b
0
y"�
Q
11
-
r
A".
i}
�
Y�

WORKSHEET #1
1( .
j
Oak -Bark SWP3
I I
I L
BEST MANAGEMENT PRACTICES (BWs) IDENTffICATION
Completed liy. W.E.
'A'Swis
Title. Pit.
Datei April N09
Instructions: Describe the Best Management Practices that you have selected to include in your plan.` For cach.of the basefine.BU?s,
describe actions that will be incorporated into facility operations. "Alio, describe any addif-io'nal. BWs"(activity-spebific
and site -specific) that you have selected.
]EIMPs
Brief Description ofActivitles,4,
Good Housekeeping
Storage of chemicals to minimize contact with storm water (under cover & on pallets); maintain clekworle4
areas; training of employees; minimize waste accumulation.
Preventative
Weekly inspections of bulk storage and chemical hanftg areas monthly inspections ofall containmefit/dildng
Maintenance
structures.
Inspection
On a semi - basis, perform visual inspection to identify any: potential problems that may cause storm Water
contamination (e.g,, leaks/cracks. in dikes).
Spill Prevention and
Educate employee on proper han4fing of chemicals; inform employees about MSDS information and reporting
Response
procedures'for any spiMeak incident; maintain a readily available supply: ot spill prevention kit materials (e.g,
absorbent materials).
Sediment and Erosion
Regrade and seed the facility property as necessary to minimize erosion. Construction zones vOch'iftvolving land
Control
disturbment should be reseeded.
M ' anagement of
Build curbing to direct strorn water around processing areas.
Runoff
Additional BMPs
Ps
Verify proper dike pump -out methods. Monitor chemical recOrq of bulk chemicals and ensure safe &
(Activity- and Site_
en*onmentally neutral procedures are followed..
Specific)
i

s?
r
�y
.r
Oak -Bark SWP3
WORKSHEET #2
r .
IMPLEMENTATION OF BMPs ?
Instructions: Develop a schedule for 'implementing each BMP. Provide a brief description of each BN . the steps necessary to
implement the BMP (e.g,, any construction or design); and the schedule for completing those steps (list
approximate dates).
B1VIWs
Description -of Action(s) Required for -implementation
Scheduled
Notes
Completion Date
Good Housekeeping
1. Perform weekly sweeping of floors in the warehouses and other
..
1. On -going
.
building areas. �
.
2. Conduct employee training.
2. Annual
Preventative
1. Wcckly inspection of the processing areas and schedule timely
1. On -going i
:r
Maintenance
hauling (&pm1) of the waste materials.
2. Wspeet chemical cortafim and equipment for any potential
ieaks/spills.
A
2. On -going
Inspection
1. Conduct visual inspection of the facility and record the inspection;
1. Semi-annual
results using the Ord sheet provided.
Spill Prevention and
1. Maintain a readily available supply of spiMeak clew -up kit
1. On -going
Response
materials. 2. Inform employees about MSDS irdo.
Z Amival
Sediment -and Erosion
1. Keep areas sooded/grassed.
1. On -going
Control
2. Rcgrade and seed site to mirurnim erosion.
2. On -going
Management of Storm
L Maintain the atotm water dnunW ditrhe_ s and kccp clear of debris.
1. On -going
Water Runoff
2. Budd curbing around groom g areas.
-
2. On -going
0
b

Ber¢cit:mark Vaiiao Compaetson,for Stormwater,Samp}i'nn'Event
obu#fall 6
0
1'
i
Pgralg3eters _ _. ;:.._
Y
Benchmark
Period 1 E;
s Period 2€
Pertoli.3.
Period 4
Period 1
Period 1
Period 2
patia„Dafe'I
Ir
`Daft'!: -
Date.--
--Date:
_Date:
Date:"
'; .1/17I11
415111 .
..
"
�,. 9120I11.
1 il29111 "
� 1/11! 12 _'
; : 3/3/12
6112/12
Itt;
' 82gults's
,r'Rgsutta
B91WI&
--Results '
" Resuub
Res.
Biochemical 0 en Demand: BOD
? 30
's. 6:. >
18 .....'
S .
53
39
8
9 .
Chemical en,C]emand" CODJ
120
32'--- -;-•---W
__'t
;t -.:55
6 '
93
'20
3 65
Total -Suspended Solids (TSS)
100
7.5.
24.7 ' S
231
23.1 '
81.3' ;
6.8
29
Total lqeldahl Nitroen (jKNj
20
61 A
46.5
3.8 _. -
- 3.3' '
50.3
52.3
.... 2:3-
Nltrate+Nitrite-N NO2+NO3=N
f0
12.5
13:9 .
196
3.29-
18.2
.10.6
-1.31
Ammonia as Nitr en. NH3-N - = ;
, .7.2
54.9
62.i
#`_ 1.4 .'
2.4
26.6
67.2
-0.3
Total Phosphorus TP _ ::,
2
1.01,." __
_ : T.04`R ,_
; 0.28
0.14' ...
2.08
0.94.
0.27
Hexamine-'
. 25000i t
776
.16:
'i -.10 -
L. 10. _
<10'
10,
10" "
Formaldeh de
0.5 ;
.0.13'-
0.307. %'
0:206
0.066
0.047
0.086-
0.069 :g
Methanol....
•7700----:
--- ^10,
7-101--..
10 ,�
-10
<10
-10"10
"
Total.Residual Chlorine TRC ^'
- U281,:;
0.002-
F: 0.004 "r
; 0 - ..
0
0.032
0.016'
0.01-
Lead Total Recoverable _._- _ _ : r ,.
L-- 0;03 <
0.01
0.01
,' - 0:01"
_ 0.0 i'
0.01 -
0.01
0.01
Copper, Total Recoverable.
0.007-
0.01
0.012
0.02
0.008
0.011
0,007
0.011
Zinc, �__ �
TotalRecoverable- -_ -_-. i
,;-- 0.067 -,..�
. -, 0.037:"
}__ 0.132
�.�..0:062....
' . 0,029
0.058 -.
0.019,
0.069
Man anese; Totat'Recnverabie
NIA.. x
^ 0.15'1 '�>'.-0.359'-�
_
0!07
0.061 .
1.23.
0.22-
0.014'=
Acute Tox1 LC50
x. A'
's< j
75.209b:3;
9r.
s
r
>100%
Method 1664 SGT-HEM. Nan-Palar. 0$�G
155
's
:::; 5 ,,
4. 5
5
_ .6 - __
,. 5
....... 5.....-
PH. _ .. _.
-..6 to 9- -
7.22: ..
M 7.08 . {
;, . 6.73 r
6.74
6.88`
6.9
Nate; All results in rng/L except pH which Is In Standard Units.
Note: When entering data, do not use o signs.

11fir ,find rnark
ftndWiarh iwCompar . ls.onlbi Storm ftkr-UmDHj'EV4j'
C�uifalI:� 2",
. ... .. .
Period I
Period
Period 3
Period 4
Period I
Period i
bate:-'7"
:Dat6-i te'i.
ffite-.'
Date:
'Datt
-
Date:
9120/11
11/29111-
1111712,
3/3/11-
R-esu
EMU&
&S-WSA
7.7
Biochemical"10,
Oxygen'.Demand'(800)
30
49
120
291
--4-
39
Chemical Oxygen Demand. COD
1 120,
178
399
32
28
96! --T
189
Total Sus nded Sofids,(TSS)
100;
57Z
�'66,5'
-.Jq­
5.9.
59
113
20A
Total,K4eldahl Nitrogen (TKN)'
20
27.1
89.8
62.6
:1 3r(3--l-,
—1 T
4: 1'
25.5
Nitrate+ Nitriw-N, (NO2+NO3-N)
.1
'0
I.M
'65
1,76
0.89
'0.91,
_11,14
T.- 1. 72'-'
Ammonia as Nitrogen (NH3,7N)
7.2
23
23 ,
---"I G'
13-
0.6.,
-2.7
8.5 11
Total Phosphorus (,TP)'
2' '149i,--'-0.35-
35
,0'37
.0.04
A04
0.37,
0.13
Hexamine
W2500E0,,
--.-..21.4--
10
10
10
10
—IT . ......
Formaldehyde------,
0.5
'j. 5
1.85-
0.75
4.25
.0.3�'
1.26,
2.1
Methanol..
�7700-
10 1
4
'10.7
-----10
10.
'10 r
%
Total. Residual Chlorine (TRC)
t 0.028
. ..... 0
0.018
.0
'0
-0 t
Ol
Lead, otalRecoverable
-0.03----
- 0.01
0.01'
.70.01
0.01
0.01--
Co r,:Totai Recoverable:.:
-0.-007
OAM'
0.433'
0.052
0,014,
0.108
0.089
Zinc Total Recoverable"--,
:-0.067
0.46
0,811
0.144
0,087
0:34
0.25
Manganese, Total Recoverable
N/A.
0.258"J.
:A176-,
0.022.1
.O. 043
tt 5011
Acute,Toxicllcr
Appdx. A
-100%-
Method 1.6.S.4.S.GT-.HEM (Non'Polar O&G)
"115 1
A
!.,. ; 4
.. 5
-7
5
5
5
pH
7.47
7.42
7,19-
T82 -
7.04,
Note: All resub in mg/L except pH which Is In Standard Units.
Note: When entering darte, do not use <> signs.

3
-�
Period 2 F
Period 2
^Pedod2
Period 2,
'Period 3'
Date:
Date:
pate:
-_�
" 17abe 1,
''©ate:
416112
5!9/12
-5129/12•-
6112112 .
`"7/31112'
Results
Results •,
Results
Resuf4s'i
B_qsijlts
4
5 30.....
.
`5
12"
66
189
54... `-
° 70
19. ._
134
125
42
6
19.9 --- .:.
-.
1.3
'4.8
1,22
1 01
0.39
1.03
'0.4`
1.2,
0:17
' 0.8
:4
0.32
"0.19
-.
=10. ,.;
10
10
10
0.79
4.4
.0.319- t,
2.56
^ :10"
10
90.
.0
0.021 '
'%
0.032
0 '
0.01 "
O.01:..
0 01 ' ,a.
0:01' "
r0.057
0,174
; .._
0.049
0.06
0.292
0:802
0.211
0.61
0.046
0.092 — -,
"s _
: 0.066 ,
0.035
_-
g
•::7.25

5ilac Be Ihtnartt Vatue CCm arison for Stormwatsr:Sam p lltt 1EWent
Oufai! a0R
u
r
Benchmark
Period.7
V Period ?
Period 3,
_Pedal 4
Period,!
Date
,Date' '
. . Date;
Date:
M"
iDate:
_
Datli'`
1117h1
415/17 "'
`"Moli1
11/29/11
1/1Ill 2
313/11
Resul
ROstifts .,
ResultsAgirls
gM! s'
'Results
- :7
Biochemical O en'Demand: ROD
4 30 -.;
42
45
8
.6
13'
Chemical Oxygen, Demand; COD .
120
'155
167
68 _
37
55
104�'
1 otal:Sus ended Solids SS
; . .100
123 -
='41:3
24.6 ,
11.9
58.7 ' "'{�
� 2i:4
Total K'eldahl'Nitrogen KN)
20
"7.5,-'• m'
29,7
1.8;
2`-
2.64
Nitrate+Nitrite=N NO2+NO3-N
10
0.56
"1:48
13.72
0.5'
0:38"
Ammonia ssNitno en NH3-N s
7.2
8.1
0:3-
0.4
0.9: -1
L A
Total Phos onus TP
. -... _-2.._.... �.
„ . 0.4
0.17
-ww_... 0.34..
.0.15
0.28 .
, 0.2
Hexamine ..
..25000..�.;
1:".. '10 i
;,__:: l0.._. i
10
10
10
10'
Formaldehyde- " _
0.5
10.1
2.45
0.26
0.2
0.089
0.83 I
Methanol _ :..._.
7700
10
10
10 _.
. _ :_ .1© ,
_.-.__-_-..10.1 ,.._._..,
..._. i0, .:.
Total Residual Chlorine TRC _.
0.028
0 ----;'
, _-0.003 i
0
0
0
0
Lead, Total Recoverable _...
6.03 .-
_ -'0.01
0:011 k
0.01
�.0:01
70.01
0:01
Cn rTotal Recoverable
0.249
0955
.011
0.038
0:223
015A
Recoverable
;0.067
1:04
1.01
0.5
0.194
0.485
0Zinc;�Total 357
Manganese, Total Recoverable
NIA
:0.239_
'0.125�'
0
..0.023
0.044.
10.032•
Acute Toxlci .LC50
'42%
- -
Method 1664 SGT-HEM Non -Polar O&G
15
5
5
5 --
5 ,- -.-ii
;`-- 5 x
H �.,
...
6109
_. 7.27•-'
4.7
Note: All rasufts in rnWL except pH which Is In Standard Units.
Note: When entering data, do not use ca signs.

a
Pono d 2
Period 2'
Pedod, 2
Perlod.3
Date:
---Da
'Datw. --
-DitI6..
4/6/12
"1 5/9112-
T5/29—/12
6/12/12-
7131112
Resufts
R#§jlkl
ResUlts
158
14
4
lo
336
64
95
53
20�
23
17.8
4.9
1.58'.,
'0.66!
0.31
1.02
1.5
13
.......
'04 1
1—
0.25
'0.32
0.17."
'0.09
-10
101
10
0."925,'
0,756
0.251
2.16
10
.10
101,
10
0
0.007
'0.013
'0
7
-0,01,
0.01-1-1.
0.01
0.323
0.175
0.047
0.087
1.16
0.409
0,167
0.377
-0.073—
0.038--
0,017-",
0.024
5
5
8.9Y!
8.57'
7.91-',
7.7

=S+iar Benchmark Value Comparison -for Stormwater Samoling'E iit
,Outfaftl 60
B mark
71
Perlod;1 _
Period 2
Period,2
Period<2
:Period,2 '
Period 3
"Date:
-Date:
Date:"
3/3/11- `
','_'
'_" 5/9i12
6/291.12
-6/12/12"-`.
`7/31I12
,_
1-�'-11221112
Results
� R
Rgs!� ;
, Results
Results'Results
Biochemical Oxygen Demand BOD
30
18
22' °
is .
7
19
Chemical Oxygen Demand COD
120
93
85
r 62
63
72
Total Sus nded Solid§ (TSS)
1GO
27.8
21.6
10.6
34.4
14.2
Total ICeldahl Nitrogen KN
20,
9.7
9.5
11.1
1.2
7.7
Nitrate+Nitrite-N NO2+NO3-N ,
10'
0:79
0.65
1'.12
0.21
3.5
Ammonia as Nitroen(NH3-N
7:2
B.B
4.6 °
3.6`.
0.6
3.1
Total Phosphorus P .. ......
.2
0.28
0.51
0.45
0.16
0:28'
Hexamine
.25000
10�
10
,t
: 10'
10
Formaldehyde.
0.5
0.635,
0.375
1.77
0.27
4
Methanol
7700
10
10 l
10
10
'10...
Total Residual Chlorine RC
0.028
0
10
0.012
0.028
0r
Lead, Total,Recoverable
_ _.003 ..
0.q1
0.01..
_...: 0.01 .._
: --
0,01--
Copper, Total' Recoverable
0.007
0,056
0.078
0.057
0,048
0.107- -
zinc. Total Recoverable�
0-067
0,423'
0.689
0.492
0.232
0.756'
Man anese Total Recoverable •
N/A_ ::::.._
.0.032,-
.0.109
- 0.052.-.-_
'°
0.039
' 0.074�
Acute.Toxic• LC50.
A x: A
b _:
ti '
t--
70.7055 <
m
_
Method 1664 SGT=HEM Nan -Polar O&G
- 15
5
5
5
_ _
pN:
8.39 ....,
7AT.
Note: All insults in mg/L except pH which is in Standard Unh.
Note: When entering data, do not use n signs.

PO Box 7565
Asheville, NC 28802
Phone: [phone]
Fax: [phone]
. Environo mttal Testing Solutions, Inc.
June 22, 2012
Mr. Jay Baker
Enviro Chem
6602 Windmill Way
Wilmington, NC 28405
RE: ETS PROJECT NUMBER: 8080
Dear.Mr. Baker:
Enclosed are the results of a toxicity test for a sample from Hexion received by Environmental
Testing Solutions, Inc. on June 13, 2012.
Parameter: Test,Pnicedure , EPA Method: Final Results
Code Number (24-hour L,CQ
Methods for Measuring the Acute Toxicity of
TAE6C Effluents and Receiving Waters to Freshwater and EPA-821-R-02-012 > 100%
Marine Organisms, October 2002.
(P.imephiMu prameles Acute LC50 TaziE.!!X-Test) _ —
_ - _ �rz-'�-. .•emu _ _ _ _.—,.,.-__
If this test was performed as an NPDES requirement or by Administrative Letter, please enter a
>100% on the Effluent Discharge Monitoring Form (MRA) for the collection date
Jane 12, 2012 using the parameter code TAE6C.
Additionally, please sign and submit the original DWQ Aquatic Toxicity Form (AT-1) by
July 31, 2012.
If you have any questions concerning these results, please feel free to contact me.
Sincerely,
CJ*1tA---
Jim Sumner
laboratory Director
This report should not be reproduced, except in its entirety, without the written consent of EhvirunmenW Testing Solutions, inc.
The results in this report relate only to the samples subrtinted for analysis. 1 --
i�wwr�.rYwww�ww� w�ww w. ww
North Carolina Cerricate Numbers Biological Analyses: 37, Drinking Water. 37786, Wastewater: 600
South Carolina Cert y7cate Number: Clean Water Act 99053-001

in
%P.' Eavvenmantal *asttV Sotutkms. Irre.
Effluent Toxicity Report Farm - Chronic PaWFail and Acute LC,o
PO Box 7565'
Asheville, NC 28802
Phone: [phone]
Fax: [phone]
E-mail: [e-mail]
Date: June 22, 2012
Facility: Eavlromim(al Chem Inc. - NPDES 11i NC- S000533
Pipe#: 001 Cown)r Calumbps
Hezion - Sffw
Laboratory Performing Teat: Environmental Testing Solutions; Inc. ^
Comments: -
Signature of Operator in Responsible Charge:
Prot: 8090
--
Signature of Laboratory Supervisor — .-
Sample: 120613.100
Mail Origlasl To: North Carolina Department of Environment and Naiiva! Rmunm
Chromic TesfRemlts
DWQ/ Euvirom cntal Sciences Branch
Calmlaxed r:
1621 Mail Service Ceaber
Tabular r:
Raleigh, NC 27699-1621-
%Reduction:
North Carolina CeriodapAnta Chronic Pass/Fail Reproduction Toxicity Teat
Pave t
Arers=c
ftwtaft
tVq
coarw
COattN
Coubvi O hms 1 2 3 4 S 6 7 8 9
10 11 12
Number of Ymmix Produced
Adult Survival: __(QIM(P)ead
TMRMXM 2
Treaanenr 2
E/1luent Percentage=
CSC'
Treatment 2 Organisms 1 2 3 4 5 6 7 8 9
10 13 12
Pass _ Fall.1
Number of Young Produced
..ti.i.q�r b.r
Adult Survival: (L)ive, (D)ead
PH (S.U.) I St Sample I st Sam le 2nd Sam le
Control
Treatment 2 E=1
R 3 j'a R 2
D.O. (mg/i) Ist Sam le 1st S le
Control
2nd S le
Treammt 2
LC,dAcute Toxicity Test
(Mortality expressed as Ik combining replicates.)
CAGMItratkm (%)
Mommty (%)
coat
a.25 1 ILL
zS
I so
too
0
0 0
0
0
0
Start Date: 06-I3-12
AIcction (Start) Date:
Sample 1 06-12.12 Sample 2
Sample Type/Druadon
coop, n�
1 X c n
Sample 2 3 3
4
AlMiMq (ing CsM3/L)
FtWd— (mg CACOA) .
GtY(G�) l53'i, `iU7
TOW Regxk lClilavae(wa/W C'0_iC
Samyle Temp. at Receipt (X)
I.C50 _ >100%
Method of Detenninarion
95%Confidence Limits
Trimmed Speamran Karbar
2
� Y,
NC to NC
Probit
" w
`x
X
Other. Visual Inspection
7.69 7.67
Coemol
7.8
1 7.7
. -
7.5 77.31
HiO C,
8.01
7.8
Organism Tested: �Ptrmplruletprmndly
Duration: I4-boors
pH (S.11.)
DO (mg(L)
DW4 fq AT L(347) iere JINS:;

s
�'-T,,,, � -, S-
Aare:
Acute Whole EMuent Toxicity Teit
(EPA-821-R-02-012).
Species: lei ales romelas Duration: 24'-tiQurs
P29t I of 2
Client:'--
Eiavironmental Cht sills " Lit.
NPDES :-
I N
Facility .,
Hctcion -
Cann _
_
Louth /i'i
Comments: ,
a
3
Test ariranRw information: Test information:
C3rpnism ale:.
.Iiendcmiwlg template;,,t
Diu and uncles otgantama were
born between:
OC-eV -1"L tisr.OD
'Incubator number:.
ftanism solute:
Gke '
:C"trowitudan water.Opc-...
.
Date med time organisms were fed:
1.- -1�.. Q1 #,IQA
ControUDeluiiou water hatch ';.
Qt,•pr1-_I'1.,
Approximate transfer vMel votunx
Live wart weight of 10 larvae
Cafteptance Limit < 0.4O ■! Z
Tranderveiml information:-
pH- � SU Temperiftre—~ 'C:
MA
FuliRetrlvNIVI <t rkentiv&V2, Samok infarmadon
Paratttetrr'`�
Control
Sample
Sample
pH (SA.1
i.sv
Calltctioa star! dare:".
Collection eod lime:,
15Z"j
Conductivity
1
Crah1composite idu`rathm)-
t mho-cmi
Alkalinity
Temperature ("C'i upon reeript:
Hardneu
,.,
Physical characteristics:
Total Residuat
�= �
Chlorine (m '1_]
x
ETS project number_
ROM
ETS sample nuoi6tr:
1201.1s. 10
Dilydiam vrenaration:
Test OotlCetltration:
6.25%,
12,5%
25%
50% ...,
10M .,•.,
mL Sample..
31.25
615
125
230..
500
ntL Dilution water.
468.75
437.5
375
250
.. 0 .
Total volume mL
500
500
500
500
500
SOP AT18 — Exhibit AT 18.3, mvisfan 06-01-11

N
11
1 S%u4a-
cumt. Htxim - Oulfs" ac
Test con cen&aaax chem4try.-
Date: OLI—
Page 2 of 2
Day
Para Auter
Conumf 6.2S%
Day I
lnWalta.--
PH (S]U
Id
Cmd.aliq (.gmh
Day
110OVIV,
Day F
RHM--�Vji
DO
Cmducoi%* "CT)
Temizatm re
Anit
Initial
Initial ; Filial
Few Res Ufa.
24-hour
.
Method•
IJW&L I&V-
UpM control timit-
4L
Lower control limit.-
-AX
LCSO median lethal -cowmVation):,
> AW.
4
R�
Cakubtfous and data reviewed:
SOP ATIS — ExhibitAM.3, revision 06-01-11

17 :411111.11�1"�,',;
, . L'I
ENVIRO"VENT OjjEMW Tgiikl C�,
&Mpli and CM.n 1-4 C-77jl-!-.w
w w
3MM31
7' WAII
�e�����nouot�on
rom
Fri OA
7IMPROMEMM:
I

i rnvi.onmentW Tasting sautions. ux
1.8
1.6
1.4
1.22
�.0
0.8
0.6
I 1.8
1.6
1.4
1.2
1.0
0.8
0.6
Rimphcdles promelas.
Acutr.Rdf r" ence. Toi xicant Control"Chart
USEPA Control Limits (f 2 Standard Deviations).
.....................................
ra......a..aa... .... •aa..
..................................................................... •...
Laboratory Confidence Limits (75 ' and 90' Percentile M)
......................................................................... 4.....................
••..►........................................................►. 4..............................
eH' ���o' ♦o' �> >� ��' ♦ o�' o� o� d� �' e'y o�a�' o�o� -ob'
Test date
• 48-hour LCM = median lethal concentration. An estimation of the concentration of potassium chloride
which is lethal to 50% of the test organisms in 48-hours.
— — Central Tendency {mean LC5}
— - 75t' Percentile Confidence Limits (mean LC,, -+SA�s )
......... Control Limits or 90t° Percentile Confidence Limits (mean LC,, t SA 40 or 2 Standard Deviations)
'M
Mrin.i.d OVr.

