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HomeMy WebLinkAboutNCS000354_Fact sheeet binder_20240410 DEQ / DEMLR FACT SHEET FOR NPDES INDUSTRIAL INDIVIDUAL STORMWATER PERMIT DEVELOPMENT Basic Information for Permit Issuance and Renewals: Permit Writer/Date Brianna Young 3/22/2024 Permit Number NCS000354 Owner/Facility Name StarPet, Inc./StarPet, Inc. SIC(NAICS)Code/Category 2821 (325211)/Plastics materials and resin manufacturing Basin Name/Sub-basin number Yadkin Pee-Dee/03-07-09 Receiving Stream/HUC UT to Back Creek/030401030403 Stream Classification/Stream Segment WS-11; HQW/ 13-2-3-3-(0.3) Is the stream impaired on 303 d list]? No Any TMDLs? No Any threatened and/or endangered species? No Any compliance concerns? See Section 2 below Any permit mods since lastpermit? See Section 1 below New expiration date 4/30/2029 Comments on Draft Permit? See Section 6 below Section 1. Facility Activities and Process: The StarPet, Inc. facility manufactures and processes PET resin for use in the beverage industry. The facility consists of two Continuous Polymerization plants, which produce the amorphous PET resin, and two Solid Stating Plants, which convert the amorphous PET into the final PET product. Raw materials are received via rail car and truck, and the final PET product is shipped via rail car and truck. The facility processes mono-ethylene glycol (MEG-liquid), di-ethylene glycol (DEG-liquid),purified terephthalic acid(powder), and isophthalic acid(powder) to produce PET chips (solid). The raw materials are offloaded from rail cars and trucks into storage tanks (tank farm with appropriate dike) and silos. Per information provided during the permit renewal, since the last permit issuance, the facility has installed a new process within the CP building that has the capability of using postconsumer recycled PET and blending that into the manufacturing process to produce rPET (recycled content Polyester chips). The recycled PET flake is received at the new flake building, where it is off-loaded from trucks and stored. The flake arrives in super sacks, which are emptied into a hopper, then conveyed to two storage silos, prior to being conveyed to the day silo on the top of the CP production building. All silos are equipped with cyclones to collect dust and are routinely inspected and cleaned. The facility also installed a Dioxane Column at the northeast corner of the CP Production building. The column strips VOC chemicals from the process water and is then sent to the RTO for destruction. The water is sent to the lift station where it is then discharged to the city POTW. Per a 3/16/2018 email, StarPet, Inc. found that the neighbor's (named Universal) old fiber plant turned warehouse outfall has a concrete pipe running under the rail tracks and a very small ditch takes it to the second holding pond and their roof gutters are piped to the property. StarPet, Inc. was under the impression Universal sold them the property. Page 1 of 6 Outfall SW001: Drainage area consists of railroad car storage area, unloading railroad car area, nitrogen tank farm, scrap metal storage area, flake building, warehouse, CP production building, SSP area, MEG/DEG tank farms, equipment storage building, storage silos, dioxane column, furnaces, heat transfer fluid(HTF)pumps, HTF storage tanks, diesel AST, oil drums, electrical transformers, gasoline caddy,used pallets, dumpsters, and two (2) sediment retention ponds. Discharge is from the second sediment retention pond. Why Industrial Sites with Stormwater are Subject to a Permit: Federal NPDES regulations define stormwater discharge associated with industrial activity in 40 CFR §122.26 (b)(14) as: "the discharge from any conveyance that is used for collecting and conveying storm water and that is directly related to manufacturing,processing or raw materials storage areas at an industrial plant. The term does not include discharges from facilities or activities excluded from the NPDES program under this part 122. For the categories of industries identified in this section, the term includes, but is not limited to, storm water [sic] discharges from industrial plant yards; immediate access roads and rail lines used or traveled by carriers of raw materials, manufactured products, waste material, or byproducts used or created by the facility; material handling sites; refuse sites; sites used for the application or disposal of process waste waters (as defined at part 401 of this chapter); sites used for the storage and maintenance of material handling equipment; sites used for residual treatment, storage, or disposal; shipping and receiving areas; manufacturing buildings; storage areas (including tank farms) for raw materials, and intermediate and final products; and areas where industrial activity has taken place in the past and significant materials remain and are exposed to storm water. For the purposes of this paragraph, material handling activities include storage, loading and unloading, transportation, or conveyance of any raw material, intermediate product, final product, byproduct or waste product. The term excludes areas located on plant lands separate from the plant's industrial activities, such as office buildings and accompanying parking lots as long as the drainage from the excluded areas is not mixed with storm water [sic] drained from the above described areas." Section 2. Monitoring Information and Compliance History: • October 2018 to March 2023, benchmarks exceeded for: o TSS 2x o BOD Ix o No monitoring data provided for MBAS, total phosphorus, nitrogen/nitrate, nitrogen/nitrite, total nitrogen, TKN, total cobalt, O&G, and ethylene glycol ■ Identified in the monitoring data spreadsheet provided during renewal but monitoring was not required for these parameters in the previous permit • Per the permit renewal application, spills that have occurred in the previous 3 years include: 0 1/17/2019 - 200 gals of Therminol 66 leaked into pump containment area due to pump seal failure. Speedy dry was used to cleanup material and disposed of properly. 0 9/24/2020 - Mono Ethylene Glycol overflowed as alarm was missed. 250 gals spilled and was contained within the dike. Material was pumped into totes for proper disposal. 0 2/23/2022 - Material handler transporting a tote filled with dirty Mono Ethylene Glycol. Tote slid off pallet and spilled 100 gals onto ground. Speedy dry was applied to spill area and cleaned up. Page 2 of 6 Section 3. Proposed Monitoring for Stormwater Discharges: The Division considered potential pollutants from past and present industrial activities and data was submitted for October 2018 to March 2023. Quantitative sampling included pH, TSS, BOD, and COD. Parameters are based on potential pollutants in the drainage area, sampling results, and in some cases, dependent upon future activities (e.g., ash removal through the drainage area). Below is a table of the proposed monitoring for each outfall at the StarPet, Inc. site. Outfall SWO01 Quarterly monitoring Total Suspended Solids BASIS: Potential pollutant from drainage area and BMP effectiveness (TSS) indicator. Quarterly monitoring pH BASIS: Pollutant indicator Quarterly monitoring Total Rainfall BASIS: Discharge potential indicator Quarterly monitoring Non-Polar Oil &Grease BASIS: Potential pollutant from lubricants; Method 1664 SGT-HEM targets petroleum-based O&G Quarterly monitoring Monthly Oil Usage BASIS: Potential pollutant from drainage area Quarterly monitoring BOD BASIS: Discharge potential indicator Quarterly monitoring COD BASIS: Discharge potential indicator Quarterly monitoring Total Nitrogen BASIS: Potential pollutant from drainage area Quarterly monitoring Ethylene Glycol BASIS: Potential pollutant from drainage area Quarterly monitoring Total Copper BASIS: Potential pollutant from drainage area Quarterly monitoring Total Lead BASIS: Potential pollutant from drainage area Total Zinc Quarterly monitoring BASIS: Potential pollutant from drainage area Total Hardness Quarterly monitoring BASIS: Monitoring for hardness dependent metals is required Page 3 of 6 Stormwater Benchmarks and Tiered Response: Rather than limits,North Carolina NPDES Stormwater permits contain benchmark concentrations. Stormwater benchmarks are numerical action levels for stormwater monitoring. Benchmarks are not effluent limits, and benchmark exceedances are not permit violations. Benchmarks provide facilities a tool for assessing the significance of pollutants in stormwater discharges and the effectiveness of best management practices (BMPs). Benchmark concentrations are intended as guidelines for the facility's development and implementation of the Stormwater Pollution Prevention Plan(SWPPP). Benchmark exceedances require the permittee to increase monitoring, increase management actions, increase record keeping, and/or install stormwater BMPs in a tiered program. The permit establishes a tiered approach to specify actions the permittee must take in response to analytical results above benchmark concentrations. The tiered structure of the permit provides the permittee and DEMLR wide flexibility to address issues that may arise with one or more parameters and/or outfalls. Metals benchmarks are calculated to mimic acute water quality standards and with the guidance of DWR. NC DWR follows established federal procedures for calculating acute standards when developing the benchmarks. Just like the acute standards, metals benchmarks normally reflect one half of the calculated Final Acute Value (the "1/2 FAV"). In most cases, translation into total recoverable values is based on an assumed hardness of 25 mg/L and a total suspended solids (TSS) concentration of 10 mg/L. Acute standards protect aquatic life from negative impacts of short-term exposure to higher levels of chemicals where the discharge enters a waterbody. The Stormwater Permitting Program applies this approach because of the ephemeral nature of rainfall events. The Division may evaluate results to determine if a smaller suite of parameters for some outfalls is adequate to characterize potential pollution or BMP effectiveness. For example, one or more metals or other parameters may serve as an adequate tracer for the presence of ash pollution during disturbance or ash removal in specific drainage areas at this site. For parameters that do not have a stormwater benchmark, the Division may develop a benchmark value if appropriate toxicity data become available or if rising trends in concentrations suggest a persistent source. A summary of the benchmarks in the draftpermit, and their basis, is below: Parameter Benchmark Basis Total Suspended 50 mg/L Based on '/2 standard benchmark of 100 mg/L Solids TSS H 6 s.u. —9 s.u. NC Water Quality Standard(Range) Non-Polar Oil & Review of other state's daily maximum benchmark Grease 15 mg/L concentration for this more targeted O&G;NC WQS that EPA Method 1664 does not allow oil sheen in waters SGT-HEM BOD 30 mg/L BPJ; Based on Secondary Treatment Regulation(40 CFR 133.03 COD 120 mg/L BPJ; Generally found at levels 4x BOD5 in domestic wastewaters Total Nitrogen 30 mg/L TKN +Nitrate+Nitrite Benchmarks (Expressed in mg/L of N Ethylene Glycol 8,000 mg/L '/2 FAV Copper Total 10 /L Acute Aquatic Criterion, '/2 FAV Lead Total 75 /L Acute Aquatic Criterion, '/2 FAV Zinc (Total) 126 µg/L Acute Aquatic Criterion, '/2 FAV Page 4 of 6 Stormwater Pollution Prevention Plan: The proposed permit conditions reflect the EPA and NC's pollution prevention approach to stormwater permitting. The Division's maintains that implementation of Best