NCS000233_Renewal application_20160830

©�L, Permit Coverage
NCDENR Renewal Application Form
National Pollutant Discharge Elimination System
Stormwater Individual Permit
NPDES Permit Number
NCS000233
Please provide your permit number in box in the upper right hand corner, complete the information in the space provided
below and return the completed renewal form along with the required supplemental information to the address indicated.
Owner Information
* Address to which permit correspondence will be mailed
Owner / Organization Name:
Trinity Manufacturing, Inc.
Owner Contact:
Daryl Mitzel
Mailing Address:
PO Box 1519 /
V
Phone Number:
910-410-2726
Fax Number:
910-817-4791
E-mail address:
dmlf2elCa%trinllymfa.
Facility Information
Facility Name:
Facility Physical Address:
Facility Contact:
Mailing Address:
Phone Number:
Fax Number:
E-mail address:
Permit Information
Permit Contact:
Mailing Address:
Phone Number:
Fax Number:
E-mail address:
Dischage Information
Receiving Stream:
Stream Class:
Basin:
Sub -Basin:
Number of Outfalls
Trinity Manufacturing, Inc.
11 E.V. Hogan Drive /
Hamlet, NC 28345-8812 V
Karen Messana
910-419-6566
kmessa na Capri n itvmfa.com
South Prong Falling Creek
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to
To LANDio
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Facility/Activity Changes Please describe below any changes to your facility or activities since issuance of your permit. Attached a
separate sheet if necessary.
Changes at the facility include implementing a batch process to produce chlorinated paraffins, constructing a maintenance/receiving/
warehouse building, and expanding the employee parking lot. See enclosures for more information.
CERTIFICATION
I certify that I am f
such information is
the information contained in the application and that to the best of my knowledge and belief
Signature
Daryl Mitzel
Print or type name of person signing above
Please return this completed application form
and requested supplemental information to:
Date
Executive Vice President
Title
SW Individual Permit Coverage Renewal
Stormwater Permitting Program
1612 Mail Service Center
Raleigh, North Carolina 27699-1612

SUPPLEMENTAL INFORMATION REQUIRED FOR RENEWAL OF INDIVIDUAL
NPDES STORMWATER PERMIT
Two copies of each of the following shall accompany this submittal in order for the application
to be considered complete:
(Do not submit the site Stormwater Pollution Prevention Plan)
Initials
A'B� 1. A current Site Map from the Stormwater Pollution Prevention Plan. The location of
industrial activities (including storage of materials, disposal areas, process areas and
loading and unloading areas), drainage structures, drainage areas for each outfall,
building locations and impervious surfaces should be clearly noted.
'f3 2. A summary of Analytical Monitoring results during the term of the existing permit
(if your permit required analytical sampling). Do not submit individual lab reports.
The summary can consist of a table including such items as outfall number,
parameters sampled, lab results, date sampled, and storm event data.
3. A summary of the Visual Monitoring results. Do not submit individual monitoring
reports. The summary can consist of a table including such items as outfall number,
parameters surveyed, observations, and date monitoring conducted.
4. A summary of the Best Management Practices utilized at the permitted facility.
Summary should consist of a short narrative description of each BMP's in place at
the facility. If the implementation of any BMP's is planned, please include
information on these BMP's.
5. A short narrative describing any significant changes in industrial activities at the
permitted facility. Significant changes could include the addition or deletion of
work processes, changes in material handling practices, changes in material storage
practices, and/or changes in the raw materials used by the facility.
6. Certification of the development and implementation of a Stormwater Pollution
Prevention Plan for the permitted facility (Sign and return attached form).
If the final year analytical monitoring of the existing permit term has not been completed
prior to filing the renewal submittal, then the last years monitoring results should be submitted
within 30 days of receipt of the laboratory reports. (i.e. do not withhold renewal submittal
waiting on lab results)

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TORM WATER SITE PLAN(RL).dwg

