NCS000057_Staff Report_20120103

NCS000057
.�_
NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Division of Water Quality
Coleen H. Sullins
Director
MRO
Dee Freeman
Secretary
STAFF REVIEW AND EVALUATION RECEIVED
NPDES Stormwater Permit DIVISION OF WATER QUALITY
Facility Name:
Chemical Specialties, Inc. (CSI) J A [ J 3 (u ] 2
NPDES Permit Number:
NCS000057 SujP SEC:. NON
Facility Location:
MOOR SV!LLE REGIONAL OFPI
5910 Pharr Mill Rd., Harrisburg, NC (Cabarrus County
Type of Activity:
Inorganic Chemical Manufacturing
SIC Code:
2819
Receiving Streams:
Rocky River [Index no. 13-17], See Figure 1
River Basin:
Yadkin -Pee Dee River Basin, Sub -basin 03-07-12
Stream Classification:
C
Proposed Permit Requirements:
See attached draft permit.
Monitoring Data:
See renewal application
Response Requested by (Date):
February 1, 2012
Central Office Staff Contact:
Return to: Robert Patterson, [phone]
Description of Onsite Activities:
• Chemical manufacturing of inorganic products for industrial and agricultural applications and wood
preservers. Also beginning to produce new organic products due to the wood preservative industry moving
away from metal based chemicals.
• Chemicals/materials include metal nitrates (calcium, magnesium, aluminum, manganese, copper,
lithium, & zinc) , metal chlorides (aluminum, magnesium, zinc, & manganese), metal acetates (magnesium,
lithium, & zinc), CCA, ACQ, DBlaze fire retardant (phosphor -ammonium boron), wax based water
repellants, organic chemicals (Dowanol*, Tergitol*, Texanol*, castor oil, & emulsifiers), and organic
pesticides (Imidicloprid & Tebuconazole).
*to be discontinued by end of 2011
Documents Reviewed:
• NPDES Stormwater Permit Application Materials
• National Heritage Program (NHP) Threatened and Endangered Species Database
• SPU File, Central Files
• EPA Sector -Specific Permit, 2008
• 2010 303(d) List, 2008 Yadkin Pee -Dee Basinwide Plan P9@RPWCq
F)
JAN 3 1 2012 u}
DENR- WATER OUALITI-
WETLANDS AND STORAMATER BRANCH
Page 1 of 5

NCS000057
History:
• Date permit first issued: December 10, 1999
• Date permit re -issued: March 2, 2007
• Date permittee submitted renewal application: September 9, 2011
Figure 1: Map of Facility
ti
IL
!Ss
I
JO
Z
Page 2 of 5

NCS000057
Central Office Review Summary:
1. Owner's Other Permits:
• WW - NC0006351
Air—NE145993, 3702500040
RCRA — NCD048467427
2. General Observations:
• 2 SDOs — 001 is a pipe, 002 is a ditch
• Indoor and outdoor storage of materials
• Portions of site drain to onsite W WTP or captured for process water use
• Site is immediately adjacent to Rocky River
• While some areas drain to the WWTP or process water, stacks could introduce pollutants from these
areas to the air and to stormwater
• They have implemented a number of BMPs to attempt to minimize Cu and Zn exposure (see page 2 of
renewal cover letter dated 9/8/1 1.
3. Impairment: This segment of Rocky River (13-17b) is impaired for Copper, Turbidity, and Biological Integrity.
The downstream segment (13-17c) is impaired for Copper, Turbidity, and Zinc. No TMDLs for this segment.
4. Threatened and Endaneered: None shown in this area.
5. Industrial Chanties Since Previous Permit: Volumes of CCA and arsenic acid are decreasing with new organic
products being produced.
6. Analytical Monitorine Notes: All samples were above the benchmarks for Cu and Zn. All other parameters were
below benchmarks. Additional monitoring was done on rainfall for Cu & Zn, and groundwater for Zn; Cu in the
rainwater was above the benchmark, and Zn in the groundwater was above benchmark. One thing to note is that
both of these are possible contaminates release from the air stacks onsite. Permittee has requested that the Cu
and Zn benchmarks be raised. However, benchmarks are not changed for individual sites, they are statewide
values used for all facilities. The receiving stream is impaired for Cu, so it is important that the permittee reduce
or eliminate Cu exposure to the maximum extent practicable (MEP). The renewal application does note changes
and BMPs related to Cu and Zn, so they are actively working on minimizing exposure. Due to the permittee's
concerns with the Cu and Zn issues in the sw discharges and the stream impairment, it may also be helpful to do
upstream & downstream monitoring. Another idea would be to investigate installing structural BMPs that are
known to help remove metals from sw (ie. bioretention). They may also need to do some internal investigation to
try and pin point sources. They have a number of BMPs that have already been implemented to target Cu and Zn
(see 2"d page of renewal application letter) JbIbULWOs thoughts on this overall issue?
7. Qualitative Monitorine Notes: Most observations were not of concern. Some results noted foam and low clarity;
one note of high suspended solids noted in 2007/2008.
Revised Permit Recommendations: Analytical Monitoring:
1. Removing lead based on Division's revised monitoring strategy. Recommend removing Arsenic based on all
results being well below the benchmark. All other parameters to remain. COD was not above the benchmark,
but some were elevated; also will be helpful to keep with the shift to organic products.
2. All analytical monitoring remains 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.
3. Benchmarks for analytical monitoring remain in 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
Page 3 of 5