Management Practices (BMPs) and traditional stormwater management practices that control the source of pollutants meets the definition of Best Available Technology (BAT) and Best Conventional Pollutant Control Technology(BCT). The permit conditions are not numeric effluent limitations but are designed to be flexible requirements for implementing site-specific plans to minimize and control pollutants in stormwater discharges associated with the industrial activity. Title 40 Code of Federal Regulations (CFR) §122.44(k)(2) authorizes the use of BMPs in lieu of numeric effluent limitations in NPDES permits when the agency finds numeric effluent limitations to be infeasible. The agency may also impose BMP requirements which are "reasonably necessary" to carry out the purposes of the Act under the authority of 40 CFR 122.44(k)(3). The conditions proposed in this draft permit are included under the authority of both of these regulatory provisions. In essence, the pollution prevention and BMP requirements operate as limitations on effluent discharges that reflect the application of BAT/BCT. Flexibility in Tier Responses: Tier Two actions provide an opportunity for the permittee to propose an alternative monitoring plan for approval by the Region: • Alternatively, in lieu of steps 2 and 3, the permittee may, after two consecutive exceedances, exercise the option of contacting the DEMLR Regional Engineer as provided below in Tier Three. The Regional Engineer may direct the response actions on the part of the permittee as provided in Tier Three, including reduced or additional sampling parameters or frequency. • If pursuing the alternative above after two consecutive exceedances, the permittee may propose an alternative monitoring plan for approval by the Regional Engineer. The permit therefore allows the permittee to petition the Regional Office for monitoring changes sooner than Tier Three (upon any four benchmark exceedances) and gives guidance on one option to take. For example, the permittee may request that mercury only be monitored semi-annually under the tiers, or that only parameters over the benchmark be monitored more frequently. In this way, changes to the monitoring scheme for any outfall could be handled outside of a permit modification. Other Proposed Requirements: • It is standard for Stormwater Pollution Prevention Plan(SWPPP)requirements to include an annual certification that stormwater outfalls have been evaluated for the presence of non- stormwater discharges, and if any are identified, how those discharges are permitted or otherwise authorized. • Requirement to submit a request for permit modification if the facility identifies or creates any new outfalls, removes outfalls, or alters any drainage area that changes potential pollutants. • The Division expects the permittee to apply best professional judgment and consider the safety of its personnel in fulfilling sampling obligations under the permit. • Federal regulations require electronic submittal of all discharge monitoring reports (DMRs). If a state does not establish a system to receive such submittals, then permittees must submit DMRs electronically to the EPA. • Quarterly QualitativeNisual Monitoring to assure regular observation of outfalls throughout year. Page 5 of 6 Section 4. Changes from previous permit to draft: • Regulatory citations added • Monitoring increased from semi-annually to quarterly for all parameters (qualitative and quantitative) • "No discharge" clarifications made • Feasibility study requirement removed per updated stormwater program requirements • Annual online SWPPP certification requirement removed per updated stormwater program requirements • eDMR requirement updated • Boilerplate language moved into body of the permit; boilerplate no longer attached • Outfall-specific monitoring been implemented to reflect industrial activity and potential pollutants specific to each discharge area • Monitoring for total copper, total lead, and total zinc as the site has an outdoor scrapyard • Monitoring for total nitrogen added back in the permit as the site has nitrogen ASTs o Removed during last permit renewal as values were consistently below benchmark o Potential pollutant in the drainage area so monitoring has been added back in during current permit renewal • Monitoring for ethylene glycol added back in the permit as this is a potential pollutant onsite o Removed during last permit renewal as values were consistently below benchmark o Potential pollutant in the drainage area, and a spill occurred, so monitoring has been added back in during current permit renewal • Monitoring for total hardness added for outfalls where monitoring for hardness dependent metals is required • Benchmarks updated for parameters per guidance from DWR Standards group on stormwater benchmarks Section 5. Changes from draft to final: • TSS benchmark corrected to 50 mg/L for HQWs Section 6. Discussions with the Facility and Regional Office: • Initial contact with facility: 11/21/2023 • Initial contact with Regional Office: 11/21/2023 • Draft sent to CO peer review: N/A • Draft sent to Regional Office: 2/23/2024 • Final permit sent for supervisor signature: 4/3/2024 Section 7. Comments received on draft permit: • None Page 6 of 6 ipt> For more Public Notices visit: usalegalnotice.com (https://wwwusalegalnotice.com) Courier-Tribune, The Publication Name: Courier-Tribune, The Publication URL: Publication City and State: Siler City, NC Publication County: Chatham Notice Popular Keyword Category: Notice Keywords: ncs000354 Notice Authentication Number: 202403271041090142718 2510867466 Notice URL: <Back (Search.aspx#searchResults) Notice Publish Date: Thursday, February 29, 2024 Notice Content NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION INTENT TO ISSUE NPDES STORM WATER DISCHARGE PERMITS The North Carolina Environmental Management Commission proposes to issue NPDES stormwater discharge permit(s) to the person(s) listed below. Public comment or objection to the draft permits is invited. Written comments regarding the proposed permit will be accepted until 30 days after the publish date of this notice and considered in the final determination regarding permit issuance and permit provisions. The Director of the NC Division of Energy, Mineral, and Land Resources (DEMLR) may hold a public hearing should there be a significant degree of public interest. Please mail comments and/or information requests to DEMLR at 1612 Mail Service Center, Raleigh, NC 27699-1612. • StarPet, Inc. [801 Pineview Road, Asheboro, NC 27203] has requested renewal of permit NCS000354 for the StarPet, Inc. facility in Randolph County. This facility discharges to an unnamed tributary to Back Creek in the Yadkin Pee-Dee River Basin. Interested persons may visit DEMLR at 512 N. Salisbury street, Raleigh, NC 27604 to review information on file. Additional information on NPDES permits and this notice may be found on our website: https://deq.nc.gov/about/ divisions/energy-mineral-and-land resources/stormwater/ stormwater-program/ stormwater-public-notices, or by contacting Brianna Young at brianna.young @deq.nc.gov or 919-707-3647. 1t: 2/29/2024 Back (Search.aspx#search Results) Use of this site is governed by our Terms of Use(/Terms-of-Use.aspx)agreement. If you have any questions please send an email to the administrator (mailto:phil ncpress.com).. Copyright©2021 North Carolina Press Association (http://www.ncpress.com/). Select Language Powered by Google Translate(https:/Itransiate.google.com) Compliance Inspection Report Permit:NCS000354 Effective: 05/11/18 Expiration: 04/30/23 Owner: Starpet Inc SOC: Effective: Expiration: Facility: Starpet Inc County: Randolph 801 Pineview Rd Region: Winston-Salem Asheboro NC 27203 Contact Person:Mark Pederson Title: Phone: 336-672-0101 Directions to Facility: System Classifications: SWNC, Primary ORC: Certification: Phone: Secondary ORC(s): On-Site Representative(s): Related Permits: Inspection Date: 03/19/2024 Entry Time 02:OOPM Exit Time: 02:30PM Primary Inspector:Ashley J Vikara Phone: 336-776-9655 Secondary Inspector(s): Kimberly Turney Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Stormwater Discharge, Individual Facility Status: Compliant ❑ Not Compliant Question Areas: Storm Water (See attachment summary) Page 1 of 3 Permit: NCS000354 Owner-Facility:Starpet Inc Inspection Date: 03/19/2024 Inspection Type:Compliance Evaluation Reason for Visit: Routine Inspection Summary: The facility was inspected on March 19, 2024. The facility has one outfall and is the outlet of two basins. The facility is recommended for renewal. Page 2 of 3 Permit: NCS000354 Owner-Facility:Starpet Inc Inspection Date: 03/19/2024 Inspection Type:Compliance Evaluation Reason for Visit: Routine Permit and Outfalls Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? ❑ ❑ ❑ #Were all outfalls observed during the inspection? ❑ ❑ ❑ # If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ❑ #Has the facility evaluated all illicit(non stormwater)discharges? 0 ❑ ❑ ❑ Comment: Page 3 of 3 INDORAMA V E N T U R E S RECE VEQ Date: 12/5/2023 Brianna Young DEC 12 2023 North Carolina DEQ 1612 Mail Service Center rEtuILR-StormwaterProgram Raleigh, NC 27699-1612 Dear Ms.Young, Attached is the supplemental information requested as well as the Storm Water Pollution Prevention Plan Certification. If you have any questions regarding this information, please contact me at(336)964-0173. Sin erely, Ma k E. Pederson, EH&S Manager StarPet, Inc 801 Pineview Road Asheboro, NC 27203 StarPet Inc 801 Pineview Road,Asheboro,North Carolina—27203,USA Tel-(336)672 0101,Fax-(336)672 1904 www.indommaventures.com 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 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. 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. Y1J� 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) STORMWATER POLLUTION PREVENTION PLAN DEVELOPMENT AND IMPLEMENTATION CERTIFICATION North Carolina Division of Energy, Mineral, and Land Resources—Stormwater Program Facility Name: Sweet we Permit Number: NCSOD0354 Location Address: 801 PlnaMa Rom Aahebom,NC 27203 County: Randolph "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. ddA Signature �4P N)-'--� Date 12J112023 Mark E Pederson EHS Manager Print or type name of person signing above Title SPPP Certification 10/13 INDORAMA V E N T U R E S StarPet BMP Summary The facility has provided structural and non-structural measures or practices to reduce the amount of pollution entering surface waters. Structural best management practices employed at the StarPet facility include providing covers over bulk storage areas, drain covers for some catch basins, and secondary containment features. Catch basins are provided to improve stormwater flow throughout the facility. Non-structural best management practices include providing rip rap at drainage ditches, semi-annual stormwater inspections, monitoring loading/unloading operations, sweeping, and good housekeeping procedures and inspections. A listing of the BMPs for the site is provided in Section 3.1.3.1. The effectiveness of the BMPs are reviewed on an annual basis and documented using the form in Appendix C. StarPet Inc 801 Pineview Road,Asheboro,North Carolina—27203,USA Tel-(336)672 0101,Fax-(336)672 1904 www.indoramaventures.com INDORAMA Tank Farm Area North of SSP This area is equipped with concrete secondary containment. Tank 1107- Tank 1107-T01 1,376,800 Ibs MEG T01 has a separate concrete containment area. Tank 1107-T02 687,200 Ibs MEG The containment areas are equipped with valves which Tank 1107-T03 73,800 Ibs MEG are locked when not in use. Accumulated water in the Tank 1115-V01 38,740 Ibs DEG containment areas is visually inspected and the Tank 1115-V02 55,300 Ibs DEG dike water is analyzed for Tank 1199-T01 440,900 Ibs COD prior to being released to the stormwater system. CG HTM Tank Farm Area East of The area is equipped with production concrete secondary building containment. Tank 3017- T VO4 is located below grade Tank 3017-V01 218,900 Ibs Therminol 66 in a containment pit. Accumulated water in the Tank 3017-VO4 2,190 Ibs Therminol V01 containment area is 66 visually inspected and the dike water is analyzed for COD prior to being released to the stormwater system. Accumulated waste in the VO4 containment area is discharged to the lift station. (4) HTM Pumps with 20-Gal East of The area is equipped with Reservoirs production small concrete secondary building containment. The containment area is visually inspected prior to being released to the VO4 containment area. StarPet Inc 801 Pineview Road,Asheboro, North Carolina—27203, USA Tel-(336)672 0101,Fax-(336)672 1904 www.ndoramaventores.com INDC)RAMA V E N T U R E S Stora-ge Silos East of The storage silos are not production equipped with secondary building containment but are 1205-T01 96,000 Ibs PET routinely inspected for Chips indications of spills. 