NCS000373_HISTORICAL FILE_20200922

STORMWATER DIVISION CODING SHEET
NCS PERMITS
PERMIT NO.
j�l CSOOD3� 3
DOC TYPE
❑ FINAL PERMIT
❑ MONITORING REPORTS
❑ APPLICATION
❑ COMPLIANCE
w OTHER H l 5-roV-i CAI.. I ��l FoK rvtrkT� oN
DOC DATE
❑ 2D200922
YYYYMMDD

NC+�000183
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MCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Ween H. Sullins
Governor Director
STAFF REVIEW AND EVALUATION
NPDES Stormwater Permit
Dee Freeman
Secretary
Facility Name:
Radiator Specialty Company
NPDES Permit Number:
NCS000183
Facility Location:
600 Radiator Rd, Matthews, NC (Union County)
Type of Activity:
Chemicals and Chemical Preparations
SIC Code:
2899
Receiving Streams:
See Figure 1
River Basin:
Yadkin River Basin, Sub -basin 03-07-12
Stream Classification:;
C
Proposed Permit Requirements:
See attached draft permit.
Monitoring Data:
" See Table 1
Response Requested by (Date):
Central"Office Staff Contact:
Return to: Brian Lowther, [phone] - -
Special Issues:
� Issiiea
Ratin Scale: l ea's` to'10 hard `
Compliance history
5
Benchmark exceedance
5
Location (TMDL, T&E
species, etc
6
Other Challenges:
• Chemicals on site
5
llifticul Ratin
21/40
Description of Onsite Activities:
The current operations that transpire at RSC are the blending and packaging of automotive chemicals and wax
bowl rings, the manufacture of polyethylene and polyvinyl chloride tubing and the packaging of automotive hose
and plumbing parts.
Documents Reviewed:
• NPDES Stormwaler Permit Application Materials
• National Heritage Program (NEP) Threatened and. Endangered Species Database
• SPU File
Page 1 of 9

NCS000183 ,
• Central Files
• EPA Sector -Specific Permit, 2008
• 303(d) List, 2006 final
• 2008 Yadkin Pee -Dee Basinwide Plan
History:
• August 31, 1994: Date.permit first issued. Analytical monitoring included BOD5, COD, TSS, Oil & Grease,
I, 2 Dichloroethene, 1, I, 1 Trichloroethane. Sampling was done annually. Includes cut-off concentrations.
BOD5 <30 mg/I, COD < 120 mg/I, TSS < 100 mg/I, Oil & Grease <30 mg/I, 1, 2 Dichloroethene <0.099
mg/I, 1, 1, 1 Trichloroethane <0.042 mg/I.
• February 19, 1999: Renewal Reminder Letter sent.
• November 12, 1999: Date permit re -issued. Analytical monitoring included BOD5, COD, TSS, Oil &
Grease, 1, 2 Dichloroethene, 1, 1, 1 Trichloroethane. Sampling was done quarterly during the 4°i year.
• March 10, 2004: Renewal Reminder Letter sent.
• June 7, 2004: Date permittee submitted renewal application.
Page 2 of 9

NC-S000183
NCS000183
MOP Scale 1:24,000
Figure l: Map of Facility
Radiator Specialty Company
Radiator Specialty Co -Matthews
Lab bide: 350 03' 36" N
Longitide: 800 39' 12" W
County: L,nion
Recamng Stream: South Fork Crooked Creek
Stream dass: C-
Sub-basn: 03-07-12 (Yadkin River Bain)
Facility Location
Page 3 of 9

NCS000183
Central Office Review Summary:
1. Owner's Other Permits:
• AFS — 3717900201
• RCRA NCD091245969
2. General Observations:
• Outfall 001 — 76% impervious- Pollutants that may be present in stormwater discharge from Outfall
001 are Volatile Organic Compounds (VOC), Biochemcial Oxygen Demand (BOD), Chemical Oxygen
Demand (COD) and Total Suspended Solids (TSS). The source of the contamination may be from the tank
farm, where the drums are.stored, where trailers are stored and during transportation of dnnns to and from
the facility to the back parking lot and runoff from the roof of the facility.
4 Outfall 002 — 73% impervious- Pollutants that may be present are BOD, COD and TSS. The source of
the contamination may be runoff from the trailers, algae and debris in the retention pond or runoff from the
roof of the facility.
Outfall 003 — 56% impervious- Pollutants that may be present are VOC, Semi-VOC, BOD, COD, and
TSS. The contamination may be from the employee parking lot, runoff from the storage of trailers, the
storage of finished products outside, the.transportation of stock between buildings.7, 8, 9 and buildings 3, 4,
5, 6 and runoff from the roof of the facility.
• Outfall 604 — 13% impervious- Poll utants.that may be present are VOC, BOD, COD, and TSS. The
contamination may be from the tank farm and/or the boiler blowdown.
• Outfall 005 - 0% impervious- Pollutants that may be present are VOCs and Semi-VOCs from
pesticides. „
3. Impairment:. South Fork Crooked Creek 13-17-20-2a and 13-17-20-2b are on the 303(d) for impaired biological
integrity. Possible sources are from agriculture, construction and urban runoff/storm sewers. Basinwide Plan
recommendations are below:
1998 Recommendations
Stream flow in the upper Crooked Creek watershed is naturally very low in the summer months and smaller
tributaries often stop flowing completely. Problems with low dissolved oxygen associated with the Union
County W.WTP discharge were thought to be contributing to impairment at the time of the 1998 basin plan. In
1996, Union County relocated its W WTP discharge to Crooked Creek downstream and some improvement in
the stream was expected in the future as a result. DWQ recommended that no discharge containing an additional
loading of oxygen -consuming waste be permitted into South Fork Crooked Creek.
2002 Recommendations
As resources and stream condition allow, D.WQ will sample South Fork Crooked Creek to evaluate any
improvement following the relocation of the Union County W WTP discharge during the next basinw,ide
planning cycle.
4. Threatened and Endangered: Based on the Natural Heritage Virtual Workroom there were no federal or state
endangered or threatened species within two miles of the facility.
5. Location: C stream
6. Industrial Changes Since Previous Permit: The following changes were listed in the application:
Extruded Hose Division (Located in Building #8) was relocated in September 1998.
The Plumbing Division was moved from Building 98 to where it was relocated in June 1999 to Building 49 in
October 2000.
The manufacture of wax rings was relocated to Building #2 in April 2002.
The manufacture of polyvinyl chloride traffic safety cones which was initiated in Building #8 in October of 2060
has permanently ceased operation. The traffic safety cone operation permanently ceased operation in August
Page 4 of 9

NCS000183
2003. All the equipment used in the manufacture of PVC traffic safety cones. was sold and shipped off -site in
March 2004.
The current operations that transpire at RSC are the blending and packaging of automotive chemicals and wax
bowl rings, the manufacture of polyethylene and polyvinyl chloride tubing and the packaging of automotive hose
and plumbing parts.
No changes have taken place in how RSC handles materials, stores materials or utilizes materials. However, the
quantity of materials moving through the facility has increased.
Analytical Monitoring Notes: Analytical monitoring was required for BOD5, COD, TSS, Oil & Grease, 1,2-
Dichloroethene, l,l,l-Trichloroethane during the 4°i year of the previous permit. The permit submitted samples
for 4 outfalls. The second quarter data was not provided because of excessive rain impeded RSC's ability to
collect representative'stormwater samples during a qualify event. A couple COD and TSS values were over the
current benchmarks for 003 and 004.
The parameters BOD, COD, TSS and Oil & Grease have been maintained in the permit because of values over
the current benchmarks and they are potential pollutants for this site. Total Petroleum Hydrocarbons (TPH) has
been added to the permit because this site has a large volume and many types of petroleum hydrocarbons.
There are no values for 1,2-Dichloroethene or 1,1,1-Trichloroethane over the benchmarks provided by Nikki
Remington on 04/02/09 (1,2-Dichloroethene: 70 rug/L and 1,1,1-Trichloroethane: 25 mg/L). Neither of these
chemicals appears to be very acutely toxic to aquatic life. Since the values were low and the neither chemical
appears to be very acutely toxic the parameters have been taken out of the renewal permit.
The industries for SIC code 2899 are covered in the EPA Multi -Sector General Permit in Sector C but there are
not parameters recommended for monitoring.
8. Qualitative Monitoring Notes: Visual monitoring was done five times at each outfalls from July 2000 to
September 2003. Outfal1 001 showed no signs of pollution. Outfal1 002 had one cloudy and poor clarity
sample. Outfall 003 had a few samples that were brown, cloudy and murky. Outfall 004 had a couple samples
that were yellow or murky. Oil and solvent odor.observed at Outfall 004.
Page 5 of 9

NCS000183
.Table 1: Analytical Monitoring - - -- - - - - -
Sample
Date
Total
Flow
(MGD)
Precipitation
(in)
Duration
(hours)
BOD
COD
TSS
Oil&Grease
1,2-Dichloroethene
1,1,1-Trichloroethane
Benchmark:
30 mg/L
Benchmark:
120 mg/L
Benchmark:
100 mg/L
Benchmark:
30 mg/L
Benchmark:
70 mg/L
Benchmark:
25 mg/L
Outfall 1
2/26/2003
0.0172
0.4
5
3
<50
62
<5
0.044
- 0.018
NA
8/14/2003
0.2498
2.9
1
4.5
<50
7
<5
<0.005
<0.005
9/4/2003
0.0301
0.35
0.5
6.2
<50
4
<5
<0.005
<0.005
Outfa H 2
NA
NA
8/14/2003
0.6876
2.9
1
2.4
<50
16
<5
<0.005
<0.005
10/8/2003
0.2134
0.9
6
16
66
94
5
<0.005
<0.005
Outfall 3
2/14/2003
0.0203
0.1
0.5
14
t j
„a...1:10:,
<5
<0.005
<0.005
NA
7/29/2003
0.0305
0.15
0.1667
18
84
51
<5
<0.005
<0.005
9/4/2003
0.0712
0.35
0.5
6.3
<50
18
<5
<0.005
<0.005
Outfall 4
2/26/2003
0.0017
0.4
5
5.1
250
3,80"'=-'+-
9
<0.005
<0.005
NA
8/14/2003
0.0478
2.9
1
9.3
<50
47
<5
0.017
0.0067
11 /19/2003
0.0099
0.6
4.92
5.2
50
60
<5
0.36
<0.005
f i Over Current Benchmark
A Data Not Collected
Page 6 of 9

NC S000183
Revised Permit Recommendations: Analytical Monitoring:
1. Maintaining monitoring for BOD, COD, TSS and O&G. Add monitoring for TPI-1. These are potential
pollutants based on sources on site. Removing monitoring for 1,2-Dichloroethene and 1,1,1-Trichloroethane.
2. pl-1 has been added to the analytical monitoring requirements.
3. All analytical monitoring has been set to semi-annually during a representative storm event as defined in Part 11
Section B. The permittee must also document the total precipitation for each event:- 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 six-month sampling period. Additionally, samples must be taken a minimum of 60 days apart,
as specified in Table 2.
4. Benchmarks for analytical monitoring have been added to this draft permit. Exceedances of benchmark values
require the permittee to increase monitoring, increase management actions, increase record keeping, and/or
install stornnvater Best Management Practices (BMPs) in a tiered program. If the sampling results are above a
benchmark value, or outside of the benchmark range, for any parameter at any outfall then the facility shall
follow the Tier 1 guidelines which require a facility inspection within two weeks and implementation of a
mitigation plan within two months. If during the term of this permit, the sampling results are above the
benchmark values, or outside of the benchmark range, for any specific parameter at a specific discharge outfall
two times in a row (consecutive), then the facility shall follow the Tier 2 guidelines which require a repetition of
the steps listed for Tier 1 and also immediately institute monthly monitoring for all parameters at every outfall
where a sampling result exceeded the benchmark value for two consecutive samples.. .
5. The permittee is required to collect all of the analytical and qualitative monitoring samples during representative
storm events as defined :in Part It Section B. Qualitative monitoring is required regardless of representative
outfall status.
6. The permittee is responsible for all monitoring until the renewal permit is issued. See Footnote 1 of Tables 1, 4,
and 5.
7. The Flow reporting requirementhas been removed per DWQ revised strategy. (The total rainfall parameter is in
this permit, however.)
8. Vehicle maintenance monitoring has been revised to semi-annually in order to coincide with analytical and -
qualitative monitoring.
Other Proposed Changes to the Previous Permit:
1. Additional guidance.is provided about the Site Plain requirements. The site map must now identify if the
receiving stream is impaired and if it has a TMDL established. It must also describe potential pollutants in each
outfall. ,The map requirements are stated more explicitly. And, the site plan must contain a list of significant
'spills that have occurred in the past three years and also must certify that the outfalls have been inspected to
ensure that they do not contain non-stormwater discharges. Additional information is provided in Part 11 Section
A.
2. Additional requirements for the Stormwater Management Plan have been specified in Part 11 Section A. More
details regarding secondary containment are provided.
3. Additional requirements for the Stormwater Pollution Prevention Plan have been specified in Part 11 Section A.
"file plan must also be updated annually to include a list of significant spills and to certify that the outfalls do not
contain non-stormwater discharges.
4. "file facility must now implement a semi-annual Facility Inspection Program of the site's stormwater
management controls as specified in Pail 11 Section A.
5. 'Information regarding the No Exposure Exclusion has been added to this draft 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. Additional information
is provided in Part I Section A.
Page 7 of 9

NCS000183
Discussions with permittee: Stuart Kerkhoff, [phone], 3/20/09
1. Describe the industrial activities onsite. Blend and package automotive chemicals.
2. Any change since the application was filed? Additional secondary containment.
3. Do you use 1,2-Dichloroethene and. 1,1,1-Trichloroethane7 I -low much and where? They are constitutes on
sore of the chemicals onsite but not in pure form.
4. What materials are stored outside? Will send an email with list of chemicals. All the outside storage tanks are
located in secondary containment structures. So, there is no stormwate• runofffrom the tanks that enters any
stormrvater outfall. In addition, should a tank have a release, it is contained in the containment system and
does not enter the environment.
S. The analytical monitoring for outfall 3 and 4 show values over our current benchmarks for COD and TSS on
2/14/2003 and 2/26/2003. Any reason for this? Outfall 003 has a lot oftrafc on the roads in that area. Not
sure why values are so high.
6. Why are outfall 005 not sampled? No industrial activities? Small drainage a.rea that does include a road so it will
need to be monitored in the fiture.
Page 8 of 9

NC-S000183
Recommendations: Based on the documents reviewed, the application information submitted on June 7, 2004
sufficient to issue an Individual Stormwater Permit.
Prepared by (Signature) ^ G' G Date o S4"fnj
Stormwater Permitting Unit Supervisor Date S� r� G
for Bradley Bennett
Concurrence by Regional Office Date
RO Water Quality Supervisor Date
Page 9 of 9

4
o�®
NC®ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor
Mr. Stuart Kerkhoff
Radiator Specialty Company
PO Box 159
Indian Trail, NC 28079
Dear Mr. Kerkhoff:
Director
March 6, 2009
Dee Freeman
Secretary
Subject: NPDES Permit Renewal Application
Radiator Specialty Co - Matthews
Permit Number NCS000183
Individual Stormwater Permit
Union County
The Division of Water Quality's Stormwater Permitting Unit (SPU) acknowledges receipt of
your renewal application for coverage under NPDES Permit Number NCS000183 on June 7, 2004. We
apologize for the lengthy delay in responding to your submittal and are now making every effort to
review your permit renewal as expeditiously as possible. Our Unit anticipates making significant
progress on individual permits over the next six months to reduce our backlog.
We are currently beginning our review of your renewal application. Please continue to comply
with all conditions and monitoring requirements in your expired NPDES stormwater permit. As
long as you have submitted a complete renewal request package and maintain compliance with those
permit conditions, stormwater discharges from this facility are authorized by that permit until the
Division issues a renewal permit or notifies you of an alternative action.
No additional information is required at this time, but we may contact you in the future. Please
notify us if any significant changes have taken place at this facility since you submitted the renewal
package. If you have any questions about this matter, please contact me at [phone],
[e-mail].
Sincerely,
Brian Lowther
Environmental Engineer
Stormwater Permitting Unit
cc: Mooresville Regional Office
Stormwater Permitting Unit Files
Central Files
Wetlands and Stormwater Branch
One
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
NorthCarolina
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX [phone] Customer Service: 1-877-623-6748
q//
Naturally
Internet: www.ncwalemuality.org
Y ;/
An Equal Opportunity 1 Affirmative Action Employer

