NCS000332_Fact sheet binder_20240628

DEQ / DEMLR
FACT SHEET FOR NPDES INDUSTRIAL INDIVIDUAL
STORMWATER PERMIT DEVELOPMENT
Basic Information for Permit Issuance and Renewals:
Permit Writer/Date Brianna Young 6/18/2024
Permit Number NCS000332
Owner/Facility Name Hexion,Inc./Hexion,Inc.—Morganton Facility
SIC(NAICS)Code/Category 2821 /Plastics materials, synthetic resins, and
nonvulcanizable elastomers
Basin Name/Sub-basin number Catawba/03-08-31
Receiving Stream/HUC UT to Little Silver Creek/030501010606
Stream Classification/Stream Segment WS-IV/ 11-34-7- 2
Is the stream impaired on 303 d list]? Yes see Section 2 below
Any TMDLs? No
Any threatened and/or endangered species? No
Any compliance concerns? See Section 2 below
Any permit mods since lastpermit? Yes see Section 1 below
New expiration date 8/31/2029
Comments on Draft Permit? See Section 6 below
Section 1. Facility Activities and Process:
The Hexion, Inc. Morganton Facility fabricates methylated resins and other specialty chemicals used in
the laminating, corrugating, and textile industries. Finished goods (melamine resin and auxiliaries) are
stored inside in small containers (5-gal pails, 55-gal drums, and 275/330-gal totes) and various-sized
ASTs. Bulk loading/unloading activities are conducted under cover and material drains to a 15,000-
gallon pit. Hazardous waste generated at the facility is stored in a covered three-sided building located
on the east side of the main facility building. Non-hazardous wastes are stored generally in totes and
adjacent to south of the three-side building.
Per the permit renewal application, stormwater that accumulates inside the diked tank farm walls is
pumped into the plant for use as process water, visually screened for pollutants before being discharged
to the stormwater system, or containerized for proper off-site disposal. A trench system and 15,000-
gallon containment vault are used to collect any spills/leaks at the tanker truck bulk liquid
loading/unloading area. Liquids that accumulate inside the containment pit are pumped into the plant for
recovery and used as process water, visually screened for pollutants before being discharged to the
stormwater system, or containerized for proper off-site disposal.
Per previous permit fact sheet, the facility primarily makes melamine laminating resin(melamine
formaldehyde)which is used in the paper industry and for flooring and cabinets. The facility also
manufactures resins for paints, textiles, and the automotive industry, and catalysts and lubes. The facility
specializes in urea formaldehyde resins, used mainly for non-structural bonding applications in the wood
products industry.
Outfall SW001:
Drainage area consists of a bermed tank farm, tanker truck loading pad, 15,000-gallon containment pit,
covered trash roll box, loading docks, flammable material and hazardous waste storage building, tote
and drum storage area, part of the trailer storage area, and the production and office building.
Page 1 of 6

Outfall SWO02:
Drainage area consists of a material storage area, construction boneyard, and part of the trailer storage
area. Potential pollutants include TSS, COD, and stainless or galvanized piping.
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:
• June 2020 to November 2023, benchmarks exceeded for:
o COD 3x
• On 2/24/2022, a release occurred of solution of water, formaldehyde, and glycerin into a
concrete secondary containment area. A partial blockage of the piping into the secondary
containment resulted in some of the solution being released to the concrete/asphalt driveway.
Approximately 10 pounds was unrecoverable due to releases to air and stormwater.
303(d) listing:
Little Silver Creek 11-34-7-(2) S-lv 1.2 FW Miles
9� From Burke County SR 1150 to Silver Creek
PARAMETER IR CATEGORY CRITERIA STATUS REASON FOR RATING 303D YEAR
Benthos(Nar,AL,FW) J[5=]JExceed1njg Criteria I Fair, Poor or Severe Bioclassrfrcation 2020
Threatened/Endangered Species:
There are no threatened or endangered species in the nearby vicinity, however, there are several species
of concern including: Eastern Creekshell (Villosa delumbis; NC status: SR), Smooth Sunflower
(Helianthus laevigatus;NC status: SC-V), Sweet White Trillium(Trillium simile; NC status: SC-V), and
Seneca Snakeroot(Polygala senega; NC status: SC-V).
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 June 2020 to November 2023. Quantitative sampling included pH, COD, ammonia, and
formaldehyde.
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 flexion Morganton site.
Outfalls SWO01 and SWO02
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: Standard monitoring parameter; Potential pollutant from
lubricants; Method 1664 SGT-HEM targets petroleum-based O&G
Quarterly monitoring
Monthly Oil Usage BASIS: Standard monitoring parameter
Quarterly monitoring
COD BASIS: Discharge potential indicator
Quarterly monitoring
BASIS: Potential pollutant from drainage area
In permit renewal application, facility requested removal of ammonia
Ammonia Nitrogen nitrogen. The permittee states the facility uses less ammonia now and
does not believe ammonia is likely to impact stormwater discharge.
Monitoring shall remain as ammonia-based chemicals are still stored and
used onsite. See Section 4 below for more information.
Quarterly monitoring
Formaldehyde BASIS: Potential pollutant from drainage area
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
Page 3 of 6