1212-T01 344,000 Ibs IPA 1207-T02 2,070,000 Ibs PTA 1207-T01 2,200,000 Ibs PTA (3) Furnaces Containing — 50 gal of East side of The furnaces are covered HTM in coils facility and the area is equipped with concrete secondary 3017-F01 containment. The 3017-F02 containment area is visually inspected and the dike 3017-F03 water is analyzed for COD prior to being released to the stormwater system. Stormwater Exposure Item Location Comments and BMPs StarPet Inc 801 Pineview Road,Asheboro,North Carolina—27203,USA Tel-(336)672 0101.Fax-(336)672 1904 www.indommaventures.com INDORAMA Storage Silos South and The storage silos are not 2901-V62 664,000 Ibs PET West of SSP equipped with secondary containment but are Chips routinely inspected for 2901-V41 184,000 Ibs PET indications of spills. Chips 2901-V42 664,000 Ibs PET Chips 2901-V43 664,000 Ibs PET Chips 2901-V44 664,000lbs PET Chips 2901-V45 664,000 Ibs PET Chips 2901-V46 664,000 Ibs PET Chips 2901-V61 177,000 Ibs PET Chips 2901-V01/02 500,000 Ibs PET Chips 2901-V03 2,000,000 Ibs PET Chips 2901-V21 2,000,000 Ibs PET Chips 2901-V22 800,000 Ibs PET Chips 2901-V23 2,000,000 Ibs PET Chips 2901-V24 2,000,000 Ibs PET Chips 2901-V63 664,000 Ibs PET Chips 2901-V64 664,000 Ibs PET Chips StarPet Inc 801 Pineview Road,Asheboro,North Carolina—27203,USA Tel-(336)672 0101,Fax-(336)672 1904 www.indorarnaventures.corn INDORAMA V E N T U R E S 2020-001 — Dioxan Column Dike East side of This area is equipped with Administration concrete secondary office containment. The containment area is equipped with a valve and power supply, which is locked when not in use. Accumulated water in the containment area is visually inspected and the dike water is analyzed for COD prior to being released to the stormwater system. Storage Silos West side of The storage silos are not facility equipped with secondary RE12-13-01V11 664,000 Ibs PET containment but are Flake routinely inspected for RE12-B-01V12 664,000 Ibs PET indications of spills. Flake 1670-V01 Surge Tank Containing SSP area The tank is covered and the 12,760 Ibs of Therminol 66 area is equipped with concrete secondary containment. The containment area is visually inspected and the dike water is analyzed for COD prior to being released to the stormwater system. 1650-K01 and 1650-K02 Motor Oil SSP area The blowers are located Reservoirs under cover and are stored on a concrete pad near a stormwater drain. A suggested BMP includes having a drain cover readily available for the stormwater drain in the event of leakage from the reservoir. StarPet Inc 801 Pineview Road,Asheboro,North Carolina—27203,USA Tel-(336)672 0101,Fax-(336)672 1904 www.indoramaventures.com INDORAMA V E N T U R E S Railcar unloading area for Glycol, East of facility Buckets are placed beneath PTA, IPA connection hoses during unloading and spill materials are located within the area. Suggested BMPs include providing the area with secondary containment. Open Scrap Metal Dumpster South of SSP The dumpsters are emptied on a regular basis and Used Pallets pallets are removed from the facility on a regular basis. Suggested BMPs include covering the dumpsters and storing used pallets in a covered area. Cyclones (2) Southeastern Dust and particulates from portion of the cyclones are stored in facility sealed drums. The area is routinely inspected and swept. Stormwater Exposure Item Location Comments and BMPs Boneyard Southern Scrap equipment and other portion of miscellaneous items are facility stored on the ground. A suggested BMP is to remove out of use equipment from the facility or cover the items with a tarp. (3) Open Dumpsters containing South of The dumpsters are emptied Plastics buildings on a regular basis. A suggested BMP is to provide covers for the dumpsters. StarPet Inc 801 Pineview Road,Asheboro,North Carolina—27203,USA Tel-(336)672 0101.Fax-(336)672 1904 w .indoramaventures.com INDORAMA V E N T U R E 5 Empty Drums South of Empty drums are Warehouse periodically removed from the facility. A suggested BMP is to store the drums inside the Warehouse. Open Trash Dumpster South of The dumpster is emptied on Warehouse a regular basis. A suggested BMP is to provide a cover for the dumpster. 2 Storage Sheds South of Hazardous waste drums Warehouse and HTM drums are stored in storage sheds. The sheds are equipped with secondary containment. 270-Gallon Diesel Tank and Gasoline East of The tank is a double-walled Mobile Cart Warehouse tank. The mobile cart is stored in the HTM storage shed. HTM Tank Area East side of The area is covered and is production equipped with concrete building secondary containment. 3087-V01 2,190 Ibs Therminol The accumulated water from VP1 the containment areas is visually inspected and 3057-V02 2,190 Ibs Therminol 66 analyzed for COD prior to being released to the 1427-E01 HTM Evaporator storrnwater system. Railcar Unloading and Locomotive West side of While solids are facility predominately unloaded in this area, a suggested BMP includes providing spill response materials in this area for any potential spill of liquids. StarPet Inc 801 Pineview Road,Asheboro,North Carolina—27203,USA Tel-(336)672 0101,Fax-(336)672 1904 www.indoremaventures.com INDORAMA Nitrogen Plant West side of Drums are periodically facility stored in this area. A suggested BMP is to store all drums inside. PTA Unloading Area East of The area is routinely production inspected. A suggested building BMP includes providing secondary containment for this area. Due to the size, the nature of the operations, and the manufacturing processes at the StarPet facility, it is technically infeasible and cost prohibitive to eliminate stormwater exposure to all process materials. The facility will investigate the feasibility of. • Re-piping secondary containment structures to discharge to the POTW instead of to the stormwater system • Storing pallets inside • Covering all dumpsters and other open storage containers The facility will review the feasibility of diverting the stormwater run-on from areas of potential contamination and methods of operations/storage practices to reduce exposure of materials to stormwater on an annual basis. StarPet Inc 801 Pineview Road,Asheboro,North Carolina—27203,USA Tel-(336)672 0101,Fax-(336)672 1904 www.indoramaventureszom IND ORAMA V E N T U R E 5 StarPet BMP Summary The facility has provided structural and non-structural measures or practices to reduce the amount of pollution entering surface waters. Structural best management practices employed at the StarPet facility include providing covers over bulk storage areas, drain covers for some catch basins, and secondary containment features. Catch basins are provided to improve stormwater flow throughout the facility. Non-structural best management practices include providing rip rap at drainage ditches, semi-annual stormwater inspections, monitoring loading/unloading operations, sweeping, and good housekeeping procedures and inspections. A listing of the BMPs for the site is provided in Section 3.1.3.1. The effectiveness of the BMPs are reviewed on an annual basis and documented using the form in Appendix C. StarPet Inc 801 Pineview Road,Asheboro,North Carolina—27203.USA Tel-(336)672 0101,Fax-(336)672 1904 www.indoramaventures.com INDORAMA V E N T U R E S Tank Farm Area North of SSP This area is equipped with concrete secondary containment. Tank 1107- Tank 1107-T01 1,376,800 Ibs MEG T01 has a separate concrete containment area. Tank 1107-T02 687,200 Ibs MEG The containment areas are equipped with valves which Tank 1107-T03 73,800 Ibs MEG are locked when not in use. Accumulated water in the Tank 1115-V01 38,740 Ibs DEG containment areas is visually inspected and the Tank 1115-V02 55,300 Ibs DEG dike water is analyzed for Tank 1199-T01 440,900 Ibs COD prior to being released to the stormwater system. CG HTM Tank Farm Area East of The area is equipped with production concrete secondary building containment. Tank 3017- T VO4 is located below grade Tank 3017-V01 218,900 Ibs Therminol 66 in a containment pit. Accumulated water in the Tank 3017-VO4 2,190 Ibs Therminol V01 containment area is 66 visually inspected and the dike water is analyzed for COD prior to being released to the stormwater system. Accumulated waste in the VO4 containment area is discharged to the lift station. (4) HTM Pumps with 20-Gal East of The area is equipped with Reservoirs production small concrete secondary building containment. The containment area is visually inspected prior to being released to the VO4 containment area. StarPet Inc 801 Pineview Road,Asheboro,North Carolina—27203,USA Tel-(336)672 0101,Fax-(336)672 1904 www.indoramaventures.com IND O RAMA V E N T U R E S Storage Silos East of The storage silos are not production equipped with secondary building containment but are 1205-T01 96,000 Ibs PET routinely inspected for Chips indications of spills. 1212-T01 344,000 Ibs IPA 1207-T02 2,070,000 Ibs PTA 1207-T01 2,200,000 Ibs PTA (3) Furnaces Containing — 50 gal of East side of The furnaces are covered HTM in coils facility and the area is equipped with concrete secondary 3017-F01 containment. The 3017-F02 containment area is visually inspected and the dike 3017-F03 water is analyzed for COD prior to being released to the stormwater system. Stormwater Exposure Item Location Comments and BMPs StarPet Inc 801 Pineview Road,Asheboro,North Carolina—27203,USA Tel-(336)672 0101,Fax-(336)672 1804 www.indoramavenlures.com INDCAAMA V E N T U R E 5 Storage Silos South and The storage silos are not West of SSP equipped with secondary 2901-V62 664,000 Ibs PET containment but are Chips routinely inspected for 2901-V41 184,000 Ibs PET indications of spills. Chips 2901-V42 664,000 Ibs PET Chips 2901-V43 664,000 Ibs PET Chips 2901-V44 664,000 Ibs PET Chips 2901-V45 664,000 Ibs PET Chips 2901-V46 664,000 Ibs PET Chips 2901-V61 177,000 Ibs PET Chips 2901-V01/02 500,000 Ibs PET Chips 2901403 2,000,000 Ibs PET Chips 2901-V21 2,000,000 Ibs PET Chips 2901-V22 800,000lbs PET Chips 2901-V23 2,000,000 Ibs PET Chips 2901-V24 2,000,000 Ibs PET Chips 2901-V63 664,000lbs PET Chips 2901-V64 664,000 Ibs PET Chips StarPet Inc 801 Pineview Road,Asheboro,North Carolina—27203,USA Tel-(336)672 0101,Fax-(336)672 1904 www.indoramaventures.00m INDCAAMA V E N T U R E S 2020-001 —Dioxan Column Dike East side of This area is equipped with Administration concrete secondary office containment. The containment area is equipped with a valve and power supply, which is locked when not in use. Accumulated water in the containment area is visually inspected and the dike water is analyzed for COD prior to being released to the stormwater system. Storage Silos West side of The storage silos are not facility equipped with secondary RE12-B-01V11 664,000 Ibs PET containment but are Flake routinely inspected for RE12-B-01V12 664,000 Ibs PET indications of spills. Flake 1670-V01 Surge Tank Containing SSP area The tank is covered and the 12,760 Ibs of Therminol 66 area is equipped with concrete secondary containment. The containment area is visually inspected and the dike water is analyzed for COD prior to being released to the stormwater system. 