NCS000057
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.
4. The permittee is responsible for all monitoring until the renewal permit is issued. See Footnote 1 of Tables 1, 4,
and 5.
Other Proposed Changes to the Previous Permit:
l . 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. 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 §I22.26(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.
Discussions with permittee: Jonna Stein, 704-455-4171, voicemail & emailed 12/13/11 — no response as of
12/30/11 (see copy of email attached)
1. Q: How was the "background" rainfall sample collected? Was it just a single sample?
a. ANSWER:
2. Q: What method is used to determine if the loaded trailer parking area goes to sw or to ww?
a. ANSWER:
CtA� u7,Xw 2,0� '� w� .ems yYY- o,; �4_ o�-d � �c
Page 4 of 5

NCS000057
Recommendations: Based on the documents reviewed, the application information submitted on September 9, 2011
sufficient to issue an Individual Stormwater Permit.
Prepared by (Signature) 'f� ✓ yt/ /I Date Z 3 o r
Stormwater Permitting Unit Supervisw Date I '0 ?� ((
forBradl y Been�nett
Concurrence by Regional Office �� / tDate
RO Water Quality Supervisor Zr 4 eG— — Date V Z-Y 2
Regional Office Staff Comments (attach additional pages as necessary)
Page 5 of 5

To: Robert Patterson January 23, 2012
From: Rob Krebs �bvv
Prepared By: Michael ParkerPf
NCS000057 Chemical Specialties, Inc
Cabarrus County
Site inspection conducted on January 19, 2012, by Michael Parker. Facility contact: Ms. Jonna Stein,
Operations Manager, [phone] and Mr. Mark Dwyer, Safety, Health and Environmental
Manager, [phone]. This request is for the renewal of the subject SW permit. This facility is
currently in the business of producing inorganic products for industrial and agricultural applications
and the wood preserving industry. Chemical Specialties (CS) is in the process of switching over to
organic based wood preserving chemicals, which is a trend throughout the wood preserving industry.
The site has two SW outfalls, one which drains to unnamed tributary to the Rocky River and the other
drains to a conveyance channel that empties into the Rocky River (RR). The RR at CS is listed as
impaired for Copper, Turbidity, and Biological Integrity. The downstream segment of the RR is listed
as impaired for Copper, Turbidity, and Zinc.
A small part of the SW generated on the western side of the CS site discharges through a steel pipe into
a conveyance channel located adjacent to the RR. This outfall is designated as outfall 001. On the day
of the site visit, the only flow observed in this pipe was drinking water being used to circulate through
jackets used to keep nearby pieces of machinery from freezing. Outfall 001 receives the least amount
of SW generated at this site and a significant portion of the industrial processes that drain to this outfall
are under roof. Even so, benchmark levels for Cu and Zn are routinely exceeded at this outfall.
Observations made during the site visit noted that there were very limited options for structural BMPs
at this outfall due to the fact the area is almost entirely paved and this part of the site sits very near the
top -of -bank of the RR. The proximity of the RR to the site (and in particular this outfall) is
problematic since storage of raw materials, loading and unloading of raw materials and the finished
product, and the various industrial processes are occurring adjacent to SW collection drains that empty
into this outfall. Major operational changes would be necessary if current operations were shifted to
another portion of the site. CS has made some improvements in this area, and additional measures are
planned.
Part of the SW generated at CS site is routed to an existing treatment lagoon that is covered under a
separate NPDES wastewater permit (NC0006351). There is also a portion of the site's SW that drains
towards the lagoon, but does not enter the lagoon. This SW eventually enters into an intermittent
channel (both by point and non -point means) that originates onsite and eventually discharges near the
south end of the property into the RR and is designated as outfall 002. On the day of the site visit, the
intermittent channel had substantial flow, even though rainfall had not occurred for at least 48 hours
prior to the site visit. It is surmised that the flow observed in the channel was predominately base flow
from seeps and groundwater sources located upstream. During the site visit, Ms. Stein informed the
writer that analytical testing for this SW outfall was being collected in -channel at an inlet structure
located = 200 feet from the channel's junction with the RR. Based on observations made during the
site visit, any testing performed at this location especially when base flow existed in the channel would
likely not provide data that was entirely reflective of the SW draining from this portion of this facility.