PO Box 7565
A,5h•Ml!e. NC 28802
-18)350 Phone: -9364.-
Fat: k828) 35ul-9363"
N E-mail: J imSuninera.,dbLeoin
Tasting Solutions, hnr-
Facility,'Enviromental Chemises, Inc. NPDES H-, NC- SOG0533 PiocS: 031- County: Olumliui.
flexion - Momentivc
Laboratory Performing Test: Environmvrqa1TestLn-aFtir7 nc. "Con
Signature of Op.,ralar in Res 'bi Chn e A
'punil e pTjcct, 7050
1 Signature of Laboratory Supery Sam ele-, 1.1040A.-2
Midi OriginatTe:.Norih Cwolhta Department of Environment and idaturtll R'�iburcie.-- I mmic-T6t Risulmj
DW'Q1 Environmental Scien--cs. araricb Cadcutated v
1621 Mail Service Center Tabular v
Ralci,vh ;N RalUCtiEY11:
IA:
North Carolina C.Hodaphniet Cbrooic Pass/Fail Reproducilon Toklcity,,Te e6t %Vt
morallij. i Reproducit-)m:
Control Organisres 1 2 3 4 5 6 7 8 1 blk. 0' 12, 0,16:10
Number 'Young, Produced it ji t. -d
k%dult SurvMl: (R)<ad Ti.
2 3 4 5 6 7 8 13.; :Fail
H 121$�
5�:-ber of Young Produc.-ki
jAdult Survival: (L)iw. (D)cad
PEI JSX.)
Contrul
Izt Sam le.
1st s n 11 do Sam 11 c
Ell (77
�k-,�atmcnt2
3
13t S,airiple
conlrol
1st Sun.x,
ED
2nd Svvnpl&�,
,rvcatment2
rMortaliry expicistJ as combining replicates.!
Martmfily
C..I,..i
&25
1 1!.5
2!;
50
100
() 1
0
1 0
0
0
`Pest Start Dak--, 04-66-1 1
co Ilection't Start)' Daw.
smilpje 2.
SampL- T Dumioll!
51
Al'Wit1hy J!.I.; 32
37
I -KO
['(-tal r.mjual 0 1 r Ft��
00
LC_j— -.75.2%
N I ctbW of DeLernlination
931�� Confidence Limits
Trimined Spearman Karber
60.61�0- to
Probit
Oilier:
77.8,
F-7 5,
"6
7 77
M
Organism 7 ested: pimephales pronaelas Duration: 24-hours
PH IS. u.)
DO (m!(,)

Page. -,,F , of 2
Daw.
Acute'wholetfflueat, To-.YJcitY Test.
(El PA4821 -P,02-012)
Species: °-.Pjmiieehales2 gronidd7UIuratibw 24-hours
NPOES#-.'
TTilley
U
Camaeents
. .. . . .. . . _7
Date and times organisms ware:
born between':
ztioo-
llncub2tor.number;
t
Organism sourer:
C)±O+ �J,_
CGntrODflutlow water type. -
Date Bud time organism n. were. fed:
-CotitraL(Dilutlowwater,
L
sApproxlrnzts transkr vessel vala",
Live Wet Weight Gf,-IOUF-Vie.:fgj.':
0011".
,,LoadiPg.(g!L):,;
limit < 0.40 it g!c,),
7rartsfer vessel information,
SU Temperature-_. V it
m �O _j
Ajarimeter—­,
.. .. .. ....
"DO (.Tqr-L)
[Conduetivity
Collection end (I m4a,
t S CY
:Crvb/Camposffi! (duration)-
,TcutMatdra j'Cl.upon.re c44
'F[2rdnuss
(In,.-; cacol_
,Teral Residual-
Fchlurine(m
f E;TS, iizitlirs;.
ETS samplk:number-,
06. 7.R6-
Test concentrattoq;..
ra tio�&­
-1`
-3%,�
25W
50%:
10M�
6 .5
250-
SOO! -
mL Dilution water:
46&75
437.5
375
�5U
0
SW
500

clieffl: Hexign, dutfill
Teat conc6tratiots chemis,'
Y:
Date. 6q-06-1 I
Page of 2
Pi -
DO 1,
Analyh.
Final,
11 aulk
7 4;
DO
I
t�L_r
rails f _-Elz _104W., - .:-.
,
1
,
Diy)
I Parameter
Aa
log
V.T
—Ififitul ,Final-1.
Fj_ I
,� iirvivaiDafiv
Of
--v,
Time* VS
Analvst,
VA,
g7g A
j"
,TcstR es u6s:
'Lower contra
'LC50 (ifi6diff Iethlll _d66E6htrati0n)-_
Calculations and data reviewed-. GN

-
Acuta Fathead N1laaswTest-24 HrSurvirel
simt Da=:; 4•0,701 {
Tca ID.
PFPR-•.r sample ID:
Enk`r0 cl u ism • Nc:i'ma xW=dv:
U.V!Dals:-#7fzIt
Lab1L`:
ETS-Envit.Testues'�eA �-u.�Is,TyrL
VSIR-Di3CfWRel.ionitirinj'E4
E—.=pk Date:
Naoiml:
, ALUTE-EP t-U t-ad2.012 'i dt SP:Cks:
FP-p(tna hales NrOm:lu
C •mmamr
>`-Ccntral� 1.0;•0
IOC:+'
LOOG9
i LI1CD �
,�:1s
115i I.U1.0 ,
ll �
50' 1-ow
'.1,000
Ja, a.lo8o
a.`>4; v
CoorlS�
Sle:a
Y-Mean
,Mean
_ Tratyforw. ArUM 3qu;re ROM
.•.ila MAX CV%
'_ _
N
"fit,
1-Tsiled
CiltICOL
.;SD.
Picm6er,
Rev
TIM,
tiv:a6e=,
D•Conuol
1,0"n
l_0^00
1.41.0
1.40*
1.41:J.
O t3.
2
0
23.
6.14
19C,0
L.LfOG
IA1:0
t.417.0
1.41`d-
OfXA
2
0.V7
2,W
0.1HIP
d
0
12.5
t}"90
IAL:1'YI
li:li0
1.4120
JAM,
0.Ox
?
Ol J,
183.1
0.1150
0.
.S
2:
L.J00f1
t.WW-
1.41:
LOT.)
141231,
O,im
2
vn
2.930
C.1151,',
J.
,•
,_
1.:0'
I.U4J
1.G3G7
Itl7A
IAis3
1.41»J:'
6-0M
2
0i761',:3'C.
m
.•INA
0.150
0.t56
6.39-,7;
0.3218
?.46.i5-
25,550
1
24*:
v.W
!} Il'9
t7
•;IJ
Tr:.aunerKs r DCor.-a: -
_ Trimieral Spearmin.NarlKr-
Trim L�el &C30 PSl+L-L �
:.c:J-!'_• L [; 3 ? 170 69 627 Sp 1 S!
Ei
It

r r: _er
• �`��'� " � Asheville, NC '3802
Phone: t828) 350-936.1
Fwc (82S)350-9368
--- __, _.. E-mail: AmSinnnert� aol.cda;
Ewlrenrnental Testing Solutions, Inc.
Fffluent'joxicity Rcport;Form ' Chronic Acute LC w Dote: clprit 22, ?O11.
Facility: EaviromentalChemist%Inc. NPDES0: NC-SOWS33 Pipe.+: 002' County., Columbus
flexion - ,Momenlive — - -
Laboratory PerfonningTesl: Environmental Testing do 42 C. Comments:
Siimawre of Operator in Responsible Charge: `ice;- Projccr: 7650
Signanir:, of Laboratari Supervis^r. r Y7�y.-----�'f _ , Sattple- 110406.29
mail; Original To: North Carolina Department of Environment and Natural.R ourcesT; Chr4 riic.Tesit RG;alts i
DWQ! Environmental Sciences Branch Calculatedc-,
1621 Mail S^rvieeCenter Tabulaii
R31cizh, NC 27699-1621
.North Carolina Ceridrlapk►rra Chronic Paw/Fail i2eproducticn Toxicity"Pest •fJ. Yertevt
yw _
�- nw.-ii Fte ro�nrrton
Control Organisms 1 2 73 d _,, 5 6 7 8 9--ti?s.-i t.r l2. , Pontr:P canvas` It
k
Number of Young Produced
AdultSurviv3l: (L)h'e,(Djad
jl7rrn,:tmt2
;Tt.rrt:n7_t .1 '
- • 1t i
-- �
=Gf:7acnt Piarccritage ' 7
Sfreatment 2 Organis1 ?. 3 4 3 6 7_- 8 9 101. 11'i l=';
,1 _
Pass Faijl�
'mni crr of Young Produced.
I:3dult Survival: (L1ive• (Dlead
- pR,(S:i=:) Isis le is" Sant le 'nd Sam le
Control
Treatns_rrt ?
D.O. (artg/l) 1st Sam 1c IstSam lc and Sam le
Contral
Trcatmant 2 EE
LCID/Acute Toxicity Teit.
(?,Iorts(iry. expressed Vas °c, Combining replicates.)
Cunrentrstinn (%j
Nlortalit)-t"•'II1
(:ontrn
6.2a
1 1? � I
PE
1 SQ
1 1011
©
1 0
1 0 1
4
1 0
110°0
LC,,) = >100%
95%Crin6dence Limits
�U IC to 1\rC
Organism Tested:
l f&f
mt Start Dwt.:: 04-06-1 1"
ICollection iStart) Date.
Sample:) 04-05' 11, Sant(il^'
Salnple'fti-pe"Duration
- •�='�
Semple I C
1 S`mpl,y
_
— r
-'A.,1in1[rtLY1 , L:U-LI
a 32
H2rJ�cli wi3 ��CCi�Li
;7
3 Cnna'ut,ic=i•; (pinh�-;l;ri1
} :.�
Toed Re.atuai �S,hv,::tirr>> a
l'.= ;0 1 .:
t S:tr;:�:l�+•rrmp �t R:t��ptS°f.l
,r-
F€i=��»a :i 0:8i
:
� .Few:.... � -..r ...—�—s- �.-.-- r-.__� -z.•—",..»..
r•-^_ W _ ��__
Method or Drtennination
Trimmed Spearman Karber
Probit
k Other: Visual Inspection
Duration: 24-hours
l f 1=w
7.Si; 1 7•65� Con+.nl 7.3' T.6
7.51 7.d8 Niga Cpm '8,'4 x;
pH (S.U.) DO (me'L)

PO Box 7365
Asheville, NC 28802
f � Phone: (828) 35U4361
Par: [phone]
_� , _ - •� �— F--trail: JirnSumncr.giol.cens�
�gs Environmental Testing50lutions, lnr— _ }
Eftiir nt Toxicity Pepart Fnrrn - C-hiotiic;Pass/Fai! znd Acute LC Date: , pril 22; 10I t
' Facility: Enviromental Chemists, Inc. NPDES #: NC- 5000533 Pipe e: 005 County: Calumhux
s Hexion - Momentive
a Laboratory PerParming'fe;t: Environmental.Tasd ' lu Jnc. %Celfiirl�ilA:P
Signature of Operator in Responsible Charge: ('reject: 7050
_
Signature of Laboratory Supervisor: �- — .�aijnQle. 110406.30'.. '
Moil Original To: North Carolina Department of Environment and Nalural Res Urccs '` Chronk Test Results i
DWQi Environmental Scieneesdiranch Calculated t: _
1621 Mail S.•rvice Center Tabular r:
Raleigh, ,NC 27699-1621 '.S Reduction:. [
'Norlli Cnroiinz Cerlqdqplmlet Chronic Pass/Fail Reproduction To-acity Test `"'' '= '—'tr ge
- _ ►iortet[t •-- Reproducti,m
Control Organisms 1 2 3 4 5 6. 7 8 9,• 10- Ill. 12- Cunlrol Ccau:+l,
Number of Your Produced
A'duh Survival: ;..livi, Dk'od
!
t-ie srnLin 2
Tralmuit �
Effluent'?ercentage
-frestr:ient 2 Organisms 1 2 3 4 5 6 7 8 9: 10 11 12
.Pass, .Fait =,
Vumbrr of Youu Plvduced
_4 - •t
Adult Survival: (Dive, [D)ead
_
!
p24 (&U.) Ist SalaPic ISt Sala 1;.1' 2nd Sam l�
Control
T'rcatnlent
7
17. n
D.O.(mgfl) 1stS2rlt ke. 1stSartt le
Control
_'ndSamole
Tr4`-attnent 2
nc
LC )Acute Toxicity Test
;,NJortality e- pressed as "w combining epiicates.l
('encenrrudan (Ai
Mortaiilr- (Y.)
jContro4
b.25
1 12.5
—F--
25 -50
100
0
0
0
0 75%
1 1J0%
:St Start Date:
)Ilictiun (Start) Dzie:
Sarnpli�', f 04-•05- l 1 Sample 2
Sample rppe Duration.
S
Al:al:n,r; (mg Caj7o:'I t
(: rlsuctiv:l}- i !rrr:ti�:'tZt1
r„al:tr:tlu.tCh°on :fn';:;i�
Sin:?lo l':r,p ut RSc�lx ('C i
32.,
..3..'Tiy-•
ci�tl
37
150,
189
-cj+6
i_C., = 42.0% ktethod of Determination
95ce Confidence Limits Trinimed Spearman Karber - =
36.800 - to 38.145 Probit ' • - �_ _ r
~ X Other: Spearman-Karber 7:ab 7.57 C,-urvl 7:8� 7:
_ . T2 2 7 16 1Hi;h CnnL 7.5 6: 7
Orgauism Tested: Phnophales promelas _ Duration: 24-hours. pH (S.V.) DO (ing(C)
Dlb'Qfarm.IT-1 (3187) ret: 11i9S

t
T!!v.
s: L�-1
flare:
Acute` Whole,Effiue6t Toxicity Test
(EPA-821-R-02-012)
Species: EtEgg tgfespromelgs, Duratiati:, 24-hourit
'Clietstr`"��•'-- Envl�ontnentaf(.'�tetttist3° Iitc:—
$acility: He:iait+=- '-- -
`Comtitentss-�— - -
i
�I'�st:or artisnrrn vrmatiorr:
=.Coati :: -U -U MIbtiS
Ij
Test iri fdrnsation:
-- -- _ ._ .
Organism age:
Z O
�Rsndamiiag teinplato:' ' —
�
Date and timed arganitms here
born between:,
t)y_p�_i1 yk
;Incubator number:- "`
, +
Organ tsnssource:
6p►xtA ?p
XantriL7liMion-water_I;ic:.: _
Data and.time organisms were ftd:
-I : Mm 4 1360
CantrotlDilutinn water;h5 t:lu. =
„ az. jl-t.�s
°A roximat. transfer vessel volume
'Der, re licate frFIL
s
L ive.wet.weigtttof tO Inrvae (p):--
0(yal,
Loading (g/L):
at[[ ranee timit •= OAU WL at ZV
01. • 071E tr e-
Transfer vessellnformation:
phi.. SIJ Temperature=.
Full=street tft.'t:lremist
s
E
i
i
Pi+ra;meter�
. '. Crintroi,
Sash [n E,
pff (S.U.) "_
�— '••c
- :`
iCSUeitiv+i stintdnie:
6+0S 41
DO (mgrl 1-
- (l
ollectlua end time:
'Conductivity
(SO
EGrabiCompusite(durati-ral:
Alkalinity
-Temperature (`i.')'upon receipt:
Alardne:t - ..
� '1
P1+5'si a1 charaeteristica:!
-5-loi�-
m` Gac aL��.
F
i
L�t3tSts)
Total Residual; ;i� ����15
MEf
Chlorine (mr,,1) E
..
j
ETS sample number:
Y
-Dtlutinn re ardt#ot><r� _, �,._.,.-._•��Y.-....- ..�=:- -
--
�-
m� Saiisplec - _.
31,25
..- -62.5
125,
:i5
mL' Dilution watt:r.
469.75
"43715,-
-3-75
2.•.0
1:+-
Tr}ts1 volume -Ow

i
Tesic.ancenlration cheitoistry.,
Dule., n!A,-P!R -11
Pagelof 2
ly
q
FlnA
OH, (S. U.)
DO CtbWL)
LP iidimthrit
'. J:
6
Final
- ---- -------
uy
p
WLt
-W— 19
'Canductlyiq (;1Mh6
1212—
3 C)
7 �Ilnfttal=�
Ajtitlal 'Pittal-4
I11MM.- Fibali-.—
itj i
Al. -VY.
x4?Ir-RV1r
N O
vMYt
�4}t
-
;r -a4,
—
i" 't A
iTll" '31,
,24 hour
Contro
6.25%
251,14
IIlk
!
Survival
M
P/6
It
07.
'24bour,�- 1, ou r_
crcontrol'limit'_-
ont
1;6,yer control limit",
Ot4tio
L�Ct�O((Inn diin lethal c6R&
Calculations and data reviewed:
N

:E
Dare:- t)-A 01.-1%
,Acute )Vhole Efflue> t Toxicity Test
(EPA-821-Ri 02-012)
Species: Pimephales prornelg Duration: 24 t burs
:lient:
Envlronmentul'Chemists fttt.
[YPi7ESN•Mcs=s,
facility:
Hexion nlTtvt_.
Colin :
%ot_i1H U5. r
Outfalllpl -
C7US
M -
_ __ l
rnct.nraa,ti<m frtt"artaretlen:: _
TOst. is /}irirrafhwt
)rganism age:
'Z ""—'
Randomiiiteg templatot
(l_,)y-0f!~t!fip`
We.and,times organisms were
9' t6w
'Incubator number:
-
orn'lietweenc
- --
- -
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ta7
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. ep
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-46-14,
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m

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A91 I
Asheville, NC 2*12
V Phone: (828) 350 ?364
-« fax: [phone]
Environmental Testing Solutions, tnc.
kpfil 22, 201 l
Mr. 14,13aker
En:,ir6ninental Chemists. lac.
660cYindntill Way
1Vilmington, NC 28.405
RE: ETS PROJL-Cf NUMBER: 7050 and 7051
Dear Mr. Sakcr:
�ncla.etl are Loxiciry
Jest results tar samples from�ilcainn-11*6in ntlr • rrrxi.ed by E nvirunmeciiak Testing
�e
5u[ution.. inc. un
,April 06, 201 I.
._ _l
Method
HUI Resales`°
�utialt
Test Procedure
_.i=hauriC.e
00.1
fie hr+ai.aedSW n{h.ruhmktkuDerl !lG':srptrohr�aw,Lu,tc4iLC�yr
2P R.afY.91
75 2%
-- � ,...'- _. -
. �.- `h1s$r:+Js t_y Me:a?v°{ q+:4a:7. Pater d EBlnsa and Rnaiuir� W am m
CEP:=1_1-r,�4'112
--_ `-"••--""'-"-`~' __ -
UO2
L"
>100%
W� m
003
34.2%
.
AleQrda tp •�L:oaSq L'a AMM _04 Cty Of am -an Qd ltawlftll WNW 1* �---�'-� :=
.... -
- _... -_�••• . _ '
0041
r�elraw�art.as�s,mmvo�v Ley •gyp aa,:ruerc
EP+� rr.=n�i:
36.9"/o
Isvosr Tau -• - .....:-Y--
..-�. - ._ .. -. `°°-'^
.•�•...-. Mefin°>w .r Afmu+4 r�<`.aais il5rjef 1'.I>;vaarr ud Rwoi�da1 Wow-
005
F.r�Fwiriar3llcar {Jrg+�ds' Llaa►u RU+giuk+p+ aAcm l>G:i
LPA-i21:l;+ru11;.
42.()%..
r: -----_._ . McYrdr tM �{e.aemt d�'Acae Taaiorr of firtEceu �� ]tew.igl Wa1e+r � - -
006 - f.reran.�m,a�m�neor�,qu•x.aeevbcY�rY�!-w.�rrah�ur�+a.Wvtiwatfa b .t8 1.R+Yur: 70.7%
ai,y„aa tw ►kaviq me AIMT:caary of e8lmaa rd R,ca+vy Watytl+r :-i>° :: _ — .._. _-_.-...
009 > 100%
Tent
.V4- 24:hour LC:e �- itiediiri,Uthal;Caacentration . Aa estimate of the c6mcint�ttigii of eMikn 4ifilch'is IEGinl-ui 50°a ar
the'tCS; or isms In 24hokm. a• _ m n'- _ ._ T R._.. _..... _ .
If:these tests �vcm pacformed u an NPDES.requimment or h Administrative Letter, please enter the resp�tivc LCp..on 4: h
Effluent'Di;eltnrge'Niciiiuuing Form (Miff• I ) for the collection date April 05, 2011 using the parameter code TAEkC
,Wditionally please sign and st{brnit the original D%Q Aquatic Toxicity Forms (AT-1) by May 31, 2011.
lt'}vu have any clucstions tu+tcenring these results, plessc Feel Free to contact Ins,
Siilc' el}
. 'umner
I z6oratofL7 Director
This report should not he repmduccd,:except in its entirety, without the tFritten consant of Environmental 'resting Sn[u€Iow.., Inc.
results in thls re ri relate Rids to the srirn les subrrtittzd Fur_an,ilvsis:.
_
", 1';,'rrh"CurolinaCcrii {cnteAulnber:;;,Biulo ieaEArta#yses: 37.Uri,,king Water- 37786Wa�itwatet:�5i)p'
SouthC'{uulituf'Gerrifcrte rtirfmber: ClI.an_Water Act: 99053-001

PO Box 7565
Z" i' �� ' " Asheville, NC 28i3(f_i
in Phone: [phone]
Fax: (828} 350-9368
q n�E-';nail: iiinSutnnercinaol.com
J EnvlmomgntW Tostlnq Sotuttoa, lnc.
Unuent Toxicity Report Form - Chronic PaislFail and Acute LC�: _ Date: Aprif22, 2016
Facility: Enviromental Chetnlats, Inc. NPDES fs: NC-S000533
Piper►: 001 Count}^ Columbas!
II 11exlon - Momentive--
i Laboratory Performing Test-. Environmenttii Testing Sol utions,_Inc. _
i Signature of Operator in Responsible Charge: — - -
i1 Signature of Laboratory Supervisor "
Cummetus; ,_
ProlcCt: 7050i
SarrtpW- 1 10106.28
Mail Original To: North Carolina Department at -Environment and Natural Re;ourm
AtVonie Tesi Reaulls
D WQ1 Envlronnicrital Sciences Branch
Calculated I.
1621 Mail Seryice Center
t-bular r;
Rileigh, NC 276A-1621
°:-Roduction:
;North Carolina Cirladaphnia Chronic Pass/Fail Reproduction Toxicity Tut
:�enciu ,.
A�eroRp
Hartutity
Re ueti6-
C2mral
Coiurul
li
Control Oigarilsrus 1 .1 3 4 5 6 7 8 9
iti+ 1 L 12
;dumber of -Young Produced
Adu It Survival:. (i,)ive Dead
' Tegatraem 2
Tiesir.tam 2 :+
E,Muent'Percentage
Treatment 2.Orgsni§iny ' 1 '- 3 4 '5 'L 7 tt' 9
:16. 1:1- 12a
�[?assrW _Fall
1N:uln b<,7 ofYoung Produced
%.•�c:5s.3a...,
+iF.�
.„
.-�..y� -
iidult Survival: [L)ive:'idkad
oil (Sx.)' 1st Stun le I st Sam Ie 2nd Sans le
Control
Treatment")
U.U. (mg/1) ist Sam Ir
Control
Treatment 2
3 `d, '1'
1 st Sam le 2nd Sam Ie
i,C50!Acute Tozicity Test
{Mortality expressed as Ve, combining replicates.)
Cuncentrstlon (% I Capita C25 12.3 25 1 So I Intl
Atortullts (°'�f 0 0 0 0 0 185"5
Start Date:
Illection (Start) Date:
r
Sample 1 04-6-1 t. Sample°2'
Sample 1'.prJUuration
;;10- C-w Wnc n
Sample l X
�empL! 2
A Ikelrat ty img CnC:D:, Lt
NarOne a (mg Caccl A)
Cunduciigily t µi3tit,ivunl!
Tma1 f.:s'sdual Gtilorne tiny Ll
Sample Tamp: ai R--ccrr. c&
LCso = 7e.2% �.Iethed of Determination
95%Confidence Limits Nother:
Trimmed Spearman Karber69.6°u to 81.20;Probit 7.5617:61 Contn;l 7.8 1 7.5;
T60 7.77 ;,ItiithCu:u. -B.l- 7:1j
Orgauisrujested: Plmephales prornelas Duration: 24-hours plf (S.U.) QO (MVL)
-D ItiQ forni .d T -1 (JA2): rev. -1 I195

is
1 ...k !
13=.� t ! . lrh_.
Environmental Testing SHMutlon; In c.
t�f luent Toxicity Report Form 'Chronic, Pass/Fail and Acut LC�o,
PO E or- 7565
AslmVillc, NC 28862
Phone: (828)"-'50-t44
Fax, (828).350-9363,
E-mail: [e-mail]
Dato:. April 22, 201 is
Facility: Enviromental Chemists, Inc. NPDES 9. NC S000533 W Pipe 4: 002 County. Columbus
Hexiou • Moineative
Labort.toryPerforming Test: Environmental Testing Solutions, Inc. i Curia' mm 7 }
SigiiatureofOperator. iftResponsible Charge, Y � Y1 1Pr(7JeCt:_IQ$�1� -
# Signature of Laboratory Supervisor. �SalnptLO 11040619.~
,:tilait Original North Carolina Department of Environment and Natural Resources � Chronic Tot' ils 06: �
DWQ/ Environmental Sciences Branch Calculated r
162E Mail Service Censer J 1'ahutar r:
Raleigh, NC 27699-1621 04 Reduction,
North Carolina Cerlodaphnla Chronic PasVFaii Reproduction Toxicity Tail .i ` Percent Average,
ktonalit roducdoo
r ontral Or anisms I 2 3 4 - 5� _.-6 7 8 9 10 ! i 12 ', C.ontrrol Coatrii
NutnB�r of Young Produced
Adu[t5urviwal: Liivt,(D)ead
Tiaittmene.,
'rumira',at2
Effluent PercentagX7--'1J
freattnenl2 Orgalilsiiii r -. 1 2 t. ..4 5 ,_e6 7 0°. 9 10 11 12 x
Pass F'aill
VumlicrofYoung Produced
A;lult Surv:v�i: (G)ivc, (D)ead
a
PH (S.L.) Ist Sam le list Sam le ?nd Siam le
Control
Trentrnant 2
t: � 'j � -1 a]
Vr S` y n
D.O. (Me) Ist Sam le kst Sam ple 2nd Sam Ic
Control
TrcatmCnt 2
1.Cso/Acute Toxicity Test
(Mortality expressed as %, combining replicates.)
Ccncentrat loll ts:) lContrall6.25 1 12A 25 so F100
Mortality (ni I () 0 0 0 U I 10°/a
Alection (Start) bate:
Sample 1 04-05-11 Sample
Sample TypeQuration
Sunpte
Sum 2
pie
G
Aacaluiits (mg CaWt L)
Hwdtiie:;tmgCatU',7
37
Conductivity (tLmhQVCrn0
Total ttrsidual.Chlorire (mg0t)
5
S:mple rang. at ilwxi;;a M ;:
-
LC, a >1000/0
Method of Determination
950i6 Confidence l.iinits
Trirnined Spearma, Karber
a
NC, to NC
Probit
"' 3
X
Other: Visual Inspection �.
7.56
7.65
_Control
7.8 7.6
7.5E
7.48
.
8.4 7A
Organism Tested: PmThalesprontefas
Duration: 24-hours
pH(S.U.)
DO(mg/L)
pWQjorMAT-1_0/B7) rev. 11,15

-.
L
E-mail
April 22, 201 l --
Facility: Environmental Chemists, [tic. NPDES -?: NC-S000533 Pipc #: 005, . County: Columbus
Flexion - Momeattva
r— �---
t
. Laborattrry Performing Test, Environmental Testing Solutions, [nc. .Comments: [;
..
{ Signature of Operator in Responsible Charge:
Project:, 7050
Signatwo of Laboratory Supervisor- ;
Sample. 110406.30...
11i©if Original To: !North Carolina Department of Environment and Natu6l Rewurc:!s E
�,Chraolc Test Results
DWQ. Environmental Seienc-s Brarmb
Calculated r:
1621 Mail Service Center
Tabular r:
Raleigh, NC 27699-1621
i
-
ii Reduction:
Morth Carulllta Cerladaphnla Cbronle Pass/Fail Reproduction Toxicity Test
- i'ercoati
\i,riye
martattt
H rcQnaiaa.
Cantroi
Cntuanl "
wontral organisms 1 3 4 5 6 7 8" 9 l0:
11 12
Number of Young Produced
Adult Survival: (L)ivej CU cad
I
I
I -
'
w; re )rent 2
7twtinenr3
LFMuent Fercentage ' \
Treatment 2 Orbanisms - „, t ­2 3 _ 4 5 6 7 8,r 9 .10,
11 1-2
;Paw, Feil
Number of Young Produced
L.._. .
:Adult Survival: (L)ivo, (D] esd
pH (S.U.) isl Sara ke Ist San m le 2nd Sam le
Control
Treatment 2
D.O. (mgtl) Ist Sam le Ist sample 2nd S 1131C
Control
Treattnent 2
LC5dAcute'1rox1clty Test
(Mortality expressed as 5* combining replicates.)
C;aatentrAtion (%)
Mortality [•;1
Coatro
6. IS
I 12,5
1 2-
1 W
tOtl
0
1 0
1 0
1 a
1 75%
100°.b
,04-0&1 I -
dlectiun (Start) Datc:
Sample 1 04-05-1 1 sur 1ple 2
Sample Type, Duration
Sanyie I X
c.
s
-• {
a
!wimple 2
sr. v t
Atka]MiN (nigUCO;;t i
32
li�rdritstml'aCG_%t_)
.37
C'axiuturir, tltmhen/erni
�I SOv.
l.illi9i
Toni Residual Chlonne tmEl[t)'f�=�
a
S:mple'f,.mp ne ReteiFt!'C) :
�,o;S'
LCni - 42.00f6 Mettlod urDetermintuion
95% Confidence Limits Trimmed Spearman !Garber
16.8% to 48.1% Probit
Other. Spearm7.5
an-Karber G 7.t7 Control 7-B J.S
7.22 7.16 rhgh Cow 7.5 6.7
Organkin Tested: Plnieph4lra pru.nrlas Duration: 24-hours pIf (S.U.) DO (mWL)
DWQ form IT-7 (3187)'reV.-1b95 .« "

I
A
Ira
G P
February 1, 2012
Peter R. Yurgel
Plant Manager
Silar Laboratories
333 Neils Eddy Road
Riegelwood, NC 28456
Subject: Stormwater permit NCS000533
Silar Laboratories
Columbus County
Dear Mr. Yurgel:
Thanks for your email of last October 31, asking for guidance on whether Silar
should begin monthly sampling based on benchmark exceedances. At that time we
exchanged emails, and you and Mr. Bazinet supplied some additional information
through November 8, 2011. DWQ appreciates the quick response, and the
collaborative character of our interactions. Essentially, you proposed that
Momentive's sampling results at their Outfall #003 provided a basis to interpret the
results at Silar's outfalls as complying with the benchmark values. I promised to
review the information, and to get back to you.
I apologize for the delay at our end. I have finally been able to review your
information with the permitting staff in Raleigh, and we have concluded that you
have not supplied enough information for us'to concur with your proposed
assessment that the Silar facility is in compliance with the stormwater benchmarks
contained in your permit. Our conclusion is qualified by the following:
• We remain committed to the principle that Silar should not be held
responsible for stormwater pollutants generated by Oak Bark, or Momentive.
• We remain receptive to data interpretation that accepts the above principle,
and that accounts for the pollutant contributions from your two neighbors.
• We have no pre -established guidance for quantifying a site's pollutant
contribution in relation to its neighbors, because site -specific circumstances
vary so widely. We are receptive to data interpretation based on sound
engineering and environmental science principles. In your atypical site
circumstances, the burden for constructing that interpretation falls on the
permittee. Your method and the subsequently transmitted sampling results
alone are not a sufficient verification that your site is not responsible for the
benchmark exceedances. You must provide a rationale that interprets those
results for us and shows benchmark compliance by a more defensible
methodology than the simple subtraction of pollutant concentrations from
different flow streams. Generally speaking, concentrations may not be
subtracted without a mass balance calculation, and typically even then only
from the same flow stream.
We are interested in working with you to resolve the question of whether you have
met the benchmarks, or not. To that end, I have asked the Central Office
Stormwater Permitting Unit (SPU) staff to provide comments on the copy of the
Site Plan that they used when considering your site. Their comments follow.