1650-K01 and 1650-K02 Motor Oil SSP area The blowers are located Reservoirs under cover and are stored on a concrete pad near a stormwater drain. A suggested BMP includes having a drain cover readily available for the stormwater drain in the event of leakage from the reservoir. StarPet Inc 801 Pineview Road,Asheboro,North Carolina—27203,USA Tel-(336)672 0101,Fax-(336)672 1804 www.indoramaventures.com INDCAAMA V E N T U R E 5 Railcar unloading area for Glycol, East of facility Buckets are placed beneath PTA, IPA connection hoses during unloading and spill materials are located within the area. Suggested BMPs include providing the area with secondary containment. Open Scrap Metal Dumpster South of SSP The dumpsters are emptied Used Pallets on a regular basis and pallets are removed from the facility on a regular basis. Suggested BMPs include covering the dumpsters and storing used pallets in a covered area. Cyclones (2) Southeastern Dust and particulates from portion of the cyclones are stored in facility sealed drums. The area is routinely inspected and swept. Stormwater Exposure Item Location Comments and BMPs Boneyard Southern Scrap equipment and other portion of miscellaneous items are facility stored on the ground. A suggested BMP is to remove out of use equipment from the facility or cover the items with a tarp. (3) Open Dumpsters containing South of The dumpsters are emptied Plastics buildings on a regular basis. A suggested BMP is to provide covers for the dumpsters. StarPet Inc 801 Pineview Road,Asheboro,North Carolina—27203,USA Tel-(336)672 0101,Fax-(336)672 1904 www.i ndoramaventures.com INDORAMA V E N T U R E S Empty Drums South of Empty drums are Warehouse periodically removed from the facility. A suggested BMP is to store the drums inside the Warehouse. Open Trash Dumpster South of The dumpster is emptied on Warehouse a regular basis. A suggested BMP is to provide a cover for the dumpster. 2 Storage Sheds South of Hazardous waste drums Warehouse and HTM drums are stored in storage sheds. The sheds are equipped with secondary containment. 270-Gallon Diesel Tank and Gasoline East of The tank is a double-walled Mobile Cart Warehouse tank. The mobile cart is stored in the HTM storage shed. HTM Tank Area East side of The area is covered and is production equipped with concrete building secondary containment. 3087-V01 2,190 Ibs Therminol The accumulated water from the containment areas is VP1 visually inspected and 3057-V02 2,190 Ibs Therminol 66 analyzed for COD prior to being released to the 1427-E01 HTM Evaporator stormwater system. Railcar Unloading and Locomotive West side of While solids are facility predominately unloaded in this area, a suggested BMP includes providing spill response materials in this area for any potential spill of liquids. StarPet Inc 801 Plneview Road,Asheboro,North Carolina—27203,USA Tel-(336)672 0101,Fax-(336)672 1904 www.indoramaventures.com INDORAMA V E N T U R E S Nitrogen Plant West side of Drums are periodically facility stored in this area. A suggested BMP is to store all drums inside. PTA Unloading Area East of The area is routinely production inspected. A suggested building BMP includes providing secondary containment for this area. Due to the size, the nature of the operations, and the manufacturing processes at the StarPet facility, it is technically infeasible and cost prohibitive to eliminate stormwater exposure to all process materials. The facility will investigate the feasibility of: • Re-piping secondary containment structures to discharge to the POTW instead of to the stormwater system • Storing pallets inside • Covering all dumpsters and other open storage containers The facility will review the feasibility of diverting the stormwater run-on from areas of potential contamination and methods of operations/storage practices to reduce exposure of materials to stormwater on an annual basis. StarPet Inc 801 Pineview Road,Asheboro,North Carolina-27203,USA Tel-(336)672 0101,Fax-(336)672 1904 www.indoramaventures.com INDORAMA V E N T U R E S StarPet Significant Changes Summary StarPet, Inc. installed a new process within the CP building that has the capability of using post- consumer recycled PET and blending that into the manufacturing process to produce rPET (recycled content Polyester chips). The recycled PET flake is received at the new flake building, where it is off-loaded from trucks and stored. The flake arrives in super sacks, which are emptied into a hopper, then conveyed to two storage silos, prior to being conveyed to the day silo on the top of the CP production building. All silos are equipped with cyclones to collect dust and are routinely inspected and cleaned. StarPet installed a Dioxane Column at the northeast corner of the CP Production building. The column strips VOC chemicals from the process water and is then sent to the RTO for destruction. The water is sent to the lift station where it is then discharged to the city POTW. StarPet Inc 801 Pineview Road,Asheboro,North Carolina—27203,USA Tel-(336)672 0101,Fax-(336)672 1904 www.indorannaventures.00m IND O RAMA V F_ N T U R E S StarPet Significant Changes Summary StarPet, Inc. installed a new process within the CP building that has the capability of using post- consumer recycled PET and blending that into the manufacturing process to produce WET (recycled content Polyester chips). The recycled PET flake is received at the new flake building, where it is off-loaded from trucks and stored. The flake arrives in super sacks, which are emptied into a hopper, then conveyed to two storage silos, prior to being conveyed to the day silo on the top of the CP production building. All silos are equipped with cyclones to collect dust and are routinely inspected and cleaned. StarPet installed a Dioxane Column at the northeast corner of the CP Production building. The column strips VOC chemicals from the process water and is then sent to the RTO for destruction. The water is sent to the lift station where it is then discharged to the city POTW. StarPet Inc 801 Pineview Road,Asheboro,North Carolina—27203,USA Tel-(336)672 0101,Fax-(336)672 1904 www.indoramaventures.00m r ^� fill ilyel � isi � ill � isia�� is � l,i i i t tit i9i3i if 9ii , ii it ' i 'll 'i s i n s I l e t t , l j t i I 1 1 ' loop � . . IIaII !fill fII ; IE{; iio ; IiIII (;I ( g ►rf`�`�i�i r�;i�Iti�jl°lir�f�i���t a 0i]0 III R - Li . , e i m o00 0 - owl 1 dF All.wo : 4 p ee d Is j ; #1 ono P ^l5lhl j Iii3rild��dF�3 1 ! ! ! Al" 1af991 ° : i ° �l : d � ? is ll : : d : l�Id l `aal � ; ti � a 1 `a11 ° � ldld.d.11ld �� Visual Results Summary 2023-03-02 2022-10-13 2022-03-17 2021-12-19 2021-05-12 2020-12-14 2020-02-25 2019-12-01 2019-03-22 2018-10-11 Light Light Light Light Light Light Light Light Light Light Color Brown Brown Brown Brown Brown Brown Brown Brown Brown Brown Odor None None None None None None None None None None Clarity 4 2 3 2 2 2 2 2 2 2 Floating Solids 1 1 1 1 1 1 1 1 1 1 Suspended Solids 4 2 2 1 1 1 1 1 1 1 Foam No No No No No No No No No No Oil Sheen No No No No No No No No No No Visual Results Summary 2023-03-02 2022-10-13 2022-03-17 2021-12-19 2021-05-12 2020-12-14 2020-02-25 2019-12-01 2019-03-22 2018-10-11 Light Light Light Light Light Light Light Light Light Light Color Brown Brown Brown Brown Brown Brown Brown Brown Brown Brown Odor None None None None None None None None None None Clarity 4 2 3 2 2 2 2 2 2 2 Floating Solids 1 1 1 1 1 1 1 1 1 1 Suspended Solids 4 2 2 1 1 1 1 1 1 1 Foam No No No No No No No No No No Oil Sheen No No No No No No No No No No Historical Historical Units Benchmark 2023-03-02 2022-10-13 2022-03-17 2021-12-19 2021-05-12 2020-12-14 2020-02-25 2019-12-01 2019-03.22 2018-ID-11 BOD S da MOIL 30.00 19.60 32.50 6.90 4.00 4.60 21.30 15.00 1.90 13.60 19.50 TSS MG& 100 00 1220.00 ]00 12.00 13.00 21.00 23.00 16.00 1900. 12.00 130,00 COD MG7. 12000 9200 <1500 3200 42 00 21.00 32 00 30.00 34.00 34.00 20.00 MBAS MG/L 0.50 Total Ph ones MOIL 2.00 Nitrogen i Nitrate tdG/L EPA300A Nitrogen/Nitrite MMG� 30.00 3M0 Total Ni .00TKN N or BTotal Cobalt 030""Grease .00H o 9 7.10 750 7.00 7.30 670 680 690 680 6.53 6.70 Elhelene G I 000Amountofminfall0.7 0.15 0.82 0.7 0.66 0.57 0.54 0.67 07 0.60 Page 1 Historkal NiSloriGal _ __ Unes Benchmsr 2023-0302 2022-10-13 2022.03-17 2021-12-19 2021-05.12 2020-12-14 2020-02-25 2019.12-01 2019-03.22 2018-10.11 BOD 508 MG/L 30.00 19.60 32.50 6.90 4.00 4.60 21.30 15.00 1.90 13.60 19.50 TSS MG/L 100.00 1220.00 7.00 1200 13.00 21.00 2300 1&00 19.00 12.00 13000 COD MGIL 120.00 9200 15.00 3200 42.00 21.00 3200 3000 34.00 34.00 20.00 WAS MG/L 0.50 Total Phos ores MG/L 2.00 Nitrogen/Nitrate MG/L EPA 300.0 Nltra n/Nitrite MG/L EPA 300.0 Total N n MG/L 30.00 _ TKN MG/L SM 4500N or B Total Cobalt MG/L 0.03 Oil B Grease MG/L i 30.00 H 'Stan0ard I 6109 710 ].50 TOG 7,30 G.m 6.80 6.90 1 6.80 6.53 670 Ethelene Glycol I MG/L 1 14.000 An nt of rainfall 1 1 07 0.151 0.62 0]1 0.68 0.57 0.54 1 0.67 0.] 0.60 Page 1 Young, Brianna A From: Mark Pederson <mark.pederson@us.indorama.net> Sent: Friday, December 1, 2023 1:50 PM To: Young, Brianna A Cc: Durgesh Kushwaha Subject: [External] RE: Stormwater permit NCS000354 for StarPet, Inc. Attachments: 2023 StarPet Supplemental and SPPP Certification Form.pdf; StarPet BMP Summary.docx; StarPet Significant Changes Summary.docx; 2018-2023 Stormwater historical results.xlsx; StarPet Facility Layout.pdf CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message button located on your Outlook menu bar on the Home tab. Good afternoon Brianna. Attached you will find the additional information as requested below, along with the Supplemental and SPPP Certification forms. The facility layout shows the location of all storage activities and drainage flow, while the BMP summary provides additional information such as chemicals stored, and containment and management practices. Other than changes identified since the effective date of the permit,there have not been any changes since the renewal application has been submitted. 2 copies of each of the attached documents will be sent to your attention. If you have any questions or need additional information, please let me know. Thanks, Mark Pederson EHS Manager StarPet Inc. 801 Pineview Rd. Asheboro,NC 27203 Phone: (336)672-0101 ext.306 Fax:(336)672-2583 Mobile: (336)964-0173 www.indoramaventures.com Our vision: To be a world-class sustainable chemical company making great products for society. Important:This email and any files transmitted with it are confidential and Disclaimer intended solely for the use of theindividual or entity wo whom they are addressed. If you have received this email in error we would request you not to copy,store or forward the email. Please return the message to the sender and delete it immediately thereafter. From:Young, Brianna A<Brianna.Young@deq.nc.gov> Sent:Tuesday, November 21, 2023 13:45 To: Durgesh Kushwaha <durgesh.kushwaha@us.indorama.net> Cc:Jason Greenwood <jason.greenwood@us.indorama.net>; Mark Pederson <mark.pederson@us.indorama.net> Subject: Stormwater permit NCS000354 for StarPet, Inc. Importance: High [External Email]-This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. 