C®ENR
North Carolina Department of Environment and
Division of Water Quality
Beverly Eaves Perdue
Governor
Mr. Stuart Kerkhoff
Radiator Specialty Company
PO Box 159
Indian Trail, NC 28079
Dear Mr. Kerkhoff:
Coleen H. Sullins
Director
June 2, 2009
Natural Resources
Subject: Draft NPDES Stormwater Permit
Permit No. NCS000183
Radiator Specialty Co -Matthews
Union County
Dee Freeman
Secretary
Enclosed with this letter is a copy of the draft stormwater permit for your facility. Please review the draft
very carefully to ensure thorough understanding of the conditions and requirements it contains.
The draft permit contains the following significant changes from this facility's current permit:
Analytical monitoringchanges:
hanges:
1. Analytical monitoring parameters, BOD, COD, TSS and O&G, have been maintained in this permit. TPH
has been added to the permit while 1,2-Dichloroethene and 1,1,1-Trichloroethane have been removed.
2. pH has been added to the analytical monitoring requirements.
3. All analytical monitoring has been set to semi-annually during a representative storm event as defined in
Part II Section B. The permittee must also document the total precipitation for each event. 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 six-month sampling period. Additionally, samples must be taken a
minimum of 60 days apart, as specified in Table 2.
4. Benchmarks for. analytical monitoring have been added to this draft permit. Exceedances 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. If the
sampling results are above a benchmark value, or outside of the benchmark range, for any parameter at
any outfall then the facility shall follow the Tier 1 guidelines which require a facility inspection within
two weeks and implementation of a mitigation plan within two months. If during the term of this permit,
the sampling results are above the benchmark values, or outside of the benchmark range, for any specific
parameter at a specific discharge outfall two times in a row (consecutive), then the facility shall follow the
Tier 2 guidelines which require a repetition of the steps listed for Tier 1 and also immediately institute
monthly monitoring for all parameters at every outfall where a sampling result exceeded the benchmark
value for two consecutive samples.
5. You are required to collect all of the analytical and qualitative monitoring samples during representative
storm events as defined in Part 11 Section B. Qualitative monitoring is required regardless of
representative outfall status. '
6. You are responsible for all monitoring until the renewal permit is issued. See Footnote 1 of Tables 1, 4,
and 5.
Wetlands and Stomrwater Branch One 1, 7
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Nor thCarolina.
Location: 512 N. Salisbury St Raleigh, North Carolina 27604 //
Phone: [phone] FAX: [phone] Customer Service: 1-871823-6748 �atul''a!L /,/
Intennet: vomv.ncvvaterquality.org
An Equal Opportunity l Affirmative Action Employer

Mr. Stuart Kerkhoff
Radiator Specialty Company
Permit No. NCS000183
7. The flow reporting requirement has been removed per DWQ revised strategy. (The total rainfall
parameter is in this permit, however.)
8. Vehicle maintenance monitoring has been revised to senni-annually in order to coincide with analytical
and qualitative monitoring. This requirement appears in all Individual Stormwater permits, however it
only applies to facilities that do vehicle maintenance. If the facility begins vehicle maintenance during the
permitted timeframe then the requirements shall apply.
Other permit changes:
1. Additional guidance is provided about the Site Plan requirements. The site map must now identify if the
receiving stream is impaired and if it has a TMDL established. It must also describe potential pollutants
in each outfall. The map requirements are stated more explicitly. And, the site plan must contain a list of
significant spills that have occurred in the past three years and also must certify that the outfalls have
been inspected to ensure that they do not contain non-stormwater. discharges. Additional information is
provided in Part II Section A.
2. Additional requirements for the Stormwater Management Plan have been specified in Part II Section A.
More details regarding secondary containment are provided.
3. Additional requirements for the Stormwater Pollution Prevention Plan have been specified in Part II
Section A. The plan must also be updated annually to include a list of significant spills and to certify that
the outfalls do not contain non-stormwater discharges.
4. The facility must now implement a semi-annual Facility Inspection Program of the site's stormwater
management controls as specified in Part II Section A.
5. Information regarding the No Exposure Exclusion has been added to this draft 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. Additional information is provided in Part I Section A.
Please submit any comments to me no later than thirty (30) days following your receipt of the draft.
Comments should be sent to the address listed at the bottom of this page. If no adverse comments are
received from the public or from you, this permit will likely be issued in about two months.
If you have any questions or comments concerning this draft permit, contact me at [phone] or
[e-mail].
Sincerely,
// /
Brian Lowther
Environmental Engineer
Stormwater Permitting Unit
cc: Mooresville Regional Office
Stormwater Permitting Unit
Attachments: Draft Permit

Re: Couple Benchmark questions
Subject: Re: Couple Benchmark questions
From: Nikki Remington <Nikki. Remington@NCMai l.net>
Date: Thu, 02 Apr 2009 16:40:58 -0400
To: Brian Lowther <[e-mail]>
CC: Connie Brower <[e-mail]>, Sandra Moore <[e-mail]>
Hi Brian,
The benchmarks for the two chemicals that you requested are as follows..
1,2- Dichloroethene (CAS # 540-59-0): 70 mg/L Limited Data
1,1,1-Trichloroethane (CAS # 71-55-6): 25 mg/L
As you can see, neither of these chemicals appear to be very acutely toxic to aquatic life. As far as
phenol is concerned, the driver for this chemical is organoleptic effects. We would expect to confront
odor issues long before we would see any toxic impacts. The organoleptic criteria is 300 ug/L, per the
EPA's National Recommended Water Quality Criteria. This would be the screening level that I would
recommend, however keep in mind that it is not a toxic endpoint.
Nikki
Brian Lowther wrote:
Nikki,
1 am working on a permit that included analytical monitoring for 1,2-Dichloroethene and
1,1,1-Trichloroethane. The permittee said the parameters are constitutes on some of the chemicals
on site. Do you think these are parameters of concern and what would the benchmarks be for them?
Also, I have another permit with phenol. Our benchmark document only has a Trout benchmark
and it states the non -trout phenol value was removed because it was based on only one value. If I
need a benchmark for phenol should I use the trout one then?
Thanks for the help,
Brian
Nikki Remington
Environmental Senior Specialist
NC Department of Environment and Natural Resources
Division of Water Quality -Classification and Standards Unit
1617 Mail Service Center
Raleigh NC 27699
[phone]
E-mail correspondence to and from this address may be subject to the
North Carolina Public Records Law and may be disclosed to third parties.
of 1 1 4/3/2009 10:06 AM

&TROAA
MCENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
DATE: June 3, 2009
TO: Enquirer -Journal
EMAIL: [e-mail]
FROM: SARAH YOUNG, DIVISION OF WATER QUALITY
SUBJECT: PUBLIC NOTICE
PAGES: 1
Please publish only the information (Public Notice) below, ONE TIME in the legal section of your paper by
Tuesday, June 9, 2009. Please fax a copy of the proof to me at [phone] for final approval prior to
publication. Within 10 days after publish date, please send the invoice and two copies of the original affidavit
to:
Sarah Young
NCDENR/DWQ Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
NC DIVISION OF WATER QUALITY INTENT TO ISSUE A STORMWATER DISCHARGE PERMIT
Public comment or objection to the draft permit is invited. Submit written comments to DWQ at the address below.
All comments received prior to July 9, 2009 will be considered in the final determination regarding permit issuance
and permit provisions.
Application: Radiator Specialty Company, PO Box 34689 Charlotte, NC 28234 has applied for an NPDES permit to
discharge stormwater from an industrial facility at: Radiator Specialty Co -Matthew, 600 Radiator Rd. Indian Trail, NC,
Union County. The facility discharges to South Fork Crooked Creek and unnamed tributary to Price Mill Creek.
Copies of the draft permit, No. NCS000183,.are available at: http://h2o.enr.state.nc.us/su/publicnotice.htm
Additional permit documents are available for the reproduction cost at:
DWQ Stormwater Permitting Unit
512 N. Salisbury Street (location, zip 27604)
1617 Mail Service Center (mail)
Raleigh, NC 27699-1617
DWQ Contact: Brian Lowther
(919)-807-6368
[e-mail]
Wetlands and Stormwater Branch
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Ralegh, North Carolina 27604
Phone: [phone] FAX: [phone] \ Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
An Equal Opportunity 1 Arfim zOve Acbon Employer
NorthCarohna
Naturally

NC DIVISION OF WATER
QUALITY INTENT TO
ISSUE A STORMWATER
DISCHARGE PERMIT
Public comment or objec
tion to the draft permit is in
vited, Submit written corn
meets to DWQ at the ad
.dress below. All comments
received prior to July 9,
2009 will be considered in
the final determination Fe
garding permit issuance
and permit provisions.
Application: Radiator Spe
cialty Company, PO Box
34689 Charlotte, NC 28234
has applied for an NPDES
permit to discharge storm
water from an industrial fa
cility at: Radiator Specialty
Co -Matthew, 600 Radiator
Rd. Indian Trail, NC, Union
County. The facility dis
charges to South Fork
Crooked Creek and un
named tributary to Price
Mill Creek.
Copies of the draft permit,
No. NCS000183, are avail
able at:
http://h2o.enr.state.nc.us/s
u/publicnotice.htm. Addi
tional permit documents
are available for the repro
duction cost at:
DWQ Stormwater
Permitting Unit
512 N. Salisbury Street
(location, zip 27604)
1617 Mail Service Center
mail)
sleigh, NC 27699-1617
DWQ Contact:
Brian Lowther
(919)-807-6368
[e-mail]
June 7; 2009
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char nluaknown e:ia' - of a newspaper own as The Enquirer -Journal, Published, issued, and
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aarspea�ia entered as second class mail in the City of Monroe in said County and
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SUeet'„. .N of Section 1-597. of the General' Statutes of North Carolina and was a
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`This .. 7 day of ...f/,t.N4l/, , , , 2009
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RADIATOR SPECIALTY COMPANY
INDIAN TRAIL, NORTH CAROLINA
TANK FARM TANK CAPACITIES
AND CONTENTS
TANKID CONTENTS
CAPACITY (GALS)
FA37
Naphthenic Oil
30,000
FA38
Mineral Spirits
30,000
FA39
Power Steering Fluid
30,000
FA40
Process Water
6,000
FA41
Process Water
6,000
FA42
Air Stripper Holding Tank
6,000
FA43
Fuel Injector and Carburetor Cleaner
6,000
FA44
Gas Treatment
6,000
FA45
Aromatic 100 Fluid
8,000
FA46
Low Odor Base Solvent
15,000
FA47
Mineral Seal Oil
8,000
FA48
Glycol ether EB
30,000
FA49
Empty
4,300
FB02
Perchloroethylene Reclaim
20,000
FB04
DOT 4 Brake Fluid
30,000
171305
Heavy Duty Silicone Spray Lubricant
15,000
FB06
Engine Brite Heavy Duty Engine Degreaser
30,000
FB07
DOT 3 Brake Fluid
30,000
FBO8
Empty
10,000
FB09
Powerzol9541
8,000
FB10
DOT 3 Brake Fluid
30,000
FBI I
Boiler Diesel Fuel
30,000
FB12
Empty
5,800
FB13
Carb-Medic
20,000
F1314
Petrolatum TB #8 (Wax)
30,000
FB15
Perchloroethylene
35,000
FDO1
Diesel Fuel — Boiler Fuel
10,000
S ECU RITY\OUTS IDESTORAGE. DOC REVISED 03/31/09

RADIATOR SPECIALTY COMPANY.
INDIAN TRAIL, NORTH CAROLINA
TANK FARM TANK CAPACITIES
AND CONTENTS
TANK ID CONTENTS CAPACITY(GALS)
FA01
Motor Flush
15,000
FA02
ATF Mercon/Dexron III
5,000
FA03
Soybean Oil
6,000
FA05
Hydro Seal 11
20,000
FA06
Super Concentrated Degreaser
7,500
FA07
Empty
15,000
FA08
Empty
6,000
FA09
Coolant System Optimizer
6,000
FA10
Carburetor and Parts Cleaner
7,500
FAII
Empty
10,000
FA12
Empty
3,000
FA 13
Empty
6,000
FAN
Liquid Wrench Multi -Use Lubricating Oil
7,500
FA15
Aromatic 150 Fluid
15,000
FA16
Empty
3,000
FA17
Empty
6,000
FA18
Empty
6,000
FA19
Diesel Fuel
30,000
FA20
Valve Medic
7,500
FA21
Octane Performance Booster
6,000
FA22
Tar & Bug Remover (Low VOC)
7,500
FA23
Kerosene
30,000
FA24
Transfusion Automatic Transmission
6,000
Fluid & Sealer
FA25
Empty
6,000
FA26
Transeal Automatic Transmission
8,000
Conditioner & Sealer
FA27
Liquid Wrench Penetrating Oil
6,000
FA28
Liquid Wrench Penetrating Oil
6,000
FA29
Empty
5,500
FA30
Empty
18,282
FA31
Empty
6,565
FA32
Refrigerant Gas
18,282 lbs.
FA33
Empty
6,000
FA34
Refrigerant Gas
18,282 lbs.
FA35
Carbon Dioxide
50,000 lbs.
FA36
Corsol35
30,000

RE: Outside Storage
-
Subject: RE: Outside Storage
From: "Stuart Kerkhoff' <[e-mail]>
Date: Tue, 31 Mar 2009 16:34:31 -0400
To: <brian. [e-mail]>
Brian,
I'm not sure we discussed it or not. All the outside storage tanks are located in
secondary containment structures. So, there is no stormwater runoff from the tanks
that enters any stormwater outfall. In addition, should a tank have a release, it is
contained in the containment system and does not enter the environment.
Thanks. Call me with any questions.
Stuart Kerkhoff
-----Original Message -----
From: Stuart Kerkhoff
Sent: Tuesday, March 31, 2009 10:49 AM
To: '[e-mail]'
Subject: Outside Storage
Brian,
Attached please find a list of the outside storage tanks located at Radiator
Specialty Company as discussed in our March 18 telephone conversation. After you
review the list, please feel free to call or email me with any comments or
questions.
Thanks.
<< File: OUTSIDESTORAGE.doc >>
Please send me a response to let me know you received this email. Thanks.
Stuart Kerkhoff
Environmental Manager
Radiator Specialty Company
Phone [phone]
Fax [phone]
[e-mail]
1 of 1 4/3/2009 9:50 AM

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Alan W. Klimek, P.E., Director
RADIATOR SPECIALTY CO-MATTHEWS
ATPN:STUART
PO BOX 159
INDIAN TRAIL,
Dear Permince:
March 10, 2004
KERKHOFF, OR SUCCESSOR
NC 28079
1�
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: NPDES Stormwater Permit Renewal
Radiator Specialty Co -Matthews
Permit Number NCS000183
Union County
Your facility is currently covered for Stormwater discharge under NPDES Permit NCS000183. This permit expires
on November 30, 2004. North Carolina Administrative Code (15A NCAC 2H.0105(e)) requires that an
application for permit renewal be riled at least 180 days prior to expiration of the current permit. In order to assure
your continued coverage under your permit, you must apply to the Division of Water Quality (DWQ) for renewal
of your permit. To make this renewal process easier, we are informing you in advance that your permit will be
expiring. Enclosed you will find an individual permit renewal application form, supplemental information request,
and Stormwater Pollution Prevention Plan certification.
Filing the application form along with the requested supplemental information will constitute your application for
renewal of your permit. As stated above, the application form must be completed and returned along with all
requested information by June 3, 2004 in order for the permit to be renewed by November 30. 2004.
Failure to request renewal by June 3, 2004 may result in a civil assessment of at least $500.00. Larger penalties
may be assessed depending on the delinquency of the request. Discharge of Stormwater from your facility without
coverage under a valid stormwater NPDES permit would constitute a violation of NCGS 143-215.1 and could
result in assessments of civil penahies of up to $25,000 per day.
If you have any questions regarding the permit renewal procedures please contact Bill Mills of the Stormwater and
General Permits Unit at [phone], ext. 548.
Sincerely,
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
cc: Central Files
Stormwater and General Permits Unit Files
Mooresville Regional Office
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
February 19, 1999
M DARRELL HINNANT
RADIATOR SPECIALTY COMPANY
PO BOX 159
INDIAN TRAIL, NC 28079
1� fir:
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: NPDES Stormwater Permit Renewal
Radiator Specialty Company
Permit Number NCS000183
Union County
Dear Permittee:
Your facility is currently covered for stormwater discharge under NPDES Permit NCS000183. This permit
expires on August 31, 1999. In order to assure your continued coverage under your permit, you must apply to the
Division of Water Quality (DWQ) for renewal of your permit. To make this renewal process easier, we are
informing you in advance that your permit will be expiring. Enclosed you will find an individual permit renewal
application form, supplemental information request, and Stormwater Pollution Prevention Plan certification.
Filing the application form along with the requested supplimental information will constitute your application for
renewal of your permit. The application form must be completed and returned along with all requested
information within thirty days of receipt of this letter in order to constitute a timely renewal filing.
Recent legislation modified the fee structure for DWQ permits. Renewal fees have been eliminated and annual
fees have been changed. The new annual fee for your permit is now $715.00 (you will be invoiced later this year
for your annual fee.) A copy of the new fee schedule is enclosed in this package.
Failure to request renewal within the time period indicated may result in a civil assessment of at least $250.00.
Larger penalties may be assessed depending on the delinquency of the request. Discharge of stormwater from
your facility without coverage under a valid stormwater NPDES permit would constitute a violation of NCGS
143-215.1 and could result in assessments of civil penalties of up to $10,000 per day.
If you have any questions regarding the permit renewal procedures please contact Darren England of the
Stormwater and General Permits Unit at [phone], ext. 545.
Sincerely,
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
cc: Central Files
Mooresville Regional Office
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