I
• Our detailed understanding of the stormwater flows on all three sites is
hindered by an insufficiently detailed site plan drawing. In most other
normal permittee circumstances, the level of detail in your site plan would be
sufficient, but this site is very complex. Without a better understanding of
the sites' inter -connectivity, DWQ cannot analyze the issue of benchmark
compliance at your site.
• : We are in possession of a reduced size copy of Momentive's drawing SD-
00002-M-02, Rev. 5, January 3, 2011. DWQ requires the following additional
information:
1. The existing topo lines on our copy are indistinct. Please make them
legible, and please be sure that legible topo is presented for the entire
permitted site.
2. The heavy internal boundary lines are not identified as to what they
delineate. Are they battery limits? Are they company boundary
limits? Are they subdrainage area limits (ie, drainage divides)?
Further they do not appear to have been placed with precision.
■ Please place with precision the boundaries between the three
companies.
• Every outfall for all three companies is fed by an internal
subdrainage area (and in the case of the Duck Pond, by an
additional off -site drainage area). Please overlay accurate
boundaries for all the subdrainage areas feeding each outfall,
and the accurate boundaries between the companies noted
above. It is not necessary to delineate with precision the off -site
areas contributing to the Duck Pond.
• Please use some graphical notation to identify points and areas
where flow from one company crosses into a second company's
area and is eventually discharged from that second company's
outfall. This should be apparent from the overlay of company
boundaries and subdrainage area boundaries, but this graphic
emphasis will help all parties focus on any problematic locations.
3. The large filled -in circles identifying the sampling points are insufficient
to describe the sampling location. Please locate the sampling points
more precisely, and provide label information that characterizes the
configuration of the sampling location: e.g., "Dip sample from ditch,"
or "Collect sample as the flow springs from the discharge weir," or "Dip
sample from the manhole invert," etc.
4. Please reduce the number of superfluous flow arrows on the drawing.
While a few arrows may be helpful and indeed are required by your
permit conditions, topo lines and drainage area boundaries generally
are sufficient to describe most of the plant area.
5. In a congested, heavily developed industrial site like yours,
subdrainage area divides may follow curb lines, or roadside ditches, or
road crowns, or roof peaks, or downspout locations, or drop inlets with
storm sewers that cross under other subdrainage areas. DWQ
requires this information on the revised drawing. This can be
especially important in your case where there are enclaves and
intertwining areas of responsibility between three companies.

6. Please note the following requirements in the permit text: in Part II
Section A 1(a), "accurate latitude and longitude of the points of
discharge", and in Section A 1(c) "A site map drawn to scale (including
a distance legend) showing: the site property boundary, the
stormwater discharge outfalls, all on -site and adjacent surface waters
and wetlands, industrial activity areas (including storage of materials,
disposal areas, process areas, loading and unloading areas, and haul
roads), site topography, all drainage features and structures, drainage
areas for each outfall, direction of flow in each drainage area,
industrial activities occurring in each drainage area, buildings, existing
BMPs, and impervious surfaces. The site map must indicate the
percentage of each drainage area that is impervious." Most of this
information is currently on Momentive's January 3, 2011 revision, but
not all of it.
7. I see what appears to be a speed bump up -slope from your Outfall
#002. Is this related to stormwater control? If so, please identify its
stormwater control function.
• DWQ is aware that the development of an adequate site plan may require a
collaborative effort with the other permittees, and we have copied them on
this letter. We are also aware that, depending on the physical factors, an
adequate site plan may require that you commission a ground survey to fill in
the missing detail in the heavily congested areas. It is doubtful that an aerial
survey could get the level of detail required for the necessary accurate
delineation. Please contact us with any questions on timing or need for a
ground survey.
• Please respond by April 1, 2012 with a revised site plan, and with a revised
interpretation of the analytical results.
• We note that your data results submitted so far show three consecutive
benchmark exceedances for multiple parameters in three of your four
outfalls. In accordance with the terms of your permit, please begin monthly
sampling and continue until we have accepted a more well -developed
argument in support of the proposed conclusion that you have met
benchmark values.
Sincerely,
Linda Willis
Cc: Red Lewis, Oak Bark
Ronald Bazinet, Momentive
DWQ 5PU — Bethany Georgoulias, Jennifer Jones, Brian Lowther, Bradley Bennett, kbp
DWQ Compliance knit — Karen Higgins

S 1 1,4 -
Sample
Date
Precipitab
on
(in)
TSS
SOD
COD
NH3
TKN
NO3 + NO2
Total P
Methavol
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Hpxamine
a
yde
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Total Zinc
Total
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k:
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Benchmar
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Benchmar
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Benchmark:
NIA
Benchmark:
0 03 mgIL
Benchmark.
15 mg/L
Benchmark:
6-9 say
-
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k:
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NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director R C��Secretary
October 22, 2010 4CT 2
i\1r. Peter Yurgel
Silar LLC �Y
333 Neils Eddy Rd.
Riegelwood, NC 28456
Subject: Final NPDES Stormwater Permit
Permit No. NC5000533
Silar LLC
Columbus County
Dear Mr. Yurgel:
In response to your renewal application for continued coverage under NPDES stormwater permit NCS000533,
the Division of Water Quality (Division) is forwarding herewith the subject state - NPDES permit. This permit is
issued pursuant to the requirements of North Carolina General Statute 143-215 .1 and the Memorandum i�f
Agreement between North Carolina and the U.S. Environmental Protection Agency dated October 13, '2007 (or :is
s-jbse luently amended).
This fin. l permit includes no major changes from the draft permit sent to you on August 23, 2010. We
received conirnents by email from Silar's President John L. Shibley on September 24, 2010 and from Sitar's s'lant
lklanagr=r Peter• Yurgel on September 17, 2010. The comments were focused on concerns on resp>>nsibie cf
contimi_iation that is beyond their.control. A meeting was held on October 14, 2010 in Wilmington tivitt•. Sitar ir�
o der to address these concerns. The final permit is consistent with permits for Hexion Specialty Cflez.6---als, !nc
and Oar', -Bark Corporation.
The qualitative monitoring strategy is quarterly. Please note that quarterly analytical monitoring; is also required
in ibis permit Failure to complete the monitoring as required is a violation of the permit and any hermit
noncompliance constitutes a violation of the Clean Water Act. Reference Part III, Section A, Item 2 "DFAly to,
Comply", Item 9 "Penalties for Tampering" and Item 10 "Penalties for Falsification of Reports" of your perm;'t for
further information.
If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable to
you, you have the right to an adjudicatory hearing upon written request within thirty (30) days foliooving receipt
of this letter. This request must be in the form of a written petition, conforming to Chapter 150B of the V"ortl
Carolina Genera[ Statutes, and filed with the Office of Administrative Hearings, Post Office Drawer 27447,
Raleigh, North Carolina 27611 -7447. Unless such demand is made, this decision shall be final and binding,
DWQ would like to have an updated site plan for our files. Please send DWQ Central Office and DVVQ
Wilmington Regional Office (attn. Linda Willis) a site plan (each) including topographical lines and property
boundaries. If Sitar LLC owns or operates any areas, storages facilities or other facilities that are not within
Silar's property boundary, please Iabel these as ,vell.
WE,Ilands and Stormwater Branch One
i-17 Mail Service Center, Ralei h, North Carolina 27699-1617 NortliCarol hie
F,huri : S 9- N. Saiisbury S. Bateigh, North Carolina 27604 ����tt�=�ill�
�hor9: 319 ?;i7 53u01 Fah; 9t9-807-64941 Customer Service: 1-877-623-6748 st i[" `
Inn?rneI: tvwr;_j�c�va'2r,,vafi y.ory
"cup.: i;: n�; r,"riv ; A�fgrna:ivP Ar..Gnn EmnIC Ypr

Mr. Peter Yurgel
Silar LLC
Permit No. NCS000533
Please take notice this permit is not transferable. Part III, B.2. addresses the requirements to be followed in case
of change in ownership or control of this discharge. This permit does not affect the legal requirements to obtain
other permits which may be required by the Division of Water Quality or permits required by the Division of
Land Resources, Coastal Area Management Act or any other Federal or Local governmental permit that may be
required.
If you have any questions or comments concerning this permit, contact Brian Lowther at [phone] or at
brian.lowther Qncdenr.gov.
Sincerely,
for Coleen H. Sullins, Director
cc: Wilmington Regional Office, Water Quality Section
Mike Mitchell, EPA Region IV
DWQ Environmental Science Section, Cindy Moore
Stormwater Permitting Unit
Central Files
Attachments
2

NCS000533
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
TO DISCHARGE STORMWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEI•l
In compliance with the provisions 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,
Silar, LLC
is hereby authorized to discharge stormwater from a facility located at
Silar, LLC
333 Neils Eddy Road
Riegelwood, NC
Columbus County
to receiving waters designated as Livingston Creek (Broadwater Lake), a class C; Sw stream in
the Cape Fear River Basin, in accordance with the discharge limitations, monitoring
requirements,. and other conditions set forth in Parts 1, II, III, IV, V and VI hereof.
This permit shall become effective November I, 2010.
This permit and the authorization to discharge shall expire at midnight on October 31, 2015.
Signed this day October 22, 2010.
foi- Coleen H. Sullins Director
Division of Water Quality
By the Authority of the Environmental Management Commission
A\

Permit No. NCS000533
TABLE OF CONTENTS
PART I INTRODUCTION
Section A: Individual Permit Coverage
Section B: Permitted Activities
Section C: Location Map
PART lI MONITORING, CONTROLS, AND LIMITATIONS FOR PERMITTED
DISCHARGES
Section A: Stormwater Pollution Prevention Plan
Section B: Analytical Monitoring Requirements
Section C: Qualitative Monitoring Requirements
Section D: On -Site Vehicle Maintenance Monitoring Requirements.
PART III STANDARD CONDITIONS FOR NPDES STORMWATER INDIVIDUAL
PERMITS
Section A: Compliance and Liability
1. Compliance Schedule
2. Duty to Comply
3. Duty to Mitigate
4. Civil and Criminal Liability
5. Oil and Hazardous Substance Liability
6. Property Rights
7. Severability
$. Duty to Provide Information
9. Penalties for Tampering
10. Penalties for Falsification of Reports
Section B: General Conditions
1. Individual Permit Expiration
2. Transfers
3. Signatory Requirements
11

Pennit No. NCS000533
4. Individual Permit Modification, Revocation and Reissuance, or
Termination
5. Permit Actions
Section C: Operation and Maintenance of Pollution Controls
I . Proper Operation and Maintenance
2. Need to Halt or Reduce Not a Defense
3. Bypassing of Stonnwater Control Facilities
Section D: Monitoring and Records
1.
Representative Sampling
2.
Recording Results
3.
Flow Measurements
4.
Test Procedures
5.
Representative Outfall
6.
Records Retention
7.
Inspection and Entry
Section-E: Reporting Requirements
l .
Discharge Monitoring Reports
2.
Submitting Reports
3.
Availability of Reports
4.
Non-Stormwater Discharges
5.
Planned Changes
6
Anticipated Noncompl;a Ana
7.
Spills
S.
Bypass
9.
Twenty-four Hour Reporting
10.
Other Noncompliance
11.
Other Information
PART IV LIMITATIONS REOPENER
PART V ADMINISTERING AND COMPLIANCE MONITORING FEE
REQUIREMENTS
PART VI DEFINITIONS
M

Permit No. NCS000533
PART I INTRODUCTION
SECTION A: INDIVIDUAL PERMIT COVERAGE
During the period beginning on the effective date of the pen -nit and lasting until expiration, the
permittee is authorized to discharge stormwater associated with industrial activity. Such
discharges shall be controlled, limited and monitored as specified in this permit. -
If industrial materials and activities are not exposed to precipitation or runoff as described in 40
CFR § 122.26(g), the facility may qualify for a No Exposure Exclusion from NPDES stormwater
discharge permit requirements. Any owner or operator wishing to obtain a No Exposure
Certification must submit a No Exposure Certification NOI form to the Division; must receive
approval by the Division; must maintain no exposure conditions unless authorized to discharge
under a valid NPDES stormwater permit; and must reapply for the No Exposure Exclusion once
every five (5) years.
SECTION B: PERMITTED ACTIVITIES
Until this permit expires or is modified or revoked, the permittee is authorized to discharge
stormwater to the surface waters of North Carolina or separate storm sewer system that has been
adequately treated and managed in accordance with the terms and conditions of this individual
permit. All stormwater discharges shall be in accordance with the conditions of this permit.
Any other point source discharge to surface waters of the state is prohibited unless it is an
allowable non-stormwater discharge or is covered by another permit, authorization, or approval.
The stormwater discharges allowed by this individual permit shall not cause or contribute to
violations of Water Quality Standards.
This permit does not relieve the permittee from responsibility for compliance with any other
applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or decree.
Part I Page 1 of 2

SECTION C: LOCATION MAP
Permit No. NCS000533
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NCS000533
Silar LLC
Lab Dude: 3413 19' 43" N
-
I I
Longitude: 78° 12 S" W
1'- �.�.
Gounty: Columbus
I
Receiving Stream: Livingston Credo
Stream Cass: C; Sw
`,►
Sub -basin: 03-06-17 (Cape Fear River Easin)
Facility Location
A4--Scale I•-24,000
Part is Page 2 of 2

Permit No. NCS000533
PART II MONITORING, CONTROLS, AND LIMITATIONS FOR
PERMITTED DISCHARGES
SECTION A: STORNIWATER POLLUTION PREVENTION PLAN
The Permittee shall develop a Stormwater Pollution Prevention Plan, herein after referred to as
the Plan. This Plan shall be considered public information in accordance with Part III, Standard
Conditions, Section E, Paragraph 3 of this individual permit. The Plan shall include, at a
minimum, the following items:
I . Site Plan. The site plan shall provide a description of the physical facility and the
potential pollutant sources which may be expected to contribute to contamination of
stormwater discharges. The site plan shall contain the following:
(a) A general location map (USGS quadrangle map or appropriately drafted
equivalent map), showing the facility's location in relation to transportation routes
and surface waters, the name of the receiving water(s) to which the stormwater
outfall(s) discharges, or if the discharge is to a municipal separate storm sewer
system, the name of the municipality and the ultimate receiving waters, and
accurate latitude and longitude of the point(s) of discharge. The general location
map (or alternatively the site map) shall identify whether each receiving water is
impaired (on the state's 303(d) list of impaired waters) or is located in a
watershed for which a TAIDL has been established, and what the parameter(s)
of concern are.
(b) A narrative description of storage practices, loading and unloading activities,
outdoor process areas, dust or particulate generating or control processes, and
waste disposal practices. A narrative description of the potential pollutants which
could be expected to be present in the stormwater discharge from each outfall.
(c) A site map drawn to scale (including a distance legend) showing: the site property
boundary, the stormwater discharge outfalls, all on -site and adjacent surface
waters and wetlands, industrial activity areas (including storage of materials,
disposal areas, process areas, loading and unloading areas, and haul roads), site
topography, all drainage features and structures, drainage areas for each outfall,
direction of flow in each drainage area, industrial activities occurring in each
drainage area, buildings, existing BMPs, and impervious surfaces. The site map
must indicate the percentage of each drainage area that is impervious.
(d) A list of significant spills or leaks of pollutants that have occurred at the facility
during the three (3) previous years and any corrective actions taken to mitigate
spill impacts.
(e) Certification that the stormwater outfalls have been evaluated for the presence of
non-stormwater discharges. The certification statement will be signed in
accordance with the requirements found in Part III, Standard Conditions, Section
Part II Page I of I I

Pennit No. NCS000533
B, Paragraph 5. The permittee shall re -certify annually that the stormwater
outfalls have been evaluated for the presence of non-stonnwater discharges.
2. Stormwater Management Plan. The stormwater management plan shall contain a
narrative description of the materials management practices employed which control or
minimize the exposure of significant materials to stormwater, including structural and
nonstructural measures. The stormwater management plan, at a minimum, shall
incorporate the following:
(a) Feasibility Study. A review of the technical and economic feasibility of changing
the methods of operations and/or storage practices to eliminate or reduce exposure
of materials and processes to stormwater. Wherever practical, the permittee shall
prevent exposure of all storage areas, material handling operations, and
manufacturing or fueling operations. In areas where elimination of exposure is
not practical, the stormwater management plan shall document the feasibility of
diverting the stormwater runoff away from areas of potential contamination.
(b) Secondary Containment Requirements and Records. Secondary containment is
required for. bulk storage of liquid materials; storage in any amount of Section
313 of Title III of the Superfund Amendments and Reauthorization Act (SARA)
water priority chemicals; and storage in any amount of hazardous substances, in
order to prevent leaks and spills from contaminating stonnwater runoff. A table
or summary of all such tanks and stored materials and their associated secondary
containment areas shall be maintained. If the secondary containment devices are
connected to stonnwater conveyance systems, the connection shall be controlled
by manually activated valves or other similar devices (which shall be secured
closed with a locking mechanism), and any stormwater that accumulates in the
containment area shall be at a minimum visually observed for color, foam, outfall
staining, visible sheens and dry weather flow, prior to release of the accumulated
stormwater. Accumulated stormwater shall be released if found to be
uncontaminated by any material. Records documenting the individual making the
observation, the description of the accumulated stormwater, and the date and time
of the release shall be kept for a period of five years.
(c) BMP Summary. A listing of site structural and non-structural Best Management
Practices (BMP) shall be provided. The installation and implementation of BMPs
shall be based on the assessment of the potential for sources to contribute
significant quantities of pollutants to stormwater discharges and data collected
through monitoring of stormwater discharges. The BMP Summary shall include a
written record of the specific rationale for installation and implementation of the
selected site BMPs. The BMP Summary shall be reviewed and updated annually.
3. Spill Prevention and Response Plan. The Spill Prevention and Response Plan (SPRP)
shall incorporate an assessment of potential pollutant sources based on a materials
inventory of the facility. Facility personnel (or the team) responsible for implementing the
SPRP shall be identified in a written list incorporated into the SPRP and signed and dated
by each individual acknowledging their responsibilities for the plan. A responsible
Part II Page 2 of ] I

Permit No. NCS000533
person shall be on -site at all times during facility operations that have the potential to
contaminate stormwater runoff through spills or exposure of materials associated with the
facility operations. The SPRP must be site stormwater specific. Therefore, an oil Spill
Prevention Control and Countermeasure plan (SPCC) may be a component of the SPRP,
but may not be sufficient to completely address the stormwater aspects of the SPRP. The
common elements of the SPCC with the SPRP may be incorporated by reference into the
SPRP.
4. Preventative Maintenance and Good Housekeeping Program. A preventative
maintenance and good housekeeping program shall be developed. The program shall list
all stormwater control systems, stormwater discharge outfalls, all on -site and adjacent
surface waters and wetlands, industrial activity areas (including material storage areas,
material handling areas, disposal areas, process areas, loading and unloading areas, and
haul roads), all drainage features and structures, and existing structural BMPs. The
program shall establish schedules of inspections, maintenance, and housekeeping
activities of stormwater control systems, as well as facility equipment, facility areas, and
facility systems that present a potential for stormwater exposure or stormwater pollution.
Inspection of material handling areas and regular cleaning schedules of these areas shall
be incorporated into the program. Timely compliance with the established schedules for
inspections, maintenance, and housekeeping shall be recorded in writing and maintained
in the SPPP.
5. Employee Training. Training programs shall be developed and training provided at a
minimum on an annual basis for facility personnel with responsibilities for: spill response
and cleanup, preventative maintenance activities, and for any of the facility's operations
that have the potential to contaminate stormwater runoff. Facility personnel (or team)
responsible for implementing the training shall be identified, and their annual training
shall be documented by the signature of each employee trained.
b. Responsible Party. The Stormwater Pollution Prevention Plan shall identify a specific
position(s) responsible for the overall coordination, development, impiementation, and
revision to the Plan. Responsibilities for all components of the Plan shall be documented
and position assignments provided.
7. Plan Amendment. The permittee shall amend the Plan whenever there is a change in
design, construction, operation, or maintenance which has a significant effect on the
potential for the. discharge of pollutants to surface waters. All aspects of the
Stormwater Pollution Prevention Plan shall be reviewed and updated on an annual
basis. The annual update shall include an updated list of significant spills or leaks of
pollutants for the previous three years, or the notation that no spills have occurred. The
annual update shall include written re -certification that the stormwater outfalls have been
evaluated for the presence of non-stormwater discharges. Each annual update shall
include a documented re-evaluation of the effectiveness of the BMPs listed in the BMP
Summary of Stormwater Management Plan.
The Director may notify the per-mittee when the Plan does not meet one or more of the
minimum requirements of the permit. Within 30 days of such notice, the permittee shall
Part It Page 3 of t I

Pemit No. NCS000533
submit a time schedule to the Director for modifying the Plan to meet minimum
requirements. The permittee shall provide certification in writing (in accordance with
Part III, Standard Conditions, Section B, Paragraph 5) to the Director that the changes
have been made.
S. Facility Inspections. Inspections of the facility and all stormwater systems shall occur as
part of the Preventative Maintenance and Good Housekeeping Program at a minimum on
a semi-annual schedule, once during the first half of the year (January to June), and once
during the second half (July to December), with at least 60 days separating inspection
dates (unless performed more frequently than semi-annually). These facility inspections
are different from, and -in addition to, the stormwater discharge characteristic monitoring
required in Part II B and C of this permit.
9. Implementation. The permittee shall implement the Plan. Implementation of the Plan
shall include documentation of all monitoring, measurements, inspections, maintenance
activities, and training provided to employees, including the log of the sampling data and
of actions taken to implement BMPs associated with the industrial activities, including
vehicle maintenance activities. Such documentation shall be kept on -site for a period of
five years and made available to the Director or the Director's authorized representative
immediately upon request.
Part It Page 4 of 1 I

Permit No. NCS000533
SECTION B: ANALYTICAL MONITORING REQUIREMENTS
Analytical monitoring of stormwater discharges shall be performed as specified in Table 1. All
analytical monitoring shall be performed during a representative stonn event. The required
monitoring will result in a minimum of 20 analytical samplings being conducted over the term of
the pen -nit at each stormwater discharge outfall (SDO):
A representative storm event is a storm event that measures greater than 0.1 inches of rainfall. The time
between this storm event and the previous storm event measuring greater than 0.1 inches must be at least
72 hours. A single storm event may have a period of no precipitation of up to 10 hours. For example, if
it rains but stops before producing any collectable discharge, a sample may be collected if the next rain
producing a discharge begins within 10 hours.
Table 1. Analytical Monitoring Requirements
Discharge
Characteristics
Units
Measurement
Fre uenc t
Sample
Type'
Sample
Location3
Total Sus ended Solids (TSS)
mg/L
quarterly
Grab
SDO
Biochemical Oxygen Demand (BOD5)
mg/L
quarterly
Grab
SDO
Chemical Oxygen Demand (COD)
mg/L
quarterly
Grab
SDO
Ammonia as Nitrogen (NH3-N)
mg/L
quarterly
Grab
SDO
Total Kjeldahl Nitrogen (TKN)
mg/L
quarterly
Grab
SDO
Nitrate + Nitrite Nitrogen
m L
quarterly
Grab
SDO
Total Phosphorus
mg/L
quarterly
Grab
SDO
Methanol
mg/L
quarterly
Grab
SDO
Total Residual Chlorine (TRC)4
mg/L
quarterly
Grab
SDO
Hexamine
mg/L
quarterly
Grab
SDO
1=onrtaldeh de
mg/L
quarterly
Giau
SD
Copper, Total Recoverable
m L-
quarterly
Grab
SDO
Zinc, Total Recoverable
mg/L
quarterly
Grab
SDO
Manganese, Total Recoverable
mg/L
quarterly
Grab
SDO
Lead, Total Recoverable
m s L
quarterly
Grab
SDO
EPA Method 1664 (SGT-HEM) —
Non -polar O&G/TPH
mg/L
quarterly
Grab
SDO
PH
standard
quarterly
Grab
SDO, 005
Effluent,
Downstream,
Upstream_
Part 11 Page 5 of 11

Perniit No. NCS000533
60
Table 3. The benchmark values in Table 3 are not permit limits but should be used as guidelines for
the permittee's Stormwater Pollution Prevention Plan (SPPP). Exceedences of benchmark values
require the permittee to increase monitoring, increase management actions, increase record keeping,
and/or install stormwater Best Management Practices (BMPs) in a tiered program._ See below the
descriptions of Tier One and Tier Two.
Table 3. Benchmark Values for AnaNtical Nlonitorina
Discharge Characteristics
Units
Benchmark
Total Suspended Solids JSS)
mg/L
100
Biochemical Oxygen Demand (BODO
mg/L
30
Chemical Oxygen Demand (COD)
mg/L
120
Ammonia as Nitrogen (NH3-N)
mg/L
7.2 -
Total K}eldahl Nitrogen (TKN)
mg/L
20
Nitrate + Nitrite Nitrogen
mg/L
10
Total Phosphorus
mg/L
2
Methanol
mg/L
7,700
Total Residual Chlorine (TRC)
mg/L
0.028
Hexamine
mg/L
25,000
Formaldehyde
mg/L
0.5
Copper, Total Recoverable
mg/L
0.007
Zinc, Total Recoverable
mg/L
0.067
Manganese, Total Recoverable
tng/L
N/A
Lead, Total Recoverable
mV L
0.03
EPA Method 1664 (SGT-HEM) —
Non -polar 0&G/TPLI
ing/L
15
pH
standard
6-9
Acute Toxicity
See
Appendix A:
Special
See Appendix
A: Special
Conditions
c�d '
dry 1 I ODD- �aOS
�
�
a
3�
3
1
13
I
i✓
i
Part II Page 7ofII

Permit No. NCS000533
Dissolved Oxygen
Grab
005 Effluent,
mg/L
quarterly
Downstream,
Upstream
Acute Toxicity'
_
Annually
Grab
SDO
Total Rainfa]18
inches
quarterly
Rain Gauge
I -
Footnotes:
I Measurement Frequency: Four time,, per year during a representative storm event.
2 Grab samples shall be collected within the first 30 minutes of discharge.
3 Sample Location: Samples shall be collected at each stormwater discharge outfall (SDO) unless representative outfall
status has been granted.
4 May discontinue monitoring this parameter for the remainder of the permit after first eight (8) sampling events, if all
results are below the benchmark value.
5 The pH at each SDO shall not be less than 6.0 standard units nor greater than 9.0 standard units for fresh water
classifications. The in stream samples are from swamp waters and may have a pH values as low as 4.3 if it is the
result of natural conditions.
6 Water Quality Standard for Dissolved oxygen: not less than 6.0 mg/l for trout waters; for non -trout waters, not
less than a daily average of 5.0 mg/l with a minimum instantaneous value of not less than 4.0 mg/l; swamp waters,
lake coves or backwaters, and lake bottom waters may have loNver values if caused by natural conditions.
7 Acute toxicity shall be performed in accordance with Appendix A: Special Conditions at the end of this permit.
8 For each sampled representative storm event the total precipitation must be recorded. An on -site rain gauge or local rain
gauge reading must be recorded. . .
The permittee shall complete the minimum 20 analytical samplings in accordance with the
schedule specified below. in Table 2. A minimum of 30 days must separate Period I and
Period 2 sample dates unless monthly monitoring has been instituted under a Tier Two
response.
Table 2. Nionitoring Schedule
Monitoring period I'2
Start
End
All Years — Quarter I
January I
March 31
All Years — Quarter 2
April 1
June 30
All Years —Quarter 3
July I
September 30
All Years —Quarter 4
October 1
December 31
Footnotes:
f Maintain quarterly monitoring during permit renewal process. If at the expiration of this permit, the
permittee has submitted an application for renewal of coverage before the submittal deadline, the permittee
will be considered for renewed coverage. Quarterly monitoring shall be done all years of the permit and the
applicant must continue quarterly monitoring until the renewed permit is issued.
2 If no discharge occurs during the sampling period, the permittee must submit a monitoring report indicating
"No Flow" within 30 days of the end of the three-month sampling period.
The permittee shall report the analytical results from the first sample with valid results within the
monitoring period. The permittee shall compare monitoring results to the benchmark values in
Part It Page 6 of 1 I