1 Good afternoon, I am working on renewing the individual stormwater permit for StarPet, Inc. (NCS000354). I need additional information in order to 1) confirm that the information I have is correct and 2)make sure the permit adequately serves the needs of the facility. Please provide the following: • The SPPP Certification Form. Supplemental Information Form, and all required attachments were not submitted with the permit application; • Site map that contains the layout of the facility with all buildings and tanks identified; • Description of chemicals stored onsite; • Description of industrial activity in each drainage area; • An electronic spreadsheet summarizing all of the monitoring data that has been collected since the effective date of the current permit; • Verification that the information in the renewal application is still complete and correct; and • An explanation of any operational changes since the renewal application was submitted. Enter your stormwater permit number into the Stormwater Permit Summary Report and you will see a form that includes the address of the facility, contact information for the permit, and the regulated stormwater outfall(s) for the facility. Please review the facility information to make sure it is correct. Information can be updated using the links provided below, where applicable: • Facility/Company name or ownership: Name/Ownership Change Form • Owner Affiliation(Legally responsible person; i.e., someone with the company who is designated to represent the company per signatory requirements or another authorized representative): Permit Contact Update Request Form • Delegation of Signature Authority (DOSA): Permit Contact Update Request Form • Billing contact: Permit Contact Update Request Form • Permit contact: Permit Contact Update Request Form • Facility contact: Permit Contact Update Request Form • Facility address only: Email Bethany og ulias • Stormwater outfall information: Email Bethany Geor og ulias • Visit the eDMR Six Steps website and complete Steps 1 and 2 • Pay outstanding permit fees: Stormwater ePgMent website Once I have the above listed information, I can continue my review. You will receive a draft permit for a 30-day comment period. During this time we will be able to address any comments or concerns you have. During the same 30-day period, the draft will be sent to a Regional Office staff member for review as well as out to public notice. Once all comments and concerns are addressed,you may be issued a final permit. Please contact me if you have any questions. Thank you, Brianna Young, MS (she/her) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR) Brian na.Young@d eq.nc.goy(e-mail preferred) PLEASE NOTE NEW EMAIL ADDRESS 2 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized state official. 3 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 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. 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. VUI 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. Y1 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) STORMWATER POLLUTION PREVENTION PLAN DEVELOPMENT AND IMPLEMENTATION CERTIFICATION North Carolina Division of Energy, Mineral, and Land Resources—Stormwater Program Facility Name: StarPet,Inc. Permit Number: NCS000354 Location Address: 801 Pineview Road Asheboro,NC 27203 County: Randolph "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 U` {� h-`' Date 12/1/2023 Mark E Pederson EHS Manager Print or type name of person signing above Title SPPP Certification 10/13 INDORAMA V E N T U R E S StarPet BMP Summary The facility has provided structural and non-structural measures or practices to reduce the amount of pollution entering surface waters. Structural best management practices employed at the StarPet facility include providing covers over bulk storage areas, drain covers for some catch basins, and secondary containment features. Catch basins are provided to improve stormwater flow throughout the facility. Non-structural best management practices include providing rip rap at drainage ditches, semi-annual stormwater inspections, monitoring loading/unloading operations, sweeping, and good housekeeping procedures and inspections. A listing of the BMPs for the site is provided in Section 3.1.3.1. The effectiveness of the BMPs are reviewed on an annual basis and documented using the form in Appendix C. StarPet Inc 801 Pineview Road,Asheboro, North Carolina—27203, USA Tel-(336)672 0101, Fax-(336)672 1904 www.indoramaventures.com INDORAMA V E N T U R E S Tank Farm Area North of SSP This area is equipped with concrete secondary containment. Tank 1107- Tank 1107-T01 1,376,800 Ibs MEG T01 has a separate concrete containment area. Tank 1107-T02 687,200 Ibs MEG The containment areas are equipped with valves which Tank 1107-T03 73,800 Ibs MEG are locked when not in use. Accumulated water in the Tank 1115-V01 38,740 Ibs DEG containment areas is visually inspected and the Tank 1115-V02 55,300 Ibs DEG dike water is analyzed for Tank 1199-T01 440,900 Ibs CG COD prior to being released to the stormwater system. HTM Tank Farm Area East of The area is equipped with production concrete secondary building containment. Tank 3017- Tank 3017-V01 218,900 Ibs VO4 is located below grade Therminol 66 in a containment pit. Accumulated water in the Tank 3017-VO4 2,190 Ibs Therminol V01 containment area is 66 visually inspected and the dike water is analyzed for COD prior to being released to the stormwater system. Accumulated waste in the VO4 containment area is discharged to the lift station. (4) HTM Pumps with 20-Gal East of The area is equipped with Reservoirs production small concrete secondary building containment. The containment area is visually inspected prior to being released to the VO4 containment area. StarPet Inc 801 Pineview Road,Asheboro, North Carolina—27203, USA Tel-(336)672 0101, Fax-(336)672 1904 www.indoramaventures.com INDORAMA V E N T U R E S Storage Silos East of The storage silos are not production equipped with secondary building containment but are 1205-T01 96,000 Ibs PET routinely inspected for Chips indications of spills. 1212-T01 344,000 Ibs IPA 1207-T02 2,070,000 Ibs PTA 1207-T01 2,200,000 Ibs PTA (3) Furnaces Containing - 50 gal of East side of The furnaces are covered HTM in coils facility and the area is equipped with concrete secondary 3017-F01 containment. The 3017-F02 containment area is visually inspected and the dike 3017-F03 water is analyzed for COD prior to being released to the stormwater system. Stormwater Exposure Item Location Comments and BMPs StarPet Inc 801 Pineview Road,Asheboro, North Carolina—27203, USA Tel-(336)672 0101, Fax-(336)672 1904 www.indoramaventures.com INDORAMA V E N T U R E S Storage Silos South and The storage silos are not West of SSP equipped with secondary 2901-V62 664,000 Ibs PET containment but are Chips routinely inspected for 2901-V41 184,000 Ibs PET indications of spills. Chips 2901-V42 664,000 Ibs PET Chips 2901-V43 664,000 Ibs PET Chips 2901-V44 664,000 Ibs PET Chips 2901-V45 664,000 Ibs PET Chips 2901-V46 664,000 Ibs PET Chips 2901-V61 177,000 Ibs PET Chips 2901-V01/02 500,000 Ibs PET Chips 2901-V03 2,000,000 Ibs PET Chips 2901-V21 2,000,000 Ibs PET Chips 2901-V22 800,000 Ibs PET Chips 2901-V23 2,000,000 Ibs PET Chips 2901-V24 2,000,000 Ibs PET Chips 2901-V63 664,000 Ibs PET Chips 2901-V64 664,000 Ibs PET Chips StarPet Inc 801 Pineview Road,Asheboro, North Carolina—27203, USA Tel-(336)672 0101, Fax-(336)672 1904 www.indoramaventures.com INDORAMA V E N T U R E S 2020-001 — Dioxan Column Dike East side of This area is equipped with Administration concrete secondary office containment. The containment area is equipped with a valve and power supply, which is locked when not in use. Accumulated water in the containment area is visually inspected and the dike water is analyzed for COD prior to being released to the stormwater system. Storage Silos West side of The storage silos are not facility equipped with secondary RE12-B-01V11 664,000 Ibs PET containment but are Flake routinely inspected for RE12-B-01V12 664,000 Ibs PET indications of spills. Flake 1670-V01 Surge Tank Containing SSP area The tank is covered and the 12,760 Ibs of Therminol 66 area is equipped with concrete secondary containment. The containment area is visually inspected and the dike water is analyzed for COD prior to being released to the stormwater system. 1650-K01 and 1650-K02 Motor Oil SSP area The blowers are located Reservoirs under cover and are stored on a concrete pad near a stormwater drain. A suggested BMP includes having a drain cover readily available for the stormwater drain in the event of leakage from the reservoir. StarPet Inc 801 Pineview Road,Asheboro, North Carolina—27203, USA Tel-(336)672 0101, Fax-(336)672 1904 www.indoramaventures.com INDORAMA V E N T U R E S Railcar unloading area for Glycol, East of facility Buckets are placed beneath PTA, IPA connection hoses during unloading and spill materials are located within the area. Suggested BMPs include providing the area with secondary containment. Open Scrap Metal Dumpster South of SSP The dumpsters are emptied on a regular basis and Used Pallets pallets are removed from the facility on a regular basis. Suggested BMPs include covering the dumpsters and storing used pallets in a covered area. Cyclones (2) Southeastern Dust and particulates from portion of the cyclones are stored in facility sealed drums. The area is routinely inspected and swept. Stormwater Exposure Item Location Comments and BMPs Boneyard Southern Scrap equipment and other portion of miscellaneous items are facility stored on the ground. A suggested BMP is to remove out of use equipment from the facility or cover the items with a tarp. (3) Open Dumpsters containing South of The dumpsters are emptied Plastics buildings on a regular basis. A suggested BMP is to provide covers for the dumpsters. StarPet Inc 801 Pineview Road,Asheboro, North Carolina—27203, USA Tel-(336)672 0101, Fax-(336)672 1904 www.indoramaventures.com INDORAMA V E N T U R E S Empty Drums South of Empty drums are Warehouse periodically removed from the facility. A suggested BMP is to store the drums inside the Warehouse. Open Trash Dumpster South of The dumpster is emptied on Warehouse a regular basis. A suggested BMP is to provide a cover for the dumpster. 2 Storage Sheds South of Hazardous waste drums Warehouse and HTM drums are stored in storage sheds. The sheds are equipped with secondary containment. 270-Gallon Diesel Tank and Gasoline East of The tank is a double-walled Mobile Cart Warehouse tank. The mobile cart is stored in the HTM storage shed. HTM Tank Area East side of The area is covered and is production equipped with concrete building secondary containment. 