STORMWATER DIVISION CODING SHEET
NCS PERMITS
PERMIT NO.
N C S Ou03-7 3
DOC TYPE
❑ FINAL PERMIT
❑ MONITORING REPORTS
❑ APPLICATION
❑ COMPLIANCE
® OTHER - HISToa.icAIL lrUron-lv�A-TIO N
DOC DATE
❑ 2D200 22
YYYYMMDD

WM
SIM
Alexander, Laura
11
From: [e-mail]
Sent: Friday, January 09, 2015 3:22 PM
To: Alexander, Laura
Subject: RE: Permit Contact Changes
Attachments: NCS000373.pdf, Signed Owner -Affiliation -Change Jan9-2015.pdf
Follow Up Flag: Follow up
Flag Status: Flagged
Laura,
Thank you for replying so quickly! I have attached a copy of the Affiliation form. I also need to update the permit contact
Person(s) and the Permit Billing Contact. Lisa Meyers is no longer working for our company and I need to have her name
removed and replaced with the following information:
Permit Contact Person(s) (Please leave Brad Hinchman as a contact as well)
Name: Heather Ashby
Title: Environmental Coordinator
Address: 40589 S Stanly School Rd, Norwood NC 28128
Phone:[phone]
Email: heather.ashbyna us.michelin.com
Permit Billing Contact
Name: Heather Ashby
Title: Environmental Coordinator
Address: 40589 S Stanly School Rd, Norwood NC 28128
Phone:[phone]
Email: heather.ashbv(cDus.michelin.com
Thanks,
Heather Ashby
Environmental Specialist/US11
Email: heather. ash bv()us.michelin. com
Phone external: [phone]
Phone internal: *7848136
D3-Michelin Restricted
Retention: 201-103 <90 days
From: "Alexander, Laura" <Iaura.alexanderoncdenr.00v>
To:"heathecashbv(cDus.michelin.com" <heather.ashbv0us.michelin.com>,
Date:. 01/09/2015 08:58 AM
Subject: RE: Permit Contact Changes

Good Morning Heather!
The attached is all the information we have listed for your company. I have not seen an updated owner affiliation form but take a
look at the attached and let me know if everything looks okay. If you find we need to make changes — you can email me the form
you mailed in. I'll be happy to make the changes.
Thank you!
Laura Alexander
Stormwater Permitting Program
NC Division of Energy, Mineral and Land Resources
1612 Mail Service Center
Raleigh, NC 27699-1612
[phone]
From: heather.ashbv(&us.michelin.com [mailto:heather.ashbv(cbus.michelin.com]
Sent: Thursday, January 08, 2015 11:10 AM
To: SVC DENR.stormwater
Subject: Permit Contact Changes
Hello,
My name is Heather Ashby and I am working on a NPDES permit renewal that is due the beginning of this year, and I am
trying to determine if my Permit Contact information for Permit NCS000373 has been updated. I mailed an Owner
Affiliation form in to the department a few months ago, but I have not heard anything back about it. Could you tell me what
you have on file for my site's so that I can determine if it is correct?
Thanks,
Heather Ashby
Environmental Specialist/US11
Email: heather.ashbyCoNs.michelin.com
Phone external: [phone]
Phone internal: *7848136
D3-Michelin Restricted
Retention: 201-103 <90 days

Division of Energy, Mineral and Land Resources
AFJIA
Land Quality Section / Stormwater Permitting Program
NCDENR National Pollutant Discharge Elimination System (NPDES)
-1N "a"° °°' PERMIT OWNER AFFILIATION DESIGNATION FORM
(individual Legally Responsible for Permit)
Use this form if there has been:
AGERCY nSE ONLY
IPFOR
Uam.lymSr
d
Vev
I Month
I MY
NO CHANGE in facility ownership or facility name, but the individual
who is legally responsible for the permit has changed.
If the name of the facility has changed, or if the ownership of the facility has changed,
do NOT use this form. Instead, you must fill out a Name -Ownership Change Form,
and submit the completed form with all required documentation.
What does "legally responsible individual" mean?
The person is either:
• the responsible corporate officer (for a corporation);
o the principle executive officer or ranking elected official (for a municipality, state, federal or other public
agency);
• the'general partner or proprietor (for apartnership or sole proprietorship);
• or, the duly authorized representative of one of the above.
1) tinter the permit number for which this change in Legally Responsible Individual ("Owner Affiliation")
applies:
Individual Permit
NG}Ct"Sti 0 0 1 0 1 3 1 7 1 3
2) Facility Information:
Facility name:
Company/Owner Organization;
Facility address:
(00 Certificate of Coverage
N I C G
Michelin Aircraft Tire Company, A Division of
Michelin N. America. Inc
40589 S Stanly School Rd
Address ,
rood NC 28128
City State Zip
To find the current legally responsible person associated with your permit, go to this websitc:
http://vortal.nedenr.org/web/Ir/sw-permit-contacts and run the Permit Contact Summary Report.
3) OLD OWNER AFFILIATION that should be removed:
Previous legally responsible individual: Lisa Meyers
First MI Last
4) NEW OWNER AFFILIATION (legally responsible for the permit):
Person legally. responsible for this permit: Preston Gray
First MI Last
Page I of 2
SW U-OW NERAFFIL-25JUIy2014

NPDES Stormwater Permit OWNER AFFILATION DESIGNATION Form
(it'no Facility Name/Ownership Change)
Plant
Title
40589 S Stanly School Rd
Mailing Address
Norwood NC 28128
City State Zip
[phone] [e-mail]
'reephone E-mail Address
Fax Number
5) Reason for this change:
A result of: ® Employee or management change
❑ Inappropriate or incorrect designation before
❑ Other
If other please explain:
The certification below must be completed and signed by the permit holder.
PERMITTEE CERTIFICATION:
I; Trej@ , attest that this application for this change in Owner Affiliation
(person legally responsible for has been reviewed and is accurate and complete to the best of my
knowledge. l understand that if all required parts of this form are not completed, this change may not be
processed.
Signature Date
PLEASE SEND THE COMPLETED FORM TO:
Division of Energy, Mineral and Land Resources
Stonnwater Permitting Program
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
For more information or staff contacts, please call 919-707-9220 or visit the website at:
http://portal.ncdetmr.org web/Ir/stotmwater
Page 2 of 2
SW U-OW NFR4FFI L-25July2014

NC Division of Energy, Mineral and Land Resources
NPDES Stormwater Permit Contacts Summary
\C DEM LR has the followine contact information in nor Permit Database for your permit as of 1/812015.
Permit Number: NCS000373
Permit Type: Stonnwater Discharge, Individual
Facility Name: Michelin Aircraft Tire Company, A Division of Michelin N. America, Inc.
Facility Addressl: 40589 S Stanly School '
Facility Address2:
City, State & Zip: Norwood. NC 28128
MUST submit a Change of Name/ownefship form to DEMLR to make any changes to this Owner information.
See "Miscellaneous Forms" at htto://Portal.ncdenr.ore/web/lr/nodes-stormwater
Owner Name: Michelin Aircraft Tire Company A Division of Michelin N America Inc
Owner Type: Non -Government Owner Type Group: Organization
*** Legally Responsible for Permit ***
(Responsible corporate officer/principle executive officer or ranking elected official/general partner or proprietor,
or any other person with delegated signatory authority from the legally responsible person.) `
Owner Affiliation: Lisa Meyers -
Addressl: 40589 S Stanly School
Address2:
City, State & Zip: Norwood, NC 28128
Title:
Work Phone: [phone] Fax:
Email Address: liisp,jones(fts mail corn
Owner Contact Person(s)
Contact Name Title re s Phone Fax Email
Bill Van Someren PO Box 19001, Greenville, SC 29615 864458-4505 864458-6887
Facility Contact Person(s)
Contact Name IW2 Address Phone f@A Email
Brad Hinchman 40589 S Stanly School Rd, Norwood, NC - 701474-7774 brad.hinchman@us.
Permit:Contact Person(s)
-
Contact Name Iuk
Address Phone -Fpx
Lama
Brad Hinchman
40589 S Stanly School Rd, Norwood, NC 704474-7774
[e-mail]
28128
chelin.com
Lisa Meyers
40589 S Stanly School, Norwood, NC 704474-7726
28128
Permit;Billing Contact
Contact Name 7)SlE
Address Phone Elm
Emaii
Lisa Meyers
40589 S Stanly School, Norwood, NC 704474-7726
1/8/2015 Page

Georgoulias, Bethany
From: Georgoulias, Bethany
Sent: Monday, October 20, 2014 2:31 PM
To: '[e-mail]'
Cc: Bennett, Bradley; Pickle, Ken
Subject: RE: Question about stormwater permit NCS000373
Heather,
I think this is something we can address at the renewal next year in the body of the permit text. I'm thinking it would be
best to include a footnote in the monitoring tables somewhere that this annual fire -testing discharge is also considered
an allowable non-stormwater discharge, consistent with discharges listed in the definition at the back of the
permit. It is subject to regional office review and approval through the permitting process, but it seems like a
reasonable inclusion in this category. Then there would not be a question about it in the future.
Has the water ever been tested for the same parameters that the facility has to test for at the SDOs? The company
could pull a sample from the lagoon and test for the same parameters that it has to sample at the outfalls through which
this water is discharged. That would be very useful to demonstrate that this discharge is not a threat to water quality. It
would also help for you to provide information about (1) where the water that fills the cooling lagoon comes from (just
captured rainfall? Is it used for anything else regularly on -site?) and (2) what chemicals might be used to treat this water
(if any).
In the meantime, I'll include this correspondence in the permit file so that the permit writer is aware of this issue and
can address the discharge at renewal.
Regards,
Belhanj� Georgotdias, Environmental 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
919 / 807-6372 (phone); 919 / 807-6494 (fax)
Websitc: httn'//aortal ncdenr oriVweb/Ir/stomiwater
E-muil cwrre.spondence to and,from phis oddre.ss m,U� he subject to the North Carolina Public Records Imc and nrgr he disclosed to thirdiximes.
From: [e-mail][mailto:[e-mail]]
Sent: Friday, October 17, 2014 11:53 AM
To: Georgoulias, Bethany
Cc: Bennett, Bradley; Pickle, Ken
Subject: RE: Question about stormwater permit NCS000373
Hi Bethany,
Thank you for responding so quickly! We do not have a separate discharge permit for the cooling lagoon water. The only
discharge that we do from the cooling lagoon is for fire fighting and testing of the fire system. I would like to address this at
the next permit renewal (which happens to be next year).
Thanks,

Heather Ashby
Environmental Specialist/US11
Email: heather.ashbv(d)..us.michelin.com
Phone external: [phone]
Phone internal: *7848136
D3-Michelin Restricted
Retention: 201-103 <90 days
From: "Georgoulias, Bethany" <bethanv.cleorcouliasonoder
To:"healhecashbyraDus.michelin.com"<healher.ashbyonus.i
Cc: "Bennett, Bradley" <bradlev.bennett(a)nCdenr.goy>, "Picl
Date: 10/16/2014 02:31 PM
Subject: RE: Question about stormwater permit NCS000373
Hi Heather,
I think we can be flexible in interpreting a discharge from annual fire testing as an allowable stormwater discharges in many
cases. For this Michelin facility in particular, do you all have a separate wastewater discharge permit for the cooling lagoon
water? It may actually be authorized because you have that permit in place. Alternatively, it is something we can address at the
next renewal since this is an individual stormwater permit.
Bethany
Belhanv Georgoulias, Environmental Engineer
NCDENR / Division of Energy, Mineral, and Land Resources
Stomnwater Permitting Program
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury Street, Raleigh, NC 27604
919 / 807-6372 (phone): 919 / 807-6494 (fax)
Website: htto://t)ortal.ncdenr.orL,/web/Ir/stormwater
E-,nail con'espnnden<'e to and fron, this address muv be subject to the Noah Curo/inn Public Records law and mur be disclosed to rhadparties.
From: heather.ashby(cbus.michelin.com [mailto:heather.ashby(-Ous.michelin.com]
Sent: Thursday, October 16, 2014 12:48 PM
To: Georgoulias, Bethany
Subject: Question about stormwater permit NCS000373
Hello Bethany,
I have a question about my facility's stormwater permit (NCS000373) that I was hoping that you could help me answer.
It was noticed in a recent internal audit that we have a non-stormwater discharge that occurs once a year when we do our
annual fire testing using our cooling lagoon water. Is this an allowable non-stormwater discharge?
The permit says that allowable non-stormwater discharges includes "...discharges of uncontaminated potable water,
waterline and fire hydrant flushings.... Discharges resulting from fire -fighting or fire -fighting training."
Thanks,
Heather Ashby
Environmental Specialist/US11

Pickle, Ken
From: Pickle, Ken
Sent: Thursday, January 23, 2014 10:45 AM
To: Bennett, Bradley
Cc: Randall, Mike; Khan, Zahid
Subject: RE: Michelin Self Disclosure phone call 1/23
Wait a minute! Wait a minute! Sorry, I need to revise the tone of my earlier email report on the phone call.
It's true the conferees in today's call only spoke to the failure to do the visual monitoring. But upon review of the letter
send by Zahid after the call, the permittee pretty much just blew off all the requirements of the stormwater permit.
• Significant failure to conduct analytical stormwater monitoring
• Apparently total failure to conduct visual monitoring
• Incomplete SPPP.
In other words, the permittee pretty much ignored all three basic requirements of NCS000373, despite having been our
permittee since 1999.
kbp
Ken Pickle
Environmental Engineer
NCDENR I DEMLR I Stormwater Permitting Program
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. oickle(&ncdenr.gov
Website: htto://i)ortal.ncdenr.org/web/Ir/stormwater
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Pickle, Ken
Sent: Thursday, January 23, 2014 10:16 AM
To: Bennett, Bradley
Cc: Randall, Mike
Subject: FW: Michelin Self Disclosure phone call 1/23
Importance: High
Bradley
Michelin Aircraft Tire in Norwood, NC (Stanly County) recently fired an employee from the EH&S staff. Michelin
subsequently discovered environmental compliance problems: Apart from the ex -employee's contribution to the issues,
they further characterize the problem as a failure of plant management.
With respect to stormwater issues, part of the subsequent discoveries included that the permittee has not been doing
the twice per year visual monitoring at their two stormwater outfalls required under NCS000373. Analytical monitoring
requirements have been met, apparently. COD, pH, and TPH were ok according to the verbal report over the phone.

KBP opinion: The reported stormwater issue does not require further action/interest from us in the Central Office.
Michelin North America corporate staff in Greenville, SC, asked how the annual summary monitoring reports should be
reported. I advised as follows:
• Boilerplate at the back of the permit directs the permittee to submit the Annual Summary to the Regional
Office. Please send that to Zahid.
o The blank reporting forms are obtainable on our website.
The permittee's other reporting obligation is to send the twice per year DMR's to the Central Office, again as per
the permit boilerplate.
Mike explored with the conferees whether the current facility expansion project may trigger other stormwater
permitting, whether by local jurisdictions or at the state level:
• Specifically — the site drains to a WS-IV — is there a local WSWS authority? Would the expansion trigger Post -
Construction?
• The conferees did not know the answer to Mike's questions, but both MRO and Michelin advised that they
would run down whether those programs may apply, and whether the contractor or other parties may have
already satisfied those permitting requirements.
Mike — did 1 leave anything out?
Ken
Ken Pickle
Environmental Engineer
NCDENR I DEMLR I Stormwater Permitting Program
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. pickle@)ncdenr.gov
Website: htto://i)ortal.ncdenr.org/web/Ir/stormwater
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Davis, Tracy
Sent: Thursday, January 23, 2014 9:10 AM
To: Vinson, Toby
Cc: Khan, Zahid; Bennett, Bradley; Pickle, Ken; Deborah Reese
Subject: Re: Michelin Self Disclosure phone call 1/23
Importance: High
Yes, I received a cc: on the email to Mitch last week and intended to forward to you all once I had a chance to
read through it (sorry, it got buried in my email). The official hard copies of the letter were delivered today. It
appears that Michelin is an Environmental Stewardship member and is self reporting its deficiencies in order to
work with DENR agencies to achieve compliance.
As such, I concur that Zahid, Bradley and/or Ken attend this conference call Thursday morning (I had not
received information that one had been set up) and be prepared to discuss the stormwater related compliance
matters. It appears that these are minor in nature and we need to work with Michelin in a timely manner to get
them resolved without any further enforcement (unless you come through me first).
Thanks for being on top of this and please keep me posted...