Permit No. NCS000533
Tier One
If: The first valid sampling results are above a benchmark value, or outside of the benchmark range, for any
parameter at any outfall;
Then: The permittee shall:
I . Conduct a stormwater management inspection of the facility within two weeks of receiving
sampling results.
2. Identify and evaluate possible causes of the benchmark value exceedence.
3. Identify potential and select the specific: source controls, operational controls, or physical
improvements to reduce concentrations of the parameters of concern, or to bring concentrations
within the benchmark range.
4. Implement the selected actions within two months of the inspection.
5. Record each instance of a Tier One response in the Stormwater Pollution Prevention Plan. Include
the date and value of the benchmark exceedence, the inspection date, the personnel conducting the
ins eclion, the selected actions, and the date the selected actions were implemented.
Tier Two
If: During the terra of this permit, the first valid sampling results from three consecutive monitoring periods
are above the benchmark values, or outside of the benchmark range, for any specific parameter at a
ific discharge outfall;
Then: The permittee shall:
1. Repeat all the required actions outlined above in Tier One.
2. Immediately institute monthly monitoring for all parameters at every outfall where a sampling result
exceeded the benchmark value for two consecutive samples. Monthly (analytical and qualitative)
monitoring shall continue until three consecutive sample results are below the benchmark values or
within the benchmark ranee.
3. If no discharge occurs during the sampling period, the permittee is required to submit a monthly
monitoring report indicating "No Flow" to comply with reporting requirements.
4. Maintain a record of the Tier Two response in the Stormwater Pollution Prevention Plan.
Tier Three
During the teen of this permit, if the valid sampling results required for the permit monitoring periods
exceed the benchmark value, or are outside the benchmark range, for any specific parameter at any specific
outfall on four occasions, the permittee shall notify the DWQ Regional Office Supervisor in writing within
30 days of receipt of the fourth analytical results. DWQ may but is not limited to:
• require that the permittee revise, increase, or decrease the monitoring frequency for the remainder
of the permit;
• require the permittee to conduct acute toxicity testing on discharges;
• require the permittee to install structural stormwater controls;
• require the permittee to implement other stormwater control measures; or
• require that the permittee implement site modifications to qualify for the No Exposure Exclusion.
Part II Page 8 of 11

Pennit No. NCS000533
This site discharges to impaired waters experiencing problems with turbidity. If a Total
Maximum Daily Load (TMDL) is approved for this segment of Livingston Creek, the permittee
may be required to monitor for the pollutant(s) of concern in the future and submit results to the
Division of Water Quality. The Division will consider the monitoring results in determining
whether additional BMPs are needed to control the pollutant(s) of concern to the maximum
extent practicable.
If additional BMPs are needed to achieve the required level of control, the permittee will be
required to (1) develop a strategy for implementing appropriate BMPs, and (2) submit a timetable
for incorporation of those BMPs into the permitted Stonnwater Pollution Prevention Plan.
SECTION C: QUALITATIVE MONITORING REQUIREMENTS
Qualitative monitoring requires a visual inspection of each stormwater outfall regardless of
representative outfall status and shall be performed as specified in Table 4, during the analytical
monitoring event. [If analytical monitoring is not required, the permittee still must conduct
quarterly qualitative monitoring.] Qualitative monitoring is for the purpose of evaluating the
effectiveness of the Stormwater Pollution Prevention Plan (SPPP) and assessing new sources of
stormwater pollution.
In the event an atypical condition is noted at a stormwater discharge outfall, the permittee shall
document the suspected cause of the condition and any actions taken in response to the
discovery. This documentation will be maintained with the SPPP.
Table 4. Qualitative Nlonitoring Requirements
Discharge Characteristics
Frequencyl
Monitoring
Location2
Color
quarterly
SDO
Odor
quarterly
SDO
Clarity
quarterly
SDO
Floating Solids
quarterly
SDO
Suspended Solids
quarterly
SDO
Foam
quarterly
SDO
Oil Sheenquarterly_SDO
Erosion or deposition at the outfallquarterly_SDO
Other obvious indicators
of stormwater pollution
quarterly
SDO
Footnotes:
I Measurement Frequency: Four times per year during a representative storm event, for each year until either
another permit is issued for this facility or until this permit is revoked -or rescinded. If at the end of this
permitting cycle the pennittee has submitted the appropriate paperwork for a renewal permit before the submittal
deadline, the permittee will be considered for renewed coverage. The applicant must continue quarterly
Part II Page 9 of 11

Permit No. NCS000533
monitoring until the renewed pennit is issued. See Table 2 for schedule of monitoring periods through the end of
this permitting cycle.
Monitoring Location: Qualitative monitoring shall be performed at each stormwater discharge outfall (SDO)
regardless of representative outfall status.
SECTION D: ON -SITE VEHICLE MAINTENANCE MONITORING REQUIREMENTS
Facilities which have any vehicle maintenance activity occurring on -site which uses more than 55
gallons of new motor oil per month when averaged over the calendar year shall perform
analytical monitoring as specified below in Table 5. This monitoring shall be performed at all
stormwater discharge outfalls which discharge stormwater runoff from vehicle maintenance
areas, and in accordance with the schedule presented in Table 2 (Section B). All analytical
monitoring shall be performed during a representative storm event.
Table 5. Anah'tical Nlonitoring Requirements for On -Site Vehicle Alaintenance
Discharge Characteristics
Units
Measurement
Frequency]
Sample
Tye2
Sample
Location3
H
standard
quarterly
Grab
SDO
Total Petroleum Hydrocarbons
[EPA Method 1664 (S'GT--HEM)J
mg/l
quarterly
Grab
SDO
Total Suspended Solids
mYZ]
quarterly
Grab
SDO
Total Rainfall4
inches
quarterly
Rain gauge
New Motor Oil Usage
gallons/month
quarterly
Estimate
-
Footnotes:
Measurement Frequency: Four. times per year during a representative storm event, for each year until either
another permit is issued for this facility or until this permit is revoked or rescinded. If at the end of this
permitting cycle the permittee has submitted the appropriate paperwork for a renewal permit before the submittal
deadline, the permittee-will be considered for renewed coverage. The applicant must continue quarterly
monitoring until the renewed permit is issued. See Table 2 for schedule of monitoring periods through the end of
this permitting cycle.
2 If the siornwater runoff is controlled by a stormwater detention pond a grab sample of the discharge from the
pond shall be collected within the first 30 minutes of discharge from the pond.
3 Sample Location: Samples shall be collected at each stormwater discharge outfall (SDO) that discharges
stornwater runoff from area(s) where vehicle maintenance activities occur.
4 For each sampled representative storm event the total precipitation must be recorded. An on -site or local rain
gauge reading must be recorded. t
Monitoring results shall be compared to the benchmark values in Table 6. The benchmark
values in Table 6 are not permit limits but should be used as guidelines for the permittee's
Stonnwater Pollution Prevention Plan (SPPP). Exceedences of benchmark values require the
permittee to increase monitoring, increase management actions, increase record keeping, and/or
install stormwater Best Management Practices (BMPs), as provided in Part 11 Section B.
Part II Page 10 of

Pemit No. NCS000533
Table 6. Benchmark Values for Vehicle Maintenance Analytical Monitoring
Discharge Characteristics
Units
Benchmark
PH
standard
6-9
Total Petroleum Hydrocarbons (TPH)
[EPA Alethod 1664 (SGT-HEM)]
m��
15
Total Suspended Solids (TSS)
mg/L
L 100
Part 11 Page 11 of 11

Permit No. NCS000533
PART III STANDARD CONDITIONS FOR NPDES STORAIWATER INDIVIDUAL PERMITS
SECTION A: COMPLIANCE AND LIABILITY
Compliance Schedule
The permittee shall comply with Limitations and Controls specified for stormwater discharges in
accordance with the following schedule:
Existing Facilities already operating but applying for permit coverage for the first time: The Stormwater
Pollution Prevention Plan shall be developed and implemented within 12 months of the effective date of the
initial permit and updated thereafter on an annual basis. Secondary containment, as specified in Part I1,
Section A. Paragraph 2(b) of this permit, shall be accomplished within 12 months of the effective date of
the initial permit issuance.
New Facilities applying for coverage for the first time and existing facilities previously permitted and
applying for renewal under this permit: The Stormwater Pollution Prevention Plan shall be developed and
implemented prior to the beginning of discharges from the operation of the industrial activity and be
updated thereafter on an annual basis. Secondary containment, as specified in Part 11, Section A, Paragraph
2(b) of this permit shall be accomplished prior to the beginning of discharges from the operation of the
industrial activity.
2. Duty to Comply
The permittee must comply with all conditions of this individual permit. Any permit noncompliance
constitutes a violation of the Clean Water Act and is grounds for enforcement action; for permit
termination, revocation and reissuance, or modification; or denial of a permit upon renewal application.
a. The permittee shall comply with standards or prohibitions established under section 307(a) of the
Clean Water Act for toxic pollutants within the time provided in the regulations that establish these
standards or prohibitions, even if the permit has not yet been modified to incorporate the
requirement.
b, i he Clean Water Act provides that any person who violates a permit condition is subject to a civil
penalty not to exceed $25,000 per day for each violation. Any person who negligently violates any
permit condition is subject to criminal penalties of 52,500 to 25,000 per day of violation, or
imprisonment for not more than 1 year, or both. Any person who knowingly violates permit
conditions is subject to criminal penalties of $5,000 to $50,000 per day of violation, or
imprisonment for not more than 3 years, or both. Also, any person who violates a permit condition
may be assessed an administrative penalty not to exceed $10,000 per violation with the maximum
amount not to exceed $125,000_ [Ref: Section 309 of the Federal Act 33 USC 1319 and 40 CFR
122.41(a).]
C. Under state law, a daily civil penalty of not more than ten thousand dollars ($10,000) per violation
may be assessed against any person who violates or fails to act in accordance with the tenns,
conditions, or requirements of a permit. [Ref: NC General Statutes 143-215.6A].
Any person may be assessed an administrative penalty by the Director for violating section 301,
302, 306, 307, 308, 318 or 405 of the Act, or any permit condition or limitation implementing any
of such sections in a permit issued under section 402 of the Act. Administrative penalties for Class
I violations are not to exceed $10,000 per violation,'with the maximum amount of any Class I
penalty assessed not to exceed $25,000. Penalties for Class I1 violations are not to exceed
Part III Page 1 of 8

Permit No. NCS000533
$10,000 per day for each day during which the violation continues, with the maximum amount of
any Class II penalty not to exceed $125,000,
Duty to Mitigate
The permittee shall take all reasonable steps to minimize or prevent any discharge in violation of this
individual permit which has a reasonable likelihood of adversely affecting human health or the environment
Civil and Criminal Liability
Except as provided in Part III, Section C of this permit regarding bypassing of stormwater control facilities,
nothing in this individual permit shall be construed to relieve the permittee from any responsibilities,
liabilities, or penalties for noncompliance pursuant to NCGS 143-215.3, 143-215.6A, 143-215.613, 143-
215.6C or Section 309 of the Federal Act, 33 USC 1319. Furthermore, the permittee is responsible for
consequential damages, such as fish kills, even though the responsibility for effective compliance may be
temporarily suspended.
5. Oil and Hazardous Substance Liability
Nothing in this individual permit shall be construed to preclude the institution of any legal action or relieve
the permittee from any responsibilities, liabilities, or penalties to which the permittee is or may be subject to
under NCGS 143-215.75 et seq. or Section 311 of the Federal Act, 33 USC 1321.
6. Property Rights
The issuance of this individual permit does not convey any property rights in either real or personal
property, or any exclusive privileges, nor does it authorize any injury to private property or any invasion of
personal rights, nor any infringement of Federal, State or local laws or regulations.
7. Severability
The provisions of this individual permit are severable, and if any provision of this individual permit, or the
application of any provision of this individual permit to any circumstances, is held invalid, the application
of such provision to other circumstances, and the remainder of this individual permit, shall not be affected
thereby.
8. Duty to Provide Information
The permittee shall furnish to the Director, within a reasonable time, any information which the Director
may request to determine whether cause exists for modifying, revoking and reissuing, or terminating the
permit issued pursuant to this individual permit or to determine compliance with this individual permit. The
permittee shall also furnish to the Director upon request, copies of records required to be kept by this
individual permit.
9. Penalties for Tampering
The Clean Water Act provides that any person who falsifies, tampers with, or knowingly renders inaccurate,
any monitoring device or method required to be maintained under this individual permit shall, upon
conviction, be punished by a fine of not more than $10,000 per violation, or by imprisonment for not more
than two years per violation, or by both. If a conviction of a person is for a violation committed after a first
conviction of such person under this paragraph, punishment is a fine of not more that $20,000 per day of
violation, or by imprisonment of not more than 4 years, or both.
Part III Page 2 of 8

Permit No. NCS000533
10. Penalties for Falsification of Reports
The Clean Water Act provides that any person who knowingly makes any false statement, representation, or
certification in any record or other document submitted or required to be maintained under this individual
permit, including monitoring reports or reports of compliance or noncompliance shall, upon conviction, be
punished by a fine of not more than $10,000 per violation, or by imprisonment for not more than two years
per violation, or by both.
SECTION B: GENERAL CONDITIONS
1. Individual Permit Expiration
The permittee is not authorized to discharge after the expiration date. In order to receive automatic
authorization to discharge beyond the expiration date, the permittee shall submit forms and fees as are
required by the agency authorized to issue permits no later than 180 days prior to the expiration date. Any
permittee that has not requested renewal at least 180 days prior to expiration, or any permittee that does not
have a permit after the expiration and has not requested renewal at least 180 days prior to expiration, will be
subjected to enforcement procedures as provided in NCGS § 143-2153.6 and 33 USC 1251 et. seq.
2. Transfers
This permit is not transferable to any person except after notice to and approval by the Director. The
Director may require modification or revocation and reissuance of the permit to change the name and
incorporate such other requirements as may be necessary under the Clean Water Act. The Permittee is
required to notify the Division in writing in the event the, permitted facility is sold or closed.
3. Sienatory Requirements
All applications, reports, or information submitted to the Director shall be signed and certified.
All applications to be covered under this individual permit shall be signed as follows:
(1) In the case of a corporation: by a principal executive officer of at least the level of vice-
pieaideui, ul ills uuiy audivri/ed rcpresentaiive, if such representative is responsible for
the overall operation of the facility from which the discharge described in the permit
application form originates;
(2) In the case of a partnership or limited partnership: by a general partner;
(3} In the case of a sole proprietorship: by the proprietor;
(4) In the case of a municipal, state, or other public entity: by a principal executive officer,
ranking elected official, or other duly authorized employee.
All reports required by the individual permit and other information requested by the Director shall
be signed by a person described above or by a duly authorized representative of that person. A
person is a duly authorized representative only if-
(1) The authorization is made in,kTiting by a person described above;
(2) The authorization specified either an individual or a position having responsibility for the
overall operation of the regulated facility or activity, such as the position of plant
manager, operator of a well or well field, superintendent, a position of equivalent
Part Ill Page 3 of 9

Permit No. NCS000533
responsibility, or an individual or position having overall responsibility for environmental
matters for the company. (A duly authorized representative may thus be either a named
individual or any individual occupying a named position.); and
(3) The written authorization is submitted to the Director.
Any person signing a document under paragraphs a. or b. of this section shall make the following
certification:
"I certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate,
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations."
4. Individual Permit Modification, Revocation and Reissuance, or Termination
The issuance of this individual permit does not prohibit the Director from reopening and modifying the
individual permit, revoking and reissuing the individual permit, or terminating the individual permit as
allowed by the laws, rules, and regulations contained in Title 40, Code of Federal Regulations, Parts 122
and 123; Title 15A of the North Carolina Administrative Code, Subchapter 2H .0100; and North Carolina
General Statute 143-215.1 et al.
5. Permit Actions
The permit may be modified, revoked and reissued, or terminated for cause. The notification of planned
changes or anticipated noncompliance does not stay any individual permit condition.
SECTION C: OPERATION AND MAINTENANCE OF POLLUTION CONTROLS
Proper Operation and Maintenance
The permittee shall at all times properly operate and maintain all facilities and systems of treatment and
control (and related appurtenances) which are installed or used by the permittee to achieve compliance with
the conditions of this individual permit. Proper operation and maintenance also includes adequate
laboratory controls and appropriate quality assurance procedures. This provision requires the operation of
back-up or auxiliary facilities or similar systems which are installed by a permittee only when the operation
is necessary to achieve compliance with the conditions of this individual permit.
Need to Halt or Reduce Not a Defense
It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or
reduce the permitted activity in order to maintain compliance with [lie condition of this individual permit.
Bvpassint! of Stormwater Control Facilities
Bypass is prohibited and the Director may take enforcement action against a permittee for bypass unless:
Bypass was unavoidable to prevent loss of life, personal injury or severe property damage; and
Part III Page 4 of 8

Permit No. NCS000533
b. There were no feasible alternatives to the bypass, such as the use of auxiliary control facilities,
retention of stormwater or maintenance during normal periods of equipment downtime or dry
weather. This condition is not satisfied if adequate backup controls should have been installed in
the exercise of reasonable engineering judgment to prevent a bypass which occurred during normal
periods of equipment downtime or preventive maintenance; and
The permittee submitted notices as required under, Part 1I1, Section E of this permit.
If the Director determines that it will meet the three conditions listed above, the Director may approve an
anticipated bypass after considering its adverse effects.
SECTION D: MONITORING AND RECORDS
Representative Sam ]p inQ
Samples collected and measurements taken, as required herein, shall be characteristic of the volume and
nature of the permitted discharge. Analytical sampling shall be performed during a representative storm
event. Samples shall be taken on a day and time that is characteristic of the discharge. All samples shall be
taken before the discharge joins or is diluted by any other waste stream, body of water, or substance.
Monitoring points as specified in this permit shall not be changed without notification to and approval of
the Director.
2. Recording Results
For each ineasurement, sample, inspection or maintenance activity performed or collected pursuant to the
requirements of this individual permit, the permittee shall record the following information:
a. The date, exact place, and time of sampling, measurements, inspection or maintenance activity;
b. The individual(s) who performed the sampling, measurements, inspection or maintenance activity,
C. The date(s) analyses were performed;
d. The individual(s) who performed the analyses;
e. The analytical techniques or methods used; and
f. The results of such analyses.
Flow Measurements
Where required, appropriate flow measurement devices and methods consistent with accepted scientific
practices shall be selected and used to ensure the accuracy and reliability of measurements of the volume of
monitored discharges.
Test Procedures
Test procedures for the analysis of pollutants shall conform to the EMC regulations published pursuant to
NCGS 143-215.63 et. seq, the Water and Air Quality Reporting Acts, and to regulations published pursuant
to Section 304(g), 33 USC 1314, of the Federal Water Pollution Control Act, as Amended, and Regulation
40 CFR 136.
PartIII Page 5 of 8

Permit No. NCS000533
To meet the intent of the monitoring required by this individual permit, all test procedures must produce
minimum detection and reporting levels and all data generated must be reported down to the minimum
detection or lower reporting level of the procedure.
5. Representative Outfall
If a facility has multiple discharge locations with substantially identical stormwater discharges that are
required to be sampled, the permittee may petition the Director for representative outfall status. If it is
established that the stormwater discharges are substantially identical and the permittee is granted
representative outfall status, then sampling requirements may be performed at a reduced number of outfalls.
6. Records Retention
Visual monitoring shall be documented and records maintained at the facility along with the Stormwater
Pollution Prevention Plan. Copies of analytical monitoring results shall also be maintained on -site. The
permittee shall retain records of all monitoring information, including all calibration and maintenance
records and all original strip chart recordings for continuous monitoring instrumentation, and copies of all
reports required by this individual permit for a period of at least 5 years from the date of the sample,
measurement, report or application. This period may be extended by request of the Director at any time.
Inspection and Entry
The permittee shall allow the Director, or an authorized representative (including an authorized contractor
acting as a representative of the Director), or in the case of a facility which discharges through a municipal
separate storm sewer system, an authorized representative of a municipal operator or the separate storm
sewer system receiving the discharge, upon the presentation of credentials and other documents as may be
required by law, to;
a. Enter upon the permittee's premises where a regulated facility or activity is located or conducted,
or where records must be kept under the conditions of this individual permit;
b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of
this individual permit;
inspect at reasonable times any facilities, equipment (including momioring and controi equipment),
practices, or operations regulated or required under this individual permit; and
d. Sample or monitor at reasonable times, for the purposes of assuring individual permit compliance
or as otherwise authorized by the Clean Water Act, any substances or parameters at any location.
SECTION E: REPORTING REQUIREMENTS
Discharge Monitoring Reports
Samples analyzed in accordance with the terms of this permit shall be submitted to the Division on
Discharge Monitoring Report forms provided by the Director. Submittals shall be delivered to the Division
no later than 30 days from the date the facility receives the sampling results from the laboratory.
The permittee shall submit an Annual Summary Data Monitoring Report to the appropriate DWQ Regional
Office by March I of each year that summarizes data from the previous calendar year. The submittal shall
be on forms supplied by the Division.
Part III Page 6 of 8

Permit No. NCS000533
When no discharge has occurred from the facility during the report period, the permittee is required to
submit a discharge monitoring report, within 30 days of the end of the three-month sampling period, giving:
all required information and indicating "NO FLAW" as per NCAC T15A 02B .0506.
The permittee shall record the required qualitative monitoring observations on the SDO Qualitative
Monitoring Report form provided by the Division, and shall retain the completed forms on site. Visual
monitoring results should not be submitted to the Division, except upon DWQ's specific requirement to do
so.
Submitting Reports
Two signed copies of Discharge Monitoring Reports (DMRs) shall be submitted to:
Central Files
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
In addition, a separate signed Annual Summary DMR copy shall be submitted to the local DWQ Regional
Office (RO) by March- I of each year (See 1. above).
Addresses for each RO and the counties covered by each RO can be found here:
http://�%-wiv.enr.state.ne.us/htznl/regionaloffices.htnil. The permittee shall retain the completed originals
on site. Visual monitoring results should not be submitted to the Regional Offices or Central Files unless
specifically requested by DWQ.
Availabilitv of Renorts
Except for data determined to be confidential under NCGS 143-215.3(a)(2) or Section 308 of the Federal
Act, 33 USC 1318, all reports prepared in accordance with the terms shall be available for public inspection
at the offices of the Division of Water Quality. As required by the Act, analytical data shall not be
considered confidential. Knowingly making any false statement on any such report may result in the
imposition of criminal penalties as provided for in NCGS 143-215.6B or in Section 309 of the Federal Act.
Non-Stormwater Discharges
If the storm event monitored in accordance with this Individual Permit coincides with a non-stormwater
discharge, the permittee shall separately monitor all parameters as required under the non-stormwater
discharge permit and provide this information with the stormwater discharge monitoring report.
5. Planned Chanties
The permittee shall give notice to the Director as soon as possible of any planned changes at the permitted
facility which could significantly alter the nature or quantity of pollutants discharged. This notification
requirement includes pollutants which are not specifically listed in the Individual Permit or subject to
notification requirements under 40 CFR Part 122.42 (a).
6. Anticipated Noncompliance
The permittee shall give notice to the Director as soon as possible of any planned changes at the permitted
facility which may result in noncompliance with the Individual Permit requirements.
Part III Page 7 of 8

Pennit No. NC5000533
S 12-i1is
The permittee shalt report to the local DWQ Regional Office, within 24 hours, all significant spills as
defined in Part VI of this permit. Additionally, the perrnittee shall report spills including: any oil spill of 25
gallons or more, any spill regardless of amount that causes a sheen on surface waters, any oil spill
regardless of amount occurring within 100 feet of surface waters, and any oil spill less than 25 gallons that
cannot be cleaned up within 24 hours.
a. Anticipated bypass. If the permittee knows in advance of the need for a bypass, it shall submit
prior notice, if possible at least ten days before the date of the bypass; including an evaluation of
the anticipated quality and affect of the bypass.
b. Unanticipated bypass. The permittee shall submit notice within 24 hours of becoming aware of an
unanticipated bypass.
9. Twenty-four Hour Reportine
The permittee shall report to the central office or the appropriate regional office any noncompliance which
may endanger health or die environment. Any information shall be provided orally within 24 hours from
the time the permittee became aware of the circumstances. A written submission shall also be provided
within 5 days of the time the permittee becomes aware of the circumstances.
The written submission shall contain a description of the noncompliance, and its causes; the period of
noncompliance, including exact dates and times, and if the noncompliance has not been corrected, the
anticipated time compliance is expected to continue; and steps taken or planned to reduce. eliminate, and
prevent reoccurrence of the noncompliance.
The Director may waive the written report on a case -by -case basis if the oral report has been received
within 24 hours.
10. Other Noncompliance
The permittee shall report all instances of noncompliance not reported under 24 hour reporting at the time
monitoring reports are submitted.
11. Other Information
Where the permittee becomes aware that it failed to submit any relevant facts in a Notice of Intent to be
covered under this Individual Permit or in any report to the Director, it shall promptly submit such facts or
information.
Part III Page 8 of 8

NCS000533
PART IV LIMITATIONS REOPENER
This individual permit shall be modified or alternatively, revoked and reissued, to comply with any applicable
effluent guideline or water quality standard issued or approved under Sections 302(b) (2) (c), and (d), 304(b) (2) and
307(a) of the Clean Water Act, if the effluent guideline or water quality standard so issued or approved:
Contains different conditions or is otherwise more stringent than any effluent limitation in the individual
permit; or
b. Controls any pollutant not limited in the individual permit.
The individual permit as modified or reissued under this paragraph shall also contain any other requirements in the
Act then applicable.
PART V ADMINISTERING AND COMPLIANCE MONITORING FEE
REQUIREMENTS
The permittee must pay the administering and compliance monitoring fee within 30 (thirty) days after being billed by
the Division. Failure to pay the fee in timely manner in accordance with 15A NCAC 2H .0105(b)(4) may cause this
Division to initiate action to revoke the Individual Permit.
PART VI DEFINITIONS
Act
See Clean Water Act.
2. Allowable Non-Stormwater Discharges
This permit regulates stormwater discharges. Non-stormwater discharges which shall be allowed in the
stormwater conveyance system are:
(a) All other discharges that are authorized by a non-stormwater NPDES permit.
(b) Uncontaminated groundwater, foundation drains, air -conditioner condensate without added
chemicals, springs, discharges of uncontaminated potable water, waterline and fire hydrant
flushings, water from footing drains, flows from riparian habitats and wetlands.
(c) Discharges resulting from fire -fighting or fire -fighting training.
Best Management Practices (BMPs)
Measures or practices used to reduce the amount of pollution entering surface waters. BMPs may take the
form of a process, activity, or physical structure. More information on BMPs can be found at:
http://cfpub.epa.gov/npdes/storinwater/nienuofbmps/index.cfin.
4. Bypass
A bypass is the known diversion of stormwater from any portion of a stormwater control facility including
the collection system, which is not a designed or established operating mode for the facility.
Bulk Storage of Liquid Products
Liquid raw materials, manufactured products, waste materials or by-products with a single above ground
storage container having a capacity of greater than 660 gallons or with multiple above ground storage
containers located in close proximity to each other having a total combined storage capacity of greater than
1,320 gallons.
Appendix A: Page 1 of 4

Pennit No. NCS000533
6. Certificate of Coverage
The Certificate of Coverage (COC) is the cover sheet which accompanies the Individual Permit upon
issuance and lists the facility name, location, receiving stream, river basin, effective date of coverage under
the permit and is signed by the Director.
7. Clean Water Act
The Federal Water Pollution Control Act, also known as the Clean Water Act (CWA), as amended, 33 USC
1251, et. seq.
8. Division or DWO
The Division of Water Quality, Department of Environment and Natural Resources.
9. Director
The Director of the Division of Water Quality, the permit issuing authority.
10. EMC
The North Carolina Environmental Management Commission.
IL Grab Sample
An individual sample collected instantaneously. Grab samples that will be analyzed (quantitatively or
qualitatively) must be taken within the first 30 minutes of discharge.
12. Hazardous Substance
Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the Clean Water Act.
13. Landfill
A disposal facility or part of a disposal facility where waste is placed in or on land and which is not a land
treatment facility, a surface impoundment, an injection well, a hazardous waste long -tern storage facility or
a surface storage facility.
14. Municipal Separate Storm Sewer System
A stormwater collection system within an incorporated area of local self-government such as a city or town.
15. No Exposure
A condition of no exposure means that all industrial materials and activities are protected by a storm
resistant shelter or acceptable storage containers to prevent exposure to rain, snow, snowmelt, or runoff.
Industrial materials or activities include, but are not limited to, material handling equipment or activities,
industrial machinery, raw materials, intermediate products, by-products, final products, or waste products-
DWQ may grant a No Exposure Exclusion from NPDES Stormwater Permitting -requirements only if a
facility complies with the terms and conditions described in 40 CFR § 122.26(g)
16. Notice of Intent
The state application form which, when submitted to the Division, officially indicates the facility's notice of
intent to seek coverage under an Individual Permit.
17. Permittee
The owner or operator issued a certificate of coverage pursuant to this Individual Permit.
Appendix A: Page 2 of 4 Pages