Trinity Manufacturing, Inc.
Stormwater Discharge Permit Renewal - 2016
NCS 000233
Analytical Monitoring Results Summary for Outfall OF-1
Outfall
OF-1
Total
Rainfall
SM 5210B
EPA 410.4
SW-846 9020E
EPA 300.0
SW846 9040C
BOD
COD
Chloroplij rin
Chloride
pH
Testing Lab
Benchmark
inches
30 mg/L
120 mg/L
µg/L
860 mg/L
6-9
Date Sample
Collected,
mm-dd-yy
06-26-16
0.4
2.25
16.8
23.1
10.3
7.37
Test America
02-04-16
0.5
4.67
24.1
111
7.19
Test America
02-04-16
0.5
42
8.46
ALS
08-20-15
0.4
3.5
4.32
48.4
8.46
Test America
08-20-15
0.4
1
28
8.46
G-Cal
11-17-14
0.35
4.29
25.0
1 18.2
7.63
Test America
11-17-14
0.35
27.2
7.63
G-Cal
09-04-14
0.3
4.54
25.4
22.9
8.46
Test America
09-04-14
0.3
48.5
8.46
G-Cal
12-04-13
0.3
MDL NP m /L
33.7
33.4
7.0
Test America
12-04-13
0.3
29.7
7.0
G-Cal
08-19-13
0.9
MDL ND2 m /L
6.06
4.58
7.3
Test America
08-19-13
0.9
4.2
7.3
G-Cal
01-31-13
0.3
64.7
7.89
G-Cal
01-17-13
0.6
5.08
9.31
29.3
7.3
Test America
05-09-12
0.3
16
29
7.29
7.3
Test America
05-09-12
0.3
ND < 50
7.3
G-Cal

Trinity Manufacturing, Inc.
Stormwater Discharge Permit Renewal - 2016
NCS 000233
Analytical Monitoring Results Summary for Outfall OF-1
Outfall
OF-1
Total
Rainfall
SM 5210B
EPA 410.4
SW-846 9020E
EPA 300.0
SW846 9040C
BOD
COD
Chloropi fin
Chloride
pH
Testing Lab
Benchmark
inches
30 mg/L
120 mg/L
µg/L
860 mg/L
6-9
Date Sample
Collected,
mm-dd-yy
06-26-16
0.4
2.25
16.8
23.1
10.3
7.37
Test America
02-04-16
0.5
4.67
24.1
111
7.19
Test America
02-04-16
0.5
42
8.46
ALS
08-20-15
0.4
3.5
4.32
48.4
8.46
Test America
08-20-15
0.4
1
28
8.46
G-Cal
11-17-14
0.35
4.29
25.0
18.2
7.63
Test America
11-17-14
0.35
27.2
7.63
G-Cal
09-04-14
0.3
4.54
25.4
22.9
8.46
Test America
09-04-14
0.3
48.5
8.46
G-Cal
12-04-13
0.3
MDL ND m L
33.7
33.4
7.0
Test America
12-04-13
0.3
29.7
7.0
G-Cal
08-19-13
0.9
MDL N4 m IL
6.06
4.58
7.3
Test America
08-19-13
0.9
4.2
7.3
G-Cal
01-31-13
0.3
64.7
7.89
G-Cal
01-17-13
0.6
5.08
9.31
29.3
7.3
Test America
05-09-12
0.3
1 16
29
7.29
7.3
Test America
05-09-12
0.3
1
1
ND < 50
7.3
G-Cal

Trinity Manufacturing, Inc.
SUMMARY OF VISUAL MONITORING RESULTS (2012 — 2016)
Stormwater Permit No. NCS000233
Outfall No. OF-1
Other
Sampling
Color
Odor
Clarity
Floating
Suspended
Foam
Oil Sheen
Erosion or
Obvious
Date
Solids
Solids
Deposition
Indicators
of Pollution
06
Light gray
None
2
1
1
None
None
None
None
0.41,
.4"
02
Light gray
None
2
1
1
None
None
None
None
0.51,
.5"
08-20-15
Light gray
None
2
1
1
None
None
None
None
0.4"
11-17-14
No Color
Grayish
None
2
1
1
None
None
None
None
0.35"
Medium Tint
09-04-14
NoColor
0.3"
Medium Tint
None
2
1
2
None
None
None
None
12-04-13
No Color
0.3"
Light
None
2
1
1
None
None
None
None
089
No Color
0.91,
0."
Light
None
2
1
1
None
None
None
None
01-31-13
Not
Typical
Typical
Typical
Typical
Typical
Typical
Typical
None
0.3"
Observed
01
Typical
No
Typical
Typical
Typical
No
No
Not
None
0.61,
Observed
04-0412
Typical
Typical
Typical
Typical
Typical
Typical
Typical
Not
None
> 0.1"1
1
1
1
1 Observed
Form 9046 — Stormmter Visual Summary