Tracy
Tracy E. Davis, PE, CPM
Director - Division of Energy, Mineral, and Land Resources
NC Dept. of Environment and Natural Resources
tracy.davi s@ncdenr. gov
[phone]
Email correspondence to and from this address may be subject to the NC Public Records Law and may be
disclosed to third parties.
On Jan 22, 2014, at 4:50 PM, "Vinson, Toby" <[e-mail]> wrote:
Tracy,
I don't know if you already addressed this, but I recommend, Zahid, Ken and/or Bradley (if Bradley is
back from Plymouth) to attend the conference call tomorrow. Zahid, can you get the phone number for
Ken and Bradley to participate.
I'll ask Deborah to check on NPDES fee payment and let you know.
Toby
From: Khan, Zahid
Sent: Wednesday, January 22, 2014 3:32 PM
To: Davis, Tracy
Cc: Bennett, Bradley; Vinson, Toby; Pickle, Ken
Subject: FW: Self Disclosure
Tracy,
I received this letter from my counterpart in MRO Division of Air Quality regarding self -disclosure. This
letter was addressed to Mr. Mitch Gillespie, Assistant Secretary for Environment and copy to you and
two other directors. I am not sure whether you already taken care of this issue. The reason I am sending
this mail because Ron Slack (Regional Supervisor of Air Quality) asked me to attend a phone call
tomorrow 9 AM to discuss stormwater issues with Facility Manager. If anyone from Stormwater already
talked with this facility, or contacted the Facility Manager, it will be no sense to join in this phone
conference call. If you guys did not contact this facility, then it will be better for me to join in this
conference call and discuss details of deficiencies under the stormwater permit. Please advise ASAP.
Thanks
Zahid
From: Slack, Ron
Sent: Wednesday, January 22, 2014 10:10 AM
To: Khan, Zahid
Subject: FW: Self Dislclosure
Ronald Slack, Environmental Program Supervisor IV

NC DENR, Division of Air Quality
Mooresville Regional Office
610 East Center Avenue, Suite 301
Mooresville NC, 28115
Phone:[phone]
Fax: [phone]
www.ncair.org
ron.slack @ ncdenr.eov
Email correspondence to and from this address is subject to the North Carolina Public Records Law
and may be disclosed to third parties unless the content is exempt by statute or other regulation.
From: Daniel, Lee
Sent: Wednesday, January 15, 2014 9:43 AM
To: Slack, Ron; Foutz, Joe
Subject: FW: Self Dislclosure
Fyi. Do you agree that they left out these records and observations?
Lee A. Daniel I Chief, Technical Services Section
Division of Air Quality I NC Dept Environment and Natural Resources
1641 Mail Service Center I Raleigh, NC 27699-1641
Green Square Office Complex 217 West Jones Street
Phone/Fax:[phone]
ee.danlelno ncdenLeOV I www.ncair.org
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties unless
the content is exempt by statute or other regulation.
From: Holman, Sheila
Sent: Tuesday, January 14, 2014 3:10 PM
To: Daniel, Lee
Subject: FW: Self Dislclosure
Lee:
Per my voice mail message.
Sheila
Sheila Holman, Director
NCDENR, Division of Air Quality
1641 Mail Service Center
Raleigh, NC 27699-1641
Phone/Fax: [phone]
www.ncair.org
Sheila. holma n(abncdenr.gov

Email correspondence to and from this address is subject to the North Carolina Public Records Law and
may be disclosed to third parties unless the content is exempt by statue or other regulation.
From: preston.grav(caus.michelin.com[mailto:preston.gray(alus.michelin.com]
Sent: Tuesday, January 14, 2014 3:07 PM
To: Gillespie, Mitch; Holman, Sheila; Davis, Tracy; Matthews, Dexter
Cc: iack.smith(Onelsonmullins.com; [e-mail]; kris.mcvey(alus.michelin.com;
[e-mail]; [e-mail]; robert.wilkins-
n521848(&us.michelin.com; brad. hinchman() us. michelin.com
Subject: Self Dislclosure
Assistant Secretary Gillespie,
Attached is a copy of a self disclosure Michelin is submitting to your attention concerning
certain compliance issues for our facility in Norwood, NC regarding the NC air, stormwater and
waste programs. I am inviting you or your staff to contact me directly concerning any response
to the disclosure and our request for assistance in making sure the facility achieves complete
compliance with all of your program's requirements. Thank you for your assistance in this
matter.
Preston Gray, Facility Manager
Michelin North America, US 11
Norwood, NC 28128
704-474-7757

Pkkle, Ken
From: Davis, Tracy
Sent: Thursday, January 23, 2014 9:10 AM
To: Vinson, Toby
Cc: Khan, Zahid; Bennett, Bradley; Pickle, Ken; Deborah Reese
Subject: Re: Michelin Self Disclosure phone call 1/23
Importance: High
Yes, I received a cc: on the email to Mitch last week and intended to forward to you all once I had a chance to
read through it (sorry, it got buried in my email). The official hard copies of the letter were delivered today. It
appears that Michelin is an Environmental Stewardship member and is self reporting its deficiencies in order to
work with DENR agencies to achieve compliance.
As such, I concur that Zahid, Bradley and/or Ken attend this conference call Thursday morning (I had not
received information that one had been set up) and be prepared to discuss the stormwater related compliance
matters. It appears that these are minor in nature and we need to work with Michelin in a timely manner to get
them resolved without any further enforcement (unless you come through me first).
Thanks for being on top of this and please keep me posted...
Tracy
Tracy E. Davis, PE, CPM
Director - Division of Energy, Mineral, and Land Resources
NC Dept. of Environment and Natural Resources
tracy.davis a,ncdenr.€zov
[phone]
Email correspondence to and from this address may be subject to the NC Public Records Law and may be
disclosed to third parties.
On Jan 22, 2014, at 4:50 PM, "Vinson, Toby" <toby.vinson c2ncdenr.gnu> wrote:
Tracy,
I don't know if you already addressed this, but I recommend, Zahid, Ken and/or Bradley (if Bradley is
back from Plymouth) to attend the conference call tomorrow. Zahid, can you get the phone number for
Ken and Bradley to participate.
I'll ask Deborah to check on NPDES fee payment and let you know.
Toby
From: Khan, Zahid
Sent: Wednesday, January 22, 2014 3:32 PM
To: Davis, Tracy
Cc: Bennett, Bradley; Vinson, Toby; Pickle, Ken
Subject: FW: Self Disclosure

Tracy, 4`
I received this letter from my counterpart in MRO Division of Air Quality regarding self -disclosure. This
letter was addressed to Mr. Mitch Gillespie, Assistant Secretary for Environment and copy to you and
two other directors. I am not sure whether you already taken care of this issue. The reason I am sending
this mail because Ron Slack (Regional Supervisor of Air Quality) asked me to attend a phone call
tomorrow 9 AM to discuss stormwater issues with Facility Manager. If anyone from Stormwater already
talked with this facility, or contacted the Facility Manager, it will be no sense to join in this phone
conference call. If you guys did not contact this facility, then it will be better for me to join in this
conference call and discuss details of deficiencies under the stormwater permit. Please advise ASAP.
Thanks
Zahid
From: Slack, Ron
Sent: Wednesday, January 22, 2014 10:10 AM
To: Khan, Zahid
Subject: FW: Self Dislclosure
Ronald Slack, Environmental Program Supervisor IV
NC DENR, Division of Air Quality
Mooresville Regional Office
610 East Center Avenue, Suite 301
Mooresville NC, 28115
Phone:[phone]
Fax: [phone]
www.ncair.org
[e-mail]
Email correspondence to and from this address is subject to the North Carolina Public Records Law
and may be disclosed to third parties unless the content is exempt by statute or other regulation.
From: Daniel, Lee
Sent: Wednesday, January 15, 2014 9:43 AM
To: Slack, Ron; Foutz, Joe
Subject: FW: Self Dislclosure
Fyi. Do you agree that they left out these records and observations?
Lee A. Daniel I Chief, Technical Services Section
Division of Air Quality I NC Dept Environment and Natural Resources
1641 Mail Service Center I Raleigh, NC 27699-1641
Green Square Office Complex 217 West Jones Street
Phone/Fax:[phone]
Iee.danielCEDncdenr.¢ov I www.ncair.ore
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties unless
the content is exempt by statute or other regulation.

From: Holman, Sheila
Sent: Tuesday, January 14, 2014 3:10 PM
To: Daniel, Lee
Subject: FW: Self Dislclosure
Lee:
Per my voice mail message.
Sheila
Sheila Holman, Director
NCDENR, Division of Air Quality
1641 Mail Service Center
Raleigh, NC 27699-1641
Phone/Fax: [phone]
www.ncair.org
sheila.holman(o ncdenr.gov
Email correspondence to and from this address is subject to the North Carolina Public Records Law and
may be disclosed to third parties unless the content is exempt by statue or other regulation.
From:yeston.grayCfus.michelin.com[mailto:preston.gray(0)us.michelin.com]
Sent: Tuesday, January 14, 2014 3:07 PM
To: Gillespie, Mitch; Holman, Sheila; Davis, Tracy; Matthews, Dexter
Cc: jack.smith(a)nelsonmullins.com; [e-mail]; [e-mail],
mvra.carpenterCalus.michelin.com; martin.wardle(&us.michelin.com; robert.wilkins-
n521848(a)us.michelin.com; brad. hinchman(o)us. michelin.com
Subject: Self Dislclosure
Assistant Secretary Gillespie,
Attached is a copy of a self disclosure Michelin is submitting to your attention concerning
certain compliance issues for our facility in Norwood, NC regarding the NC air, stormwater and
waste programs. I am inviting you or your staff to contact me directly concerning any response
to the disclosure and our request for assistance in making sure the facility achieves complete
compliance with all of your program's requirements. Thank you for your assistance in this
matter.
Preston Gray, Facility Manager
Michelin North America, US I
Norwood, NC 28128
704-474-7757

10F
Pickle, Ken
From:
Pickle, Ken
Sent:
Thursday, January 23,
To:
Khan, Zahid
Cc:
Randall, Mike; Bennett,
Subject:
RE: Self Disclosure
Hi Zahid,
2014 2:57 PM
Bradley; Bou-ghazale, Samar; Georgoulias, Bethany
Please see my comments inserted in your note below. I've been fairly wordy, so that you can critique my thinking on
your questions. Let me know if we need to discuss further.
Others on distribution: Contrary perspectives?
Ken
Ken Pickle
Environmental Engineer
NCDENR I DEMLR I Stormwater Permitting Program
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. pickle( ncdenr.aov
Website: http://Portal.ncdenr.orci/web/Ir/stormwater
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Khan, Zahid
Sent: Thursday, January 23, 2014 10:00 AM
To: Pickle, Ken; Randall, Mike
Subject: FW: Self Disclosure
FYI,
Mike and Ken: Please let me know if you think some changes in stormwater permit required with new additions on this
facility.
Zahid, it depends on whether the new plant expansion presents stormwater risks of a different character than those
already covered by the permit. I mean, we are already asking them to test for COD, TPH, and pH based on the previous
assessment of the pollutant risks from their industrial activity in 2005 by our staff in RCO and Marcia Allocco in MRO. If
the new plant expansion involves raw materials or processes significantly different, (like are they now manufacturing
DDT in this expansion? Are they now using methyl mercury in the new process? Etc.) then we would consider revising the
permit. Otherwise, we are inclined to continue on with the permit as is. So, if what we have here is just an expansion of
the manufacturing capacity of aircraft tires, with essentially the some processes and materials, I do not think we need to
revise the permit.
The new Stormwater discharge outfall (SDO) should be added in our monitoring requirements.
Zahid, as per almost all of our stormwater permits, the text of NCS000373 was written to require sampling at "each
stormwater discharge outfall" Part II page 5 of 9. This means that when new outfolls are added through plant

r
expansions or other changes, we don't have to revise the permit text. The permittee is obligated to test the stormwater
outfalls, no matter that the number of discharges may change during the term of the permit. NPDES wastewater permits
typically are written to identify individual outfalls (#001, #002, #003, etc.), but the NPDES stormwater oermits typically
are not.
Do you think they need to modify the permit and send a revision request. No:
• 1 have not heard that the expansion presents significantly different pollution risks than the originally permitted
industrial activity. So on this count (the expansion), no revision to the permit is necessary, in my opinion.
I concur with Michelin's own assessment of their bad behavior— we had a bad employee, and we had a failure in
senior management. I'm impressed with their ownership of the problem and even their response as to the
particulars. I note however, that they did not report a change in the management system that would preclude
the next bad apple from again highlighting the failures of senior management. Myra (Greenville, SC corporate
EH&S Mgr) might be encouraged to think about that. However, as to revising the permit because of their bad
behavior:
o We try not to revise our permits in a punitive way. I mean, we don't consider increasing permit
conditions as a sort of punishment. So, their bad behavior would only result in more stringent permit
conditions if we thought increased conditions were actually necessary to keep management focused on
controlling stormwater pollution.
o With that background, I'm impressed with Michelin's response, once they uncovered the deficiencies in
compliance. (Consultants, attorneys, and senior management got involved.) Again, their management
system failed for forty months, but they have responded, and (they say) with no reported environmental
impact. I do not think we need more stringent permit conditions as a way to get plant management
focused on better control of potential pollutants.
o So on this count of bad behavior, no revision to the permit is necessary, in my opinion.
o However: I think my outline above is consistent with Tracy's perspective on no more enforcement. Being
fully consistent with Tracy's perspective, and while avoiding 'enforcement actions', you still might
consider if MRO would want to require some periodic (or one-time) narrative report from the facility as
to how they will be changing the EH&S management structure to reduce the likelihood of another forty
months of non-compliance.
Thanks for your help
Zahid
From: Khan, Zahid
Sent: Wednesday, January 22, 2014 3:31 PM
To: Davis, Tracy
Cc: Bennett, Bradley; Vinson, Toby; Pickle, Ken
Subject: FW: Self Disclosure
Tracy,
I received this letter from my counterpart in MRO Division of Air Quality regarding self -disclosure. This letter was
addressed to Mr. Mitch Gillespie, Assistant Secretary for Environment and copy to you and two other directors. I am not
sure whether you already taken care of this issue. The reason I am sending this mail because Ron Slack (Regional
Supervisor of Air Quality) asked me to attend a phone call tomorrow 9 AM to discuss stormwater issues with Facility
Manager. If anyone from stormwater already talked with this facility, or contacted the Facility Manager, it will be no
sense to join in this phone conference call. If you guys did not contact this facility, then it will be better for me to join in
this conference call and discuss details of deficiencies under the stormwater permit. Please advise ASAP. Thanks
Zahid

From: Slack, Ron
Sent: Wednesday, January 22, 2014 10:10 AM
To: Khan, Zahid
Subject: FW: Self Dislclosure
Ronald Slack, Environmental Program Supervisor IV
NC DENR, Division of Air Quality
Mooresville Regional Office
610 East Center Avenue. Suite 301
Mooresville NC, 28115
Phone:[phone]
Fax: [phone]
www.ncair.org
[e-mail]
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.
From: Daniel, Lee
Sent: Wednesday, January 15, 2014 9:43 AM
To: Slack, Ron; Foutz, Joe
Subject: FW: Self Dislclosure
Fyi. Do you agree that they left out these records and observations?
Lee A. Daniel I Chief, Technical Services Section
Division of Air Quality I NC Dept Environment and Natural Resources
1641 Mail Service Center I Raleigh, NC 27699-1641
Green Square Office Complex 217 West Jones Street
Phone/Fax:[phone]
[e-mail] I www.ncair.orR
Email correspondence to and from this address is subject to the North Carolina Public Records Law and maybe disclosed to third parties unless the content is exempt
by statute or other regulation.
From: Holman, Sheila
Sent: Tuesday, January 14, 2014 3:10 PM
To: Daniel, Lee
Subject: FW: Self Dislclosure
Lee:
Per my voice mail message.
Sheila
Sheila Holman, Director

