NCS000179_Email RE Draft Permit Questions_20201116

Gamble, Aana C
From: Gamble, Aana C
Sent: Monday, November 16, 2020 10:17 AM
To: [e-mail]
Cc: Reed, Isaiah L
Subject: RE: [External] RE: Draft Permit - NCS000179 - Low & Bonar Inc
Hi Tom,
I hope this email finds you well! Please see below for the responses to your questions:
1) The measurable storm event seems to get rid of the 0.1 inches of rainfall requirement for a representative storm
event, am I correct in reading it that way? The main criteria is that a discharge occurs during the measurable
rain event and that it's been more than 72 hours since the last measurable storm event and discharge.
This is correct.
2) The permit also seems to require that we maintain a rain gauge onsite, is this a change(D.1.c)? We already have
one so that's no problem for us but I would highlight that as a change for most facilities.
Technically, neither permit required that you maintain a rain gauge onsite. The old permit required "an on -site rain
gauge or local rain gauge," and the new permit requires "an on -site rain gauge or regional rain gauge located within
one (1) mile of the facility."
3) Is the "estimated average monthly oil usage" for oil use outdoors or in areas of the facility that could discharge
to stormwater or total motor and hydraulic oil usage at the facility?
The average monthly oil usage is total motor and/or hydraulic oil usage at the facility, regardless of whether it is
outdoors or has the potential to discharge (see table 1).
4) When "estimated average monthly oil usage" is reported on the DMR is the period of the estimated average
since the last sampling event, last six months, last year, or some other time period? Can we estimate our oil
usage in 2020 and use that for all 2021-2024 DMRs as long as conditions haven't substantially changed?
Estimating your average monthly oil usage on an annual basis, then using that as a forecast is acceptable, as long as
site conditions don't substantially change. You will want to record your methodology for estimating the average.
5) Finally, for compliance purposes do we need to maintain some kind of log of our motor and hydraulic oil usage
to demonstrate the basis for our estimated average monthly oil usage?
Yes, the basis for estimating the average monthly oil usage should be recorded to demonstrate compliance.
Thank you very much! Let me know if you have any additional questions.
Aana Gamble
Environmental Specialist II
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
Phone: [phone]
Email: [e-mail]
Physical Address: 512 North Salisbury Street
Mailing Address: 1612 Mail Service Center
Raleigh, NC 27699-1612

[feputrnrM c! Emmonn�enral Qwli��
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: [e-mail] <tom.buller@Iowa ndbonar.com>
Sent: Wednesday, November 11, 2020 1:53 PM
To: Gamble, Aana C <[e-mail]>
Cc: Reed, Isaiah L <[e-mail]>
Subject: [External] RE: Draft Permit - NCS000179 - Low & Bonar Inc
mExte rnal email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to=
A couple questions.
1) The measurable storm event seems to get rid of the 0.1 inches of rainfall requirement for a representative storm
event, am I correct in reading it that way? The main criteria is that a discharge occurs during the measurable
rain event and that it's been more than 72 hours since the last measurable storm event and discharge.
2) The permit also seems to require that we maintain a rain gauge onsite, is this a change(D.1.c)? We already have
one so that's no problem for us but I would highlight that as a change for most facilities.
3) Is the "estimated average monthly oil usage" for oil use outdoors or in areas of the facility that could discharge
to stormwater or total motor and hydraulic oil usage at the facility?
4) When "estimated average monthly oil usage" is reported on the DMR is the period of the estimated average
since the last sampling event, last six months, last year, or some other time period? Can we estimate our oil
usage in 2020 and use that for all 2021-2024 DMRs as long as conditions haven't substantially changed?
5) Finally, for compliance purposes do we need to maintain some kind of log of our motor and hydraulic oil usage
to demonstrate the basis for our estimated average monthly oil usage?
Thank youl
Tom Buller
Tom Buller
HSE Manager North America
D [phone]
M [phone]
P.O. Box 1057, Enka, NC 28728
1301 Sand Hill Road, Candler, NC 28715 USA
[phone] www.lowandbonar.com

LOW & BONAR
now part of Freudenberg
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From: Gamble, Aana C <[e-mail]>
Sent: Friday, October 23, 2020 2:00 PM
To: Buller, Tom <tom.buller@Iowa ndbona r.com>
Cc: Reed, Isaiah L <[e-mail]>
Subject: Draft Permit - NCS000179 - Low & Bonar Inc
***WARNING*** This is an external e-mail and is not a part of internal communication. Please use caution when opening
attachments or when following embedded links.
Mr. Buller,
Thank you for speaking with me earlier today regarding the Low & Bonar draft permit. I have attached a copy of the
draft NPDES Individual Industrial Stormwater Permit for Low & Bonar, Inc. (permit number NCS000179), as well as a
cover letter. I apologize for the long delay in getting this draft to your facility for review, as we have had quite a bit of
turnover in the stormwater permitting group. Please review the draft permit and submit and questions or comments to
me within 30 days of receipt. This permit will also be sent to public notice in the near future for public review.
Information on permits that are under public notice can be located at this link:
https://deg.nc.gov/about/divisions/energy-mineral-and-land-resources/stormwater/stormwater-program/stormwater-
ublic.
Thank you very much! Please don't hesitate to contact me with any questions or comments.
Sincerely,
Aana Gamble
Environmental Specialist II
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
Phone: [phone]
Email: [e-mail]
Physical Address: 512 North Salisbury Street
Mailing Address: 1612 Mail Service Center
Raleigh, NC 27699-1612
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

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