Trinity Manufacturing, Inc.
SUMMARY OF VISUAL MONITORING RESULTS (2012-2016)
Stormwater Permit No. NCS000233
Outfall No. OF-1
Other
Sampling
Floating
Suspended
uso
ErosioDeposition
Ovious
Date
Color
Odor
Clarity
ids
fended
Foam
Oil Sheen
Indicators
of Pollution
06
Light gray
None
2
1
1
None
None
None
None
0.41,
.4"
02
Light gray
None
2
1
1
None
None
None
None
0.51,
.5"
08-20-15
Light gray
None
2
1
1
None
None
None
None
0.4"
11-17-14
No Color
Grayish
None
2
1
1
None
None
None
None
0.35°
Medium Tint
09-04-14
No Color
0.3"
Medium Tint
None
2
1
2
None
None
None
None
12-04-13
No Color
0.3"
Light
None
2
1
1
None
None
None
None
089
No Color
0.91,
0."
Light
None
2
1
1
None
None
None
None
01
Not
Typical
Typical
Typical
Typical
Typical
Typical
Typical
Observed
None
0.31,
0.3"
01
Typical
No
Typical
Typical
Typical
No
No
Not
None
0.61,
0.6"
Observed
04-04-12
Not
Typical
Typical
Typical
Typical
Typical
Typical
Typical
Observed
None
> 0.1"
I
I
I
I
I
I
I
Form 9046 - Stormwater Visual Summary

Trinity Manufacturing Inc.
Stormwater Discharge Permit NCS 000233
Best Management Practices (BMPs)
Best Management Practices for the site include a combination of operational and source
control BMPs. These BMPs have been implemented to minimize precipitation contact with
potentially contaminating activity, contain and treat precipitation contacting industrial activity,
and preemptively provide systems and equipment to deal with unanticipated occurrences.
General BMPs implemented throughout the facility to achieve stormwater pollution prevention
goals include:
• Vegetative areas are created and maintained to prevent erosion and sedimentation.
• Loading and unloading operations are either covered and/or done in areas designed to
catch stormwater which may contact these operations as well as any minor drips associated
with connecting or disconnecting.
• Storage of all bulk liquid materials at Trinity is provided with secondary containment.
Stormwater collected in these secondary containment areas is treated and discharged
through the sanitary sewer in accordance with its POTW IUP permit.
• Impervious surface are sloped to catch basins and routed to a stormwater detention pond
for the majority of industrial activity. Use of the stormwater detention pond is incorporated
in the Spill Response Plan
• Concrete pad areas are sloped and laid out to minimize or prevent stormwater run-off into
areas containing significant materials associated with industrial activity.
• Significant material areas are included as part of facility inspections to identify improvement
opportunities.
Best Management Practices (BMPs) address potential pollutant areas that have been identified
during facility inspections. The BMPs are designed to help reduce the potential for stormwater
pollution. BMP categories considered include: Flow Diversion, Exposure Minimization, Mitigate
Practices, Sediment and Erosion Prevention, Infiltration Practices, and Other Preventive
Practices such as Good Housekeeping, Preventive Maintenance, Visual Inspections, Spill and
Stormwater Plan Training, and Documentation.

Area 1- Storage of drums containing surfactant liquids and non -hazardous waste as well as
storage of empty totes and drums.
• Materials are stored in this area only on a temporary basis. While stored in this
area, containers are readily visible and any leakage or run-off can be dealt with
quickly.
• Drums of liquid surfactant are used on a seasonal basis. These inventories are
minimized and managed to eliminate carry-over of inventory between seasons.
• Drumming of dry materials in the area is scheduled around weather forecasts and
covered during periods of unanticipated precipitation. Following completion, the
area is swept to prevent contamination.
Area 3- Storage of empty nitromethane metal drums.
• Drums are pumped until empty and the bung caps are re -secured before being
temporarily stored while awaiting pickup.
• Empty drums are picked up for recycling on a frequent and regular basis.
Area 4- Railcar loading/unloading stations (Chloropicrin & Chlorine).
• Spill containment (railcar pans) is included at each railcar loading station. The pans
are piped to a treatment tank, treated if necessary, and discharged to the sanitary
sewer.
• Area lighting and video cameras facilitate enhanced surveillance of loading
operations above and beyond operator attendance.
• Loading operations are instrumented and automated to minimize opportunities for
overfilling.
Area 5- Storage area for used equipment.
• Used equipment stored in the area is decontaminated prior to its storage.
• Storage containers allow small, primarily metal, parts to be housed out of the
weather, minimizing opportunity for the formation of rust.
Area 6- Railcar loading stations (Caustic and HCI).
• Spill containment (railcar pans) is included at each railcar loading station. The pans
are piped to a treatment area, treated if necessary, and discharged to the sanitary
sewer.