NCDENR, Division of Air Quality
1641 Mail Service Center
Raleigh, NC 27699-1641
Phone/Fax: [phone]
www.ncair.ora
[e-mail]
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties unless the content is exempt by statue or other regulation.
From: r)reston.gray(@us.michelin.com fmailto:preston.oray(cbus michelin.com]
Sent: Tuesday, January 14, 2014 3:07 PM
To: Gillespie, Mitch; Holman, Sheila; Davis, Tracy; Matthews, Dexter
Cc: iack.smith(cbnelsonmullins com; [e-mail] com; [e-mail] com;
myra.carpenter(cbus.michelin.com; martin.wardle(a)us.michelin com; robert.wilkins-n521848Calus.michelin com;
brad. hinchman(aus. michelin com
Subject: Self Dislclosure
Assistant Secretary Gillespie,
Attached is a copy of a self disclosure Michelin is submitting to your attention concerning certain compliance
issues for our facility in Norwood, NC regarding the NC air, stormwater and waste programs. I am inviting you
or your staff to contact me directly concerning any response to the disclosure and our request for assistance in
making sure the facility achieves complete compliance with all of your program's requirements. Thank you for
your assistance in this matter.
Preston Gray, Facility Manager
Michelin North America, US I
Norwood, NC 28128
704-474-7757

January 14, 2014
Via FedEv and Electronic Mail
Mr. Mitch Gillespie
Assistant Secretary for Environment
North Carolina Department of Environment
and Natural Resources
Environment and Natural Resources Building
217 W. Jones Street
Raleigh, NC 27.604
Dear Mr. Gillespie:
Michelin North America, Inc. ("Michelin") is writing to voluntarily report to the North
Carolina Department of Environment and Natural Resources ("Department") that it has
discovered certain deficiencies in environmental compliance at its facility located at 40589 South
Slanly School Road, Norwood, North Carolina ("Facility"). This letter provides the Department
the information Michelin has available to date concerning the deficiencies it has discovered
under the Facility's stormwater permit, air permit, and requirements for management of
hazardous waste under the Resource Conservation and Recovery Act ("RCRA"). This letter also
provides information on the steps Michelin has taken to date, as well as its action plan for the
future, to ensure full compliance with all applicable environmental regulations and permits at the
Facility.
The deficiencies in the environmental compliance requirements at the Facility were
discovered upon the departure of the former environmental coordinator at the Facility. As a
routine matter concerning environmental compliance for all facilities, Michelin undertook a
specific review of all applicable environmental regulations and active permits at the Facility.
"the review uncovered deficiencies related to the stormwater permit, the air permit, and
management of hazardous waste under RCRA. The initial discovery of non-compliance
occurred in December. As information was being developed on the initial findings, Michelin
sought assistance from outside cnvironmental counsel and began collecting the information
necessary to identify any additional instances of noncompliance and to determine the actions that
needed to he taken to achieve compliance and correct such deficiencies. The process has been
complex and ongoing until, and through, the date of this letter. Professionals within Michelin
with expertise in these program areas were tasked with compiling and reviewing the information
necessary to determine the scope of the deficiencies and the specific actions needed to achieve
compliance. The details on the discovered deficiencies and corrective actions are provided later
in this letter.

Michelin does not have any information indicating that any of these deficiencies were
knowing or willful. Further, it does not appear that the deficiencies caused harm to the
environment or created a risk to public health. Finally, based on the information compiled by
Michelin, there is no indication that the deficiencies were the result of a hick of good faith efforts
to understand or comply with applicable regulations.
Michelin has a strong policy of environmental compliance, a commitment to the
protection of the environment and public health, and a commitment to be good corporate citizen.
Therefore, Michelin is voluntarily and promptly notifying the Department of these various
deficiencies and seeks the Department's assistance and concurrence in Michelin's efforts to
achieve compliance and overcome these deficiencies. Through the engagement of outside
environmental counsel as well as environmental professionals inside and outside Michelin,
immediate and effective action has been taken and is planned to bring the Facility back into full
environmental compliance. In order to aid Michelin in these efforts, Michelin respectfully
requests (1) a meeting to review this information, (2) any assistance and guidance that the
Department may provide with respect to Michelin's action plan for compliance, and (3)
consideration for Michelin's self -disclosure under the Department's Policy on Environmental
Penalty for Self -Reported Violations. Michelin also invites the Department to visit the Facility,
either as part of the requested meeting or at its discretion, to review compliance and any
remaining tasks to achieve full compliance at the Facility.
Upon the Department's review of this self -disclosure, if it is determined that additional
information is needed, Michelin is prepared to work with the Department to obtain any such
additional information. Further, Michelin is committed to work with the Department in
managing environmental operations at the Facility in a way that will rebuild the Department's
confidence in the Facility's ability to maintain compliance in the future.
As a result of discovery of Ilicsc deficiencies we are contacting our Environmental
Stewardship Initiative coach with the intent to withdraw from the program. We hope that we
will be able to re -apply for membership al some point in the future when we have demonstrated
that we can sustain our progress and fully represent the tenets of the program.
Details of the Deficiencies Under the Stormwater Permit
Pursuant to the stormwater permit for the Facility, sampling of stormwater discharges
were required semi-aimually. Michelin reports that six of the required semi-annual sampling
events under the stormwater permit were not conducted from August 1, 2010 through ,tune 30,
2013. Upon discovery of the deficiency, the semi-annual analytical sampling (but not qualitative
monitoring) was performed in December 2013. Michelin also inspected the Facility pursuant to
the stormwater permit in December 2013, but cannot locate any documentation indicating that
the semi-annual inspections of the Facility required by the stormwater permit, prior to December
2013, were conducted.
In addition to the above, the NPDES stormwater permit issued for the Facility was not
located at the Facility. A copy of the permit has been obtained from the Department and is now
available onsite at the Facility. Moreover, the Stormwater Pollution Prevention Plan required by
01

the permit was incomplete and not certified and the Department was not notified of a small
expansion of the Facility that has recently been completed. An outside consultant has been
engaged to provide a complete review and update to the existing SWP3 Plan. This Plan is
expected to be available on site no later than February 17, 2014.
Further, the SPCC Plan was found to be in place but was not certified. An engineering
consultant was immediately engaged to review and certify file SPCC Plan. 'file SPCC Plan has
now been certified and signed by the Facility Manager. The Facility is currently in compliance
with respect to the required SPCC Plan. Finally, the NPDES Permit annual fee was due in
September of 2013. While Michelin's review of the Department's NCDENR website indicates
that no fees are outstanding, Michelin has no record of payment. Therefore, the Facility is
Prepared to pay the fee if the Department finds that fees are in fact outstanding.
Details of the Deficiencies Under the Air Permit
Various inspections and other record keel) ing compliance documentation were found to be
deficient under the Facility's air Permit and applicable Department regulations.
The following chart outlines deficiencies discovered, the applicable regulation and/or
corresponding permit requirement, and the applicable correction plan.
Applicable
Permit
Observation:
Correction Plan:
Regulation:
Reg uiremenC
15A NCAC 2D
Section 2.1-
Only the first 6-month VE
As of January 2014, VE
.0508(1)
B.2.c & d
observation was completed
observations are being
and the observation was not
Performed by a Method 9
performed by a Method 9
trained person.
certified person.
15A NCAC 2D
Section 2.1-
The months of .Tan, Feb,
As of January 2014, VE
.0508(0
C.2.c & d
Mar, May Jun, Sep, and Nov
observations are being
were completed but not by a
Performed by a Method 9
Method 9 certified Person.
trained Person.
15A NCAC 2D
Section 2.1-
The months of Jan, Feb,
As of January 2014, VE
.0508(t)
D.3.c & d
Mar, May, .tun, Sept, and
observations are being
Nov were completed but not
performed by a Method 9
by a Method 9 certified
trained Person.
person..
15A NCAC 2Q
Section 2.1-
The months of Jan, Feb,
As of January 2014, VE
.0508(f)
F.2.c & d
Mar, May, Jun, Sep, and
observations are being
Nov were completed but not
performed by a Method 9
by it Method 9 certified
trained Person.
Person
3

15A NCAC 2Q
Section 2.2-
Only one monthly EP VOC
Facility responsible
.0508(t)
A. Lc & d
Work Practice Log was on
personnel resumed the
file.
observations during the
month of December 2013
and will continue monthly
and properly document
results.
15A NCAC 21)
Section 2.1-
Monthly
calculations
have
Data currently being
.0524
B.3.b
not been
completed
since
collected in order to
July.
calculate emission estimates.
15A NCAC 2Q
Section 2.1-
Monthly
calculations
have
Data currently being
.0508(O
D.4.d
not been
completed
since
collected in order to
July.
calculate emission estimates
15A NCAC 2D
Section 2.2-
Monthly
calculations
have
Data currently being
.1100
B.La
not been
completed
since
collected in order to
July.
calculate emission estimates.
15A NCAC 2Q
Section 2.2-
Monthly
calculations
have
Data currently being
.0711
B.2.c
not been
completed
since
collected in order to
July.
calculate emission estimates
15A NCAC 2D
Section 2.1-A
Monthly
calculations
have
Data currently being
.0958
not been
completed
since
collected in order to
July.
calculate emission estimates
15A NCAC 2D
Section 2.1-13
Monthly
calculations
have
Data currently being
.0515
not been
completed
since
collected in order to
July.
calculate emission estimates
15A NCAC 2D
Section 2.1-13
Monthly
calculations
have
Data currently being
.0524
not been
completed
since
collected in order to
July.
calculate emission estimates
15A NCAC 2D
Section 2.1-C
Monthly
calculations
have
Data currently being
.0515
not been
completed
since
collected in order to
July.
calculate emission estimates
15A NCAC 2D
Section 2.1-D
Monthly
calculations
have
Data currently being
.0503
not been
completed
since
collected in order to
July.
calculate emission estimates

15A NCAC 2D
Section 2.1-D
Monthly
calculations
have
Data currently being
.0515
not been
completed
since
collected ill order to
.tidy.
calculate emission estimates
15A NCAC 2D
Section 2.1-E
Monthly
calculations
have
Data currently being
.0515
not been
completed
since
collected in order to
July.
calculate emission estimates
15A NCAC 21)
Section 2.l-F
Monthly
calculations
have
Data currently being
.0515
not been
completed
since
collected in order to
July,
calculate emission estimates
ISA NCAC 21)
Section 2.1-F
Monthly
calculations
have
Data currently being
.0958
not been
completed
since
collected in order to
July.
calculate emission estimates
15A NCAC 2D
Section 2.1-G
Monthly
calculations
have
Data currently being
.0515
not been
completed
since
collected in order to
July.
calculate emission estimates
15A NCAC 2D
Section 2.1-G
Monthly
calculations
have
Data currently being
.0958
not been
completed
since
collected in order to
.hdy.
calculate emission estimates
15A NCAC 2Q
Insignificant
Monthly
calculations
have
Data currently being
.0503(8)
Activities
not been
completed
since
collected in order to
July.
calculate emission estimates
Michelin will update its compliance achievements as these tasks are completed.
Details of the Deficiencies Regarding the Resource Conservation and Recovery Act
The Facility received a small shipment of solvent -based waste material in five gallon
pails in the second quarter of 2012 from a related facility in Kansas City, Missouri. It was
discovered in December 2013 that the pallet of five gallon pails was still at the Facility and was
overdue for disposal under the applicable regulations. The material has now been manifested
and sent offsite for disposal under appropriate safeguards and procedures.
In addition to the above, it was discovered that the hazardous waste manifests required to
be maintained onsite for three years were not fully maintained at the Facility. Specifically,
Michelin cannot locate 2011 and 2012 manifests but was able to locate records for 2013. Efforts
to obtain copies of 2011 and 2012 manifests are ongoing with the transporters and disposal
facilities. Il is expected that these records should be available by January 17, 2014.
5

Finally, hazardous waste training records it the facility were not well -documented.
Therefore, Michelin has undertaken the task of providing training under the RCRA requirements
for all employees. This training is being implemented now and it is expected that all training
should be complete and documentation as required will be available by March 14, 2014.
Summary
Michelin is voluntarily disclosing the above deficiencies recently discovered by it and
seeks the assistance of the Department to ensure that its efforts to achieve compliance to date and
its contemplated actions not yet taken to achieve Bill compliance are appropriate and sufficient.
Michelin requests a meeting with the Department to review this information as soon as possible.
Plant Manager, Mr. Preston Gray, and key staff from the Facility will attend the meeting along
with counsel. Please contact me at your earliest convenience with proposed dates for such a
meeting, and, if the Department desires, a date for the Department to visit the racility.
Thank you for the opportunity to work with the Department to address these deficiencies,
and for your consideration of this disclosure under the Department's Policy on Environmental
Penally for Self -Reported Violations.
Respectfully submitted,
Preston Gray
Michelin North America, Inc.
USI 1, Facility Manager
cc: Mr. Tracy Davis, Division Director, Stormwater Division
Mr. Dexter Matthews, Division Director, Waste Management Division
Ms. Sheila Holman, Division Director, Air Quality Division
Mary Giorgi, Esquire (fin electronic nail only)
Newman Jackson Smith, Esquire (via electronic nail onl))•
6

Pickle, Ken
From: Davis, Tracy
Sent: Friday, January 24, 2014 11:31 AM
To: Harwood, Joseph E
Cc: Vinson, Toby; Khan, Zahid; Bennett, Bradley; Randall, Mike; Pickle, Ken; Moore, James;
Gillespie, Mitch; Holman, Sheila; Matthews, Dexter; Bush, Ted
Subject: FW: Michelin Self Disclosure phone call 1/23
Joe,
As a follow up to your email to Michelin, I wanted to let you know (if case you hadn't heard) that the Division of Air
Quality staff at the MRO arranged a conference call with Michelin folks that was held yesterday. Below is a list of
participants.
With regards to DEMLR and its stormwater and erosion and sedimentation control programs' tie into this situation, here
is where we are:
a. Michelin is behind on some reports but the latest sampling showed there were no exceedances of their
stormwater water quality limits; and
b. A modification of their erosion and sedimentation control plan and stormwater permit will be necessary to
address some additional work they have conducted that is presently not covered by these approvals.
DEMLR staff is working with Michelin to address these items and Michelin indicated they will have everything to us by
February 15 to bring the site into compliance (which we agreed to).
Thanks, and we will keep you and Mitch posted when all DEMLR matters have been addressed.
Tracy
From: Khan, Zahid
Sent: Thursday, January 23, 2014 12:22 PM
To: Vinson, Toby; Davis, Tracy
Cc: Bennett, Bradley; Pickle, Ken; Randall, Mike
Subject: RE: Michelin Self Disclosure phone call 1/23
Toby,
Below is the list of participants in this phone call.
Michelin:
Preston Gray - Plant Manager, Norwood
Robert Wilkins - EHS Manager, Norwood
Brad Hinchman - EHS Manager, in training, Norwood
Dan Rembert - Corporate, Air
Rafal Krugly - Corporate, Water
Myra Carpenter - Corporate Environmental Manager
Air Quality:
Ronald Slack, Division of Air Quality Regional Supervisor [e-mail]
Bruce Ingle, MRO DAQ Compliance Supervisor [e-mail]
Joe Foutz, Assigned DAQ Inspector for Michelin, joe.foutz@ncdenr,gov

Y
DEMLR/Land Quality MRO Staff
Zahid Khan, Energy, Mineral and Land Resources Regional Supervisor, [e-mail]
James "Chip" Moore, Assistant Regional Engineer, Energy, Mineral and Land Resources
[e-mail]
DEMLR/ Stormwater Program Central Office Staff
Ken Pickle, , Energy, Mineral and Land Resources Environmental Engineer, ken.pickle(oncdenr.gov
Randall, Mike, Energy, Mineral and Land Resources Environmental Engineer, [e-mail]
Thanks
Zahid
From: Vinson, Toby
Sent: Wednesday, January 22, 2014 4:51 PM
To: Khan, Zahid; Davis, Tracy
Cc: Bennett, Bradley; Pickle, Ken; Deborah Reese
Subject: RE: Michelin Self Disclosure phone call 1/23
Tracy
I don't know if you already addressed this, but I recommend, Zahid, Ken and/or Bradley (if Bradley is back from
Plymouth) to attend the conference call tomorrow. Zahid, can you get the phone number for Ken and Bradley to
participate.
I'll ask Deborah to check on NPDES fee payment and let you know.
Toby
From: Khan, Zahid
Sent: Wednesday, January 22, 2014 3:32 PM
To: Davis, Tracy
Cc: Bennett, Bradley; Vinson, Toby; Pickle, Ken
Subject: FW: Self Disclosure
Tracy,
I received this letter from my counterpart in MRO Division of Air Quality regarding self -disclosure. This letter was
addressed to Mr. Mitch Gillespie, Assistant Secretary for Environment and copy to you and two other directors. I am not
sure whether you already taken care of this issue. The reason I am sending this mail because Ron Slack (Regional
Supervisor of Air Quality) asked me to attend a phone call tomorrow 9 AM to discuss stormwater issues with Facility
Manager. If anyone from Stormwater already talked with this facility, or contacted the Facility Manager, it will be no
sense to join in this phone conference call. If you guys did not contact this facility, then it will be better for me to join in
this conference call and discuss details of deficiencies under the stormwater permit. Please advise ASAP. Thanks
Zahid
From: Slack, Ron
Sent: Wednesday, January 22, 2014 10:10 AM
To: Khan, Zahid
Subject: FW: Self Dislclosure