3087-V01 2,190 Ibs Therminol The accumulated water from VP1 the containment areas is visually inspected and 3057-V02 2,190 Ibs Therminol 66 analyzed for COD prior to being released to the 1427-E01 HTM Evaporator stormwater system. Railcar Unloading and Locomotive West side of While solids are facility predominately unloaded in this area, a suggested BMP includes providing spill response materials in this area for any potential spill of liquids. StarPet Inc 801 Pineview Road,Asheboro, North Carolina—27203, USA Tel-(336)672 0101, Fax-(336)672 1904 www.indoramaventures.com INDORAMA V E N T U R E S Nitrogen Plant West side of Drums are periodically facility stored in this area. A suggested BMP is to store all drums inside. PTA Unloading Area East of The area is routinely production inspected. A suggested building BMP includes providing secondary containment for this area. Due to the size, the nature of the operations, and the manufacturing processes at the StarPet facility, it is technically infeasible and cost prohibitive to eliminate stormwater exposure to all process materials. The facility will investigate the feasibility of: • Re-piping secondary containment structures to discharge to the POTW instead of to the stormwater system • Storing pallets inside • Covering all dumpsters and other open storage containers The facility will review the feasibility of diverting the stormwater run-on from areas of potential contamination and methods of operations/storage practices to reduce exposure of materials to stormwater on an annual basis. StarPet Inc 801 Pineview Road,Asheboro, North Carolina—27203, USA Tel-(336)672 0101, Fax-(336)672 1904 www.indoramaventures.com INDORAMA V E N T U R E S StarPet Significant Changes Summary StarPet, Inc. installed a new process within the CP building that has the capability of using post- consumer recycled PET and blending that into the manufacturing process to produce rPET (recycled content Polyester chips). The recycled PET flake is received at the new flake building, where it is off-loaded from trucks and stored. The flake arrives in super sacks, which are emptied into a hopper, then conveyed to two storage silos, prior to being conveyed to the day silo on the top of the CP production building. All silos are equipped with cyclones to collect dust and are routinely inspected and cleaned. StarPet installed a Dioxane Column at the northeast corner of the CP Production building. The column strips VOC chemicals from the process water and is then sent to the RTO for destruction. The water is sent to the lift station where it is then discharged to the city POTW. StarPet Inc 801 Pineview Road,Asheboro, North Carolina—27203, USA Tel-(336)672 0101, Fax-(336)672 1904 www.indoramaventures.com Historical Historical Units Benchmark 3/2/2023 10/13/2022 3/17/2022 12/19/2021 5/12/2021 12/14/2020 2/25/2020 12/1/2019 3/22/2019 10/11/2018 BOD(5 day) MG/L 30.00 19.60 32.50 6.90 4.00 4.60 21.30 15.00 1.90 13.60 19.50 TSS MG/L 100.00 1220.00 7.00 12.00 13.00 21.00 23.00 16.00 19.00 12.00 130.00 COD MG/L 120.00 92.00 <15.00 32.00 42.00 21.00 32.00 30.00 34.00 34.00 20.00 MBAS MG/L 0.50 or Total Phosphorus MG/L 2.00 7W Nitrogen/Nitrate MG/L EPA 300.0 Nitrogen/Nitrite MG/L EPA 300.0 Total Nitrogen MG/L 30.00 TKN MG/L SM 4500 N(org)B Total Cobalt MG/L 0.03 Oil&Grease MG/L 30.00 pH "Standard 6 to 9 7.10 7.50 7.00 7.30 6.70 6.90 6.80 6.53 6.70 Ethelene Glycol MG/L 14,000 Amount of rainfall 0.7 0.15 0.82 0.7 0.68 6.80 0.57 0.54 0.67 0.7 0.60 Page 1 Visual Results Summary 3/2/2023 10/13/2022 3/17/2022 12/19/2021 5/12/2021 12/14/2020 2/25/2020 12/1/2019 3/22/2019 10/11/2018 Light Light Light Light Light Light Light Light Light Light Color Brown Brown Brown Brown Brown Brown Brown Brown Brown Brown Odor None None None None None None None None None None Clarity 4 2 3 2 2 2 2 2 2 2 Floating Solids 1 1 1 1 1 1 1 1 1 1 Suspended Solids 4 2 2 1 1 1 1 1 1 1 Foam No No No No No No No No No No Oil Sheen No No No No No No No No No No r cr opri"1! ark` ' �.�. — iar_ f. — — — — _ j. ^V E LLJ ' '� '�• --- 7 - — �JP _ S ' •� OZZ't�- ID WLU c : LU w rrr� ino xvnai v�i O j "` Lx � •w ti �z 1 :' .0tLU i rD Q 4. oui 4 T.� ir D_ ® + N s � � 1N3Wdif1O3 � /• s o 0 I w Zo 7 C O 70 m ` Of m 1 r o ` a 11 m¢ I '� m a a` L H. ` A i _ CL m o g 8 8 8 E g a a a a a JI t .wr.rr -��•+-�e- Ate._,. - . 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Questions about sampling can be addressed at the time of permit renewal. Thank you, Brianna Young, MS(she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov(e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public during this challenging time. From: Mark Pederson <mark.pederson@us.indorama.net> Sent:Tuesday, October 25, 2022 3:06 PM To:Young, Brianna A<Brianna.Young@ncdenr.gov> Subject: [External] Stormwater Permit Renew CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to Report Spam. Good afternoon Brianna. Thank you for your response earlier today. I am attaching StarPets Stormwater Permit renewal application for your consideration. I know that Section 5 of Form 2-F may not meet your requirements at this time, but wanted to at least get the application in before the deadline date. I had spoken to Lily Kay about this section and she advised to get the application in and try to resolve the Non-Stormwater Discharge issue after. I understand your position on what chemicals we should analyze for and will schedule collection and testing accordingly. I am just concerned about testing for chemicals that are not associated with our processes,and then having to test for those chemicals whenever a stormwater sample is collected. The one facility to our east has been shut down for several years, and since we are surrounded by railroad tracks on three sides of the facility and Pineview Road to the 1 north, I don't think there is a reasonable chance for chemical substances from other facilities to migrate onto our property. Please let me know what you think. The hard copy of the application will be mailed out tomorrow. Regards, Mark Pederson EHS Manager StarPet Inc. 801 Pineview Rd. Asheboro, NC 27203 Phone: (336) 672-0101 ext. 306 Fax: (336) 672-2583 Mobile: (336) 964-0173 www.indoramaventures.com Our vision: To be a world-class sustainable chemical company making great products for society. Important: This email and any files transmitted with it are confidential and Disclaimer intended solely for the use of theindividual or entity wo whom they are addressed. If you have received this email in error we would request you not to copy, store or forward the email. Please return the message to the sender and delete it immediately thereafter. 2 11/20/23,4:48 PM North Carolina Secretary of State Search Results • File an Annual Report/Amend an Annual Report • Upload a PDF Filing • Order a Document Online - Add Entity to My Email Notification List • View Filings • Print a Pre-Populated Annual Report form • Print an Amended a Annual Report form Business Corporation Legal Name StarPet Inc. Prev Legal Name StarPet Subsidiary Inc. Information Sosld: 1188584 Status: Current-Active O Date Formed: 2/11/2011 Citizenship: Foreign State of Incorporation: DE Fiscal Month: December Annual Report Due Date: April 15th Currentgnnual Report Status: Registered Agent: Corporation Service Company Addresses https://www.sosnc.gov/onIine_services/search/Business_Registration_ResuIts 1/2 11/20/23,4:48 PM North Carolina Secretary of State Search Results Reg Office Reg Mailing Mailing 2626 Glenwood Ave Ste 550 2626 Glenwood Ave Ste 550 801 Pineview Road Raleigh, NC 27608 Raleigh, NC 27608 Asheboro, IL 27203-3192 Principal Office 801 Pineview Road Asheboro, IL 27203-3192 Off icers Vice President Chief Financial Officer President Sachin Agarwalla Saswati Biswas Muthukumar Paramasivam Heller 4235 South Stream Blvd Suite 450 801 Pineview Road 4235 South Stream Blvd Charlotte NC 28217 Asheboro NC 27203 Charlotte NC 60015 Vice President Secretary Hitendra Mathur Hunter Stamey 4235 South Stream Boulevard, Suite 450 4235 South Stream Blvd Suite 450 Charlotte NC 28217 Charlotte NC 28217 Stock https://www.sosnc.gov/online_services/search/Business_Registration_ResuIts 2/2 Young, Brianna A From: Young, Brianna A Sent: Wednesday, November 9, 2022 11:59 AM To: Mark Pederson Cc: jason.greenwood@us.indorama.net Subject: Starpet, Inc. stormwater permit renewal application NCS000354 Good afternoon, The Division of Energy, Mineral, and Land Resources (DEMLR)Stormwater Permitting Program acknowledges receipt of your renewal application for coverage under NPDES Permit Number NCS000354. Please continue to comply with all conditions and monitoring requirements in your current 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. Please note that due to the current backlog and staff shortages, review of this permit renewal is not scheduled until 2024, however this schedule is subject to change. Please let me know if you have any questions in the interim. Thank you, Brianna Young, MS(she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov(e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 ,�: D_ E � � NORTH CAROLINA Department of Environmental Quality Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public during this challenging time. 1 RECEIVE INDORAMA V E N T U R E S NOV 2022 7EMLR-Storl"wat"Prograilbate: 10/25/2022 Brianna Young North Carolina DEQ 1612 Mail Service Center Raleigh, NC 27699-1612 Dear Ms. Young, Attached is the renewal application for the Stormwater Permit issued to StarPet, Inc. (Permit No. NC50003545). There are a few items I had trouble completing for this renewal. The first has to do with Table A of Form 2F. StarPet has never been required to test at Max or Avg Daily discharge, and never determined Flow-Weighted Composite analysis. StarPet has also never been required to test for some of the pollutants or parameters listed. Table C of Form 2F requires the listing of pollutants in Exhibits 2F-2, 2F-3 and 2F-4, which are reasonably expected to be present in the stormwater. I listed the applicable chemicals that are associated with our process, but since these chemicals are contained in an enclosed process, StarPet does not expect these to be found in the stormwater, and the stormwater samples have never been analyzed for these constituents. Table D of Form 2F requires information such as duration of storm event, maximum flow rate and total flow from rain event. Again, StarPet has never been subject to these requirements, and thus do not have that information available. Lastly, Section 5 of form 2F requires the certification of non-stormwater discharges. As outlined in the application, stormwater from the facility flows through two sediment ponds prior to discharge from the outfall. StarPet has visually monitored the outfalls over the years and verified that even when there is no discharge into the first sediment pond, there continues to be a discharge from the outfall. StarPet has noted that the flow continues even when there is a significant period of time in-between rainfall events. StarPets' position is that there is groundwater intrusion into the settlement ponds which results in the discharge. The question I have in regard to this is, how would I certify to NCDEQ that the discharge is actually ground water and not related to discharges from the facility operations. Any clarification/help on this issue is appreciated. If you have any questions regarding this information, please contact me at(336) 964-0173. Sinc rely, Mar E. Pederson, EH&S Manager StarPet, Inc 801 Pineview Road Asheboro, NC 27203 StarPet Inc 801 Pineview Road,Asheboro,North Carolina—27203,USA Tel-(336)672 0101,Fax-(336)672 1904 www.indoramaventures.com r RECEIVED Ir EPA identification Number NPDES Permit Number Facility Name Form Approved 03/05119 NCR000004218 NCS000354 StarPet,Inc. OMB No.2040-0004 Form U.S.Environmental Protection Agency 1 \=,EPA Application for NPDES Permit to Discharge Wastewater NPDES GENERAL INFORMATION SECTION -D i 1.1 Applicants Not Required to Submit Form 1 Is the facility a new or existing publicly owned Is the facility a new or existing treatment works 1.1.1 treatment works? "1.2 treating domestic sewage? If yes, STOP. Do NOT complete No If yes, STOP. Do NOT 0 No Form 1. Complete Form 2A. complete Form 1. Complete Form 2S. 1.2 Applicants Required to Submit Form 1 1.2.1 Is the facility a concentrated animal feeding 1.2.2 Is the facility an existing manufacturing, E operation or a concentrated aquatic animal commercial,mining, or siivicultural facility that is a- production facility? currently discharging process wastewater? o [] Yes 4 Complete Form 1 0 No [] Yes 4 Complete Form No z and Form 213. 