• Area lighting and video cameras facilitate enhanced surveillance of loading
operations above and beyond operator attendance.
• Loading operations are instrumented and automated to minimize opportunities for
overfilling.
Area 7- Brine filter waste collection dumpster and salt unloading.
• Dumpster is set in a curbed area to allow collection of any leakage.
• Dumpster is kept covered to prevent stormwater contact.
• Salt conveying system is inspected and cleaned as part of the preventative
maintenance program.

Trinity Manufacturing Inc.
Stormwater Discharge Permit NCS 000233
Best Management Practices (BMPs)
Best Management Practices for the site include a combination of operational and source
control BMPs. These BMPs have been implemented to minimize precipitation contact with
potentially contaminating activity, contain and treat precipitation contacting industrial activity,
and preemptively provide systems and equipment to deal with unanticipated occurrences.
General BMPs implemented throughout the facility to achieve stormwater pollution prevention
goals include:
• Vegetative areas are created and maintained to prevent erosion and sedimentation.
• Loading and unloading operations are either covered and/or done in areas designed to
catch stormwater which may contact these operations as well as any minor drips associated
with connecting or disconnecting.
• Storage of all bulk liquid materials at Trinity is provided with secondary containment.
Stormwater collected in these secondary containment areas is treated and discharged
through the sanitary sewer in accordance with its POTW IUP permit.
• Impervious surface are sloped to catch basins and routed to a stormwater detention pond
for the majority of industrial activity. Use of the stormwater detention pond is incorporated
in the Spill Response Plan
• Concrete pad areas are sloped and laid out to minimize or prevent stormwater run-off into
areas containing significant materials associated with industrial activity.
• Significant material areas are included as part of facility inspections to identify improvement
opportunities.
Best Management Practices (BMPs) address potential pollutant areas that have been identified
during facility inspections. The BMPs are designed to help reduce the potential for stormwater
pollution. BMP categories considered include: Flow Diversion, Exposure Minimization, Mitigate
Practices, Sediment and Erosion Prevention, Infiltration Practices, and Other Preventive
Practices such as Good Housekeeping, Preventive Maintenance, Visual Inspections, Spill and
Stormwater Plan Training, and Documentation.

Area 1- Storage of drums containing surfactant liquids and non -hazardous waste as well as
storage of empty totes and drums.
• Materials are stored in this area only on a temporary basis. While stored in this
area, containers are readily visible and any leakage or run-off can be dealt with
quickly.
• Drums of liquid surfactant are used on a seasonal basis. These inventories are
minimized and managed to eliminate carry-over of inventory between seasons.
• Drumming of dry materials in the area is scheduled around weather forecasts and
covered during periods of unanticipated precipitation. Following completion, the
area is swept to prevent contamination.
Area 3- Storage of empty nitromethane metal drums.
• Drums are pumped until empty and the bung caps are re -secured before being
temporarily stored while awaiting pickup.
• Empty drums are picked up for recycling on a frequent and regular basis.
Area 4- Railcar loading/unloading stations (Chloropicrin & Chlorine).
• Spill containment (railcar pans) is included at each railcar loading station. The pans
are piped to a treatment tank, treated if necessary, and discharged to the sanitary
sewer.
• Area lighting and video cameras facilitate enhanced surveillance of loading
operations above and beyond operator attendance.
• Loading operations are instrumented and automated to minimize opportunities for
overfilling.
Area 5- Storage area for used equipment.
• Used equipment stored in the area is decontaminated prior to its storage.
• Storage containers allow small, primarily metal, parts to be housed out of the
weather, minimizing opportunity for the formation of rust.
Area 6- Railcar loading stations (Caustic and HCI).
• Spill containment (railcar pans) is included at each railcar loading station. The pans
are piped to a treatment area, treated if necessary, and discharged to the sanitary
sewer.

• Area lighting and video cameras facilitate enhanced surveillance of loading
operations above and beyond operator attendance.
• Loading operations are instrumented and automated to minimize opportunities for
overfilling.
Area 7- Brine filter waste collection dumpster and salt unloading.
• Dumpster is set in a curbed area to allow collection of any leakage.
• Dumpster is kept covered to prevent stormwater contact.
• Salt conveying system is inspected and cleaned as part of the preventative
maintenance program.

Trinity Manufacturing Inc.
Stormwater Discharge Permit NCS 000233
Significant Industrial Activity Changes
Changes in industrial activity at the site since the previous stormwater permit application
include implementing a process to produce chlorinated paraffins at the Trinity Manufacturing
facility. This is a batch process where dry chlorine gas is reacted with raw paraffin or olefin wax
in a reactor. This process is in contained areas. The original BMP philosophies for the facility
have been extended to encompass this process. Also, a maintenance/receiving/wa rehouse
building has been constructed and the parking lot has been expanded at the facility as well.