Permit No. NCS000533
18. Point Source Discharge of Stormwater
Any discernible, confined and discrete conveyance including, but not specifically limited to, any pipe, ditch,
channel, tunnel, conduit, well, or discrete fissure from which stornwater is or may be discharged to waters
of the state.
19. Representative Storm Event
A storm event that measures greater than 0.1 inches of rainfall. The time between this storm event and the previous
storm event measuring greater than 0.1 inches must be at least 72 hours. A single storm event may have a period of
no precipitation of up to 10 hours. For example, if it rains but stops before producing any collectable discharge, a
sample may be collected if the next rain producing a discharge begins within 10 hours.
20. Representative Outfall Status
When it is established that the discharge of stormwater runoff from a single outfall is representative of the
discharges at multiple outfalls, the DWQ may grant representative outfall status. Representative outfall
status allows the permittee to perform analytical monitoring at a reduced number of outfalls.
21_ Secondary Containment
Spill containment for the contents of the single largest tank within the containment structure plus sufficient
freeboard to allow for the 25-year, 24-hour storm event.
22. Section 313 Water Priority Chemical
A chemical or chemical category which:
a. Is listed in 40 CFR 372.65 pursuant to Section 313 of Title III of the Superfund Amendments and
Reauthorization Act (SARA) of 1986, also titled the Emergency Planning and Community Right -
to -Know Act of 1986,
b. Is present at or above threshold levels at a facility subject to SARA title I1I, Section 313 reporting
requirements; and
C. Meets at least one of the following criteria:
(1) Is listed in appendix D of 40 CFR part 122 on Table It (organic priority pollutants), Table
III (certain metals, cyanides; and phenols) or Table IV (certain toxic pollutants and
hazardous substances);
(2) Is listed as a hazardous substance pursuant to section 311(b)(2)(A) of the CWA at 40
CFR 116.4; or
(3) Is a pollutant for which EPA has published acute or chronic water quality criteria.
23. Severe Property Damaue
Means substantial physical damage to property, damage to the control facilities which causes them to
become inoperable, or substantial and permanent loss of natural resources which can reasonably be
expected to occur in the absence of a bypass. Severe property damage does not mean economic loss caused
by delays in production.
24. Sienifrcant Materials
Includes, but is not limited to: raw materials; fuels; materials such as solvents, detergents, and plastic
pellets; finished materials such as metallic products; raw materials used in food processing or production;
hazardous substances designated under section 10 ] (14) of CLRCLA, any chemical the facility is required to
report pursuant to section 313 of Title III of SARA; fertilizers; pesticides; and waste products such as ashes,
slag and sludge that have the potential to be released with stormwater discharges.
25. Significant Spills
Includes, but is not limited to: releases of oil or hazardous substances in excess of reportable quantities
under section 311 of the Clean Water Act (Ref: 40 CFR 110.10 and CFR 1 17.21) or section 102 of
CERCLA (Ref: 40 CFR 302.4).
Appendix A: Page 3 of 4 Pages

Permit No. NCS000533
26. Stormwater Discharge Outfall (SDO)
The point of departure of stormwater from a discernible, confined, or discrete conveyance, including but not
limited to, storm sewer pipes, drainage ditches, channels, spillways, or channelized collection areas, from
which stormwater flows directly or indirectly into waters of the State of North Carolina.
27. Stormwater Runoff
The flow of water which results from precipitation and which occurs immediately following rainfall or as a
result of snowmelt.
28. Stormwater Associated with Industrial Activity
The discharge from any point source which is used for collecting and conveying stormwater and which is
directly related to manufacturing, processing or raw material storage areas at an industrial site. Facilities
considered to be engaged in "industrial activities" include those activities defined in 40 CFR 122.26(b)(14).
The term does not include discharges from facilities or activities excluded from the NPDES program.
29. Stormwater Pollution Prevention Plan
A comprehensive site -specific plan which details measures and practices to reduce stormwater pollution and
is based on an evaluation of the pollution potential of the site.
30. Total Maximum Daily Load (TMDL)
TMDLs are written plans for attaining and maintaining water quality standards, in all seasons, for a specific
water body and pollutant. (A list of approved TA1DLs for the state of North Carolina can be found at
http://h2o.enr.state.ne.us/tnidL/)
31. Toxic Pollutant
Any pollutant listed as toxic under Section 307(a)(1) of the Clean Water Act.
32. Vehicle Maintenance Activity
Vehicle rehabilitation, mechanical repairs, painting, fueling, lubrication, vehicle cleaning operations, or
airport deicing operations.
33. Visible Sedimentation
Solid particulate matter, both mineral and organic, that has been or is being transported by water, air,
gravity, -or ice from its site of origin which can be seen with the unaided eye.
34, 25-year, 24 hour storm event
The maximum 24-hour precipitation event expected to be equaled or exceeded, on the average, once in 25
years.
Appendix A: Page 4 of 4 Pages

NCS000533
APPENDIX A: ACUTE TOXICITY TESTING FOR STORMWATER OUTFALLS
L AANUAL TESTING PASS/FAIL ACUTE TOYICITY TESTING
The permittee shall conduct acute toxicity tests on a yearly basis using protocols defined in the North
Carolina Procedure Document entitled "Pass/Fail Methodology for Determining Acute Toxicity in a
Single Effluent Concentration"(Revised-July, 1992 or subsequent versions). The monitoring shall be
performed as a "water flea" (Ceriodaphnia dubia) 48-hour static test.
Stormwater samples shall be collected as a single grab sample. Samples for self -monitoring purposes
must be obtained during a representative storm event. The tests will be performed during the first six
months of the year (January -June).
If at any time there is significant mortality at a stormwater effluent concentration of 100%, the results
will be considered as a benchmark exceedance of toxicity.
All toxicity testing results required as part of this permit condition will be entered on the Stormwater
Discharge Monitoring Form (DMR) for the month in which it was performed, using the parameter code
TGA313. One copy shall be submitted to Central Files, and one copy shall be submitted to the
Stormwater Permitting Unit as follows:
Attention: Central Files
Division of Water Quality
1617 Mail Service"Center
Raleigh, North Carolina 27699-1617
Attention: Stormwater Permitting Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Additionally, DNN'Q Form AT-2 for Acute Pass/Fail "Tests (original) is to be sent to the following
address:
Attention: NC DENR / DWQ / Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be sent and postmarked to the Environmental Sciences
Section and Central Files no later than 30 days after the end of the month in which the test was
conducted.
Test data shall be complete and accurate and include all supporting chemical/physical measurements
performed in association with the toxicity tests, as well as all dose/response data. Total residual chlorine
of the stormwater toxicity sample must be measured and reported if chlorine is employed for disinfection
of the stormwater discharge.
If there is no stormwater discharge from the facility during the months which toxicity monitoring is
required, the permittee will complete the inforniation located at both the top of the aquatic toxicity (AT)
Appendix A. Page 1 of 4

Pennit No. NCS000533
test forni and DMR indicating the facility name, permit number, stormwater outfall number, county, and
the month/year of the report with the notation of "No Flow" in the comment area of the form. The
permittee shall submit three (3) "no flow" reports: one report shall be submitted to the Environmental
Sciences Section,'one to the Stormwater Permitting Unit (SPU) Central Office, and one report shall be
sent to Central Files at the address cited above.. The permittee shall submit acute to_vicity monitoring as
outlined above, at the nev7 available representative storm event.
IL ACTIONS FOR FAILURE OF PASS/FAIL TESTING:
Should any single scheduled monitoring indicate a failure to meet toxicity benchmark levels, a
series of measures shall occur:
1) Within 30 calendar days from availability of the test results, the permittee shall contact the
Division SPU Central Office and the Regional Office Supervisor in titer.
a. If other stormwater monitoring parameters have exceeded benchmark values, the
Regional Office may exempt the permittee from additional acute toxicity monitoring
(other than regularly scheduled test periods), at the Regional Office 's discretion. The
permittee shall continue to address all other stormwater parameter benchmark
exceedances.
b. If the permittee has not exceeded other benchmark values, or if the Regional Office
does not exempt the permittee from additional monitoring, the permittee shall
immediately institute nionthly acute toxicity monitoring with a 48-hour multiple dilution
test per U.S. EPA Method 2002.0: "Methods for Measuring the Acute Toxicity of
Effluents to Freshwater and Marine Organisms," EPA 821/R-02/012 (October 2002).
III. ACTIONS IF MOiVTH_L Y MONITORING IS INSTITUTED(tIUL TIPLE-DIL UTION
TESTING};
If monthli, acute toxicity monitnrino is instituted ner Section 11 ahnve; the nermittPr chill norfnrm
the tests per the following conditions:
I ) An LC50 greater than 100% shall be used as a benchmark passing endpoint; Stormwater
Permitting Unit (SPU) Central Office may determine alternative endpoints as "passing" on a
case -by -case basis, depending on the specific characteristics of the facility's stormwater
discharge. Multiple dilution tests will be run at 100"/,, 50`Yo, 25"/,, 12.5°/,, 6.251% and W/„
stormwater unless other test concentrations are determined appropriate by the Stormwater
Permitting Unit (SPU) Central Office.
2) Multiple Dilution Test Results shall be submitted on form AT-1 for Acute Multiple Dilution
Tests. The parameter code is TAA313. The permittee shall:
a. Submit form AT-1 (original) to the DWQ Environmental Sciences Section.
b. Send a completed a Stormwater DMR form (original) with an attached form AT-1
(original) to DWQ Central Files.
c. Send a completed a Stormwater DMR form (copy) with an attached form AT-1 (copy) to
the DWQ Stormwater Permitting Unit.
Appendix A: Page 2 of 4 Pages

Permit No. NCS000533
3) The permittee shall perform nrontlrly acute toxicity monitoring until one of the following
permit conditions is met:
a. THREE CONSECUTIVE MULTIPLE -DILUTION TESTS PASS. No further tests
need to be performed until next regularly scheduled test period.
-OR-
b. EITHER OF THE FOLLOWING OCCURS:
i. A TOTAL OF FIVE MULTIPLE -DILUTION TESTS HAIL
-OR-
ii. THREE CONSECUTIVE MULTIPLE -DILUTION TESTS FAIL.
If either of the above occurs, f n-ther actions are necessary. See IV. below.
4) The permittee shall submit a summary of all test results for the multiple dilution test series
along with complete copies of the test reports as received from the laboratory to the Regional
Office Supervisor, to DWQ Central Files and to SPU. These shall be sent and postmarked within
30 calendar days of receipt of the last failed or passed multiple -dilution test (as described above
in 111. 3)).
IV. ACTIONS FOR FAILURE OFAIULTIPLE DILUTION TESTS (TRE, TRI or OTHER
MEASURES):
If the permittee fails either A TOTAL OF FIVE multiple -dilution tests or TILE THIRD
CONSECUTIVE multiple -dilution test as described in Section H13) b., the permittee shall execute
the following:
1) A toxicity reduction evaluation (TRE) shall be automatically instituted. Within 30 calendar days
from availability of the test results, the permittee shall contact the Division SPU Central Office
and the Regional Office Supervisor in writing.
a. The permittee shall submit one copy of a plan for conducting a TRE to the DWQ SPU,
and one copy to the DWQ Environmental Sciences' Section. These copies shall be
submitted..-ithin 60 calendar days of the date of DWQ SPU's direction to perform the
TRE.
b. This plan must be approved by DWQ SPU before the TRE is begun. A schedule for
completing the TRE shall be established in the plan approval. A Toxicity Identification
Evaluation (TIE) may be a component of the TRE.
c. Upon DWQ's approval, the TRE schedule may be modified if toxicity is intennittent
during the TRE investigations. A revised WET test schedule may be established by
DWQ for this period.
2) Additionally after the first year that TRE results have been collected and submitted, depending
on results the Regional Office may (among options):
• Require the permittee to install structural stormwater controls;
• Require the permittee to implement other stormwater control measures or BMPs;
• Require the permittee to collect and treat the discharge and/or eliminate the
discharge;
• Require that the permittee implement site modifications to qualify for the No
Exposure Exclusion; or
Appendix A: Page 3 of 4 Pages

Permit No. NCS000533
• Require that the permittee perform up -stream and downstream biological assessment
in the receiving water.
V MEASURES APPLICABLE TO ALL TESTS. -
All acute toxicity test results shall be submitted in a concise summary at the end of the five year
permit term. One copy of this report shall be sent to the Regional Office Supervisor, one copy to the
SPU Central Office, and one copy to the DWQ Environmental Sciences Section.
Should any test data from either these monitoring requirements or tests performed by'the North Carolina
Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re-
opened and modified to include alternate monitoring requirements.
If the Permittee monitors any pollutant more frequently than required by this permit, the results of such
monitorino shall be included in the calculation & reporting of the data submitted on the DMR & all
Acute 'Toxicity Fornis submitted.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
ortanism survival and appropriate environmental controls, shall constitute an invalid test and will require
immediate follow-up testing; to be completed no later than the last day of the month following the month
of the initial monitorina.
Appendix A: Page 4 of 4 Pages

1 MAY-02-2011 MON 09:27 AM HEXION/ACME FAX NO.9106554749 P. 02
MCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
October 22, 2010
Mr. Peter Yurgel
Silar LLC
333 Neils Eddy Rd.
Riegelwood, NC 26456
Dee Freeman
Secretary
Suliect: Final NPDES Stormwater Permit
Permit No. NCS000533
Silar LLC
Columbus County
Dear Mr. Yurgel:
In response to your renewal application for continued coverage under NPDES stormwa ter permit NCS000533,
the Division of Water Quality (Division) is forwarding herewith the subject state - NPOE.S permit, This permit is
issued pursuant to the requirements of North Carolina General Statute 143-215 .1 and the Memorandum of
Agreement between North Carolina and the U.S. Environmental Protection Agency dated October 15, 2007 (or as
subsequently amended).
This final permit includes no major changes from the draft.permit sent to you on August 23, 2010. We
received comments by email from Silaes President John L Sh►bley on September 24, 2010 and from Silar's Plant
Manager Peter Yurgel on September 17, 2010. The comments were focused on concerns on responsible of
contamination that is beyond their control. A meeting was held on October 14, 2010 in Wilmington with Silar in
order to address these concerns. The final permit is consistent with permits for Fle),don Specialty Chemicals, Inc
and Oak -Sark Corporation.
The qualitative monitoring strategy is quarterly. Please note that quarterly analytical monitoring is also required
in this -permit. Failure to,complete the -'monitoring as required is a violation of the permit and any permit
noncompliance constitutes it violation of the Clean Water Act Reference Part IIi, Section A, Item 2 "Duty to
Comply", Item 9 "Penalties for Tampering" and Item 10 "Penalties for Falsification of Reports" of your permit for
further information.
If any parts, measurement frequencies or sampling requirements contained in this permit are -unacceptable to
you, you have the right to an adjudicaatory hearing upon written request within thirty (30) days following receipt
of this letter. This request crust be in the -form of a Written petition, conforming to Chapter 150B of the North
Carolina General Statutes, and filed with the Office of Administrative Hearings, Post Office Drawer 27447,
Raleigh, North Carolina 27611 -7447. Unless such demand is made, this decision shall be final and binding.
DWQ would like to have an updated site plan for our files. Please send DWQ Central Office and DWQ
Wilmington Regional Office (aft. Linda Willis) a site plan (each) including topographical lines and property
boundaries. If Silar LLC owns or operates any areas, storages facilities or other facilities that are not within
Silar's property boundary, please label these as well.
Wetlands and $lomarater5m4 One
1617 Mal Service center. Rata4h. North camp ne V691�9617 NO Carolina
Locadorc: 512 N. Sabbvey St Raleigh. Nonh CamAna 27604 "� �� r "J/�
Phone: 919-W7-63001 FAX: [phone] % Customer SeNim 1.977.523.6746 )�/�[
trttamet www.novetetquaiity.org
•.. C�.,�,1-..nl•..f l.f .rfl..wnfMa ♦....nn r..nn'.w.-f

MAY-02--2011 MON 09:27 AM HEXION/ACHE
FAX NO. 9105554749
P. 03
Mr. Peter Yurgel
Sitar LLC
Permit No. NC5000533
Please bake notice this permit is not transferable. Part III, B.2. addresses the requirements to be followed in case
of change in ownership or control of this discharge. This permit does not affect the legal requirements to obtain
other permits which may be required by the Division of Water Quality or permits required by the Division of
Land Resources, Coastal Area Management Act or any other Federal or Local governmental permit that may be
required.
If you have any questions or comments concerning this permit, contact Brian Lowther at [phone] or at
briandowther Onrelm ov.
Sincerely,
'- Ij
for CoIeen H. Sullins, Director
cc: Wilmington Regional Office, Water Quality Section
Mike Mitchell, EPA Region IV
DWQ Environmental Science Section, Cindy Moore
Stormwater Permitting Unit
Central Piles
Attachments
0

' MAY-02-2011 MON 09:27 AM NEXION/ACME FAX NO. 9106954749
NCS000533
' STATE OF NORTH CAROUNA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
'
TO DISCHARGE STORMWATER UNDER THE
NATIONAL POLLUTANT_ DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions 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,
Siiar, LLC
is hereby authorized to discharge stormwater from a facility located at
Sitar. LLC
333 Neils Eddy Road
Riegelwood, NC
Columbus County
1
to receiving waters designated as Livingston Creek (Broadwater Lake), a class C; Sw stream in
the Cape Fear River Basin, in accordance with the discharge limitations, monitoring
requirements, and other conditions set forth in Parts I, IL U1, IV, V and VI hereof.
This permit shall become effective November 1, 2010.
Tlvs permit and the authorization to discharge shall expire at midnight on October 31, 2015.
Signed this day October 22, 2010.
' for Coleen H. Sullins Director
Division of Water Quality
By the Authority of the Environmental Management Commission
1
P. 04

MAY-02-2011 MON 09:27 AM HEX ION/ACME FAX NO. 9106564749 P. 05
Permit 14o. NCS000533
TABLE OF CONTENTS
PART I INTRODUCTION
Section A: Individual Permit Coverage
Section B: Pem-fitted Activities
Section C: Location Map
PART IT MONITORING, CONTROLS, AND UNGTATIONS FOR PERMITTED
DISCHARGES
Section A: Stormwater Pollution Prevention Plan
Section B: Analytical Monitoring Requirements
Section C: Qualitative Monitoring Requirements
Section D: On -Site Vehicle Maintenance Monitoring Requirements
PART III STANDARD CONDITIONS FOR NPDES STORMWATER INDIVIDUAL
PERMITS
Section A: Compliance and Liability
1.
Compliance Schedule
2.
Duty to Comply
3.
Duty to Mitigate
4.
Civil and Criminal Liability
S..
Oil and Hazardous Substance Liability
6.
Property Rights
7.
Severability
S.
Duty to Provide Information
9.
Penalties for Tampering
10.
Penalties for Falsification of Reports
Section B. General Conditions
L
Individual Permit Expiration
1.
Transfers
3.
Signatory Requirements
i

MAY-02-2011 MON 09:28 AM HEXION/ACME
FAX NO, 9106554749 P. 06
Permit No. NCSO00533
4. Individual Permit Modification, Revocation and Reissuance, or
Termination
5.
Permit Actions
Section C: Operation
and Maintenance of Pollution Controls
1.
Proper Operation and Maintenance
2_
Need to Halt or Reduce Not a Defense
3.
Bypassing of Stormwater Control Facilities
Section D: Monitoring
and Records
1.
Representative Sampling
2.
Recording Results
3,
Flow Measurements
4.
Test Procedures
S.
Representative Outfall
6,
Records Retention
7.
Inspection and Entry
Section E: Reporting Reauirements
1.
Discharge Monitoring Reports
2.
Submitting Reports
3.
Availability of Reports _
4.
Non-Stormwater Discharges
S.
Planned Changes
6.
Anticipated Noncompliance
7.
Spills
8.
Bypass
9,
Twenty-four Hour Reporting
10.
Other Noncompliance
11.
Other Information
PART rV LIMITATIONS REOPENER
PART V ADMINISTERING AND COMPLIANCE MONITORING FEE
REQUiREMEN"TS
PART VI DEFINITION'S
ii

_ NAY-02-2011 MON 09:28 AM HEX1ON/ACMI; FAX NO. 9106554749 P. 07
Permit No. NCS000533
I PART I INTRODUCTION
' SECTION A. INDIVIDUAL PERMIT COVERAGE
During the period beginning on the effective date of the permit and lasting until expiration, the
' pe nittee is authorized to discharge stormwater associated with industrial activity. Such
discharges shall be controlled, limited and monitored as specified in this perinit.
-If industrial materials and activities are not exposed to precipitation or runoff as described in 40
CFR § 122.26(g), the facility may qualify for a No Exposure Exclusion from NPDES stormwater
discharge permit requirements. Any owner or operator wishing to obtain a No Exposure
' Certification must submit a No Exposure Certification NDI form to the Division; must receive
approval by the Division; must maintain ho exposure conditions unless authorized to discharge
under a valid NPDES stormwater permit, and must reapply for the No Exposure Exclusion once
every five (5) years.
SECTION B: PERMITTED ACTIVITIES'
Until this permit expires or is modified or revoked, the permittee is authorized to discharge
stormwater to the surface waters of North Carolina or separate storm sewer system that has been
' adequatcly treated and managed in accordance with the terms and conditions of this individual
permit. All stormwater discharges shall be in accordance with the conditions of this permit.
Any other point source discharge to surface waters of the state is prohibited unless it is as
allowable non-stormwater discharge or is covered by another permit, authorization, or approval.
The stormwater discharges allowed by this individual permit shall not cause or contribute to
violations of Water Quality Standards.
This permit does not relieve the ermittee from responsibility for compliance with an other
p P P Y mp Y
applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or decree.
Part t Page t of 2

HA-Y-02-2011 MOIL 09:28 AM HEX ION/ACME
FAX NO. 9106554749
Im
SE, CVIGN C-. LOCATION MAP
Pemlit No. NCS000533
4
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9
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NC5000533
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Silar LLC
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Longib-ide: 78P 1Z 5" W
cokmty- colurfts
ReceNriq Stremn: U,4nqszm Credo
Stream a ass. C; sw
Sub -barn: 03t6-17 (QVe Fear RINw Barn)
Part I Page 2 of 2
Facility Location

- MAY-02-2011 MON 09:28 Ali HEXlON/ACME FAX NO. 9106554749
9
' Permit No. NCSOMS33
PART B MONITORING, CONTROLS, AND (LIMITATIONS FOR
PERMITTED DISCHARGES
SECTION A: STORMWATER POLLUTION PREVENTION PLAN
The Pennittee shall develop a StoImwater Pollution Prevention Plan, herein after referred to as
the Plan. This Plan shall be considered public information in accordance with Part III, Standard
Conditions, Section E, Paragraph 3 of this individual perrnit. The Plan shall include, at a
minimum, the following items:
1. Site Plan. The site plan shall provide a description of the physical facility and the
potential pollutant sources which may be expected to contribute to contamination of
stormwater discharges. The site plan shall contain the following:
(a) A general location map (USGS quadrangle wrap or appropriately drafted
equivalent snap), showing the facility's location in relation to transportation routes
and surface waters, the name of the receiving water(s) to which the stormwater
outfall(s) discharges, or if the discharge is to a municipal separate storm sewer
system, the name of the municipality and the ultimate receiving waters, "
accurate latitude and longitude of the point(s).of discharge. The general location
map (or alternatively the site map) shall identify whether each receiving water is
impaired (on the state's 303(d) list of impaired waters) or is located in a
watershed for which a TNIDL has been established, and what the parameter(s)
of concern are.
(b) A narrative description of storage practices, loading and unloading activities,
outdoor process areas, dust or particulate generating or control processes, and
waste disposal practices. A narrative description of the potential pollutants which
could be expected to be present in the stormwater discharge from each outfall.
(c) A site map drawn to scale (including a distance legend) showing: the site property
boundary, the stormwater discharge outfalls, all on -site and adjacent surface
waters and wetlands, industrial activity areas (including storage of materials,
disposal areas, process areas, loading and unloading areas, and haul roads), site
topography, all drainage features and structures, drainage areas for each ourfali,
direction of flow in each drainage area, industrial activities occurring in each
drainage area, buildings, existing BiWs, and impetvious surfaces. The site map
must indicate the percentage of each drainage area that is impervious.
(d) A list of significant spills or leaks of pollutants that have occurred at the facility
during the three (3) previous years and any corrective actions taken to mitigate
spill impacts.
(e) Certification that the stormwater outfalls have been evaluated for the presence of
non-stormwater discharges. _ The certification statement will he signed in
accordance with the requirements found in Part III, Standard Conditions, Section
Part R Page 1 of 11

MAY_02-2011 MON 09!28 AM IIEXION/ACME FAX NO. 9106654749
rPermit No. NCS000533
IB, Paragraph S. The permittee shall re -certify annually that the stormwater
outfalls have been evaluated for the presence of non-stormwater discharges.
2. Stormwater Management Plan The stormwater management plan shall contain a
narrative description of the materials management practices employed which control or
minimize the exposure of significant materials to stormwater, including structural and
nonstructural measures. The stormwater management plan, at a minimum, shall
incorporate the following.
(a) Feasibility Study. A review of the technical and economic feasibility of changing
the methods of operations and/or storage practices to eliminate or reduce exposure
of materials and processes to stormwater. Wherever practical, the permittee shall
prevent exposure of all storage areas, material handling operations, and
manufacturing or fueling operations. In areas where elimination of exposure is
not practical, the stormwater management plan shall document the feasibility of
divertirig the stormwater runoff away from areas of potential contamination.
(b) Secondary Containment Requirements and Records. Secondary containment is
required for: bulk storage of liquid materials; storage m any amount of Section
313 of Title III of the 5uperfund Amendments and Reauthorization Act (SARA)
water priority chemicals; and storage in any, amount of hazardous substances, in
order to prevent leaks and spills from contaminating stormwater runoff. A table
or summary of all such tanks and stored materials and their associated secondary
containment areas shall be maintained. If the secondary containment devices are
connected to stormwater conveyance systems, the connection shall be controlled
by manually activated valves or other similar devices (which shall be secured
closed.with a locking mechanism), and any stormwater that accumulates in the
containment area shall beat a minimum visually observed for color, foam, outfall
staining, visible sheens and dry weather flow, prior to release of the accumulated
stormwater. Accumulated stormw ter shall be released if found =to be
uncontaminated by
anyymateria L Records documenting the individual making the
o servation, the description of the accumulated stormwater, and the date and time
.of the release shall be kept for a period of five years.
(c) BMP Summary. A listing of site structural and non-structural Best Management
Practices (BMP) shall be provided The installation and implementation of BMPs
shall be based on the assessment of the potential for sources to contribute
significant quantities of pollutants to stormwater discharges and data collected
through monitoring of stomiwater discharges. The BMP Summary shall include a
written record of the specific rationale for installation and implementation of the
selected site BMPs. The BMP Summary shall be reviewed and updated annually.
3. Spill Prevention and Response Plan. The Spill Prevention and Response Plan (SPRP)
shall incorporate an assessment of potential pollutant sources based on a materials
inventory of the facility. facility personnel (or the team) responsible for implementing the
'_- SPRP shall be identified in a written list incorporated into the SPRP and signed and dated
by each individual acknowledging their responsibilities for the plan. A responsible
Part 11. Page 2 of I I
F. 10

MAY-02-2011 MON 09:29 AM HEXION/ACME FAX NO, 9106554749 P. I
1
Permit No. KCS000533
person shall be on -site at all times during facility operations that have the potential to
contaminate stormwater runoff through spills or exposure of materials associated with the
facility operations. The SPRP must be site stormwater specific. Therefore, an oil Spill
Prevention Control and Countermeasure plan (SPCC) may be a component of the SPRP,
but may not be sufficient to completely address the stormwater aspects of the SPRP. The
common elements of the SPCC with the SPRP may be incorporated by reference into the
SPRP.
4. ' Preventative Maintenance and Good Housekeeping Program. A preventative
maintenance and good housekeeping program shall be developed. The program shall list
all stormwater control systems, stormwater discharge outfalls, all on -site and adjacent
surface waters and wetlands, industrial activity areas (including material storage areas,
material handling areas, disposal areas, process areas, loading and unloading areas, and
haul roads), all drainage features and structures, and existing structural BMPs. The
program shall establish schedules of inspections, maintenance, and housekeeping
activities of stormwater control systems, as well as facility equipment, facility areas, and
facility systems that present a potential for stormwater exposure or stormwater pollution.
Inspection of material handling areas and regular cleaning schedules of these areas shall
be incorporated into the program. Timely compliance with the established schedules for
inspections, maintenance, and housekeeping shall be recorded in writing and maintained
in the SPPP.
5. Employee Training. Training programs shall be developed and training provided at a
minimum on an annual basis -for facility personnel with responsibilities for. spill response
and cleanup, preventative maintenance activities, and for any of the facility's operations
that have the potential to contaminate stormwater runoff. Facility personnel (or team)
responsible for implementing the training shall be identified, and their annual training
shall be documented by the signature of each employee trained,
6. Responsible Party. The Stormwater Pollution Prevention Plan shall identify a specific
positions) responsible for the overall coordination, development, implementation, and
revision to the Plan. Responsibilities for all components of the Plan shall be documented
and position assignments provided.
7. Plan Amendment. The permittee shall amend the Plan whenever there is a change in
design, construction, operation, or maintenance which has a significant effect on the
potential for the. discharge of pollutants to surface waters. All aspects of the
Stormwater Pollution Prevention Plan shall be reviewed and updated on an annual
basis. The annual update shall include an updated list of significant spills or leaks of
pollutants for the previous three years, or the notation that no spills have occurred. The
annual update shall include written re -certification that the stormwater outfalls have been
evaluated for the presence ofnon-stonnwater discharges. Each annual update shall
include a documented re-evaluation of the effectiveness of the BMPs listed in the BMP
Summary of the Stormwater Management Plan.
The Director may notify- the permittee when the Plan does not meet one or more of the
minimum requirements of the permit- Within 30 days of such notice, the permittee shall
Part 11 Page 3 of i l