Ronald Slack, Environmental Program Supervisor IV
NC DENR, Division of Air Quality
Mooresville Regional Office
610 East Center Avenue, Suite 301
Mooresville NC, 28115
Phone:[phone]
Fax: [phone]
www.ncair.org
[e-mail]
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.
From: Daniel, Lee
Sent: Wednesday, January 15, 2014 9:43 AM
To: Slack, Ron; Foutz, Joe
Subject: FW: Self Dislclosure
Fyi. Do you agree that they left out these records and observations?
Lee A. Daniel I Chief, Technical Services Section
Division of Air Quality I NC Dept Environment and Natural Resources
1641 Mail Service Center I Raleigh, NC 27699-1641
Green Square Office Complex 217 West Jones Street
Phone/Fax: [phone]
lee.danielOncdenr.gov I www.ncair.org
Email correspondence to and from this address is subject to the North Carolina Public Records Law and maybe disclosed to third parties unless the content is exempt
by statute or other regulation.
From: Holman, Sheila
Sent: Tuesday, January 14, 2014 3:10 PM
To: Daniel, Lee
Subject: FW: Self Dislclosure
Lee:
Per my voice mail message.
Sheila
Sheila Holman, Director
NCDENR, Division of Air Quality
1641 Mail Service Center
Raleigh, NC 27699-1641
Phone/Fax: [phone]
www.ncair.org
sheila.holman(@ncdenr.00v

Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties unless the content is exempt by statue or other regulation.
From: preston.gray(d)us.michelin com[mailto:preston.gray5us.michelin.com]
Sent: Tuesday, January 14, 2014 3:07 PM
To: Gillespie, Mitch; Holman, Sheila; Davis, Tracy; Matthews, Dexter
Cc: iack.smithO)nelsonmullins.com; mary.giorgi(aus.michelin.com; kris.mcvey(aus.michelin.com;
myra.caroenterCalus.michelin.com; martin.wardleCalus.michelin.com; robert.wilkins-n521848Ca)us.michelin.com;
brad. hinchmanaus.michelin.com
Subject: Self Dislclosure
Assistant Secretary Gillespie,
Attached is a copy of a self disclosure Michelin is submitting to your attention concerning certain compliance
issues for our facility in Norwood, NC regarding the NC air, stormwater and waste programs. I am inviting you
or your staff to contact me directly concerning any response to the disclosure and our request for assistance in
making sure the facility achieves complete compliance with all of your program's requirements. Thank you for
your assistance in this matter.
Preston Gray, Facility Manager
Michelin North America, US 11
Norwood, NC 28128
704-474-7757

I•
APIDNATVF ....... R'ctvl 1
GORES:;* -tESOUE SAL C S
ICLe
: MAR 0 3
2UU5
"R 1 7 2005 Michael F. Easley, Governor
O William G. Ross Jr., Secretary
(� North Carolina Department of Environment and Natural Resources
TER QUALITY - Alan W. Klimek, P. E. Director
D TORMWATER BRANCH /@ Division of Water Quality
WA TER !/ t• ', 7p� Coleen 11. Sullins, Deputy Director
%W4; `eft 1 SEC I AN Division of Water Quality
1 rY
STAFF REVIEW AND EVALUATION MRO
NPDES Stormwater Permit
Facility Name:
Michelin Aircraft Tire Company, LLC
NPDES Permit Number:
NCS000373
Facility Location:
Norwood, NC (Stanly Co.)
Type of Activity:
Industrial —Tires and Inner Tubes
SIC Code (if applicable):
3011
Receiving Streams:
UT to Cedar Creek, index no. 32-12-(1)
River Basin:
Yadkin -Pee Dee River Basin, Sub -basin 03-07-08
Stream Classification:
WS-IV
Proposed Permit Requirements:
See attached draft permit.
Compliance Schedule:
See Part V, Section A of the attached draft permit
Basis for Monitoring:
See attached Monitoring Data Analysis. TSS monitoring was removed
(average well below benchmark at both outfalls). Permit retains
annual PH and COD monitoring (most recent COD value at SDO #2
was at the benchmark of 120 mg/1), and now also includes Oil &
Grease monitoring (fueling and cleaning activities at this site). Vehicle
Maintenance monitoring changed to quarterly in the 4" year for
consistency with other permits.
Basis for Other Requirements:
Removed cutoff concentrations per D WQ revised monitoring strategy
for individual Stormwater permits (implemented for all second term
permits with analytical monitoring requirements). Monitoring data are
instead compared to benchmark concentrations during renewal review.
Flow monitoring removed from Sections B and D per DWQ revised
monitoring strategy. Instead, Pan 11. Sec. A clarifies that SPPP site
map include drainage area for each outfall in acres and percent
impervious area in each drainage area. Total Rainfall and Event
Duration parameters also added to Section D. Vehicle maintenance
activities did not trigger monitoring last term.
Response Requested by (Date): March 25, 2005
Central Office Staff Contact: Bethany Georgoulias, [phone], ext. 529
DOCUMENTS REVIEWED
NPDES Stormwater Permit Application Materials
S/ W Permit File
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 [phone]
VAT
NN DENR
Customer Service
1-877-623-6748

NCS000373
Analytical &Qualitative Monitoring Results summary
Yadkin -Pee Dee Basinwide Plan (rev. March 2003)
1999 Permit Application Materials (Central Files)
Central Office Review Summary:
Facility does not discharge to impaired waters, but this segment of Cedar Creek is designated as Water Supply
waters. No major issues were noted for this sub -basin that would impact this stormwater permit.
Significant Changes: Since last renewal, the facility has (1) removed the retread operation, eliminating significant
sources of rubber particulates (from bag filter/cyclone and trailer used to capture the grinding dust); (2) added
concrete containment area to the lacolene solvent unloading station; (3) discontinued use of chlorine gas; (4)
revised several spill reporting, hazardous waste control, and security plan procedures; and (5) begun implementing
an ISO14001 Environmental Management System.
Qualitative Monitoring Results: No problems noted. Company continues to perform semi-annual observations.
Analytical Monitoring: See attached Monitoring Data Analysis. No monitoring performed in latter half of 2003
because of drought in Stanly County. Reviewer recommends removing TSS monitoring, but retaining annual
monitoring for COD and pH. All parameters had average concentrations below benchmarks, but the last COD
sample was right at the benchmark concentration of 120 mg/I. Permittee rounded pH values to the nearest whole
number and should be recording values at least to the tenth decimal place.
Previous monitoring requirements were based on EPA group application for this industry. According to 1999 Data
Analysis Summary and Application Review (D. England, Permit Reviewer), Total Zinc would normally be a
pollutant of concern for this type of industry, but Zinc monitoring was not warranted for this facility. The
company's 1999 submittal letter indicated that this site does not store or use zinc oxide (as typical of other tire
manufacturers) and instead uses rubber stock mixed at other facilities; the letter asserted that ZnO becomes
encapsulated in the rubber matrix and is unavailable as a stormwater contaminant. Tire grindings might still have
been a potential source of zinc, but the site removed the largest source of rubber particulates when it removed the
retread operation during the last term (see Significant Changes).
Reviewer also recommends adding Oil and Grease (O&G) monitoring (annual) because of fueling and cleaning
activities at this site. Michelin stores and/or transfers fuel oil, diesel fuel, solvents, and lubricants at this site, and
the 1999 Data Analysis Summary notes O&G should be monitored —but it was only included under vehicle
maintenance activities.
Flow monitoring is being removed from all renewal permits, per a revised DWQ strategy for stormwater permits.
Instead, the permit clarifies that the SPPP site map should include drainage area for each outfall in acres and
percent impervious area in each drainage area. DWQ felt it was unnecessary to require flow monitoring because
the Division currently does not use flow data from stormwater discharges no wastewater), and because, if ever
needed (for enforcement purposes, or any other unforeseen reasons), total flow could be estimated for any event
based on the rainfall amount, duration, and percent impervious drainage area (information required as part of the
SPPP and the permit already).
Follow-up with the contact (Don Matthews, 704-474-7726) on 2/ 18/2005:
• Verified on -site vehicle maintenance operations did not exceed 55 gallons of new motor oil per month.
• Although site maps note heptane loading/unloading stations, the site no longer stores or uses heptane.
The facility switched to lacolene, a tackifier (used to make the rubber sticky) solution that has much lower
levels of benzene than other solvent blends. During the last permit term, concrete containment was
installed around the lacolene unloading station. Also, the company's best management practices keep the
station's drainage under lock and ensure inspection for oil and debris before releasing any rainwater down
the dike drain.
• The contact verified that there was no residual dust from the former retread operation exposed to
stormwater; everything was thoroughly cleaned off the premises when the operation was removed.
• Advised that pH values be recorded to the tenth decimal place (not rounded to nearest whole number).
Recommendation: Based on the documents reviewed, the application information submitted on March 23, 2004 is

w
North Carolina Department of
Environment and Natural Resources
Division of Water Quality
[phone]
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NCS000373
Regional Office Staff Comments

Stormwater Monitoring Data Analysis
Permit: NC5000373 CMC = Criterion Maximum Concentration
Facility: Michel/n Aircraft Tire FAV = Final Acute Value
Reviewer: B. Georgoulias ND = Not Detected
Receiving Waters: -
Classification:
Special Notes:
UT to Cedar Creek
WS-/V
Permittee only required to monitor first and last year of last permit term (averages below cut-off concentrations)
Comparison based on arithmetic average of monitoring results for each outfall, except pH evaluated bygeometric mean.
Values are for Freshwater. Check criteria for Saltwater and Human Health Consumption (Water Supply) when applicable.
Parameter
Benchmark
Conc.
'Outfall
#1
Outfall
#2.
Units
'
Source
Chemical Oxygen Demand
(COD)"
120
ND
70
m I
BPJ, 4 x (BOD5)
Oil and Grease
30
-
-
m I
BPJ, Wastewater Permits
H (geometric mean)**
6-9
6.3
6.3
su
Water Quality Standard (Except Sw waters can be as low as 4.3)
TSS (Total Suspended Solids)"
100
20
14
m I
BPJ, EPA Multi -Sector Permit
"One COD value at Outfall #2 recorded as 120 mg/l; therefore, recommend monitoring in renewal. No TSS values above benchmark.
"Permittee rounded pH observations to nearest whole number (should keep at least one decimal place).
Benchmarks last updated 2/9/2005 by B. Georgoulias
3/1/2005 Page 1

nn'4X q� 19aIq
NCS000373 fCe,/„ {�r Q Ol/29/99
• 4. Oil and Grease (O&G)
The state -of North �olina has assigned a benchmark value of 30.mg/l for determining.the need to monitor
O&G in stormwater. Evaluation of the grab sample data submitted in the group application to the USEPA
indicates O&G in excess of this benchmark in 7.7% of the group application samples. The average values
for the data are below the benchmark. However, O&G will be monitored because activities_ such as fueling,
servicing, cleaning, and storage of vehicles and equipment present a significant potential for contamination
of stormwater. This determination is consistent in keeping with the requirements of all other North
Carolina Stormwater Permits covering industrial activities that include vehicle maintenanceand fueling_
5.
6.
O&G
30 mg/I
# of Min Max % in excess
Type samples Average Median Value Value of benchmark
Grab 13 9.9 2.5 1 76- 7.7
Chemical Oxygen Demand (COD)
The state of North Carolina has assigned a benchmark value of 120 mg/I for determining the need to
monitor COD in stormwater. Evaluation of the grab sample data submitted in the group application to the
USEPA indicates COD in excess of this benchmark in 23.1% of the group application grab samples and
38.5% of the composite samples. The average values for the data were also above the benchmark. COD is
a pollutant of concern based on the submitted data, therefore monitoring of this parameter is determined to
be warranted for this term of the permit.
COD
120 mg/l
# of
Min
Max
% in excess
Type
samples
Average
Median Value
Value
of benchmark
Grab
13
160.1
67.0 13.0
812
23.1
Composite
13
114.4
78.0 2.8
321
38.5
Total Phosphorus (TP)
The state of North Carolina has assigned a benchmark value of 2 mg/1 for determining the need to monitor
TP in stormwater. Evaluation of the grab sample data submitted in the group application to the USEPA
indicates TP in excess of this benchmark in 0.0% of the group application grab samples and 7.7% of the
composite samples. The average values for the data are below the benchmark, therefore TP will not be
considered a pollutant of concern for this term of this permit.
TP
2 mg/I
# of
Min
Max
% in excess
Type
samples
Average
Median Value
Value
of benchmark
Grab
13
0.60
0.35 0.05
1.65
0.0
Composite
13
1.0
0.30 0.03
8.65
7.7
Page 2 of 4

ZINCS000373 01/29/y'9 .
7. Total Suspended Solids (TSS)
The state of North Carolina has assigned a benchmark value of 100 mg/I for determining the need to
monitor TSS in stormwater. Evaluation of the sample data submitted, in the group application to the USEPA
indicates TSS in excess of this benchmark in 53.8% of the group application grab samples and 61.5% of the
composite samples. The average values for the data were also above the benchmark. Total Suspended
Solids is a pollutant of concern based on the submitted data, therefore monitoring of this parameter is
determined to be warranted for this term of the permit.
TSS
100 mg/I
Type
# of
Average
Median Min
Max
z % in excess
samples
Value
Value
of benchmark
Grab
6
131.8
63 12.0
498
33.0
Composite
6
219.7
229 6
760
50.0
8. Total Phenols (TPh)
The state of North Carolina has assigned a benchmark value of .35 mg/I for determining.the need to
monitor TPh in stormwater. Evaluation of the grab sample data submitted in the group application to the
USEPA indicates TPh in excess of this benchmark in 0.0% of the group application grab samples and
25.0% for the composite samples (20.0% represents 1 of 4 samples)..The.average values for the data are
below the benchmark, therefore TP will not be considered a pollutant of concern for this term of the permit.
TPh
.35 mg/I
Type
# of
Average
Median Min
Max
% in excess
samples
Value
Value
of benchmark
Grab
4
0.014
0.009 0.005
0.031
0.0
Composite
4
0.120
0.010 0.009' --
- 0.432
25.0
9. Total Zinc (TZ)
The state of North Carolina has assigned a benchmark value of 0.1 mg/1 for determining the need to
monitor TZ in stormwater. Evaluation of the grab sample data submitted in the group application to the
USEPA indicates TP in excess of this benchmark in 63.6% of the group application grab samples and
90.9% of the composite samples. The average values for the data were also above the benchmark. Total
Zinc would be a pollutant of concern based on the submitted data, however, the permittee has indicated that
their facility is not characteristic of the facilities sampled in the group data. They !jonot -handle, zinc_oxi_d_e_
i as a raw material.on site, as is typical of other tire manufacturing facilities, consequently_zinc oxide is
generally unavailable as a stormwater contaminant. With this distinction in mind, monitoring of this
parameter is determined not to be warranted for this term of the permit.
TZ
0.1 mg/I
# of
Min
Max
% in excess
Type
samples
Avera e Median
Value
Value
of benchmark
Grab
11
1.6 0.22
0.09
7.6
63.6
Composite
11
0.98 0.27
0.01
7.5
90.9
Page 3 of 4