Trinity Manufacturing Inc.
Stormwater Discharge Permit NCS 000233
Significant Industrial Activity Changes
Changes in industrial activity at the site since the previous stormwater permit application
include implementing a process to produce chlorinated paraffins at the Trinity Manufacturing
facility. This is a batch process where dry chlorine gas is reacted with raw paraffin or olefin wax
in a reactor. This process is in contained areas. The original BMP philosophies for the facility
have been extended to encompass this process. Also, a maintenance/receiving/warehouse
building has been constructed and the parking lot has been expanded at the facility as well.

STORMWATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND.IMPLEMENTATION
CERTIFICATION
North Carolina Division of Energy, Mineral, and Land Resources - Stormwater Permitting
Facility Name:
Permit Number:
Location Address:
County:
Trinity Manufacturing, Inc.
NCS000233
11 EV Hogan Dr
Hamlet, NC 28345
Richmond
"I certify, under penalty of law, that the Stormwater Pollution Prevention Plan (SPPP) document and all attachments were
developed and implemented under my direction or supervision in accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information required by the SPPP. Based on my inquiry of the person or persons
who manage the system, or those persons directly responsible for gathering the information, the information gathered is, to the
best of my knowledge and belief, true, accurate and complete."
And
"I certify that the SPPP has been developed, signed and retained at the named facility location, and the SPPP has been fully
implemented at this facility location in accordance with the terms and conditions of the stormwater discharge permit."
And
"I am aware that there are significant penalties for falsifying information, including the possibility of fines and imprisonment for
knowing violations."
Sign (according to permit signatory requirements) and return this Certification. DO NOT
SEND STORMWATER POLLUTION PREVENTION PLAN WITH THIS CERTIFICATION.
Signature
Daryl Mitzel
Print or type name of person signing above
Date4 / 4
Executive Vice President
Title
SPPP CertificaUon 10113

STORMWATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
North Carolina Division of Energy, Mineral, and Land Resources — Stormwater Permitting
Facility Name:
Permit Number:
Location Address:
County:
Trinity Manufacturing, Inc.
NCS000233
11 EV Hogan Dr
Hamlet, NC 28345
Richmond
"I certify, under penalty of law, that the Stormwater Pollution Prevention Plan (SPPP) document and all attachments were
developed and implemented under my direction or supervision in accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information required by the SPPP. Based on my inquiry of the person or persons
who manage the system, or those persons directly responsible for gathering the information, the information gathered is, to the
best of my knowledge and belief, true, accurate and complete."
And
"I certify that the SPPP has been developed, signed and retained at the named facility location, and the SPPP has been fully
implemented at this facility location in accordance with the terms and conditions of the stormwater discharge permit."
And
"I am aware that there are significant penalties for falsifying information, including the possibility of fines and imprisonment for
knowing violations."
Sign (according to permit signatory requirements) and return this Certification. DO NOT
SEND STORMWATER POLLUTION PREVENTION PLAN WITH THIS CERTIFICATION.
Signature
Daryl Mitzel
Print or type name of person signing above
Date fflzs%r6
Executive Vice President
Title
SPPP Certification 10/13

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August 25, 2016
SW Individual Permit Coverage Renewal
Stormwater Permitting Program
1612 Mail Service Center
Raleigh, NC 27699-1612
Re: Stormwater Discharge Permit No. NCS000233
Dear Sir or Madam,
11 E. V. Hogan Drive
P.O. Box 1519
Hamlet, NC 28345
910-582-5650
910-817-4791 (fax)
Enclosed is the information required by the Division of Energy, Mineral and Land Resources for renewal of Trinity
Manufacturing Inc.'s NPDES Individual Stormwater Permit. Following is a list of the enclosed information:
Signed copy of Renewal Application Form
Supplemental Information Checklist form
o Current site map from our Stormwater Pollution Prevention Plan
o Summary of Analytical Results
o Summary of Visual Monitoring Results
o Summary of Best Management Practices
o Short narrative of Significant Changes in Industrial Activities
o Signed Certification of the development and implementation of a Stormwater Pollution Prevention
Plan
If you have any questions, Karen Messana is our contact person for the permit and SPPP. She can be reached at 910-
419-6566.
Best Regards,
*arylMitzel
Executive Vice President
Enclosures
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