MAY-02-2011 MON 09:29 AM HEXIOil/ACME FAX NO. 9106554749 P. 12
Permit No. NCS000333
submit a time schedule to the Director for modifying the Plan to meet minimum
requirements. Thc.perraittee shall provide certification in writing (in accordance with
Part IN, Standard Conditions, Section B, Paragraph 5) to the Director that the changes
have been made.
S. Facility Inspections.. Inspections of the facility and all stormwater systems shall occur as
part of the Preventative Maintenance and Good Housekeeping Program at a minimum on
a semi-annual schedule, once during the first half of the year (January to June), and once
during the second half (July to December), with at least 60 days separating inspection
dates (unless performed more frequently than semi-annually). These facility inspections
are different from, and in addition to, the stormwater discharge characteristic monitoring
required in Part U B and C of this permit.
9. Implementation. The permittee shall implement the Plan. Implementation of the Plan
shall include documentation of all monitoring, measurements, inspections, maintenance
activities, and.training provided to employees, including the log of the sampling data and
of actions taken to implement BWs associated with the industrial activities, including
vehicle maintenance activities. Such documentation shall be kept on -site for a period of
five years and made available to the Director or the Director's authorized representative
immediately upon request.
Part 11 Pagc 4 of 11

_ MAY-0222011r MON 09:29. AM HEX ION/ACME
FAX N0, 9106554749
P. 13
Permit No. NCS000533
SECTION B: ANALYTICAL MON][TORING REQUI EMIENTS
Analytical monitoring of stormwater discharges shall be performed as specified in Table 1. All
analytical monitoring shall be performed during a representative storm event. The required
monitoring will result in a minimum of 20 analytical samplings being conducted over the tern of
the permit at each stormwater discharge outfall (SDO).
A representative storm event is a storm event that measures greater than. 0.1 inches of rainfall. The time
between this storm event and the previous storm event measuring greater than 0.1 inches must be at least
72 hours. A single storm event may have a period of no precipitation of up to 10 hours. For example, if
if rains but stops before producing any collectable discharge, a sample may be collected if the next rain
producing a discharge begins within 10 hours.
Table 1. Ana"eal Monitorine Renuirements
Discharge
Characteristics
Units
Measurement.
Treen ut .
Sample
TYPe2
Sample
Location3
Total Suspended Solids SS
m
quarterly
Grab
SDO
Biochemical Oxygen Demand BOD5)
mpVL
quarterly
Grab
SDO
Chemical Ox en Demand COD)
to L
quarterlY
Grab '
SDO
Ammonia as Nitrogen(NH3-N)
ME&
quarterly .
Grab
SDO
Total' Kieldahl Nitrogen (TKN)
m
quaiterlY
Grab
SDO
Nitrate +•Nitrite Nitro en
m L
queerly
Grab
SDO
Total Phosphorus
m L
queerly
Grab
SDO
Methanol
to L
quattedY
Grab'
SDO
Total Residual Chlorine (TRC)4
m
quarterly
Grab
SDO
Hexamine
az
quarterly
Grab
SDO
Forntaldeit de
m
queerly
Grab
SDO
Co er, Total Recoverable
ni
quarterly .
Grab
SDO
Zinc, Total Recoverable
m
quarterly
Grab
SDO
Man arise, Total Recoverable
mglL
quarterly
Grab
SDO
Lead, Total Recoverable
m VL
quarterly
Grab
SDO
EPA Method'1654 (SGT-HEM) —
Non- clan O&G1TPH
to
quarterly
Grab
SDO
PH'
standard
quarterly
Grab
SDO, 005
Effluent,
Downstream,
U stream
Part 11 Page 5 of 11

1 , MAY-02-2011 MON 09;29 AM HEXlON/ACHE FAX NO.9106554749 P. 14
Permit No. NCS000533
Dissolved Oxygen ' •
Gram
005 Effluent,
mg/L
quarterly
.Downstream,
LT stream
Acute Toxicity I
_
Annually
I Grab
5D0
Total Rainfall$
inches
quarterly lRainGauge
Footnotes:
1 Measurement Frequency: Four times per year duz isg a representative storm event
2 Grab samples shall bo collected within die first 30 minutes o£ discharge.
3 Sample Location: Samples shaft be collected at each storntwater discharge outfall (SDO) unless representative outfall
status has been granted.
4 May discontinue monitoring this parameter for the remainder of the permit a&er first eight (6) sampling events, if all
results are below the bencbnmk value.
5 The pH at each SDO shall not be less than 6.0 standard units nor greater than 9.0 standard units for fresh water
classifications. The in stream samples am from swamp waters and may have a pH vahses as ,low as 4.3 if it is the
result of natural conditions.
6 Water Quality. Standard for Dissolved oxygen: not less than 6.0 mg/1 for trout waters; for non-trout'waters, not
leas than a daily average of 5.0 mg/l with a micTmiun instantaneous value of not less than 4,0 m,gll; swamp waters,
lake coves or backwaters, acid lake bottom waters may have lower values if caused by natural conditions.
7 Acute toxicity shall be perfonued in accordance with Appendix A: Special Conditions at the end of this pennit-
8 For each sampled representative storm event the total precipitation roust be recorded An on -site rain gauge or local rain
gauge reading must be recordcd.
The permittee shall complete the minimum 20 analytical samplings in accordance with the
schedule specified below in Table 2. A minimum of 30 days must separate Period 1 and
Period 2 sample dates unless monthly monitoring has been instituted, under a Tier Two
response.
Table 2. Monitoring Schedule
Monitoring period""
Start
End
All Years — Quarter 1
January 1
March 31
All Years —Quarter 2
April 1
June 30
All Years — Quarter 3
July 1
Septetub'er 30
All Years — Quarter 4
October 1
December 31
FOOmo.tes:
1 Maintain quarterly monitoring during permit renewal process, if at the expiration of this permit, the
penninee has submitted an application for renewal of coverage before the submittal deadline, the pertnittee
will be considered for renewed coverage. Quarterly monitoring shall be done all years of the permit and the
applicant n st continue quarterly monitoring until the renewed permit is issued.
2 If no discharge occurs during the sampling period, the petmirtee must submit a monitoring report indicating
"No Flow" within 30 days of the and of the three -monde sampling period.
The permittee shall report the analytical results from the first sample with.valid results within the
monitoring period: The permittee shall compare monitoring results to the benchmark values in
Part 11 Page 6 of t 1

�— HAY-02-2011 MOH 09: 30 AM HEX I OWACMtE
FAX NO, 9106554749
P. 15
Permit No. NCS000533
Table 3. The benchmark values in Table 3 are not permit limits but should be used as guidelines for
the permittee's Stormwater Pollution Prevention Plan-(SPPP), Exceedences of benchmark values
require the permittee to increase monitoring, increase tnanagerhent dcddhs, increase record keeping,
and/or install stormwater Best Management Practices (BMPs) in a tiered program. See below the
descriptions of Tier One and Tier Two.
Table 3_ Benehninrlt Valium fnr AnulvAral Mnnittnrina
Discharge Characteristics
Units
Benchmark
Total Suspended Solids (TSS)
mg/L
100
Biochemical Oxygen Demand (BODs)
mg/L
30
Chemical Oxygen Demand (COD)
mg/L
120
Ammonia as Nitrogen (NH3-N)
mgtL
7.2
Total Kjeldahl Nitrogen (TKN)
mg/L
20
Nitrate } Nitrite Nitrogen
mgIL
10
Total Phosphorus
mg2
2.
Methanol
mgIL
7,700
Total Residual Chlorine (TRC)
mg/L
0.028
Hexamine
mg/L
25,000 i
Formaldehyde
mg/L
0.5
Copper, Total Recoverable
mg/L
0.007
Zinc, Total Recoverable
mg/L
0.067
Manganese, Total Recoverable
mg/L
N/A
Lead, Total Recoverable
mom,
. 0.03
EPA Method 1664 (SGT-HEM) r
Non polar O&G/T'PH
mgfL
1 S
pH
standard
6-9
Acute Toxicity
See
Appendix A:
Special
See Appendix
A: Special
Conditions
Part Il Page 7 of 11

MAY-02-2011 MON 09:30 AM HEXIONfACME FAX N0, 9106554749 P. i6
1
PenrY t No. NCS000533
Tier One
if -The first valid sampling results are above a benchmark value, or outside of the benchmark range, for any I
,Darameter at anv oulfall: J
Then: The permittee shall:
1. Conduct a stormwater management inspection of the facility within two weeks of receiving
sampling results.
2. Identify and evaluate possible causes of the benchmark value exceedence.
3. Identify potential and select the specific: source controls, operational controls, or physical
improvements to reduce concentrations of the parameters of concern, or to bring concentrations
within the benchmark range.
4. Implement the selected actions within two months of the inspection.
a. Record each instance of a Tier One response in the Stormwater Pollution Prevention Plan. Include
the date and value of the benchmark exceedence, the inspection date, the personnel conducting the
inspection, the selected actions, and the date the selected actions were implemented.
Tier Two
If: During the term of this permit, the fast valid sampling results from three consecutive monitoring periods
are above the benchmark values, or outside of the benchmark range, for any specific parameter at a
Then: The permittee shall:
I . Repeat all the required actions outlined above in Tier One.
2. Immediately institute monthly monitoring for all parameters at every outfall where a sampling result
exceeded the btn'chmark value for two'consecutive samples. Monthly (analytical and qualitative)
monitoring; shall continue until three consecutive sample results are below the benchmark values or
within the benclunark range.
3. If no discharge occurs during the. sampling period,,dte permittee is required to submit a monthly
monitoring report indicating "No Flow" to comply with reporting requirements.
4. Maintain a record of the Tier Two response in the Stormwater Pollution Prevention Plan.
Tier Three
During the term of this permit, if the valid sampling results required for the permit monitoring periods
exceed the benchmark value, or are outside the benchmark range, for any specific parameter at any specific
outfall on four occasions, the permittee shall notify the DWQ Regional Office Supervisor in writing within
30 days of receipt of the fourth analytical results. DWQ may but is not limited to:
require that the permittee revise, increase, or decrease the monitoring frequency for the remainder
of the permit;
+ require the permittee to conduct acute toxicity testing on discharges;
+ require the pernittee to install structural stormwater controls;
• require the permittee to implement other stormwater control measures; or
• require that the ermittee ' )lement site modifications to qualify foe the No f_xE2surc Exclusion.
Part TI Page a of 1 I

MAY-02,2011 MON 09:30 Ate HEX10N/ACtiE FAX N0, 9i05554749 p, 17
1 __
Permit No. NICS000533
This site discharges to impaired waters experiencing problems with turbidity. If a Total
Maximum Daily Load (TMDL) is approved for this segment of Livingston Creek, the permittee
may be required to monitor for the pollutants) of concem in the future and submit results to the
Division of Water Quality. The Division will consider the monitoring results in determining
whether additional BMPs are needed to control the.pollutant(s) of concern to the maximum
extent practicable.
If additional BMPs are needed to achieve the required level of control, the permittee will be
required. to (1) develop a strategy for implementing appropriate BN Ps, and (2) submit a timetable
for incorporation of those BWs into the permitted Stormwater Pollution Prevention Plan,
SECTION C: QUALITATIVE MON170RING REQUIREMENTS
Qualitative monitoring requires.a visual inspection of each stormwater outfall regardless of
representative outfall status and shall be performed as specified in Table 43 during the analytical
monitoring event. [If analytical monitoring is not required, the permittee still must conduct
quarterly qualitative monitoring.] Qualitative monitoring is for the purpose of evaluating the
effectiveness of the Stonnwater Pollution Prevention Plan (SPPP) and assessing new sources of,
stormwater pollution.
In the event an atypical condition is noted at a stormwater discharge outfall, the permittee shall
document the suspected cause of the.condition and any actions takers in response to the
discovery. This documentation will be maintained with the SPPP.
Table 4. Qualitative Mo nitaring -Rea uirements
Discharge Characteiristics
Freque.n6yi
Monitoring.
Location
Color
uarterl
SDO
Odor
quarterly
SDO
Clarity
uarterl
SDO
Floating Solids
quarterly
SDO
Su ended Solids
erl
SDO.
Foam
quarterly
SDO
Oil Sheen
Quarterly
SDO
Erosion or d sition at the outfall
quarterly
SDO
Other obvious indicators
of stormwater pollution
quarterly
SDO
Footnote;•.:
I Measurement Frequency. Four times per year during a representative storm event, for eaeh year until either
another permit is issued for thi3 facility or until this permit is revoked or rescinded. If at the end of this
permittitig cycle the pennitree has submitted the appropriate paperwork for a renc-wal permit before the submittal
deadline, the permitter will be considered for renewed coverage. The applicant must continue quarterly
Partil Page 9 of l l

I
_ MAY-02-2011 MON 09:30 AM HEX IONIACHE FAX NO, 9106554749 P. 19
1
Permit No. NCS000533
monitoring until the renewed perm t is issued. See 'fable 2 for Schedule of monitoring periods through the end of
this permitting cycle.
2 Monitoring Location: Qualitative monitoring shsli be perfarmad at each stormwater discharge outfall (SDO)
regardless of representative outfall status.
SECTION D: ON -SITE VEIHICLE MAINTENANCE MONITORING REQUIRENItENTS
Facilities which have any vehicle maintenance activity occurring on -site which uses more than 5S
gallons of new motor oil per month when averaged over the calendar your shall perform
analytical monitoring as specified below in Table 5. This monitoring shall be performed at all
stormwater discharge uutfalls which discharge storrnwater runoff from vehicle maintenance
areas, and in accordance with the schedule presented in Table 2 (Section B). All analytical
monitoring shall be performed during a representative storm event.
Table 5, Analytical Monitoring Requirements for On -Site Vehicle Maintenance
Distharge Characteristics
Units
Measurement
Fre uent t
Sample
Ty pe_2
Sample
Location3
H
standard
quarterly
Grab
SDO
Total Petroleum Hydrocarbons
PA Method 1664 {SGT-EEM)
'9/1
quarterly
Grab
SDO
Total S ended Solids
m 1
q uarterly .
Grab
SDO
Total Rainfal14
inches
quarteriX
Rain ati e
New Motor Oil Usage
allons/month
quarterly
Estimate
-
I flotmotes:
l Measurement Frequency: Four times per year during a representative storru event, for each year until either
another permit is issued for this facility or until this permit is revoked or rescinded. If at the end of ddg
permitting cycle the permtttee has submitted the appropriate paperwork for a renewal permit before the submittal
deadline, the permince will be considered for renewed coverage. The applicant must continue quarterly
monitoring until the renewed permit is issued. Sec Table 2 for schedule of monitoring periods through the end of
this permitting cycle.
2 If the stormwater runoff is controlled by a stormwater detention pond a grab sample of the discharge from the
pond shall be collected within the first 30 miauutrs of discharge from the pond.
3 Samplc Location: Samples shall be collected at each atarmwater diechatgt: outfall (SDO) that discharges
stormwater runoff from area(s) where vehicle maintenance activities occur,
a for each sampled representative storm event the total precipitation must be recorded. An on -situ or local rain
gauge reading must be recorded.
Monitoring results shall be compared to the benchmark values in Table 6. The benchmark
values in Table 6 are not permit limits but should be used as guidelines for the permittee's
Stonuwater Pollution Prevention Plan (SPPP). Exceedences of benchmark values require the
permittee to increase monitoring, increase management actions, increase record keeping, and/or
install stormwater Best Management Practices (BMPs), as provided in Part II Section B.
Part 1I Page to of 11

MAY-02-2011 MON 09:31 AM HEXION/ACME FAX N0. 9106554749 P. 19
Table 6
Permit No. NCS000533
Benchmark Values for Vehicle Maintenance Analytical Monitoring
Discharge Characteristics
Units
Benchmark
PH
standard
6-9
Total Petroleum Hydrocarbons (TPH)
[EPA Method 1664 �SGT-HE*j
Total Sus ended Solids (TSS)
T mg(L
100
Pert II Page 11 of 1 l

MAY-02-2011 MON 09:31 Ate HEX]ON/ACME
FAX NO, 9106554749
P. 20
1
I
Perrin No, NCS000533
PART III STANDARD CONDITIONS FOR Wi DES STORMWATERINDIVIAUAL PFSMITS
SECTION A: CONVLiANCR AND LIABILITY
Compliance Schedule
The permitteo shall comply with Limitations and Controls specified far storawster discharges in
accordance with the following schedule:
Existing Facilities already operating but applying for permit coverage fnr the first time: The Stortawater
Pollution Prevention Plan shall be developed and implemented within 12 tnoaths of the effective date of the
initial permit and updated chereaf er on an annual basis. Secondary containment, as specified in Part IL
Section A, Paragraph 2(b) of this permit, shall be accomplished within 12 monrhs of the effective date of
the initial permit issuance.
New Facilities applying for coverage for the firm time and existing facilities previously permitted and
applying for renewal under this permit: 'Lire Stormwater Pollution Prevention plan shall be developed and
implemented prior to the beginning of discharges from the operation of the industrial activity and be
updated thereafter on ati annual basis. Secondary containment, as specified in Part II, Section A, Paragraph
2(b) of this permit shall be accomplished prior to the beginning of discharges &= the operation of the
industrial activity.
2. Dun, to Cowl
The permutes must comply with all conditions of this individual permit Any permit noncompliance
constitutes a violation of the Clean Water Act and is grounds for enforcetneat action; for permit
termination, revocation and reissuance, or modification; or denial of a permit upon renewal application-
a. The permittee shall comply with standards or prohibitions established under section 307(a) of the
Clean Water Art for toxic pollutants within the time provided in the regulations that establish these
standards or prohibitions, even if flit permit has not yet been modified to incorporate the
requirement
b. Tbz Clean Water Act provides that any person who violates a permit condition is subject to a civil
penalty not to exceed $25,000 per day for each violation. Any person who negligently violates any
permit condition is subject to criminal penalties of $2,500 to 25,000 ptr day of violation, or
imprisonment for not more titan 1 year, or both. Any person who knowingly violates permit
conditions is subject to criminal penalties of $5,000 to $50,000 per day of violation, or
imprisoameat for not more than 3 years, or both. Also, any person who violates a permit condition
maybo assessed an administrative penalty not to exceed 510,000 per violatioa with the maximum
amount not to excocd S 125,000. [Ref- Section 309 of the Federal Act 33 USC 1319 and 40 CFR
122.41(a).]
C. Under state law, a daily civil penalty of not more than ten thousand dollars ($10,000) per violation
may be assessed against any person who violates or fails to act in accordance with the terms,
cou&tioos, or requirements of a permit. [Ref: NC General Stmtcs 143.215.6A].
d. Any person Wray be assessed an administrative penalty by the Director for violating section 301,
302, 306, 307, 303, 319 or 405 of the Act, or any permit condition or limitation implementing any
of such sections in a permit issued =dtr section.402 of the Act Administrative penalties for Class
I violations am not to exceed $10,000 per violation, with the maximum amount of any CLzss I
penalty assessed not to exceed S25,000. Penalties for Class II violations arc not to exceed
Part III Page 1 of 8

_MAY-02-2011 MOH 09;31"RM HEXION/ACME" FAX NO. 9106554749 P. 21
Permit No. NCS000533
' $10,000 per day for each day during which the violation continues, with the maximum amount of
any Class 11 penalty not to exceed &125,000.
3. pia to Nlig are
The permittce shall take all reasonable steps to minimize or prevent any discharge in violation of this
individual permit which has a reasonable likelihood of adversely affecting human health or the environment.
4. Civtland Ctirnir►a1 I.ial�ility
]"accept as provided in Part 111, Section C of this permit regarding bypassing of stormwater couuol facilities,
nothing in this individual persuit shall be construed to relieve the permittee from sty responsibilities,
liabilities, or penalties for noncompliance pursuant to NCGS 143-215.3, 143-215.6A, 143-215.6B, 143-
215.6C or Section 309 of the Federal Act, 33 USC 1319. Furthermore, the permittee is responsible for
consequential damages, such as fish kills, evea though the responsibility for eBective compliance may be
temporarily suspended.
5. _Oil and Hazardous Subetattgc� Liability
QNodung in this individual permit shall be construed to preclude the institution of any legal action or relieve
the permittee from any responsibilities, liabilities, or penalties to which the permiuze is or may be subject to
under NCGS 143-215.75 et seq. or Section 311 of The Federal Act, 33 USC 1321.
6, Property Righ
The issuance of this" individual;5ermit does not convey any property rights in either real or personal "
property, or any exclusive privileges, nor does it autborize any injury to private property or any invasion of
peTsonal' sights, nor any infringement of Federal, State or local laws or regulations.
7. Shverabilitx
The provisinns of this individual permit are severable, and if any provision of this individual permit, or the
applicaridn of any.provision of thin individual. permit to any circtunstanees, is Mid. invalid,. the application
of such provision to other circumstances, and the remainder of this individual permit, shall not be affected
thereby.
8: . Duty to Prnvidt Infamodon
The petmime shall fiunish to the Director, within a reasonable ti mc, any information which the Director
may request to determine whether cause exists for modifying, rovoldng and reissuing, or terminating the
permit issued pursuant to this individual permit or to determine compliance with this individual permit The
permince; shall also fumish.to the Director upon request, copies of records required to be kept by this
individual permit.
D. Penalties forTamimrinn
The Clean Water Act provides that any person who falsifies, tampers with, or lmbwingly renders inaccurate,,
any monitoring device of method required to be maintained under -this individual permit shall, upon
conviction, be punished by a fine of not more than $10,000 per violatioti, or by imprisonment for not more
than two years per violation, or by both. If a conviction of a person is for a violation committed after a first
conviction of such person Linder this paragraph, punishment is a fine of not more that $20,000 per day of
violation, or by imprisonment of not more than 4 years, or both.
Part III Page 2 of

I_ MAY-02-22011 MON 09;31 AM HEXION/ACME
FAX NO, 9106554749 P. 22
�J
in. Penalties for alsification a(ftorts
Penult No. NCS000533
no Clean Water Act provides that any person who knowingly makes any false statement, reptrsentation, or
1 certification in any record or other documrut submitted or required to be maintained tuider this individual'
permit, including monitoring reports or reports of compliance or noncompliance shalt, upon conviction, be
punished by a fine of not more than S10,000 per violation, or by imprisonment for not more than mo years
per violation, or by both.
SECiiONB: GENERA. CONDMONS
1n M4uW Permir Exniration
The permittee ii not authorized to discharge after the expiration date: In order to receive automatic ,
aurboriration to discharge beyond the expiration date, the pertnitree shall Submit forms and fees as are
required by the agency authorized to issue permits no later than l80 days prior to the expiration date. Any
permittee that has not requested rmtwal -at least 180 days prior to expiration, or any perrni�rrer that does not
have a. permit after the expiration and has not requested renewal at least 1 go days prior to expiration, will be
subjected to eotorcemeut procedures as provided in NCGS .§ 143-2I53.5 and 33 USC 1251 et seq.
2. Transfers
This permit is not transferable to any person except after notice to and approval by the Director. The
Director may require modification or revocation and rcWuance of the permit to change the name and
incorporate such other requirements as may be necessary der the Cleats Water Act: The Permittee is
required to notify the Division in writing in the event the permitted facility is said or closed.
3. S to uirements
All applications, reports, or information submitted to the Director shalt be sigmed'and certified_
a. All applications �o be covered under this individual permit shall be signed as follows:
{1) In the case o f a corporation: by a principal executive officer of at leas# the level of vice-
president, or his duly authorized representative, if such representative is responatble for
the overall operation of the facility from which the discharge descri1=d'in the permit
application form originates;
(2) 'In the case of o partnership or limited partnership: by a general partner,
(3) In the case of a sole proprietorship: by the proprietor,
(4) In the case of a municipal, state, or other public entity. by a principal executive officer,
rartldng elected official, or other duly authorized employee.
b. All reports requirrci by the individual permit and other infortnation requested by die Dirrctor shall
be signed by a person described above or by a duly authorized representative of that person. A
person is a duly authorized representative only if
(1) The authorization is made in writing by a person described above;
(2) The authorization specified either an individual or a position having responsibility for the
overall operation of the regulated facility or activity, such as the position of plant
rttanager, operator of a well or well field, superintendomr, a position of equivalent
Partin Page 3 of g

MAY-02-2011 MON 09:31 AM HEXION/ACME FAX NO. 9106564749 P. 23
Pmnmit No. NCS000533
responsibility, or an individual or position having overall responsibility for environmental
matrcrs far the'company. (A duly authorized reprctentative may thus be either a named .
individual or any -individual occupying a named position.); and
(3) -The written authorization is submitted to the Director.
G. Any person signing a document under paragapbs a. or b. of this section shall stake the following
certification;
"I certify, under penalty of law, that this document and all attachments were prepared under my
direction of suprrviaion in accordance with a system designed to assure that qualified personae]
properly gather and evaluate the information submitted Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, w the best of my knowledge and belief, true, accurate,
and complete. i am aware that dwrt are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations."
4. Indivi5L=j PMij Modificatiom Reyoce 'on and Reictuance or. Termin lion
The issuance of this individual permit does hot prohibit the Director from reopening and modifying the
individual permit, revoking and reissuing the individual permit, or terminating the individual perrnit as
allowed by the laws, rules, and regulations contained in Title 40, Code of Federal Regulations, Parts 122
and 123; Title 15A of the North Carolina Administrative Code, Subchapter 2H .0100; and ]North Carolina
General Statute 143-215.1 et al.
5. Permit kctjs�ns
The permit may be modified, revoked and reissued, or terminated for cause. The notification of punned
charges er anticipated noucamplianee does not stay any individual permit condition.
SECTION C: OPERATION AND MA.INTENaCNCE OF POLLUTION CONTROLS
Proper Operation and Maintentnnce
T11e permittee shall at all times properly operate and maintain all facilirica and systems of treatment and
control (and related appurtenances) which are installed or used by the permittee to achieve compliance with
the conditions of this individual permit Proper operation and maintenance al,o includes adequate
laboratory controls and appropriate qualiry assurance procedures, This provision requires the operation of
back-up or auxiliary facilities or similar systems which are installed by a penniaee only when the operation
is necessary to achieve compliance with'the conditions -of this individual permit.
2. Need10 Halt or Reduce Not a Defense
It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or
reduce the permitted activity in order to maintain compliance with the condition of this individual permit
3. 13yp�sing of Stormwates Control Facilities
aypass is prohibited and the Director may take cnforcemtnt action against a petmiuee for bypass unless:
a. Bypass was -unavoidable to prevent loss of life, personal injury or severe property damage; and
Part III Page 4 of 8