110R- l i99
MICHELIN®
MICHELIN NORTH AMERICA, INC.
Post Office Box 2846
Greenville, South Carolina 29602 Certified P 502 571 702
December 4, 1998
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
N. C. Division of Water Quality
P.O.Box 29535
Raleigh, North Carolina 27626-0535
Re: Michelin Aircraft Tire Corporation
Norwood, NC
Dear Mr. Bennett
On behalf of the site in reference, 1 am pleased to submit an application for a
NPDES permit to discharge storm water. Forms 1 and 2F, a storm drainage
drawing, an excerpt from a USGS map and a check in the amount of $400.00
are enclosed.
This plant was a participant in the group application for storm. water permits
sponsored by the Rubber Manufacturers Association. Sampling data from a
fraction of the group were provided with the application. For that reason, the
Norwood facility did not sample its storm flows for this application.
An important distinction for the Norwood facility is that it does not receive or
handle zinc oxide as a raw material. Other plants mix the rubber stock used at
Norwood in which zinc oxide is an important ingredient. Once mixed into the
bulk rubber, the zinc oxide is encapsulated in the matrix and "generally not
available as'a storm Water contaminant. We regard This arrangement as
beneficial for storm water quality.
May I express appreciation to Mr.. William C. Mills for his guidance and
assistance. Please feel free to contact me at [phone] as you wish.
Sincerely,
Michelin North America, Inc.
James D. Fannin
Environmental Engineer

�er.Zco.ti 3-D 64 tb N�j�O,
`�`
%�B� [e Permit'N°o. NCS000373j�cw 0
SECTION B: ANALYTICAL MONITORING REQUIREMENTS
Daring the period beginning on the effective date of the permit and lasting until expiration, the
permittee is authorized to discharge stormwater subject to the provisions of this permit.
Analytical monitoring of stormwater discharges shall be performed as specified below in Table
1.
All analytical monitoring shall be performed during a representative storm event. The required
monitoring will result in a minimum of 5 analytical samplings being conducted over the term of
the permit at each stormwater discharge outfall (SDO). The permittee shall complete the
minimum 5 analytical samplings in accordance with the schedule specified below in Table 2.
Table 1. Analytical Monitoring Requirements
. Discharge
Measurement
Sample
Sample
Characteristics
Units
Frequencyl
Type2 :
Location3
Chemical Oxygen Demand (COD)
mnJl
�nu`Ily
Grab
SDO
H
standard
/-4�An ualiy
Grab
SDO
Oil and Grease4
m 1./,
I/ H ) Ann ally
Grab4
SDO
Total Rainfall
inches
A�� Annually
Rainfall Event Duration �.�
�minutes
L'� Annually
Footnotes:
1 Measurement Frequency: Once per year
on the month and day of issua I of the F
u
permit tern. A year is defined as the 12 month period beginning
See Table 2 for schedule of monitoring periods.
2 If the stormwater runoff is conl'rolled•by a stormwater detention pond, a grab sample of the discharge from the
pond shall be collected within the first 30 minutes of discharge. If the detention pond discharges only in response
to a storm event exceeding a ten year design storm, then no analytical monitoring is required and only qualitative
monitoring shall be performed.
3 Sample Location: Samples shall be collected at each stormwater discharge outfall (SDO) unless representative
outfall status has been granted.
4 The grab sample for oil and grease should be skimmed from the surface in a quiescent (calm) zone. if possible.
Table 2. Monitoring schedule (for Permits issued 06/01 0/ 5
:` Monitoring period
Sample Number
Start
End
Year I
1
June 1, 2005
May 31, 2006
Year 2
2
June I, 2006
May 31, 2007
Year 3
3
June I, 2007
May 31, 2008
Year 4
3
June 1, 2008
May 31, 2009
Year 5
5
June 1, 2009
May 31, 2010
SECTION C: QUALITATIVE MONITORING REQUIREMENTS
Part 11 Page 4 of 6

Permit No. NCS000373
Qualitative monitoring requires a visual inspection of each stormwater outfall regardless of
representative outfall status and shall be performed as specified below in Table 3. Qualitative
monitoring is for the purpose of evaluating the effectiveness of the Stormwater Pollution
Prevention Plan (SPPP) and assessing new sources of stormwater pollution. No analytical tests
are required. Qualitative monitoring of stormwater outfalls is performed when stormwater
discharge occurs but does not need to be performed during a representative storm event.
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 Stormwater Pollution Prevention
Plan.
All qualitative monitoring will be performed twice per year, once to the spring (April - June) and
once in the fall (September - November).
f
Table 3. Qualitative Monitoring Requirements
Discharge Characteristics
Frequency
Monitoring
Locations
Color
Semi -Annual /
/,SDO
Odor
//
,Semi -Annual C
v
7 SDO
ClaritySemi-Annda
11 �,.,
SDO
FloatingSolids
/Sem Annual
SDO
Suspended Solids
ff "'
( Semi,Annual
SDO
Foam
i
Semt-Annual
SDO
Oil Sheen
Semi -Annual
SDO
Other obvious indicators
Semi -Annual
SDO
of stormwater pollution
Footnotes:
1 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 4. This monitoring shall be performed at all
outfalls which discharge stormwater runoff from vehicle maintenance areas.
All analytical monitoring shall be performed during a representative storm event. The required
monitoring will result in a minimum of 4 analytical samplings being conducted over the term of
the permit at each stormwater discharge outfall (SDO) which discharges stormwater runoff from
Part 11 Page 5 of 6

Permit No. NCS000373
vehicle maintenance areas. The permittee shall complete the minimum 4 analytical samplings in
accordance with the schedule specified in Table 5. below.
Table 4. Analytical Monitoring Requirements for On -Site Vehicle Maintenance
Discharge Characteristics
Units
Measurement
Frequencyl
Sample
Type'-
Sample
Location3
H
standard
Quarterly- 4' year
Grab
SDO
Oil and Grease
m /I
Quarterly- 4' year
Grab
SDO
Total suspended Solids
m I
Quarterly- 4" year
Grab
SDO
New Motor Oil Usage
allons/month
Quarterly- 4' year/
Estimate
Total Rainfall
inches
Quarter/ 4�,yea�\,
_
Rainfall Event Duration
minutes
Quanerlyt 4" ye ��
Footnotes:
I Measurement Frequency: Once per quarter during
month period beginning on the month and day of i�
periods. /
2 If the stormwater runoff is control
pond shall be collected within the
to a storm event exceeding a ten y
monitoring shall be performed.
3 Sample Location: Samples
stormwater runoff from are
'fable 5. Monitoring schedule
tit term. A year is defined as the 12
See Table 5 for schedule of monitoring
Mention pond, a grab sample of the discharge from the
:harge. If the detention pond discharges only in response
no analytical monitoring is required and only qualitative
at each stormwater discharge outfall (SDO) that discharges
maintenance activities occur.
(for Permits issued 06/01/05)
Monitoringperiod,
'Sample Number
Start
End
Year 4 - 1" quarter
I
June 1, 2008
August 31, 2009
Year 4 - 2"a quarter
2
September 1, 2008
November 30, 2008
Year 4 - 3`d quarter
3
December 1, 2008
February 28, 2009
Year 4 - 4"' quarter
4
March I, 2009
May 31, 2009
Part 11 Page 6 of 6

NCS000373
` 3/29/2005 Addendum to Staff Report for NCS000373
The analytical monitoring strategy for stormwater permits is shifting to Semi -Annual (spring and
fall windows —same as qualitative monitoring) in most cases to ensure sufficient data are
collected at facilities throughout the permit term. Also, benchmark concentrations are being
incorporated into permits for most parameters [except for nutrients, when the only reason is that
discharge is to NSW classified waters (not because of materials or processes), and the purpose is
only to determine whether a site is a significant contributor.] Stormwater discharge
measurements above these benchmark levels will prompt the permittee to re-examine the
effectiveness of its BMPs and SPPP, and to document efforts taken to reduce run-off
contamination.
This permit is being revised prior to Public Notice to (1) require semi-annual monitoring (a
change from annual in the previous permit), (2) to include benchmark concentrations for COD,
pH, and Oil & Grease in Section B, and (3) require semi-annual monitoring for vehicle
maintenance activities (as well as benchmarks for those parameters). This facility historically
has not triggered vehicle maintenance monitoring and will not likely be affected by the changes
to Section D.
IM

Section B: Chapter 8
Yadkin -Pee Dee River Subbasin 03-07-08
Includes Yadkin River below High Rock Dam, Lick Creek, Badin
Mountain Creek and Lake
8.1 Water Quality Overview
Subbasin 03-07-08 at a Glance
Land and Water
Total area: 294 mi'
Stream miles: 155.0
Lake acres: 5,048.8
Population Statistics
1990 Est. Pop.: 18,811 people
Pop. Density: 68 persons/mi'
Land Cover (%)
Forest/Wetland: 67.9
Surface Water: 8.0
Urban: 0.8
Cultivated Crop: 2.5
Pasture/
Managed Herbaceous: 20.9
This long, relatively narrow subbasin is made up almost
entirely of reservoirs in the Yadkin -Pee Dee River below
High Rock dam. Tuckertown, Narrows (Badin), Falls and
Tillery dams are all contained within its boundaries. Major
tributaries that are discussed here include Lick Creek and
Mountain Creek. The confluence with the Uwharrie River
(subbasin 03-07-09) between Falls and Tillery marks the
beginning of the Pee Dee River. Municipalities within the
subbasin include Denton, Richfield, Badin and Norwood.
A map including the locations of NPDES discharges and
water quality monitoring stations is presented in Figure 13-
9. Table B-16 contains a summary of monitoring data
types, locations and results. Use support ratings for waters
in this Subbasin are summarized in Table B-17. Appendix
I provides a key to discharge identification numbers. Refer
to Appendix III for a complete listing of monitored waters
and more information about use support ratings.
There is a significant amount of public land in this subbasin, especially when compared with
other parts of the Yadkin -Pee Dee River basin. Morrow Mountain State Park is nestled in a large
bend of the river between Falls and Tillery. In addition, there are large tracts of the Uwharrie
National Forest along the southeastern shoreline of Badin Lake and south beyond where the
Uwharrie River enters the Yadkin -Pee Dee.
Public land likely contributes significantly to the 68 percent forested area. A very small portion
of the Subbasin is characterized as urban and 8 percent is surface water, reflecting two large
reservoirs and the riverine environment. The estimated population of the basin and the density
are low, although projected population increases range from 21 percent in Stanly County to 25
percent in Davidson County between 2000 and 2020.
There are ten NPDES permitted discharges and one registered animal operation (swine).
Although a few discharge violations were reported during this assessment period, most were
minor and no facility is currently in significant noncompliance. The capacity for poultry
production in this subbasin increased by 50 percent between 1994 and 1998.
Section 8: Chapter 8 - Yadkin -Pee Dee River Subbasin 03-07-08 191

Sector Notebook
Rubber and Miscellaneous Plastics Products
Exhibit 21
Rubber Products Manufacturing Process Pollution
fugitive emissions are also produced as the chemicals are loaded into the mixer.
Emissions from the internal mixers are typically controlled by baghouses.
Exhausts from the collection hoods are ducted to the baghouses for control of
particulate and possibly particle -bound semi-volatiles and metals. The
following is a list of the major chemicals used in the rubber compounding and
mixing processes which can constitute these fugitive emissions:
• Processing Aids - zinc compounds
• Accelerators - zinc compounds, ethylene thiourea, and diethanolamie
• Activators- nickel compounds, hydroquinone, phenol, alphanaphthylamine,
and p-phenytenediamine
• Age Restorers - selenium compounds, zinc, compounds, and lead compounds
• Initiator - benzoyl peroxide
• Accelerator Activators - zinc compounds, lead compounds, and ammonia
• Plasticizers - dibutyl phthalate, dioctylphthalate, and bis(2-ethylhexyl
adipate)
• Miscellaneous Ingredients - titanium dioxide, cadmium compounds,
organic dyes, and antimony compounds.
VOC emissions are also an environmental concern in the rubber product
manufacturing process. A 1994 RMA Emissions Factors study analyzed data on
VOC emissions resulting from the mixing, milling, extruding, calendering,
vulcanizing, and grinding processes. Although the findings showed extremely low
VOC emissions for each pound of rubber process, large facilities processing great
quantities of rubber face the potential of significant VOC emissions. For example,
a facility must process 100,000 pounds of rubber to produce 10 pounds of VOCs
during the mixing process. These emissions may add up, however, at large tire
facilities producing 50,000 tires a day. The following are the finalized RMA VOC
emissions factors for the various processes:
• Mixing: l x 104 lb VOC/lb rubber mixed (uncontrolled, i.e., before the
control device)
• Milling: 8 x 10 5 lb VOC/lb rubber processed
• Extruding: I x 1 t) 5 lb VOC/lb rubber processed
September 1995
35
SIC Code 30

"
Rubber and Miscellaneous Plastics Products Sector Notebook Project
Solid Waste
• Calendering: 3 x 10 5 lb VOC/lb rubber processed
• Vulcanizing: 4 x 10 ° lb VOC/lb rubber processed
• Grinding (during finishing): 6 x 10 3 lb VOC/lb rubber removed
(controlled, i.e., after the control device).
The RMA VOC emissions factors have been sent to EPA for review and possible
inclusion in AP-42.
Solvent evaporation is another source of VOC emissions. Solvents are used in
various capacities during the rubber product manufacturing process. For example,
solvents are used to degrease equipment and tools and as a type of adhesive during
building. Typically, releases of solvents occur either when the spent solvent
solutions are disposed as hazardous wastes or when degreasing solvents are allowed
to volatilize. In some facilities, mold release compounds, sprayed onto the cavities
of compression molds, produce significant fugitive emissions. Solvents are
becoming less of an issue as water, silicon, and non -solvent based release
compounds are now common.
Solid wastes are also an issue at rubber product manufacturing facilities. Surface
grinding activities that generate dust and rubber particles are typically controlled by
a primary cyclone and a secondary baghouse or electrostatic precipitator. This
baghouse-captured particulate matter (chemicals, ground rubber, etc.) from
compounding areas, banburys, and grinders is a source of solid waste. Used
lubricating, hydraulic, and process oils are also prevalent at most manufacturing
facilities.
Scorched rubber from mixing, milling, calendering, and extruding is a major solid
waste source within the rubber product manufacturing facilities, as is waste rubber
produced during rubber molding operations. Waste rubber can be classified into
three categories: (1) uncured rubber waste; (2) cured rubber waste; (3) off -
specification products. Currently, much of the uncured rubber waste is recycled at
the facility. Cured rubber waste is either recycled at the facility or sold to other
companies who use it to make products such as mud Flaps and playground mats.
Off -specification products can be sold to other companies who make products from
shredded or scrap rubber or it can be disposed. These practices are discussed further
in the section on pollution prevention.
Code 30 36 September 1995

Sector Notebook Project Rubber and Miscellaneous Plastics Products
Waste Water
Waste water from cooling, heating, vulcanizing, and cleaning operations is an
environmental concern at many facilities. Contaminants can be added to waste water
in direct contact cooling applications such as extruder cooling conveyors and from
direct contact steam used in vulcanizing operations. The residual in adhesive
dispensing containers and contaminated adhesives can also be sources of
contaminated waste water.
Zinc is of particular concern as a constituent of storm water for the facilities
involved in manufacturing and processing rubber products. A study by the RMA
identified several processes through which zinc might be introduced into storm
water. Inadequate housekeeping is considered to be the primary source of zinc.
Inefficient, overloaded or malfunctioning dust collectors and baghouses are another
source of zinc. Faciliti s that grind rubber usually -i m e_dust. is dust, composed
partially of zinc, can go untreated no dust collector and be released into the
atm`osphere_thrcugh ventilation fans. The -ventilation fans, which are typically
located the ceilings, deposit the dust on the roof where it is exposed to rain and
hence to storm water. Some facilities use zinc stearate slurry to prevent sticking
between rubber products and have indicated that the slurry frequently drips to the
floor and eventually drains to a storm water outlet.
Like plastic products, the leaching potential of rubber products disposed in landfills
poses a potential environmental concern. This is a concern for rubber product
manufacturing facilities which may have to dispose of scrap rubber that they are
unable to sell. The RMA assessed the levels of chemicals, if any, leached from
waste rubber products using EPA's June 13, 1986 proposed Toxicity Characterization
Leaching Procedure (TCLP). TCLP tests were performed on 16 types of rubber
products to assess the leaching potential of over 40 different chemicals which
included volatile organics, semi -volatile organics and metals. Results of the TCLP
study indicate that none of the rubber products tested, cured or uncured, exceeded
proposed TCLP regulatory levels. Most compounds detected were found at trace
levels (near method detection limits) from ten to one hundred times less than
proposed TCLP regulatory limits. The TCLP regulatory levels adopted after June
13, 1986 were even less stringent than the original proposal.
September 1995 37 SIC Code30