1 and Form 2C, 1.2.3 Is the facility a new manufacturing,commercial, 1.2.4 Is the facility a new or existing manufacturing, mining,or silvicultural facility that has not yet commercial,mining,or siivicultural facility that c commenced to discharge? discharges only nonprocess wastewater? Cr w ❑ Yes 4 Complete Form 1 0 No Yes 4 Complete Form 0 No and Form 2D. 1 and Form 2E. 1.2.5 Is the facility a new or existing facility whose discharge is composed entirely of stormwater a associated with industrial activity or whose discharge is composed of both stormwater and non-stormwater? 0 Yes 4 Complete Form 1 ❑ No and Form 2F unless exempted by 40 CFR 122.26(b)(14)(x)or b 15). SECTION ••- AND LOCATION(40 2.1 Facility Name StarPet,Inc. 0 2.2 EPA Identification Number U 0 NCR000004218 2.3 Facility Contact Name(first and last} FSr. e Phone number 4 Jason Greenwood Technical Manager (336}302 9980 a Email address jason.greenwood@us.indorama.net d 2.4 Facility Mailing Address zStreet or P.O. box 801 Pineview Road City or town State ZIP code Asheboro NC 27203 EPA Form 3510-1(revised 3-19) Page 1 EPA Identification Number NPOES Permit Number Facility Name Form Approved 03105/19 NCR000004218 NCS000354 StarPet,Inc. OMB No.2040-0004 2.5 Facility Location Street,route number,or other specific identifier Q o 801 Pineview Road U o County name County code(if known) Randolph 076 0 E _j City or town State ZIP code a z Asheboro NC 27203 SECTIONCODES 3.1 SIC Code(s) Description(optional) 2821 Plastics Material and Resin Manufacturing w w v a V U z 3.2 NAICS Code(s) Description(optional) c 325211 Plastics Material and Resin Manufacturing V 4.1 Name of 0 erator StarPet,Inc. c 4.2 Is the name you listed in Item 4.1 also the owner? o ❑ Yes ❑✓ No 0 L 4.3 Operator Status ❑ Public—federal ❑ Public—state ❑ Other public(specify) p 0 Private ❑ Other(specify) 4.4 Phone Number of Operator (336)672-0101 4.5 Operator Address . Street or P.O. Box g E 801 Pineview Road City or town State ZIP code o e Asheboro North Carolina 27203 L CL Email address of operator O jason.greenwood@us.indorama.net SECT • c 5.1 Is the facility located on Indian Land? ❑ Yes No EPA Form 3510-1(revised 3-19) Page 2 EPA Identification Number NPoES Permit Number Facility Name Form Approved 03/05/19 NCR000004218 NCS000354 StarPet,Inc. OMB No.2040-0004 SECTION -• 1 6.1 Existing Environmental Permits(check all that apply and print or type the corresponding permit number for each) m ❑ NPDES(discharges to surface ❑ RCRA(hazardous wastes) ❑ UIC(underground injection of o y water) fluids) 3 E ❑ PSD(air emissions) ❑ Nonattainment program(CAA) ❑✓ NESHAPs(CAA) 08157T14 r x ❑ Ocean dumping(MPRSA) ❑ Dredge or fill(CWA Section 404) ❑ Other(specify) ul SECTIONI 7.1 Have you attached a topographic map containing all required information to this application?(See instructions for C specific requirements.) ca ,/❑ Yes ❑ No ❑ CAFO—Not Applicable(See requirements in Form 26.) SECTIONOF I 8.1 Describe the nature of your business. StarPet,Inc.manufactures and processes PET resin for use in the beverage industry. The facility consists of two Continuous Polymerization plants,which produce the amorphous PET resin,and two Solid Stating Plants,which convert the amorphous PET into the final PET product. Raw materials are received via rail car and truck,and the final PET product is shipped via rail car and truck. 07 0 L R Z SECTION •• 1 9.1 Does your facility use cooling water? m ❑✓ Yes ❑ No SKIP to Item 10.1. M 9.2 Identify the source of cooling water. (Note that facilities that use a cooling water intake structure as described at a,+, 40 CFR 125, Subparts I and J may have additional application requirements at 40 CFR 122.21(r). Consult with your o Y NPDES permitting authority to determine what specific information needs to be submitted and when.) Asheboro Public Water System c SECTION 1 VARIANCE I 1 10.1 Do you intend to request or renew one or more of the variances authorized at 40 CFR 122.21(m)?(Check all that w apply. Consult with your NPDES permitting authority to determine what information needs to be submitted and when.) Cr ❑ Fundamentally different factors(CWA ❑ Water quality related effluent limitations(CWA Section Section 301(n)) 302(b)(2)) ❑ Non-conventional pollutants(CWA ❑ Thermal discharges(CWA Section 316(a)) Section 301(c)and(g)) ❑✓ Not applicable EPA Form 3510-1(revised 3-19) Page 3 EPA Identification Number NPDES Permit Number Facility Name Form Approved 03105119 NCR000004218 NC5000354 StarPet,Inc. OMB No.2040-0004 CERTIFICATIONSECTION 11.CHECKLIST AND I 11.1 In Column 1 below,mark the sections of Form 1 that you have completed and are submitting with your application. For each section,specify in Column 2 any attachments that you are enclosing to alert the permitting authority.Note that not all applicants are required to provide attachments. Column 1 Column 2 0 Section 1:Activities Requiring an NPDES Permit ❑ wl attachments El Section 2:Name, Mailing Address,and Location ❑ wl attachments 0 Section 3:SIC Codes ❑ wl attachments 0 Section 4:Operator Information ❑ wl attachments ❑� Section 5: Indian Land ❑ wl attachments c 0 Section B: Existing Environmental Permits ❑ wl attachments d E ✓❑ Section 7:Ma ❑ wl topographic P ma ❑ wl additional attachments U) c ❑✓ Section 8:Nature of Business ❑ wl attachments ❑✓ Section 9:Cooling Water Intake Structures ❑ wl attachments m a �]✓ Section 10:Variance Requests ❑ wl attachments c ❑✓ Section 11:Checklist and Certification Statement ❑ wi attachments J9 11.2 Certification Statement U I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted.Based on my inquiry of the person or persons who manage the system,or those persons directly responsible for gathering the information,the information submitted is,to the best of my knowledge and belief,true,accurate,and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. Name(print or type first and last name) official title DU"F-SH C• KUSHVQAHA A v P (UPERAlI0NS) Signature Date signed to 12,410 2.-A EPA Form 3510.1(revised 3-19) Page 4 EPA Identification Number NPDES Permit Number Facility Name Form Approved 03105119 NCR000004218 NCS000354 StarPet, Inc. OMB No.204NO04 Form U.S Environmental Protection Agency 2F V EPA Application for NPDES Permit to Discharge Wastewater NPDES STORMWATER DISCHARGES ASSOCIATED WITH INDUSTRIAL ACTIVITY SECTIONOUTFALL LOCATION 1.1 Provide information on each of the facility's outfalls in the table below Outfall Receiving Water Name Latitude Longitude Number 001 Back Creek 35' 46' 4 8" N 79' 49' 17.58" W c a c.o a 19 r-' SECTIONPR• 2.1 Are you presently required by any federal,state,or local authority to meet an implementation schedule for constructing, upgrading,or operating wastewater treatment equipment or practices or any other environmental programs that could affect the discharges described in this application? ❑ Yes ✓❑ No 4 SKIP to Section 3. 2.2 Briefly identify each applicable project in the table below. Brief Identification and Affected dutfails Final Compliance Dates Description of Project (list outlall numbers) Source(s)of Discharge Required Projected c E m a L Q E 2.3 Have you attached sheets describing any additional water pollution control programs(or other environmental projects that may affect your discharges)that you now have underway or planned?(Optional Item) ❑ Yes ❑✓ No EPA Form 3510-2F(Revised 3-19) Pagel EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19 NCR000004218 NCS000354 StarPet,Inc. OMB No.2040-0004 SECTION •' 1 + IV 3.1 Have you attached a site drainage map containing all required information to this application?(See instructions for cc a specific guidance.) o ® Yes ❑ No SECTIONPOLLUTANT SOURCES 4.1 Provide information on the facility's pollutant sources in the table below. outfall Impervious Surface Area Total Surface Area Drained Number (within a mile radius of the facility) (within a mile radius of the facility) specify units specify units 001 63 % 23.98 acres specify units specify units specify units specify units specify units specify units specify units specify units specify units specify units 4.2 Provide a narrative description of the facility's significant material in the space below. (See instructions for content requirements.) The facility processes Mono Ethylene Glycol(MEG-liquid),Di-Ethylene Glycol(DEG-liquid),Purified Terephthalic Acid u (powder),and Isophthalic Acid(powder)to produce PET chips(solid). The raw materials are off loaded from rail cars oand trucks into storage tanks(tank farm with appropriate dike)and silos. (n The facility hires a company to manage the landscaping,which includes the application of herbicides and fertilizers. c 0 4.3 Provide the location and a description of existing structural and non-structural control measures to reduce pollutants in stormwater runoff. See instructions forspecificguidance.) Stormwater Treatment Codes outfall from Number Control Measures and Treatment Exhibit 2F-1 list 001 Two sediment retention ponds for sediment and erosion control 1-t1 001 Tank Farm Dikes-stormwater is collected and analyzed prior to discharge. NA 001 Spill Prevent Response-All spilled material collected for disposal,spill kits located near areas NA 001 Storm Water Sewer Covers-collection of sediment and other solid materials. NA 001 Inspection of plant grounds and equipment for leaks NA 001 Annual employee training on Stormwater Pollution Prevent Plan NA EPA Form 3510-2F(Revised 3-19) Page 2 EPA Identification Number NPDES Penn t Number Facility Name Form Approved 03/05/19 NCR0O0004218 NCS000354 StarPet,Inc. OMB No.2040-0004 - 5.1 1 certify under penalty of law that the outfall(s) covered by this application have been tested or evaluated for the presence of non-stormwater discharges. Moreover, I certify that the outfalls identified as having non-stormwater discharges are described in either an accompanying NPDES Form 2C, 2D,or 2E application. Name(print or type first and last name) Official title OURGFSH C 'U SHWA-HA A V P Lol°C•RA7 t 0NS) Signature Date signed 10 2c,(2.oJ2. Lb. 5.2 Provide the testing information requested in the table below. Outfall' Onslte 13ralgg�P0lrrts c NuiRbey Dgscripteon ofTestiag+Method Usll Dabl3(s)o�Testlng: Directly Qdsi�nreti " L - DuiIn m 001 Water is always discharging from outfall,even after o . weeks of no rainfall. Groundwater intrusion into the 1Z sediment ponds is the source of discharge. SECTION • SIGNIFICANT LEAKS OR 1 6.1 Describe any significant leaks or spills of toxic or hazardous pollutants in the last three years, a, c 1/17/2019-200 gals of Therminol 66 leaked Into pump containment area due to pump seal failure. Speedy dry was v7 used to cleanup material and disposed of properly. 4 O 9/24/2020-Mono Ethylene Glycol overflowed as alarm was missed. 