MAY-02-2011 MON 09:32 AM HEXION/ACME FAX N0, 9106554749 P. 24
Permit No. NCS000533
b. There were no feasible alternatives to the bypass, such as the use of auxiliary control facilities,
retcnrion of stormwater or maintenance during normal periods of equipment downtime or dry
weather. This condition is not satisfied if adequate backup -controls should have been •installed'in
the cx=ise of reasonable engineering judgment to prevent a bypass which occurred during normal
periods of equipment downtime or preventive nudnWn=ce; and
C. The permittee submitted notices as required under, Part U1, Section E of this permit.
If the Director dcre mines that it will meet the three conditions listed above, the Director may approve an
anticipated bypass after considering its adverse effects.
SECTION D: MOINITORNG AND RECORDS
L Rmescrit4fiva SALM131i
Samples collected and measurements talcen, as required herein, shall be characteristic of the volume and
nature of the peimiaed discharge, Analytical sampling shall be performed during a representative storm
event. Samples shall be taken on a day and time that is characteristic of the discharge. All samples shall be
taken before ti4 discharge jofns or is diluted by any other waste dream, body of water, or substance.
Monitoting points w specified in this permit -shall nor be changed without notification to and approval of
the Director:
■ 2. Rmarding_Results
For each measurement, sample, inspection or maintenance activity performed or collected pursuant to the
requirements of this individual permit, the perm tme shall record the following information:
a Tho date, exact place, and time of sampling, measurements, inspection or maintenance activity,
b. The individual(s) who performed the sampling, measurements, inspection or maintenance activity,
G. The date(s) analyses were performed;
d. The individual(s) who performed the analyses;
e. The analytical techniques or methods used; and
f. The results of such analyses_
3. Flow Measurements
Where required, appropriate flow m:asurcment devices and methods consistent with accepted scientific
practices shall be selected and used to ensure the accuracy and reliability of measurements of the volume of
monitored discharges.
4. Test procedures
Test procedures for the analysis of pollutants shall conform to the F-MC regulations published pursuant to
NCGS 143-215.63 et, scq, the Weer and Air Quality Reporting Acts, and to regulations published pursuant
to Section 304(g), 33 USC 1314, of the Federal Water Pollution Control Act, as Amended, and Regulation
40 CFR 13 6.
Part III - Page 5 of 9

HAY_02-2011 MAN 09 32 AM HEXION/ACHE FAX NO, 9106554749
Permit No. NCS000533
To meet the intent of the monitoring required by this individual•petrnit, ale test procedures must produce
minimum detection and reporting levels and all data generated must be reported down to the minimum
detection or lower reporting level of the procZdurd.
' 5. RmMentative Outfall
If a facility bas multiple discharge locations with substantially identical ctormwater.diaebarges that are
required to be sampled, the permit= may petition the Director for representative outfall status. If it is
established that the stormwater discharges are substantially identical and the permitter- is gtantcd
representative outfaU stems, than sampling mquirenunts"may be performt d at a reduced nusabcr of outfatls.
6. ecords Retention
Visual monitoring shall be documented and records maintained at the facility along with the Stortnwattr
Pollution Prevention Plan. Copies o f analytical monitoring rtsults shall also be maintained on -site. The
petniittee shall retain records of all monitoring information, including all calibration and maintenaticc
retards and all original strip chart recordings for continuous monitoring instntmzntation, and copies of all
reports required by this individual ,permit for a period of at least 5 years from the date of the sample,
measurement, report or application. This period may be extended by request of the Director at any time.
inspection and End
The permittee shall allow the Director, or an authorized representative (including an authorized contractor
acting as a representative of the Director), of in the case of a facility which discharges through a municipal
separate storm sewer system, an authorized representative of a runicipal operator or the separate storm
st wcr system receiving the discharge, upon the presentation of credcntiela and other documents as may be
required by law, to;
a. Entcr upon the perrnittec's premises where a regulated facility or activity is located or conducted,
or where records must be kept under the conditions of this individual permit;
b, Have access to and copy, at reasonable times, any records that must be kept under the conditions of
this individual permit;
C. Inspect at reasonable times any facilities, equipment (including monitoring and con 1ml equipment),
practices, or operations regulated or required under this individual permit; and
d. Sample or monitor at reasonable times, for The purposes of assuring individual permit compliance
or as otherwise authorized by the Clean Water Act, any'substances or parameters at any location.
sECfION Rs REPORTING R1EQUU1FMNTS
1. - D i Br- arc o itorin R its
Samplt3 analyzed in accordance with the terms of this permit shall be submitted to the Division on
Discharge Monitoring Report forms provided by the Director. Submittals shall be delivered to the Division
no later than 30 days from the date the fncility receives the sampling rtsults from the laboratory.
The.permitme shall submit an Annual Summary Date Monitoring Report to the appropriate DWQ Regional
Office by March t of each year that summarises data from the previous calendar year. The submittal shall
be on forms 4-upplied by the Division.
Pert III page 6 of a
P. 25

MAY-02-2011 MON 09:32 AM HEXION/ACME FAX N0. 9106554749
IPermit No. NCS000533
Wheo•no discharge has occurred from the facility during the report period, time pernnittee is required to
submit a discharge monitoring report, within 30 days of time and of the three-month sampling period, giving
all required information and indicating "NO FLOW ' as per NCAC T 15A 02B .0506.
The petsnitme shall record the rcgtaired qualitative monitoring observations on the SDO Qualitative
Monitoring Raport form provided by the Division, and shall retain the corpleted forms on bte. Visual
monitoring results should not be submitted to the Division, except upon DWQ'a specific requirement to do
so.
2- sulmlicting Room
Two signed copies of Discharge Monitoring Report9 (DMRs) shall be submitted to:
Central Fifes
Division of Water Quality
1617 Mail Service Center
Raleigh, North. Carolina 21699-1617
In addition, a separate signed Annual Sun=Lary D_MR copy shall be submitted to the local DWQ Regional
Office (RO) by March l of each year (See 1. above)..
Addresses for each RO and the countits covered by each RO can be found here:
htttn:/lvww.enr.state.nc.t,slhtmUreeionaloffrces.html. The permittee shall retain the completed originals
on site. Visual monitoring results should not be submitted to the Regional Offices or Central Files unless
specifically requested by DWQ_
1 3. Avallabili
Lty of Reports
Except for -data determined to be confidential under NCGS 143-215.3(a)(2) or Section 308 of the Federal
' Act, 33 USC 1318, all reports prepared in accordgnce•with the tens shall be available for.public inspection
at the offices of the Division of Water Qualiry. As required by the Act, analytical data shall not be
considered confidential. Knowingly making anytilse statement oa any such report may result in the
' imposition of criminal penalties as provided for in NCGS 143-215.6E or in Section 309k of the Federal Act
4. Non-StorrnwatarDischarees
If the storm event monitored in accordance with this Individual Permit coincides with a non-stormwatcr
discharge, the permittee shall" separately monitor all parameters as required under the nor!-btormwater
discharge permit and provide this information with the stormwater discharge monitoring report.
1 5. Planned Change.
The permittee shall give notice to.the Director as soon as possible of any planned cbanges at the permitted
facility which could significantly alter the nattue or quantity of pollutants discharged. This notification
requirement includes pollutants which are not specifically lu-ted in the Individual Permit or subject to
notification requirements under 40 CFR Part 122.42 (a).
6. Anticipate�NoMMpliance
The pemiittee shall give notice to the Director as soon as possible of any planned changes at the permitted
facility which may result in noncompliance with the Individual Permit requirements.
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MAY-02-2011 MON 09.:32 AM HEXIOhl/ACME FAX NO. 9106554749 P. 27
n
Peru& Na. NCS000533
7, i is ,
The permittee shall report to the local DWQ Regional Office, within 24 hours, all significant spills as
defined in Part VI of this pen it. Additionally, the permittee shall report spills including: any oil spill of 25
' gallons or more, any spill regardless of amount that causes a sheen on surface waters, any oil spill
regardless of amount occurring within 100 feet of surface waters, and any oil spill less than 25 gallons that
cannot be cleaned up within 24 bolus. .
a. Anticipated bypass. if the permittee knows in advance of the need for a bypass, it shall submit
prior notica, if possible at least ten days before the date of the bypass; including an evaluation of
the anticipated quality and affect of the bypass.
b. Unanticipated bypass. The permittee shall submit notice within 24 hours of becoming aware of an
unanticipated bypass.
9- Twenty-four Hour R ortin
The permittee shall report to the central office or the appropriate regional office any noncomplianca which
may endanger health or the environment. Any information shall be provided orally within 24 hours from
the time the permittee became aware of the circumstances. A written gubmissinn shall also be provided
within 5 days of the tirne the permittee becomes aware of the circumstances.
The written submission shall contain a description of the noncompliance, and its causes; the period of
noncompliance, including exact dates and druet,, and if the noncompliance has not been corrected, the
anticipated time compliance is expected to continue; and steps taken or planned to reduce, eliminate, and
prevent reoccurrence of the noncompliance.
The Director may waive the writtea report on a case -by -case basis if die oral report has been received
within 24 hotus.
10. Other No cons li
The pertittee shall report all instances of noncomplianca not reported under 24 hour reporting at the time
inorritoring reports are submitted.
11. other1grgmagon
Where the permittee becomes aware that it failed to submit any relevant facts in a Notice of lntcnt to be
covered under this individual Permit or in any report to the Director, it shall promptly submit such facts or
information.
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I_ MAY702--2011 ION 09; 32 AM- HEX I OVACME -FAX NO, 9106554749 P, 28
NCS000533
' PART rV LMTATIONS REOPENER
Tbii individual permit shall be modified or alternatively, revoked and reissued, to coaVly with any appticabla
e®scent guideline or water quality standard issued or approved under Sections 302(b) (2) (c), and (d), 304(b) (2) and
307(a) of the Clean Water Act, if die effluent guideline or water quality standard so issued or approved:
a. Contains different conditions or is otherwise more stringent than any effluent limitation in the individual
permit: or
b. Controls any pollutant not limited in the individual permit.
The individual permit as modified or raissved under this paragraph shall also contain any other requirements in the
Act then applicable.
PART V ADNU NI,STERrNG AND COMPLU NCE MONITORING FEE
RFQUMEMENTS
The permittee must pay the admiuistering and compliance monitoring fee within 30 (tbirty) days after being billed by
the Division. Failures to pay the fee in timely manner in accordance with 15A NCAC 213 .0105(b)(4) may cause this
Division to initiate action to revoke the individual Permit.
PART VI . DEFINITIONS
1. Act
See Clean Water Act.
2. Allowable Non -Stow water Dischtirce�
This permit regulates stotmwater discharges. Nan-stormwater discharges which shall be allowed in the
stormwater conveyance systmn are:
(a) All other discharges that are authorizedby a non-stormwater NPDES permit.
(b) Uncontaminated groundwater, foundation drains, air -conditioner condensate without added
chemicals, springs, discharges of uncontaminated potable water, waterline and fire hydrant
flushings, water from footing drains, 0nws from riparian habitats and wetlands.
(c) Discharges resulting from fire -fighting or fire -fighting training.
3. Rest Man Bement Practices BMPsI
Measures or practices used to reduce the amount of pollution entering surface waters. BMPs may take the
form of a process, activity. or physical structure. More information on BMPs can be found at:
htip://cfpub.epa.gov/npdea/stormwater/menuofbtnpsrindex, efin.
JRVPMR
A.bypass is dte known diversion ofstormwamr from any portion of a stormwater control facility including
the collection system; which is not a designed or established operating mode far the facility.
5. 13u1k Sto a of Li uid Products '
Liquid raw materials, manufactured products, waste materials or by-products with a single above ground
storage container having a capacity of greater than 650 gallons or with multiple above ground storage
conraiaers located in close proximity to each odder having a total combined storage capacity of greater than
i,320 Ballow,
Appendix A: Page 1 of 4

MAY-02-2011 MON 09:33 AM HEXiON/ACME
FAX NO. 9106554749 P. 29
Permit No. NCS0005'J3
6. Certificate of Cover d
The Certificate of Coverage (COL') is the cover sliect which accompanies the Individual Permit upon
issuance and lists the facility name, location, receiving stream, river basin, effective date of coverage under
the permit and is signed by the Director.
7. Cltsn Water Act
Tie Federal Water Pollution Control Act, also known as the Cleats Water Act (CWA), as awcaded, 33 USC
12S1, et seq.
S. D'viciou or DW
Ibe Division of Water Quality, Department of Env6nn=t and Natural Resources.
9 _Dimor
The Director of the Division of Water Quality, the permit issuing authority.
10. EMC
'free North Carolina Environmental Management Commission.
11- Grab arp1e
' An individual sample collected instaotancously. Grab samples that will be analyzed (quantitatively or
qualitatively) must be taken within the. first 30 minutes of discharge.
12. HHazardnus Substance
Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the Clean Water Act.
13. LaQdfill
' A disposal facility or part of a disposal facility where waste is placed in or on land and which is not a land
treatment facility, a surface impoundment, an injection well, a hazardous waste long-term storage facility or
a surface storage facility. .
' 14: M-IM&iP41 stowye Stom sewer'Sys
A stormwater collection system wide n an incorporated area of local self-government such as a city or town -
IS. -No [ixnogU
A condition of no tVosure means that all i,nduatrW materials and activities are protected by a storm
resistant shelter or acceptable storage Wntaintrs to prevent exposure to rain, snow, snowmelt, or runoff:
Industrial materials or activities include, but are not limited to, material handling equipment or activities,
' indutstrW machinery, raw materials, imenncdiate products, by-products, fwal products, or waste products.
DWQ may grant a No Exposure Exclusion from NPDES Stormwater Fermirting requirements only if a
facility complies with the terms and conditions described in 40 CFR § 122.26(p)
16.. Notice of Intent
The state application form which, when submitted to the Division, officially indicates the faciliv/s notice of
intent to seek coverage under an Individual Permit.
17. Penn'x
The owner or operator issued a certificate of coverage pursuant to this individual Permit.
Appendix A: Page 2 of 4 Pages

MAY-02-2011 MON 09,33 AM REH10N/ACME FAX NO. 8106554749 P. 30
Permit No. NCS000533
18. , Point§ourcc_Discharge ofStormwater
Any discanibla, coafined and discrete conveyance including, but not specifically limited to, any pipe, ditch,
channel, tunnel, conduit, well, or discrete fissure from which srormwater is or may be discharged to waters
of the state.
19. R•epresemativo Sent
A storm event that measares greater than 0.1 inches of rainfall. The time between this storm event and the previous
storm event measuring greater than 0.1 inches trust be at least 72 hours. A single storm event may have a period of
no precipitation of up to 10 hours. For example, if it rains but stops before ptnducing any collectable discharge, a
sample may be collected if the next rain producing a discharge begins within 10 hours.
20. •RepM%=tative Outfall Status
When it is established that the discharge of stormwater runoff from a single outfnll is repmsmtative of the
discharges at multiple outfails, the DWQ may grant representative outfdl status. Representative outwl.
status allows the permitme to perform analytical monitoring at a mdt=d number of outfalls.
21. SMQndary Contairw=t
Spill containment for rho contents of the single iergest tattle within the containment structure plus sufficient
freeboard to allow for the 2S-year, 24-hour storm everts
22. Section 313 Water Priority_Chemi_cai
A chemical or chemical category which:
a. 13 listed in 40 CFR 372.65 pursuant to Section 313 of Title III of the Superfund Amendments and
Reauthorization Act (SARA) of 1986, also titled the Emergency Planning and Community Right -
to -Know Act of 1986;
b. 1c present at or above threshold'levels at a facility subject to SARA title tll, Section 313 reporting
requirements; and
C. Meets at least one, of the following criteria:
(1) Is listed in appendix D of 40 CFR part 122 on Table 11(organic priority pollutants), Table
III (certain metals, cyanides, and phenols) or Table IV (certain toxic pollutants and
hazardous substances);
(2) Is listed as a hazardous substance pursuatt to section 311(b)(2)(A) of the CWA at 40
CFR 116.4; or
(3) Is a pollutant for which EPA has published acute. or chronic water quality, criteria.
23. Severe P 90mize
Means substantial physical damage to property, damage to the, control facilities which eatises them to
become inoperable, or substantial and permanent loss of natural resources which can reasonably be
expected to occur in the absence of a bypass. Severe property damage does not mean economic loss caused
by delays in production.
24. ignificant 1a4aterialc
Includes, but is not limited to: raw materials; fitels; materials such as solvents, detergents, and plastic
pellets; finished materials such as metallic products; raw rnatetiab used in food processing or production;
hazardous substances designated under section 101(14) of CERCLA; any chemical the facility is required to
report pursuant to section 313 of Title III of SARA, fertdizets; pesticides; and waste products such as ashes,
slag and sludge that bava the potetuial to be released with stormwst.er discharges.
25. Sinificant Spills
Includes, but is not limited to: releases of oil or hazardous substances in excess of reportable quantities
under section 311 of the Clean Water Act (Ref 40 CFR-110.10 and CFR 117.21) or section 102 of.
CERCi.A (Ref 40 CFR 302.4).
Appendix A: page 3 of Pages

MAC'-02-2011 MOIL 09: 33 AM ILEX I ON/ACME FAX NO. 9106564749
P. 31
I
Perstut No. NCS000533
1
26.
Stormwatcr 12ivIwrte Outfall 1SDO)
The point of departure of stormwater from a discernible, confined, or discrete conveyance, including but not
limited to, storm sewer pipes, drainage. ditches, channels, spillways, or channelized collection areas, from
1
which stormwater flows directly or indirectly into waters of the State of North Carolina.
27.
Stormwater Run i�ff
'
The flow orwarer which results from precipitation and which occurs immediately following rainfall or as a
result of snowmelt. .
23.
Srormwator AFsociated with fn_ oriel Activity
The discharge from any point source which is used for collecting and conveying stormwater and which is
directly related to manufacturing, processing or raw material storage areas at an industrial site. Facilities
considered to be engaged in "industrial activities" include those activities defined in 40 CFR 122.26(b)(14).
The term does not include discharges from facilities or activities excludod from the NPDES program.
29.
Stoimwater Pollution Prevo tin Plan
A comprehensive siwapeci$e plan which details measures and practices to seduce stornT=rer pollution and
is based on an evaluation of the pollution potential of the alum
30.
TLtral_MaxImum Daily Load. CLlv[DL
TMDLs are written plans for attaining and maintaining water quality standards, in all seasons, for a specific .
'
water body and pollutant. (A list of approved TMDLs for tho state of North Carolina can ba found at
littp:/th2o.crir.statc-ne.us/tmdl/)
31.
Tox g Pollutant
Any pollutant fisted as toxic under Section 307(a)(1) of the Clears Water Act.
32.
Vehicle Maintenance Activity
Vehicle rehabilitation, mechanical repairs, painting, fueling, lubrication, vehicle cleaning operations, or
'
airport deicing operations.
33.
Visible Sedimentatign
Solid particulate matter, both mineral and organic, that has been or is being transported by water, air,
gravity„ or icc from its site of origin which can be send with the unaided eye.
34.
25-Year. 24 hour Storm event
The tnaximurn 24-hour precipitation.event expected to be equaled or exceeded, on the average, once in 25
yam.
Appendix A Page 4 of 4 Pages

MAY-02-2011 MON 09:33 AM HEXION/ACME
FAX NO. 9106554749
P. 32
0
NCSoa0S33
APPENDIX_A: ACUTE TOXICITY TESTING FOR STORMWATER OUTFALLS
I ANNU4l TESTING (P_ASS/FAIL ACUTE TOXICITY TESTING
The permittee shall. conduct acute toxicity tests on a yearly basis using protocols defined in the North
Carolina Procedure Document entitled "Pass/Fail Methodology for Determining Acute Toxicity in a
Single Effluent Concentration" (Revised-July,1992 or subsequent versions). The monitoring shall be
performed as a `water flea" (Ceriodaphriia deebia) 49-hour static test.
Stormwater samples shall be collected as a single grab sample. Samples for self -monitoring purposes
must be obtained during, a representative storm event. The tests will be performed during the first sbc
months of the year (January -June).
If at any time there is significant mortality at a stormwater effluent concentration of IUD%. the results
will be considered as a benchmark exceedance. of toxicity.
All toxicity testing results required as part of this permit condition will be entered on the Stormwater
Discharge Monitoring Fornr (DMR) for the month in which it was performed, using the parameter code
TGA3B. One copy strap be submitted to Central Files, and one copy shall be submitted to the
Stormwater Permitting Unitas follows:
Attention: Central Files
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
' Attention: 'Storiiawater Permitting Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Additionally, DWQ Form AT-3 far Acute Pass/Fail Tests (original) is to be sent to the following
address:
Attention: NC DENR 1 DWQ 1 Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be sent and postmarked to the Environmental Sciences
Section, and Central Files no later than 30 days after the end of the month in which the test was
conducted.
Test data shall be complete and accurate and include all supporting chemical/physical measurements
performed in association with the toxicity tests, as well as all doseiresponse data. Total residual chlorine
of the stonnwater toxicity sample trust be measured and reported if chlorine is employed for disinfection
of the stormwater discharge.
If there is no stormwater discharge from the facility during the months which toxicity monitoring is
required, the permittee will complete the infonnation located at both the top of the aquatic toxicity (AT)
Appendix A.: Page t of 4

MAYY02-2011 MON 09:33.ASS HEXION/ACHE FAX NO. 9106554749
P. 33
1 Permit No. NCS000533
test form and DMR indicating the facility name,. permit number, stormwater outfall number, county, and
the month/year of the report with the notation of "No Flow" in tlic comment area of the form. The
permittee shall submit three (3) "no flow" reports: one report shall be submitted to the Environmental
Sciences Section, one to the Stormwater Permitting Unit (SPU) Central Office, and one report shall be
sent to Central Files ai the address cited above._ The permittee shall submit acute toxicity monilor,ng as
outlined above, at the next available representative storm event.
H. ACT -Toms Fog FAILME OF PASSIFAIL TESTING:
Should any single scheduled monitoring indicate a failure to meet toadeity benchmark levels, a
series of measuires shall occur:
1) Within 30 calendar days from availability of the test results, the permittee shall contact the
Division SPU Central Office and the Regional Office Supervisor in writf
a. If other stormwater monitoring parameters have exceeded benchmark values, the
Regional Office may exempt the permittee from additional acute toxicity monitoring
(other than regularly scheduled test periods), at the Regional Office 's discretion. The
ernuttee shall continue o address al I other stormwater parameter b nchmark
exceedances.
b. If the permittee his not exceeded other benchmark values, or if the Regional Office
does not exempt the permittee from additional monitoring, the permittee shall
immediately institute monthly acute toxicity monitoring with a 48-hour multiple dilution
test per U.S. EPA Method 2002.0: "Methods for Measuring the Acute Toxicity of
Effluents to Freshwater and Marine Orpnisms," EPA 621/R-02/012 (October 2002).
III ACTIONS IF MONTA'LYMONTORING IS INSTITUTED ULTIPLE-DILUTION
TF-STINGI:
If monthly acute toxicity monitoring is instituted per Section 11 above, the permittee shall perform
the tests per the following conditions:
.1) An LC50 greater than 100% shall to used as a benchmark passing endpoint; Stormwater
Permitting Unit (SPU) Central Office may determine alternative endpoints as "passing" on a
case -by -case basis, depending on the specific cheracteristics of the facility's stormwater
discharge. Multiple dilution tests will be run at 100%, 50%, 25%,12-5%, 6.25% and 0%
stormwater unless other test concentrations are determined appropriate by the Stormwater
Permitting Unit (SPU) Central Office_
2) Multiple Dilution Test Results shall be submitted on form AT-1 for Acute Multiple Dilution
Tests. The parameter code is TAA3B. The permittee shall:
a. Submit form AT-1 (original) to the DWQ Environmental Sciences Section.
b. Send a completed a Stormwater DMR form (original) with an attached form AT-1
(original) to DWQ Central Files.
c. Send a completed a Storaiwater bM - form (copy) with an attached form AT-1 (copy) to
the DWQ Stormwater Permitting Unit.
Appendix A. Page 2 of 4 Pages

1 _ _MAY-02.201 l MQ�I 09_34 AM HFX 1 ON/ACME FAX NO, 9106554749 P. 34
Permit No. NCS000533
3) The permittee shall perform monthly acute toxicity monitoring until one of the fnllowina
permit conditions is met:
n. THREE CONSECUTIVE MULTIPLF.-DILUTION TESTS PASS. No further tests
need to be performed until next regularly scheduled test period.
-OR-
b. EITHER OF THE FOLLOWING OCCURS:
i. A TOTAL OFLIV MULTIPLE -DILUTION TESTS FAIL
-OR-
ii. THREE_ CONSECUTIVE MULTIPLE-DILLMON TESTS FAIL.
If either of the above occurs, further actions are necessary. See iV.-below.
4) The permittee shall submit a summary of all test results for the tilultiple dilution test series
along with complete copies of the test reports as received from the laboratory to the Regional
Office Supervisor, to DWQ Central Files and to SPU. These shall he sent and postmarked within
30 calendar days of receipt of the last failed or passed multiple -dilution test (as described above
in III. 3)).
I1! ACTIONS FOR FAILURE OF MULTIPLE DILUTION MSTS(TRE, TRI or OTHER
MEASURES); -- -
If the perinittee fails either A TOTAL OF•FIYE multiple -dilution tests or THE TYMD
CONSECUFIVE,midriple-diludon test as described in Section III 3) b., the permittee shall execute
the following:
1) A toxicity reduction evaluation (TRE) shall be automatically instituted. Within 30 calendar days
from availability of the test results, the permittee shall contact the Division SPU Central Office
and the Regional Office Supervisor in writing.
a. The permittee shall submit one copy of a plan for conducting a THE to the DWQ SPU,
and one copy to the DWQ Environmental Sciences' Section. These copies shall be
submitted within 60 calendar days of the date of DWQ SPU's direction to perform the
TRE.
b. This plan must be approved by DWQ SPU before the THE is begun. A schedule for
completing the TRE. shall be established in the plan approval. A Toxicity Identification
Evaluation ('TIE) may be a component of the TRE.
c. Upon DWQ's approval, the THE schedule may be modified if toxicity is intermittent
during the THE investigations: A revised WET test schedule may be established by
DWQ for this period.
2) Additionally after the first year that THE results have been collected and submitted, depending
on results the Regional Office may (among options):
Require the permittee to install structural stormwater controls;
• Require the permittee to implement other stormwater control measures or Bmps;
• Require the permittee to collect and treat the discharge and/or eliminate the
discharge;
• Require that the permittee implement site modifications to qualify for the No
Exposure Exclusion; or
Appendix A: Page 3 of 4 Pages

MAY-02-2011 MON 09;34 AM HEXION/AGME
FAX NO: 9106554749
P. 35
Permit No. NCS000533
• Require that the permittdc perform up -stream and downstream biological assessment
in the receiving water.
V MEASURES APPLICABLE TO ALL TESTS:
All acute toxicity test results shall be submitted: in a concise summary at the end of the five year
permit term. One copy of this report shall be sent to the Regional Office Supervisor, one copy to the
SPU Central Office, and one copy to the DWQ Fnvironmcntal Sciences Section.
Should any test data from either these monitoring requirements or tests performed by the North Carolina
Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re-
opened and modified to include alternate monitoring requirements.
If the Permittee monitors any pollutant more frequently than required by this permit, the results of such
monitoring shall be included in the calculation & reporting of the data submitted on the DMR & all
Acute Toxicity Forms submitted.
NOTE: Failure to achieve test conditions as specified in the cited docurilent, such, as minimum control
organism survival and appropriate environmental controls, shall constitute an invalid test and will require
immediate follow-up testing to be completed no later than the last day.of the month following the month
of the initial monitoring.
Appendix A: Page 4 of 4 Pages

Compliance Inspection Report
Permit: NCS000533 Effective: 11/01/10 Expiration: 10/31/15 Owner: Sitar LLC
SOC: Effective: Expiration: Facility: Silar LLC - Riegelwood
County: Columbus 333 Neils Eddy Rd
Region: Wilmington
Riegelwood NC 28456
Contact Person: Peter Yurgel Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 01/24/2012 Entry Time: 01:00 PM
Primary Inspector: Linda Willis
Secondary Inspector(s):
Jean Conway
Reason for Inspection: Routine
Permit Inspection Type: Stonnwater Discharge, Individual
Facility Status: ■ Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Certification: Phone:
Exit Time: 05:00 PM
Phone: [phone]
Phone:
Inspection Type: Compliance Evaluation
Page: 1