Page Two
Based on the analytical data collected to -date at outfall 002 (and reported to the Division), benchmark
exceedances for Cu and Zinc are numerous. The existence of base flow in the channel, however,
would tend to dilute the SW flow, and any data collected would likely not provide an accurate
characterization of the SW draining to this outfall. It is unknown, however, as to whether the
analytical testing performed at this outfall was conducted when base flow existed or when the channel
was predominately SW. The SW that drains from this portion of the CS site enters the channel at
several different locations rather than one defined point. Ms. Stein informed the writer that the channel
was often dry or nearly dry during the warm weather months, which would be indicative of a channel
that originates as an ephemeral channel and begins a transition to intermittent prior to reaching the RR
near the south end of the CS property. Complicating this matter is the fact that CS has both point and
non -point SW sources discharging into this channel, therefore, locating a sampling location that will
capture the SW originating from this portion of the property, but not include superfluous base flow in
the channel will be difficult. Further discussions and/or additional site visits will likely be necessary to
determine whether the current sampling location is the more appropriate location to capture the SW
from the south side of the CS site.
Another likely contributor to this facilities inability to consistently comply with their benchmark limits
is the historical use of the site as a wood preservatives manufacturer. CS has been in operation since
the 60's, and the bioaccumulation of wood preservation constituents are likely prevalent in the soils
and on the equipment scattered throughout the site. Although current SW exposure practices are likely
a significant improvement over those of the past, any constituents that may have accumulated in the
soils and in the industrial process areas have the potential to be released during storm events and
ultimately effect SW quality. CS also has air emissions, but it is unclear as to whether these emissions
could have played a significant role in failure of CS to meet benchmark requirements. There are also
operational improvements that may help in reducing pollutant levels. For example, scrap copper used
in the manufacturing of the wood preservatives is stored in bags at one location on -site, but must be
transported across site by fork-lift to where it is processed. In the area where the bags of scrap copper
are stored for manufacturing, small flakes of copper can be seen on the pavement in the vicinity of the
unloading area that are exposed to rain events. The leaching of copper from these flakes into SW is
highly probably given the acidity of area rainfall. These observations were discussed with Ms. Stein
and operational improvements were suggested.
Zinc has also been problematic at CS with many reported results above benchmark levels, however,
according to Ms. Stein, all sources of Zinc used in the manufacturing process are under roof. Again,
historical manufacturing activities at this facility may be playing a part in the sources of current zinc
levels, but it was noted by the writer that a large part of the site is covered by galvanized metal
buildings and much of the piping used in the manufacturing processes are exposed galvanized piping
which may be slowing leaching zinc into the site's SW during rainfall events and as they corrode. It
was suggested to Ms. Stein that some of the many internal outfalls located throughout the CS property
(including some roof drainage) be sampled to help determine the effect, if any that the metal structures
and piping may be having on zinc concentrations in the site SW. Ms. Stein was amenable to
conducting this sampling in hopes it will help identify possible sources of zinc. In the meantime, this
Office recommends that the renewed permit incorporate the suggested language (Mandatory Best
Management Practices) that will hold in abeyance tiered testing for benchmark exceedances as long as
the other investigative activities are completed, including the possibility of site specific BMPs based
on the results of a Division approved monitoring plan.

Page Three
In a follow-up to questions asked by the CO regarding this site, Ms. Stein was asked how the
"background" rainfall sample she collected and analyzed was obtained. She said that various
collection containers were placed throughout the site during a rain event. The rainfall in each container
was then combined into one container and the resulting mixture tested for Cu and Zn. Ms. Stein was
also asked if the SW from the loaded trailer parking area went directly to SW or to the WWT lagoon.
Her response was that there was a pipe at the lower end of the trailer parking lot that received all the
SW from this area and was fitted with a valve. Normally, the valve remained open in case of a spill so
the spill would be sent to the WWT lagoon, but during rainfall events, the valve was closed and all SW
was directed to outfall 002.
At this time, CS is not required to conduct any in -stream monitoring for copper or zinc in either their
SW permit or their NPDES wastewater permit. Instream testing may also help CS identify to what
extent they may contributing to the RR's impairment for Cu, especially during storm events. This
testing will be brought to the attention of CS in the inspection report that will be forwarded to the
company.
In conclusion, CS has instituted a number of physical and operational improvements designed to help
reduce contaminant exposure and more are planned in the coming months. With the suggested
language noted above regarding BMP evaluation included in the permit, CS will be able to investigate
and eventually implement management and operational strategies that will hopefully improve SW
pollutant concentrations and possibly effect a reduction in in -stream Cu impairment.
It is recommended that the subject SW permit be issued with consideration given to the
comments/recommendations as contained in this report
/mlp