NCS000151_Draft Permit Cover Letter_20201013

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
BRIAN WRENN
Acting Director
Savannah Carroll
Arauco Panels USA LLC
985 Corinth Road
Moncure, NC 27559
Ms. Carroll:
NORTH CAROLINA
Environmental Quality
October 13, 2020
Subject: Draft NPDES Stormwater Permit
Permit No. NCS000151
Arauco Panels USA LLC - Moncure Facility
Chatham County
The Division of Energy, Mineral, and Land Resources' Stormwater Permitting Program
acknowledges receipt of your renewal application for coverage under NPDES Permit
No. NCS000151 on December 4, 2013. Enclosed with this letter is a copy of the
DRAFT stormwater permit for your facility. Please review the draft carefully to ensure
thorough understanding of the conditions and requirements it contains.
The draft permit contains the following significant changes from the facility's current
permit:
1. You are required to collect analytical and qualitative monitoring samples
during "measurable storm events" as defined in Part II, Section B. This
term is different from the "representative storm event" in earlier permits.
2. Requirements for the Stormwater Pollution Plan (SPPP) have been updated
in Part II, Section A.
3. Changes have been made to several monitoring parameters, including a
change to two benchmarks. Stormwater benchmarks are not permit limits,
but rather guidelines for implementing the Stormwater Pollution Prevention
Plan (SPPP). A benchmark exceedance is not a permit violation; however, the
permittee must respond to exceedances as directed in the Tiers.
• Vehicle maintenance (Tables 5,6) monitoring parameters have been
revised as follows:
QN or-th Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
E512 North Salisbury Street 1 1612 Mail Service Center I Raleigh, North Carolina 27699-1612
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o Non -Polar Oil & Grease [EPA Method 1664 (SGT-HEM)]
replaces Oil & Grease/TPH. The benchmark for Non -polar Oil
& Grease using this method is 15 mg/L. This requirement
appears in all individual stormwater permits; however, it only
applies to facilities that perform onsite vehicle maintenance
activities. If the facility begins vehicle maintenance during the
permit cycle, the requirements shall apply.
o pH monitoring is no longer required for discharges only
associated with vehicle maintenance activities.
4. Tiered responses have been added to this permit. Exceedances of
benchmark values require the permittee to increase monitoring, increase
management actions, increase record keeping, and/or install stormwater
Best Management Practices (BMPs) in a tiered program in accordance with
Part II, Section B of this permit.
S. A new section on Special Conditions has been added in Part II, Section E to
comply with federal regulations requiring electronic submittal of discharge
monitoring reports.
6. Civil and administrative penalty amounts have been updated to reflect
current federal law in Part III, Section A, 2 (b) and (g).
Please review the draft permit and submit any comments to me. Due to our large backlog
and need to finalize permits in a timely manner, please submit comments no later than 15
days following your receipt of the draft. If you should need more time to review the permit,
please contact me within 15 days to request more time. Comments may be emailed to me at
aana.gambleOncdenr.gov or mailed to my attention at NC DEMLR, Stormwater Permitting
Program, 1612 Mail Service Center, Raleigh, NC 27699-1612. If you have any questions,
please email me or call me at [phone].
Sincerely,
Aana Gamble
DEMLR Stormwater Division
Attachment: Draft Permit NCS000151
cc: Savannah Carroll, Arauco USA LLC Moncure Facility, Savannah. Carroll Parauco.com
Jeff McMillian, Arauco USA LLC Moncure Facility, Jef£McMillianParauco.com
Thad Valentine, DEMLR Raleigh Regional Office, thad.valentinePncdenr.gov
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9L9.707.9200