250 gals spilled and was contained within the dike. Material was pumped into totes for proper disposal. c 2/23/2022-Material handler transporting a tote filled with dirty Mono Ethylene Glycol. Tote slid off pallet and spilled 100 gals onto ground. Speedy dry was applied to spill area and cleaned up. SECTION •' • •1 See the instructions to determine the pollutants and parameters you are required to monitor and,in turn,the tables you must o com fete.Not all applicants need to complete each table. 7.1 Is this a new source or new discharge? o ❑ Yes 4 See instructions regarding submission of ❑ No 4 See instructions regarding submission of W estimated data. actual data. Tables A,B,C,and D H 7.2 Have you completed Table A for each outfall? ❑✓ Yes ❑ No EPA Form 3510-2F(Revised 3-19) Page 3 EPA Identification Number NPOES Permit Number Facility Name Form Approved 03/05/19 NCR000004218 NCS000354 StarPet,Inc. OMB No.2040-0004 7.3 Is the facility subject to an effluent limitation guideline(ELG)or effluent limitations in an NPDES permit for its process j wastewater? �; ❑ Yes ❑✓ No 4 SKIP to Item 7.5. 7.4 Have you completed Table B by providing quantitative data for those pollutants that are(1)limited either directly or indirectly in an ELG and/or(2)subject to effluent limitations in an NPDES permit for the facility's process wastewater? ❑ Yes © No 7.5 Do you know or have reason to believe any pollutants in Exhibit 2F-2 are present in the discharge? ❑ Yes Z No 4 SKIP to Item 7.7. 7.6 Have you listed all pollutants in Exhibit 2F-2 that you know or have reason to believe are present in the discharge and provided quantitative data or an explanation for those pollutants in Table C? r © Yes ❑ No 7.7 Do you quality for a small business exemption under the criteria specified in the Instructions? "+ ❑ Yes+SKIP to Item 7.18. ❑✓ No € 7.8 Do you know or have reason to believe any pollutants in Exhibit 2F-3 are present in the discharge? "'? ❑ Yes ❑✓ No 4 SKIP to Item 7.10. ^g ; 7.9 Have you listed all pollutants in Exhibit 2F-3 that you know or have reason to believe are present in the discharge in ..' Table C? _' ❑ Yes ❑ No o` 7.10 Do you expect any of the pollutants in Exhibit 2F-3 to be discharged in concentrations of 10 ppb or greater? . ❑ Yes ❑✓ No 4 SKIP to Item 7.12. 7.11 Have you provided quantitative data in Table C for those pollutants in Exhibit 2F-3 that you expect to be discharged in W- concentrations of 10 ppb or greater? ❑ Yes 0 No 7.12 Do you expect acrolein,acrylonitrile,2,4-dinitrophenol,or 2-methyl-4,6-dinitrophenol to be discharged in concentrations of 100 ppb or greater? ❑ Yes 0 No 4 SKIP to Item 7.14. 7.13 Have you provided quantitative data in Table C for the pollutants identified in Item 7.12 that you expect to be discharged in concentrations of 100 ppb or greater? ❑ Yes 0 No 7.14 Have you provided quantitative data or an explanation in Table C for pollutants you expect to be present in the discharge at concentrations less than 10 ppb(or less than 100 ppb for the pollutants identified in Item 7.12)? ❑ Yes ❑� No 7.15 Do you know or have reason to believe any pollutants in Exhibit 2F4 are present in the discharge? ❑ Yes ❑� No-* SKIP to Item 7.17. 7.16 Have you listed pollutants in Exhibit 2F4 that you know or believe to be present in the discharge and provided an explanation in Table C? ❑ Yes ❑✓ No 7.17 Have you provided information for the storm event(s)sampled in Table D? ❑� Yes ❑ No EPA Form 3510-2F(Revised 3-19) Page 4 EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19 NCR000004218 NCS000354 StarPet,Inc. OMB No.2040-0004 Used or Manufactured Toxics 7.18 Is any pollutant listed on Exhibits 2F-2 through 2F4 a substance or a component of a substance used or o manufactured as an intermediate or final product or byproduct? a 0 Yes ❑ No-> SKIP to Section 8. 0 7.19 List the pollutants below,including TCDD if applicable. 0 1.Acetaldehyde 4. 7. m cc 2 5. $Antimony 3. 6. 9, SECTIONr • DATA r 8.1 Do you have any knowledge or reason to believe that any biological test for acute or chronic toxicity has been made on 2 any of your discharges or on a receiving water in relation to your discharge within the last three years? 0 c ❑ Yes ❑� No-+ SKIP to Section 9. :r N � 8.2 Identify the tests and their purposes below. Test(s) Purpose of Test(s) Submitted to NPDES Date Submitted x Permitting Authority? 0 ca ❑ Yes ❑ No U ❑ 0 ❑Yes No m ❑ Yes ❑ No SECTION ' CONTRACT ANALYSIS INFORMATION1 9.1 Were any of the analyses reported in Section 7(on Tables A through C)performed by a contract laboratory or consulting firm? ❑ Yes ❑ No 4 SKIP to Section 10, 9.2 Provide information for each contract laboratory or consulting firm below. Laboratory Number I Laboratory Number 2 Laboratory Number 3 Name of laboratory/firm Meritech,Inc. c ig 0 :� 0 Laboratory address 642 Tamco Road }' Reidsville,NC 27320 c Q ea L c Phone number U (336)342-4748 Pollutant(s)analyzed BOD COD TSS pH EPA Form 3510-2f(Revised 3-19) Page 5 EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05119 NCR000004218 NC5000354 StarPet,Inc. OMB No.2040-0004 SECTION1 CHECKLIST AND CERTIFICATION41 r 10.1 In Column 1 below,mark the sections of Form 2F that you have completed and are submitting with your application.For each section,specify in Column 2 any attachments that you are enclosing to alert the permitting authority.Note that not all applicants are required to complete all sections or provide attachments. Clumml: GoIafnn 2 ❑✓ Section 1 ❑ wl attachments(e.g.,responses for additional outfalls) ❑✓ Section 2 ❑ w/attachments ❑� Section 3 © wl site drainage map ✓❑ Section 4 ❑ wl attachments i ❑ Section 5 ❑ wl attachments ✓❑ Section 6 ❑ wl attachments I I ';I ✓❑ Section 7 ❑✓ Table A ❑ wl small business exemption request l .o, ,t. ❑✓ Table B ❑ wl analytical results as an attachment i ❑� Table C ✓❑ Table D v ❑✓ Section 8 ❑ w/attachments _ V Section 9 ❑ wlattachments(e.g.,responses for additional contact laboratories or firms) ❑✓ Section 10 ❑ 10.2 Certification Statement !certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel propedy gather and evaluate the information submitted.Based on my inquiry of the person or persons who manage the system or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete.l am aware that there are significant penalties for submitting false information,including the possibility of fine and imprisonment for knowing violations. Name(print or type first and last name) Official title 9uRGpsH C. - A AV P CdnEt�-rlon�s� Signature Date signed I 2.L# 2o22 EPA Form 3510-21'(Revised 3-19) Page 6 EPA Idenfification Number NPOES Permit Number Facility Name dutfall Number Form Approved 03M/19 NCRO00004218 NCS000354 StarPet,Inc. OMB No.2040-0004 TABLE A.CONVENTIONAL AND NON • • 1 You must provide the results of at least one anal sis for every pollutant in this table.Complete one table for each outfall.See instructions for additional details and re uirements. Maximum Daily Discharge Average Daily Discharge Source of (specify units) (specify units) Information Pollutant or Parameter Number of storm Grab Sample Taken Grab Sample Taken (new sourcelnew During First Flow-Weighted ed During First Flow-Weighted Events Sampled dischargers only,use 30 Minutes Composite 30 Minutes Composite codes in instructions) 1. Oil and grease NA NA NA 2, Biochemical oxygen demand(BODs) 21.03 NA NA NA 3, Chemical oxygen demand(COD) 42.00 NA NA NA 1 4, Total suspended solids(TSS) 23.00 NA NA NA 1 5. Total phosphorus NA NA NA NA NA 6. Total Kjeldahl nitrogen(TKN) NA NA NA NA NA 7. Total nitrogen(as N) NA NA NA NA NA pH(minimum) 6.53 NA 1 8. pH(maximum) 7.30 NA i 1 Sampling shall be conducted according to sufficiently sensitive test procedures(i,e.,methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or required under 40 CFR chapter I,subchapter N or 0.See instructions and 40 CFR 122.21(e)(3). EPA Form 3510-2F(Revised 3-19) Page 7 EPA Identification Number NPDES Permit Number Fa Form Outfafl Number Form Approved 03A5119 NCR000004218 NCS000354 StarPet,Inc. OMB No.2040-0004 TABLE B.CERTAIN CONVENTIONAL AND NON CONVENTIONAL POLLUTANTS(40 CFR 122.26(c)(1)(i)(E)(4)and 40 CFR 122.21(g)(7)(vi)(A))' List each pollutant that is limited in an effluent limitation guideline(ELG)that the facility is subject to or any pollutant listed in the facility's NPDES permit for its process wastewater(if the facility is operating under an existing NPDES permit).Complete one table for each outfall.See the instructions for additional details and requirements. - l�llllu>I �YAQMseta�g 3 I C A�►eileLLDihaie ;3 ' F : 5+ ttleifi i „pnHa 1 i fi -, li Pollutariitdnd;CASNumber fatvaileiile ;G�abt to}7alie — - Nu>�thena n�ti (� ) Sa1s1� i lFlt»nr�Wehtedi , Via ' tW �t !' `�►eN�s���� (c�+�►�►�i I[�tiiing;FIWW' � � jnur�tglFitsjG �� � � dts�ff�rge�s tlNiy+t[seFr 10 Sampling shall be conducted according to sufficiently sensitive test procedures(i.e.,methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or required under 40 CFR chapter I,subchapter N or 0.See instructions and 40 CFR 122.21(e)(3). EPA Form 3510-2F(Revised 3-19) Page 9 Approved 03105/19 NCR000004218 NC5000354 StarPet,I nc. —1 OMB No.2040-0004 EPA Identification Number NPDES Permit Number I Fad14 Name I Outfall Number Form TABLE C.TO POLLUTANTS,CERTAIN HAZARDOUS SUBSTANCES,AND ASBESTOS(40 CFR 122.26(c)(1)(i)(E)(4)and 40 CFR 122.21(g)(7)(vi)(B)and List each pollutant shown in Exhibits 2F-2,217-3,and 2F4 that you know or have reason to believe is present Complete one table for each ouffall.See the instructions for additional details and requirements. T .7— 7, -Wift; W WR R! � " ='. , 7', - RIP W , 11, iNiftal 7- CAS of F 0.'P61l1UWzi4 NUMber: aude* kF1 'V ;-j Sampling shall be conducted according to sufficiently sensitive test procedures(i.e.,methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or required under 40 CFR chapter 1,subchapter N or 0.See instructions and 40 CFR 122.21(e)(3). EPA Form 3510-2F(Revised 3-19) Page 11 EPA Identification Number NPDES Permit Number Facility name OUNaII Number Form Approved 03I05I19 NCR000004218 NCS000354 StarPet,Inc. OMB No.2040-0004 Provide data for the storm event(s)that resulted in the maximum daily discharges for the flow-weighted composite sample. Dureitich of Sttlim Eveitf F 7�ofa13Rfifall)I4ftn�) f n. tft<groci �Msulllt11� �Ftowfis) 9 Da6t,of Storm Event I StormiEvte f 1 IDudh � ii��Ever�t: I �NFtaw►ro�t�RaTnl ea. M'tolus) ' ft- i�t�tes7 ,EntllofP„rviiollturairtlelR> rri 1(�' 1oadfYitfn )) , t �nh11 _.._.. �._.._..:_,.. ...��Ex ...� _ 03/17/2022 0.82 more than 72 hours NA NA Provide a description of the method of flow measurement or estimate. Flow measurement is not a requirement for the current NPDES Storm Water Permit. EPA Form 3510-2F(Revised 3-19) Page 13 2� U.S UFHMTM EHE OF THE W IWR H/�HULFa4/Je QUAeAAN41E U.SGWLS Y-.Fw" USTapo i > �r } I� tf. I lnuW eY9n Otq fte_�a..aNai W..Y ,..,j SLILE 1:210W ae.ecu.u.,..of - ..nr�+.._+wriwaewr�r r..�w w WIN wrr.n.............,.,,_nwx•».�rrawa�w.ai r ar..r...�............. ...........�.--- eur e..n � _ ww:m....germ i x . .-.._—__r., ...n.�.....� .:...., ,.n � ...n..__........_........_,.... .r.Yn R•Ro�pr.n,Ht ` :r�rR-��.�i'I�sJ b •��` fry I; �:. 1 .tile. �}I!r�,� �'' s ���f]j�;�? �lS�► \'Y4l; "' �j7•.M`�l�K�ryJjr1 .��C �` }� 4i'� � 1 A - Ls L �( je- 7/jµ • r 1 cQ - Th6at • ��' fff I-•rr�p r,`P I _ :•� • G41 5' _ \ - � -tip •,.y � ✓� h Figure 1. U GS 7.5-minute Topographic Map of T,F— _ Randleman Quadrangle. ©Propefrya.uw.ry O EnviroScience StarPet,Inc. a so +oo soaMa.m 'icr.In Any Envlronrr. Asheboro North Carolina. � i w r