Permit: NCS000533 Owner - Facility: Silar IiC
Inspection Date: 01/24=12 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Data review:
Silar is experiencing high concentrations of contaminants at several of the outfalls. Silar believes stormwater from the
Momentive and Oakbark facilities are contributory. Silar is responsible for Outfalls 001, 002, and 005. Quarterly
monitoring was conducted throughout 2011 for all 3 outfalls. Benchmark exceedances at 001 are as follows: NH3
(1 st&2nd Q), TKN (1 st&2nd 0), NO3+NO2 (1st&2nd 0), Copper (2nd,3rd&4th 0), and Zinc (2nd Q). Outfall 002
exceedances are: BOD (1,20 Q), COD (1,20 Q), NH3 (1st 0), TKN (1,20 Q), Formaldehyde (1,2&3 0), Copper (all 4),
Zinc (all 4). Outfall 005 exeeeances are: TSS (1st 0), BOD (1&2 Q), COD (1&2 0), NH3 (1st 0), TKN (2nd 0),
Formaldehyde (1 &2 0), Copper (all 4 0), Zinc (all 4 Q) and pH (2nd Q). It is possible that outfalls 002 and 005 can
receive runoff from Momentive site located upgradient A review of the raw materiaWproducts used/produced by Silar
does not include formaldehyde or hexamine. A large number of chemicals are used by Silar and some chemical
compositions include nitrogen bearing compounds. It is uncertain if any of the compounds utilized by Silar could
dissociate/decompose to form hexamine or formaldehyde. Tier 2 requirements have been triggered at each outfall,
t therefore monthly monitoring is required at all three. Four consecutive exceedances have occurred at Outfall 002 and
Outfall 005 and will require acute toxicity testing at these two outfalls. Should more recent data for Outfall 001 result in 4
consecutive exceedances of any benchmark, acute toxicity testing at that outfall will need to be implemented as well.
Please follow the instructions provided in Appendix A accordingly.
' SWP3 Review:
A feasibility study should be included in the SWP3, see the requirements of the SWP3 on page 2 of t 1 in Part 11 of your
1 permit. Employee training and facility inspections are being performed and documented in accordance with the
requirements of the permit. The SWP3 should be amended yearly and the amendments clearly documented. Please
ensure that all good housekeeping measures and BMPs that are implemented be documented.
Site Map: Please include the following information on the site map: latitude/longitude for each outfall (including the new
outfall discovered); structural divides in the drainage area such as curbs, drop stormwater inlets, pervious surfaces,
existing structural BMPs and swales; buildings, tanks, secondary containment structures, haul roads, process areas,
staging, storage or loading areas for chemical/waste/producthaw materials (with a key that indicates the specific/potential
contents of such); arrows that indicate drainage directions in each stormwater outfali drainage area; and property
' boundary lines. The accuracy of site elevations from ground survey rather than aerial survey would likely be more
precise.
Site Inspection:
' The condensate discharge from the compressor appears to support bio-growth. Permittee should consider testing the
condensate for COD. The condensate discharges via outfall 005.
The equipment in the area noted as "Silar 126" was leaking caustic but was contained. This equipment should be fixed
since rain events could contribute volumes in excess of the containment basin and cause an overflow to surface waters.
Please provide adequate maintenance for that equipment to resolve the leaks and clean up and dispose of the caustic
accordingly.
The inspector noted excessive and lush green grass growing in the vicinity of Stormwater Outfall 001 which also shows
very high nitrogen contamination. Please consider investigating any potential for groundwater contamination in this area
that may be breaking out near the surface. Groundwater contamination may be contributing to high levels of pollutants at
Outfall 001.
Page: 2

' Permit. NCS000533 owner - Facility: Silar 11C
Inspection Date: 01/24/2012 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Momentive off loads wastewater to the large storage tanks adjacent to Outfall 005. The pavement appeared to have
stains from leaks/spills. There is no containment provided at this location for the activity and any spill can be conveyed
directly to surface waters via Outfall 005. The offloading area should have secondary containment. Personnel should be
present during the entire off loading activity and each event should be documented.
There is a stormdrain drop inlet near the compressor room that had a build up of solids in it and appeared to have some
contaminants that were decomposing as evidenced by off gassing when disturbed. These stormwater drop inlets need to
be cleaned out regularly and the contents disposed of properly on a frequent basis to eliminate the build up of pollutants.
A clean out schedule for all drop catch basins should be included in the facility inspection/good housekeeping areas.
Stains from spilled wastes were noted on the concrete near the chemical disposal receptacles located adjacent to the fine
chemicals and Silar 026 buildings. There is containment provided for the storage receptacles, however better
housekeeping and careful disposal practices should be implemented. Include regular inspections for the secondary
containment receptacles.
Unrinsed drums are located within the hazardous waste storage secondary containment area. Many were tipped over
with bungs and lids not in place which can allow the contents to comingle with stormwater collected inside the
containment area. The drums should always have lids and bungs in place until the drums are able to be rinsed at the
rinsing station. Any spillage of listed waste comingled with stormwater becomes all wastewater and therefore cannot be
released from the containment area but disposed of properly in accordance with waste management regulations.
An outfall was located between the Sitar 126 and Fine Chemicals area that needs to be included in the SWP3 and
monitored in accordance with the NPDES permit requirements.
■ Concluding comments:
The NPDES permit requires actions be taken when sampling results exceed benchmarks. Tier 1 actions include a
thorough inspection of the facility within two weeks of receiving sampling results. Each area of the facility that can
e possibly contribute contamination to stormwater must be evaluated thoroughly to determine whether source controls,
operational controls, or physical improvements (structural controls) should be implemented to improve the quality of the
stormwater discharges. Whichever action is deemed adequate must be implemented within two months of the
' inspection. A record of who conducted the inspection and the selected actions must be clearly documented by the
permittee. Tier 2 requires that monthly monitoring be implemented if the results from three consecutive monitoring
periods are above the benchmarks. Tier 3 requires notification in writing to the Supervisor of DWQ Surface Water
Protection Section that stormwater exceeded benchmarks on four occasions. DWQ should then provide guidance such
' as requiring revised monitoring schedules on a more frequent or less frequent schedule, require the permittee to conduct
acute toxicity testing, require structural stormwater controls, require the permittee to implement other stormwater control
measures or require the permittee to implement site modifications to qualify for a no exposure exclusion.
' This facility has triggered tier 3 response and therefore DWQ is requiring toxicity testing at outfalls 002 and 005. DWQ is
recommending that Sitar evaluate the site for all potential sources and provide to this office in writing any improvements
whether structural or non structural that should help improve the characteristics of the run off from the site. It should
include a revised site map with all bulk tanks and chemical/raw material/product/waste storage areas numbered and
' provide a key that describes the chemicals used or stored in those areas. Your evaluation and proposed improvements
should also be incorporated into the SWP3 under a section entitled Tiered Responses. Various areas of concern have
been identified in this inspection report. Sitar personnel knows the site and the activities therein far better than DWQ
inspectors and can therefore provide the best recommendations for solutions to the stormwater problems. DWQ would
' like to provide Silar an opportunity to resolve their issues and identify the issues posed from the adjacent facilities
(Momentive and Oakbark) before exercising any of the other tier three actions at our disposal. Sitar is not compliant with
the requirement to monitor monthly, however, since Silar requested relief from monthly monitoring due to runoff from
' Oakbark and Momentive, DWQ will not deem the facility non compliant with that requirement for 2011, however, any
failure to follow the tiered requirements in the future will be addressed accordingly. A follow up inspection will be
conducted during the third quarter of this year.
' In October, 2011, you had proposed a subtraction of contaminant concentrations found at outfalls located on
Oakbark/Momentive site from the concentrations of contaminants found at your outtalls. DWQ does not believe there is
enough information to support this method for reporting purposes. You should continue to monitor and report the outfalls
in accordance with the data provided by the laboratory. DWQ will be receiving monitoring data from Oakbark and
' Momentive for their respective outfalls and therefore will have data that can be referenced.
Page: 3

' Permit: NCS000533 Owner -Facility: Sitar i1C
Inspection Date: 01/2412012 Inspection Type: Compliance Evaluation Reason for Visit: Routine
1
1
e
aPage: 4

' Permit: NCS000533
Inspection Date: 01/24/2012
Owner - Facility: Sitar LLC
Inspection Type: Compliance Evaluation
Stormwater Pollution Prevention Plan
Does the site have a Stormwater Pollution Prevention Plan?
# Does the Plan include a General Location (USGS) map?
# Does the Plan include a "Narrative Description of Practices"?
# Does the Plan include a detailed site map including outfall locations and drainage areas?
# Does the Plan include a list of significant spills occurring during the past 3 years?
# Has the facility evaluated feasible alternatives to current practices?
# Does the facility provide all necessary secondary containment?
# Does the Plan include a BMP summary?
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
# Does the facility provide and document Employee Training?
# Does the Plan include a list of Responsible Party(s)?
# Is the Plan reviewed and updated annually?
# Does the Plan include a Stormwater Facility Inspection Program?
Has the Stormwater Pollution Prevention Plan been implemented?
Comment:
Qualitative Monitoring
Has the facility conducted its Qualitative Monitoring semi-annually?
Comment:
Analytical Monitoring
Has the facility conducted its Analytical monitoring?
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
Comment:
Permit and Outt'alls
# Is a copy of the Permit and the Certificate of Coverage available at the site?
# Were all outfalls observed during the inspection?
# If the facility has representative outfall status, is it properly documented by the Division?
# Has the facility evaluated all illicit (non stormwater) discharges?
Reason for Visit: Routine
Yes No NA NE
Yes No NA NE
■ ❑ ❑ ❑
❑❑■❑
Yes No NA NE
Page: 5

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� I
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it
n
Permit: NCS000533 Owner - Facility: Silar LLC
Inspection Date. 01/24M12 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Comment: One outfall was located between the Silar 126 and Fine Chemicals areas
(noted by the reference as "drain pipe' on the Silar site map). This outfall will need to
be added to the site map, identified in the SWP3 and monitored in accordance with the
permit requirements.
Page: 6

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512 N Salisbury St, Raleigh, NC 27603 to 127 Cardinal Dr Exn, Wilmi... http://maps.google.com/maps?f=d&source=s d&saddr=512+North+Sa...
J
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807-C379
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1. Head southwest on N Salisbury St toward W Lane St
go 0.5 mi
About 2 mins
total 0.5 mi
2. Turn left at W Morgan St
go 0.2 mi
About 1 min
total 0.7 mi
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go 1.1 mi.
About 3 mins
total 1.9 mi
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go 0.7 mi
About 2 rains
total 2.6 mi
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go 122 mi
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go 1.0 mi
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0 127 Cardinal Dr Exn, Wilmington, NC 28403
These directions are for planning purposes only. You may find that construction projects, traffic, weather, or other events may cause
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1 of 1 10/13/2010 4:13 PM

Lowther, Brian
From:
John Shibley [e-mail]]
Sent:
Friday, September 24, 2010 2:51 PM
To:
Lowther, Brian
Cc:
'Peter R. Yurgel'
Subject:
RE: Draft Permit NCS000533
Attachments:
2000-10 Analytical Summary.As
Importance: High
Follow Up Flag: Follow up
Flag Status: Flagged
Dear Brian,
As a follow-up to Pete's original e-mail, I have attached a 10 year summary of the analytical data that we have obtained
concerning SW002 and SW005. I have highlighted the data where we would be in non-compliance if the draft permit
were to go into effect, which is quite significant. We have very serious concerns with respect to our permit and how we
may be potentially responsible for contamination that is beyond our control.
We would appreciate any guidance that you can provide. We look forward to hearing from you soon.
Best regards,
John L. Shibley, Ph.D.
President
Silar Laboratories
910-762-5800 x 125 (p)
910-409-3964 (c)
910-228-5033
[e-mail]
Please visit us at www. silar.com.
From: Peter R. Yurgel [mailto:[e-mail]]
Sent: Friday, September 17, 2010 11:38 AM
To: [e-mail]
Cc: John Shibley
Subject: Draft Permit NCS000533
Dear Brian,
I have been reviewing the draft stormwater permit and I have one concern. Most of the runoff to SW002 and some
to SW005 come from the Hexion facility. Silar LLC does not use Hexamine, Formaldehyde, Nitrates, Phosphates, Copper,
Zinc, Manganese, nor Lead in any of our processes. If these constituents are in the run off, they come from Hexion (and
Oak -Bark with respect to Cu, Zn, and Mn). If these items are at or above actionable levels, what recourse does Sitar have
to mitigate them if they are coming from the other companies? Please let me know your thoughts.
Thanks, and Best Regards,
Peter R. Yurgel
Plant Manager
Silar Laboratories
333 Neils Eddy Road

Riegelwood, NC 28456
ur el silar.com
910-655-6980 x5254
fax [phone]
No virus found in this incoming message.
Checked by AVG - www.avg.com
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Summary of Storm Event Monitoring
Wright Corporation NCS000156
10
6/1912002
0.14
0.008
7.80
42
170
70
38
45
1.2
0.009
2.6
55
11
1ll11/2002
0.95
0.056
9.01
20
55
63
4
4
0A
0.005
0.2
7
12
1/29/2003
0.16
0.010
7.97
23
126
14
10
16
1.0
<0.003
<5.0
21
13
5/22/2003
2.23
0.133
7,55
6
30
Il
4
4
2.2
<0.003
0.4
7
14
10/8/2003
1.93
0.115
8.35
18
42
18
4
7
3.8
<0.003
5.9
5
15
11YI912003
1.05
0.062
7.89
17
30
4
5
6
1.2
<0.003
0.9
5
16
2/11/2004
1.50
0.089
7.96
15
52
9
4
7
0.9
0.003
<5
l0
17
5/30/2004
0.91
0,054
8,87
21
151
7
13
13
0.9
0.006
<5
16
18
8/26/2004
0.63
0.037
8.96
37
276
134
15
19
0.6
0,008
8.9
35
19
11 /23/2004
0.57
0.034
10.30
218
963
92
207
241
2.2
0.004
28.0
411
20
2/3/2005
0.60
0.036
7.62
10
32
7
3
4
0.7
<0.003
2.8
4
21
4/7/2005
0,57
0,034
6.99
30
133
16
22 •
22
0.8
<0.003
17A
34
22
8/8/2005
0,61
0,036
7.17
65
156
31
3
3
1.1
0.006
1_2
0
23
12/15/2005
738
144
l63
<3
7
9
0.2
<0.003
32A
8
24
3/21/2006
0.48
0.029
7.71
86
447
114
41
46
1.1
0.011
12.8
46
25
4/3/2006
0.37
0.022
5.96
123
164
23
23
23
2.3
0.003
1.0
44
26
8/8/2006
1.10
0.065
6.58
52
122
38
15
20
0.6
0.005
0.1
2
27
11 / 16/2006
0.57
0.034
5.48
24
54
13
9
10
1.7
<0.003
3.3
4
28
2/l/2007
1.02
0.061
8.60
16
60
28
9
11
1.1
0.003
6.2
7
29
6/ 1212007
0.91
0.054
6.46
9
68
4
6
10
2.3
0.007
3.9
8
30
10/24/2007
0.39
0.023
55
123
21
10
13
1.2
0.006
2.3
9
31
4/23/2008
0.29
0.017
6.92
40
121
14
9
21
2.8
<0.002
2.8
<1
32
2/18/2009
0.33
0.009
6.73
113
391
95
6
61
1.5
0.009
4.8
46
33
5/11/2009
0.30
0.009
6.76
97
212
11
1 5
41
1.6
<0.002
5.0
2
34
9/29/2009
4.73
0.009
6.94
42
88
10
2
6
2.2
<0.01
2.3
<1
35
3/2/2010
0.55
0.009
8.51
83
157
15
l
6
0.6
<0.01
0.9
5
36
6/l/2010
0,57
0.009
T49
83
157
15
1
6
0.6
<0.01
0.9
5
Average
--
1 0.88
1 0.04
7.63
81
252
41
36
43
1.8
0.007
4.6 t
29

Summary of Storm Event Monitoring
Wright Corporation NCS000156
ANALYTICAL RESULTS FOR OUTFALL 002 - LAB WEIR
Monitoring
Period
Date
mo/dd/yr
Rainfall
(inches)
50050.000
Total
Flow
MC
00400
PH
S.U.
00310
BOD
MCA
00340
COD
mall
00530
TSS
mg11
00610
NH3
mgll
00625
TKN
Mgt]
00630
NO3+NO2
mg/I
01051
Total
Lead
mg11
71880
Formaldehyde
Mgll
Hexamine
Mali
Proposed
Levels
Record
6 to 9
30
120
100
7.2
20
10.0
0.030
0.5
25000
1
3/16/2000
0.77
0.036
7.80
44
143
33
247
24
2.0
0.006
0.2
1
2
9/18/2000
2.57
0.122
7.65
385
2,740
38
645
728
8.4
0.014
0.3
95
3
11114/2000
0.68
0,032
7.20
202
2,650
163
564
606
5.0
0.015
0.9
44
4
2/ 12/2001
0.96
0.041
8.00
69
556
61
122 1
132
2.4
0.010
0.4
7
5
5/20/2001
0.20
0.009 1
7.30
67 1
285
29
49
55
14.5
1 0.004
0.3
4
6
8/28/2001
1.30
0.062
7.40
111
506
178
71
80
1.9
0.019
0.8
9
7
1/14/2002
0.35
0.017
8.00
79
394
91
61
66
2.0
0.009
0.5
3
8
2/21/2002
0.15
0.007
7,20
415
2,045
50
470
522
3.1
<0.003
0.4
29
9
4/10/2002
0.29
0.014
7,30
234
923
186
178
212
2.8
0,014
9.9
355
10
6/19/2002
0.14
0.007
7,70
85
515
76
59
78
3.6
0,007
3.8
97
11
11/11/2002
0.95
0.045
8.76
32
114
109
14
14
1.7
0.007
0.4
37
12
1/29/2003
0,16
0.008
7.30
85
679
96
62
1 65
21.7
0.010
<25.0
132
13
5/22/2003
2.23
0.106
1 7.70
13
79
14
14
17
1.8
1 <0.003
1.0
29
14
10/8/2003
1.93
0.091
8.09
53
188
61
35
35
2.7
0.005
2.9
64
15
11/19/2003
1.05
0,050
7.97
21
51
20
8
16
1.7
<0.003
<5.0
64
16
2/11/2004
1.50
0.071
8.29
21
99
27
3
1 18
0.5
<0.003
0.7
30
17
5/30r2004
0.91
0.043
8.00
39
153
22
26
1 26
1 2.5
<0.003
<5
43
IS
8/26/2004
0.63
0.030
7.03
507
1,886
220
466
483
1.1
0.012
12.8
995
19
1IJ23/2004
0.57
0.027
7.48
281
2,070
119
503
538
4.3
0.011
56-0
I100
20
2/312005
0.60
0.028
8.40
20
97
24
22
27
2.6
0.003
11.0
30
21
4/7/2005
0.57
0.027
7.20
23
95
22
11
11
2.1
10.003
10.4
1
22
8/8/2005
0.61
0.029
7.31
39
158
43
10
28
2.4
0.004
19.0
48
23
12/15/2005
7.43
297
487
155
92
93
2.2
0.013
31.9
141
24
3/21/2006
1 0.48
0,023
T53
226
1 802
119
1 137
146
2.0
1 0.010
13.9
1 235
25
4/3/2006
0.37
0.018
6.35
1 274
1 563
91
1 36 1
66
r 3.9
1 0,007
IA
217

Summary of Storm Event Monitoring
Wright Corporation NCS000156
26
818/2006
L 10
0.052
1 7.07
82
183
48
20
27
1.1
0.004
0.1
3
27
11/16/2006
0.57
0.027
7.56
51
245
49
31
38
1.3
0.003
17.4
23
28
2/1/2007
1.02
0.048
7.44
102
261
93
46
48
1.8
0.005
13.2
25
29
6/1212007
0.91
Ob,13
6.31)
760
8,730
162
290
1,954
1.3
0.009
7.2
3750
30
10/24/2007
0.39
0.018
99
294
59
50
56
1.4
0.006
2.9
61
31
4/23/2008
0.29
0A14
7.97
99
327
37
36
74
1 2.6
0.003
8.7
1 <1
32
2/18/2009
0.33
0.016
6.87
322
1,899
141
16
438
1.5
0.005
42.8
577
33
5/11/2009
0.30
0.014
6.98
153
375
72
11
69
1.5
0.003
7.4
6
34
9/29/2009
4.73
0.224
6.86
215
816
36
8
165
2.4
<0.01
23.5
348
35
3/2/2010
0.55
0.026
7.18
198
1,620
1 51
7
1 476
1.4
1 0.038
1 57.8
1800
36
6/1/2010
0.57
0.027
7.19
203
492
111
7
56
1
L5
<0.01
11.8
38
Average
--
0.88
j 0.041
T48
164
931
81
123
208
3.2
1 0.009
11.3
1 298
ANALYTICAL RESULTS FOR OUTFALL005-SILANE WEIR
Monitoring
Period
(late
molddlyr
Rainfall
(inches)
50050.000
Total
Flow
MG
00400
pH
S.U.
00310
ROD
mWl
00340
COD
MWI
00530
TSS
mg/I
00610
NH3
mg/l
00625
TKN
mg/l
00630
NO3*NO2
MR/I
01051
Total
Lead
mg/I
71880
Formaldehyde
mg/l
Hexamine
mp11
Proposed
Levels
Record
�i;i
6 to 9
30
120
I00
7.2
20
10.0
0.030
0.5
25000
1
3/1612000
0.77
0.046
8.00
73
278
90
81
63
3.9
0.009
0.4
11
2
9/18/2000
2.57
0.153
7.60
l32
438
4
44
52
0.8
0.005
0.3
54
3
1 l! 14/2000
0.68
0.040
1 8.50
16
166
154
11
13
0.2
0,010
0.7
1
4
2/12/2001
0.86
0.051
7.70
20
146
20
28
31
0.6
0.004
0.2
2
5
5/20/2001
0.20
0.012
7.05
57
261
8
47
51
15A
0.003
0.2
5
6
8/28/2001
L30
0.077
7.40
94
466
146
63
71
0.8
0.025
0.9
9
7
4 1/1412002
0.35
0.021
1 7.90
30
168
32
26
29
1.8
<0.003
0.2
<5.0
8
2/21/2002
0.15
0.009
7.60
999
2,417
52
502
554
2.7
0.1305
0.5
43
9
4/ 10/2002
0.29
0,017
7.20
1 18
1 185
1 48
16
20
0.6
0.006
13
25

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ISO 9001:2000 Certified
SILAR LABORATORIES PHONE EXTENSIONS ACME PLANT
Main Number: 910-655-4212
Fax: [phone]
Rollover numbers: 910-655-(4401, 4901, 8025, 8108)
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100
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101
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103
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104
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106
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STORMWATER DISCHARGE OUTFALL (SDO)
MONITORING REPORT
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the
information submitted. Based on my inquiry of the person or persons who manage the system, or those persons
directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief,
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the possibility of fines and imprisonment for knowing violations."
rg
(Signature of Permittee) (Date)
S W U-248- 102107
Page 2 of 2

F70
I�la w
G
E! V
�
010
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i
G ,q-?! l '2 VlY r�/ Pf - Ur
,7V �f /�v is Zi"DSvdl o/ 921V
�1� d

-56'j, ?�CS000333
Sample
Date
Precipllatlo
n
{in{
TSS
BOD
COD
NH3
TKN
NO3 + NO2
Total P
Methanol
THC
Hexamine
Fonnalda
hyda
Total
Copper
Toot Z1nc
Total
Manganese
Total Lead
Non4Polar
OLG
pH
DO
Acute
Toxicity
100 mgll
30 mglL
120 n1WL
7.2 mg1L
20 rnWL
10 mglL
Benchmar
k:
2 mg1L
7,700
mglL
mg1L
25,000
mglL
Benchma
rk:
0.9 mglL
Benchmar
k:
0.007 mglL
Benchmar
k:
0.067mg1L
Benchmark:
N/A
Benchmark:
0.03 mg1L
Benchmark:
16 mg7L
Benchmark:
8.9 su
Benchmar
k:
malt
Outfall 001
1A2011
7.5
6
32
4
12.5
1,01
410
0,002
<10
0151
<0.01
<5
7.22
4/512011
247
16
66
6
14
3.8
139
104
410
0,004
<10
0359
QW
<5
7.08
75.20%
9202011
6
55
1.96
028
<10
0
<10
j101W001329
0072
<001
<5
6.73
23,1
6
53
24
3.3
074
<10
<7
0.061
<_01
<5
67411292011
NA
' Outfall 002: Lab Weir
1172011 57,3 49 8 3 1.65 0.35 <10 0 21,4 0258 N.01 e5 8.03
4152011 665 MEL99M 1.6 89 a 1.76 0.37 10.7 0.015 <10 0.75 0.176 <0.01 <5 7.47 > 100%
9202011 19 MR&91=1 1.7 6. 0.69 <0.04 <10 0.023 217 0.022 <0.01 <5 821
11292011
5.9 4
28
0.6
3,6
0.91
<,04
<10
<10
03
0.011
<.01
<5
7.19
NA
Outfall 005: Shane Weir
1172011
123
4
1
1
7,5
0.66
1.48
0.72
0,4
0.17
0.34
<10
<10
<10
0
0.003
0.025
<10M
<100.125
0.239
<0.012�5
7.27 12.37
415/2011
41.3
R
t17
66
1.9
03
9
1,8
0.011
<0.018.21
q_5g
709
42%
920201i
24.6
8
410
0.280.021
11292011
37
0.4
2
0.5
0.15
<10
<10
0
0.023
<0017.89
NA
Up the HIII
1172011
' 0
46.7
38
24
80
108
4 6
1
5
8 994
1.2
96.6
0
858MW0237--
<0.01
<5
7.86
4152011
0.58
26.7
0
52.85
0014
<5
7,07
37%
91202011
1.9
15.8
841
0.06
<10
0-005
<109
<104
<0.01
<5
7,43
7,03
11292011
1.1
6
0.05
<10
<0.01
<5
NA

Sample
Date
Preclpltatio
n
(InE
TSS
BOD
COD
NH3
TKN
NO3 +NO2
Total P
Methanol
TRC
Hexamins
Formalde
hyde
Total
Copper
ToUl Zinc
Total
Marlgarteas
Total Lead
Non -Polar
08G
pH
DO
Acute
Toxicity
100 mg0
30 mg1L
120 mg1L
7.2 mglL
20 mg1L
10 mg1L
Benchmar
k:
2 mglL
7,700
mglL
mg1L
26,000
mg1L
Banchma
rk:
0.6 mg1L
Benchmar
k:
0.007 mglL
Banchmar
k:
0.067mg1L
Benchmark:
NIA
Benchmark:
0,03 mgfL
Benchmark:
15 mglL
Benchmark:
0-0 su
Benchmar
k:
mglL
Outfall 001
117120ll
7.5
6
32
q
12.5
1.01
<10
0.002
<10
0.13
<0.01 0.037
0.151
<0.01
<5
7,22
4152011
247
16
66
13.9
1.04
c10
0.004
<10
0307
0.359
<0.01
<5
7.D8
75.20%
9R02011
31
6
55
1.4
3.8
1,96
0.28
<10
0
<10
D.206
0_Q62
O.D72
<(1.01
<5
6.73
11/292011
23.1
6
53
2.4
3,3
3.29
0.14
<10
<10
0,066
0.024
0.061
4.01
<5
6-74
NA
Otrtfali 002: Lab Weir
1A2011
57.3 4
86.5 120
99 1.6
1.65
0.35
<70
0
21.4
4 0.258
<(1.01
<5
8.03
4512011
89'6 1.76
0.37
10,7
0,016
<10
0.75
D.176
<0.01
<5
7.47
>100%
92W2011
11/2912011
19
59 4
9
28
1,7
06
177
0.89
0.91
<0.04
<10
0,023
217
<
_
0,022
11
<0.01
<5
821
<,04
c10
<01
<5
T 19
NA
Outfall 005: Silane Weir
1A12017
123
7,5
0.66
0_q
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0.239
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7.27 72.37
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9202011
41.3
24.6
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1.48
0.72
0.17
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0,125
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NA

�E Forest Products Division ® OMENTI
March 17, 201 1
Division of Water ,^qua ity.
Water Quality Section
ATTN: Central Files
1617 Mail Service Center
Raleigh, NC 27699-1617
RC: I St Quarter Discharge Monitoring Report 2011
i o Whoin it May Concern:
MAR 2 2 2011
Stol-mwater Pei•IniC4NC:SOOOl56 -va`��i'ssued to Momentive or-iOctober 22, 2010, The permit
requires Momentive to perfoi•ni quarterly analytical monitoring of stormwater discharges as
specified in Table- 1 of the permit. Sampling was performed on January 17, 2011 and the results
received on February 15, 201 1 . After review of the analytical results, it was determined that
several benchmarks established in Table 3 of the permit were exceeded. Please refer to the
enclosed discharge monitoring report for detailed information.
Per the requirements of the stormwater permit, exceeding any benchmark requires that a
stormwater management inspection be conducted within two weeks of receiving the analytical
data. The stormwater management inspection was conducted on February 25, 2011 and the
recommendations will be implemented within the next two months as required by the permit.
The recommendations and the benchmark exceedences will be added to the Stormwater Pollution
Prevention Plan per the requirements of the permit.
Momentive continues to strive to meet all environmental permit obligations.ui a timely fashioli. Ili`
You have any questions regarding this submittal,. Pleas contact April -!-Hanson at,910-1555-22b3,
extension 524$.
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Ronald Bazmet
Site Leader
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