_,V
Rubber and Miscellaneous Plastics Products
Sector Notebook
Tires
The resource material and pollution outputs from the tire manufacturing process
include all of the outputs discussed above in the rubber product manufacturing
process. There is however an emphasis on the VOC emissions which result from
cementing and spraying operations (see Exhibit 22) and on scrap tire disposal.
VOC Emissions
Scrap Tires
VOC emissions from the rubber tire manufacturing process are caused by solvent
application to the different tire components before, during, and after the building
process (these VOC emissions can also result from the manufacture of other rubber
products that require cementing or gluing). The principal VOC emitting processes
affected by NSPS regulations are undertread cementing operations, sidewall
cementing operations, tread end cementing operations, bead cementing operations,
green tire spraying operations, Michelin-B operations, and Michelin-C automatic
operations. Michelin-B and -C operations are confidential and cannot be revealed
to the public. They are however known and regulated by EPA. All cementing
operations refer to the system used to apply cement to any part of the tire. The green
tire spraying operation refers to the system used to apply a mold release agent and
lubricant to the inside and/or outside of green tires to facilitate the curing process and
to prevent rubber from sticking to the curing press. VOC-emissions also occur in
limited amounts from operations where rubber is heated. Such operations include
mixing, milling, extruding, calendering, vulcanizing, and grinding.
Probably the biggest environmental concern with respect to rubber tires is the
disposal of scrap tires. In 1992, it was estimated that the U.S. had approximately
two billion scrap tires, with annual additions of 200 to 250 million tires. These tires
pose three environmental threats. The first being that tire piles are a fire hazard and
burn with an intense heat which gives off dense black smoke. These fires are
extremely difficult to extinguish in part because tire casings form natural air pockets
that supply the oxygen which feeds the flames. The second threat is that the tires
trap rain water which serves as a nesting ground for various insects such as
mosquitoes, and in areas where there are scrap tire piles there tend to be severe insect
problems. The third and most important environmental threat associated with scrap
tires is that discarded tires are bulky, virtually indestructible, and when buried tend
to work their way back to the surface as casings compressed by the dirt slowly spring
back into shape and "float" the tire upward. This problem has led to either extremely
high tipping fees for scrap tires in landfills - at least twice the fee for municipal solid
waste - or total bans on whole tires in landfills. As discussed above, the RMA has
conducted testing to verify that tires are not hazardous wastes based on TCLP
analysis. The many efforts underway to address this problem are discussed in the
pollution prevention section of this profile.
SIC Code 30 38 September 1995

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Alan W. Klimek, P.E., Director
March 10.2004
MICI IELIN AIRCRAFT TIRE CORPORATION
ATTN: DON MATTHEWS, OR SUCCESSOR
40589 SOITfI I STANLY SCHOOL
NORWOOD, NC 28128
Dear Permiuee:
1�
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCE5
Subject: NPDES Stormwater Permit Renewal
Michelin Aircraft "fire Corporation
Permit Number ncs000373
Smnly County
Your facility is currently covered for stormwater discharge under NPDES Permit ncs000373. This permit expires
on September 30, 2004. North Carolina Administrative Code (15A NCAC 2FI.0105(e)) requires that an
application for permit renewal be filed at least 180 days prior to expiration of the current permit. In order to assure
your continued coverage under your permit, you must apply to the Division of Water Quality (DWQ) for renewal
of your permit. To make this renewal process easier, we are informing you in advance that your permit will be
expiring. Enclosed you will find an individual permit renewal application form, supplemental information request,
and Stormwater Pollution Prevention Plan certification.
Filing the application form along with the requested supplimental information will constitute your application for
renewal of your permit. As stated above, the application form must be completed and returned along with all
requested information by April 3, 2004 in order for the permit to be renewed by September 30, 2004.
Failure to request renewal by April 3, 2004 may result in a civil assessment of at least $500.00. Larger penalties
may be assessed depending on the delinquency of the request. Discharge of stormwater from your facility without
coverage under a valid stormwater NPDES permit would constitute a violation of NCGS 143-215.1 and could
result in assessments of civil penalties of up to $25,000 per day.
If you have any questions regarding the permit renewal procedures please contact Bill Mills of the Stormwater and
General Permits Unit at [phone], ext. 548.
Sincerely,
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
cc: Central Files
Stormwater and General Permits Unit Piles
Mooresville Regional Office
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

The Stanly News and Press
P.O. Box 488
Albemarle, NC 28002
�i [phone]
DESCRIPTION
STARTDATE CLASS
MURPHY, KIM
NCDENRIDWOIBUDGET OFFICE
RALEIGH,NC 27626-0535
WORDS INS CHG
LS 'O LS U V 1.5 L
D
MAR 1 4 2000
DENR - WATER QUALITY
POINT SOURCE BRANCH
PO BOX 29535
03/21/99 300 PUBLIC NOTICE STATE 304
NORTH CAROLINA, STANLY COUNTY
AFFIDAVIT OF PUBLICATION
Before the undersigned, a Notary
Public of said County and State, duly
commissioned, qualified, and authorized by
law to administer oaths, personally appeared:
LaJeune Waggoner, who being first duly sworn,
deposes and says: that he is Publisher of a
newspaper known as THE STANLY NEWS AND PRESS,
published, issued, and entered as second class mail
in the City of Albemarle, in said County and State;
that he is authorized to make this affidavit and sworn
statement; that the notice or other legal advertisement,
a true copy of which is attached hereto, was published
in THE STANLY NEWS AND PRESS on the dates
specified on the copy attached and that the said
newspaper in which such notice, paper, document, or
legal advertisement was published was, at the time of
each and every such publication, a newspaper meeting
all of the requirements and qualifications of Section 1-597
of the General Statures of North Carolina and was a
qualified newspaper within the meaning of Section 1-597
of the General Statures of North Carolina.
63.84
AFFIDAVIT OF INSERTION
Date: 3/23/99
.,1
NOT
a! ;n
and subject to s
i
Pztiersons wishlnc
the proposed de
same fin:wn Ing
than Apnl 23, 1'
to that dote will
of. final'determ
permiC A, public
Director of the
significant de9i
Permit.
A copy of me.(
be held where the
,ter duality finds a
areal in a proposed
535,':
The �appllcatioh and other informatbe
ion may
inspected at these locations during normal office
hours. Copies of the information on ment off lea le re avast s il-
quest
able upon request and pay
i eproduction. All such comme
nts or. requests .
iegarding a proposed Order•should make refer-`
ence to the name listedabove
,Date fdaich l8, g99r .'.'.
` David A. Goodrich
$WOfn roan : ••'KenT Staves, Director
this d2 �, ` Division of Water Quality
re
.NPDES NO 0599 South Stanly School Road:
Corporation, applied for
Norwood, North CarolmA, 28128 has appl'
a permit to discharge stromwate_ r assodated with
industrial.
MCactivities at a fatality located
rwood Stanly pd
at 405119
y OmmIS:
South, Stanly School Road, to the waters of
County. The facility discharges
the Yadkin Pee Dee River basin
March 25 1999___

Permit No. NCS000373
SECTION C: LOCATION MAP
Part I Page 2 of 2

Beverly Eaves Perdue
Governor
_ v
RIC ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Coleen H. Sullins
Director
December 7, 2009
Mr. Bill Van Someren
Michelin Aircraft Tire Company A Division of Michelin N America Inc
PO Box 19001
Greenville; SC 29615
Dee Freeman
Secretary
Subject: NPDES Stormwater Permit Coverage Renewal `
Michelin Aircraft Tire Company, A Division of
Michelin N. America, Inc.
Permit Number NCS000373
Stanly County
Dear Permittee:
Your facility is currently covered for stormwater discharge under NPDES Permit NCS000373 , This
permit expires on May 31, 2010. To assure consideration for continued coverage under your individual"'
permit, you must apply to the Division of Water Quality (DWQ) for renewal of your permit. Enclosed . ... _
you will find an individual permit Renewal Application Form, Supplemental Information request, and
Stormwater Pollution Prevention Plan Certification for your facility.
Filing the application form along with the requested supplemental information will constitute your
application for renewal of this permit. Until your permit renewal is completed and you receive a new
permit, please continue to comply with all conditions and monitoring requirements in your expired
--
NPDES Stormwater permit.
The application and supplement must be completed and returned to DWQ by March 1. 2010. Failure too�"'
request renewal within this time period will result in delay of -your permit renewal and may result in a
civil assessment. Discharge of stormwater from your facility without coverage under a valid V
stormwater NPDES permit.would constitute a violation of NCGS 143-215.1 and could result in
assessments of civil penalties of up to $25,000 per day.
If you have any questions'regarding permit renewal procedures please contact Brian Lowther of the
Stormwater Permitting Unit at (919)-807-6368 or [e-mail]. -,
Sincerely,
Bradley Bennett, Supervisor
Stormwater Permitting Unit
Cc: Central Files
SPU Files
Mooresville Regional Office
1617 Mail Service Center, Raleigh, North Carolina 27699.1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service: 1-877,623-6748
Internet vmv.nmaterquality.org
An Equal Opportunity 1 Arfrmabve Action Employer
One
NorthCarolina
Naturally

OF VAT,,
Permit Coverage
Renewal Application Form
National Pollutant Discharge Elimination System Permit Number
Stormwater Discharge Permit NC5000373
The following is the information currently in our database for your facility. Please review this information carefully and
make all corrections/additions as necessary in the space provided to the right of the current information.
Owner Affiliation Information -*Reissued Permit will be mailed to the owner address
Owner / Organization Name:
Owner Contact:
Mailing Address
Phone Number:
Fax Number:
E-mail address:
Michelin Aircraft Tire Company A Division
of Michelin N America Inc
Bill Van Someren
PO Box 19001
Greenville, SC 29615
[phone]
Facilitv/Permit Contact Information
Facility Name: Michelin Aircraft Tire Company, A Division
of Michelin N. America, Inc.
Facility Physical Address: 40589 S Stanly School
Norwood, NC 28128
Facility Contact: Don Matthews
Mailing Address:
Phone Number:
Fax Number:
E-mail address:
Discharge Information
Receiving Stream
Stream Class:
Basin:
Sub -Basin:
Number of Outfalls
40589 s Stanly School
Norwood,NC28128
Cedar Creek
WS-Iv
Yadkin River Basin
03-07-08
Impaired Waters/TMDL
Does this facility discharge to waters listed as impaired or waters with a finalized TMDL? ❑ Yes ❑ No ❑ Don't Know
( for information on these waters refer to http.//h2o. enr.state. nc, us/su/lmpaired Waters TMDL,/ )
CERTIFICATION
I certify.that I am familiar with the information contained in the application and that to the best of my knowleda_!-_ and
belief such information is true, complete and accurate.
Signature
Date
Print or type name of person signing above. I . Title
Please return this completed renewal application form to: Stormwater Permitting Unit
Attn: Brian Lowther
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

...
V
WATER
`w —i
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleco H. Sullins, Director
Division of Water Quality
November 7, 2008
Mr. David R. Stroman
Michelin Aircraft Tire Co., a Division of Michelin North America, Inc.
40589 S. Stanly School Road
Norwood, NC 28128
Subject: Permit No. NCS000373
Michelin Aircraft Tire Co., Inc.
Formerly Michelin Aircraft Tire Co., LLC
Stanly County
Dear Mr. Stroman:
Division personnel have reviewed and approved your request to change your name under the individual
permit, received on June 30, 2008.
Please find enclosed the revised Certificate of Coverage. The terms and conditions contained in the permit
remain unchanged and in full effect. This revised Certificate of Coverage is issued under the requirements of
North Carolina General Statutes 143-215.1 and the Memorandum of Agreement between North Carolina and the
U.S. Environmental Protection Agency.
If you have any questions, please contact the Stormwater Permitting Unit at [phone], extension 502.
Sincerely,
ORiGNAL SIGNEC
Coleen H. Sullins
cc: DWQ Central Files
Mooresville Regional Office
Stormwater Permitting Unit
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: h2o.encstate.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
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STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT NO. NCS000373
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act, as amended,
MICHELIN AIRCRAFT TIRE COMPANY
A DIVISION OF MICHELIN NORTH AMERICA, INC.
is hereby authorized to discharge stormwater from a facility located at
MICHELIN AIRCRAFT TIRE COMPANY, INC.
40589 SOUTH STANLY SCHOOL ROAD
NORWOOD
STANLY COUNTY
to receiving waters designated as a UT to Cedar Creek, a class WS-IV stream, in the Yadkin Pee -Dee River Basin in
accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, 111,
IV, V, and VI hereof.
,This permit shall become effective November 7, 2008
This permit and the authorization to discharge shall expire on May 31, 2010
Signed this day November 7, 2008 C ':G1NAl SJC,I1\'c `.
Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission

12-20-05
To: Division of Water Quality
Water Quality Section
Attn: Central Files
1617 Mail Service Center
Raleigh, NC 27699-1617
From: Michelin Aircraft Tire Company, LLC
NPDES Permit # ncs000373
40589 S. Stanly School Rd.
Norwood, NC 28128
Stanly County
To Whom It May Concern,
Please accept this submission summarizing both the Analytical and Qualitative results of
the Stormwater Discharge Outfalls (SDO) present on our site. This report represents the
first samples taken since the issuance of our permit in June of 2005. The sampling
follows the schedule set forth in our permit.
I would like to draw your attention towards two issues:
1. There was a mishap during the shipping of the 1 ]-21-05 stormwater samples. The lid
came off of the SDO #1 sample intended for "Oil & Grease" and emptied the contents
into the cooler. This required a second sample to be taken on 11-28-05. Therefore you
will see two sampling dates as well as two analytical and qualitative reports.
2. The Chemical Oxygen Demand (COD) reading for Stormwater Discharge Outfall 92
(160 mg/1) is above the benchmark stated in our permit (120 mg/1). This is the highest
reading recorded from this or any outfall on -site. We believe the root cause to be the
farm located directly adjacent to our site. The farm raises cattle and has a pond area that
is located across from a 24" drainage pipe that connects directly into our storm sewer.
The pond's dike has been breached and the pond empties into the storm sewer during all
significant storm events. (We have confirmed this by observing fish in our small 300
gallon pond area when there is no other way to introduce fauna into the otherwise closed
sewer system.)

Our belief is that the chemicals used on the farm combined with the waste deposited into
the pond by the cattle have driven the COD levels upward. A review of past data from
this outfall shows the lowest reading occurring in Sept. / 2004 (28 mg/1) and a peak
reading in Feb. / 2004 (120 mg/1) with an arithmetic mean of 59.25 mg/l for all past data.
A visual inspection of the farmer's pond on 12/20/05 shows that there is a constant flow
of water coming from underneath the pond's overflow pipe. The overflow pipe would
ordinarily only discharge water into the 24" drainage pipe in the event that the pond rose
significantly. The fact that there is a constant flow from beneath the pipe demonstrates
the breaching of the containment wall. The water discharging from the breach creates
cream colored foam on the water below.
Our new permit requires analytical samples to be taken twice annually. We will review
the results of the Spring, 2006 sampling to see what the COD levels are. If they are still
elevated and / or exceed the benchmark, we will determine a corrective action and
implement it. Before we react, however, we need to verify that the data point collected
on 11/21/05 was accurate and not a statistical "outlier".
Please note that we are going to explore a pair of "possible" engineering solutions. The
first may permit our facility to take stormwater samples prior to the confluence of the
farmer's pond water and our stormwater runoff. If that is feasible, it may. require the
designation of a third outfall for our site. A second option considered is to provide an
alternate path for the farmer's pond water by the introduction of additional sewers.
Discussions regarding the elevated reading for this sample were held with Wes Bell of
the Regional office of the Division of Water Quality as well as Bethany Georgoulias of
the Raleigh DWQ. Both individuals felt that the proposed plan was valid. If you have
any questions, comments or concerns, please contact me at the number below.
Respectfully,
Da HA 4 _1.
Don Matthews
EP Mgr. MATC
704-474-7726 (office)
704-474-7756 (fax)
704-244-1625 (mobile)
[e-mail] in.com

Michelin Letter
Subject: Michelin Letter
From: "Matthews, Don" <[e-mail]>
Date: 20 Dee 2005 14:14:00 -0500
To: [e-mail]
Hi Bethany,
Thanks again for all of your help. Here is a cc of the letter that I am
enclosing with our stormwater samples. It doesn't have the Michelin letterhead,
but the text is the same. Call if you have questions. Hope you have a relaxing
and safe holiday!
Don Matthews .
EP/AV/MATC
Michelin Aircraft Tire Company, Llc
40589 S. Stanly School Rd.
Michelin D-3 Restricted Norwood, NC 26128
Cat 201-101 < 90 days Phone- 704-474-7726
Fax - 704-474-7756
Cell - 704-244-1625
[e-mail]
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