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 draft permit, and their basis, is below:
Parameter Benchmark Basis
Total Suspended 100 mg/L National Urban Runoff Program(NURP) Study, 1983
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
COD 120 mg/L BPJ; Generally found at levels 4x BOD5 in domestic
wastewaters
Ammonia Nitrogen At 7.5 s.u. pH and summer(26°C) temperature from
(Summer) 5.6 mg/L Wasteload Allocation document for the coastal plain region
worst-case scenario
Ammonia Nitrogen At 7.5 s.u. pH and winter(14°C) temperature from
(Winter) 15 mg/L Wasteload Allocation document for the coastal plain region
worst-case scenario
Formaldehyde 0.5 mg/L 1/2 FAV
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
Page 4 of 6

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.
Section 4. Changes from previous permit to draft:
• Regulatory citations added
• Monitoring increased from semi-annually to quarterly for all parameters (qualitative and
quantitative)
Page 5 of 6

• "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 implemented to reflect industrial activity and potential pollutants
specific to each discharge area
• Outfall SWO02 added per permittee's request
• Footnote added for ammonia nitrogen monitoring allowing monitoring to cease after 8 samples
show below detection
o In permit renewal application, facility requested removal of ammonia nitrogen. The
permittee states the facility uses less ammonia now and does not believe ammonia is
likely to impact stormwater discharge.
o Monitoring shall remain as ammonia-based chemicals are still stored and used onsite.
o Permittee may cease monitoring after 8 consecutive samples are below detection(this is
to capture any potential legacy pollution).
• Benchmarks updated per guidance from DWR Standards group
Section 5. Changes from draft to final:
• None
Section 6. Discussions with the Facility and Regional Office:
• Initial contact with facility: 3/27/2024
• Initial contact with Regional Office: 3/21/2023
• Draft sent to CO peer review: N/A
• Draft sent to Regional Office: 5/8/2024
• Final permit sent for supervisor signature: N/A
Section 7. Comments received on draft permit:
• Mike Brown (Hexion, Inc.; via email 5/31/2024): We do not have any comments on the draft
permit.
Page 6 of 6

LocaliQ
Georgia/North Carolina PO Box 631697 Cincinnati, OH 45263-1697
South Carolina
GANNETT
ENVIRONMENTAL
AFFIDAVIT OF PUBLICATION NORTH CAROLINA COMMISSION INTENT TO ISSUEAGEMENT
NPDES STORMWATER DISCHARGE PERMITS
Brianna Young The North Carolina Environmental Management Commis-
Brianna Young slon proposes to issue NPDES stormwater discharge
/DEMLR permit(s) to the person(s) listed below. Public comment or
NODE
Q objection to the draft permits is invited. Written comments
1612 Mail Service Center regarding the Proposed permit will be accepted until 30 days
Raleigh NC 27699-1612 after the publish date of this notice and considered in the
g 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
STATE OF WISCONSIN, COUNTY OF BROWN hearing should there be a significant degree of public inter-
est. Please mail comments and/or information requests to
DEMLR at 1612 Mail Service Center, Raleigh, NC 27699-
1612.
Before the undersigned, a Notary Public, duly
• Hexion, Inc. [114 Industrial Boulevard, Morganton, NC
commissioned, qualified and authorized by law to 286551 has requested renewal of permit NCS000332 for the
administer oaths, personal) a eared said le al clerk, who Hexion, Inc. — Morganton Facility in Burke County. This
Y PP g , facility discharges to an unnamed tributary to Little Silver
being first duly sworn, deposes and says: that he/she is the Creek in the Catawba River Basin.
legal clerk of The Asheville Citizen-Times, engaged in Interested persons may visit DEMLR at 512 N. Salisbury
Street, Raleigh, NC 27604 to review information on file.
publication of a newspaper known as The Asheville Citizen- Additional information on NPDES permits and this notice
may be found on Times, published, issued and entered as first class mail in https:Hdeq.nc.gov/about/divisions/energy-mineral-and--elands
the cityof Asheville, in Buncombe County, of North resources/stormwater/stormwater-program/stormwater-
Y public-notices, or by contacting Brianna Young at
Carolina;that he/she is authorized to make this affidavit bay 15,2024 10170577rianna.young®deq.nc.gov or 919-707-3647-
M
and sworn statement;that the notice or other legal
advertisement, a true copy of which is attached here to,
was published in said newspaper in the issues dated:
05/15/2024
That said newspaper in which said notice, paper, document
or legal advertisement was published was, at the time of
each and every publication, a newspaper meeting all the
requirements and qualifications of Section 1-597 of the
General Statutes of North Carolina.
Sworn to a d ubscribed before on OS/1S/2024
egWUNr {
Notar , 't c� W Co my of •awn
if
My commission expires '
Publication Cost: $167.48
Order No: 10170577 #of Copies:
Customer No: 948986 2
PO#:
THIS IS NOT AN INVOICE!
Please do not use this form for payment remittance. V I C KY F E LTY
Notary Public
C State of Wisconsin
Page 1 of 1

Young, Brianna A
From: Brown, Mike <[e-mail]>
Sent: Friday, May 31, 2024 11:13 AM
To: Young, Brianna A; McDaniel,Jeffrey
Subject: [External] RE: [External]Draft NPDES Stormwater Permit NCS000332
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.
Brianna,
We do not have any comments on the draft permit.
Thanks,
Mike Brown
Sr.Environmental Leader—North America
[phone] MOBiLE
From:Young, Brianna A<[e-mail]>
Sent: Wednesday, May 8, 2024 7:20 AM
To: McDaniel,Jeffrey<[e-mail]>
Cc: Hamilton,Jeff<jeff.ham [e-mail]>; Brown, Mike<[e-mail]>
Subject: [External]Draft NPDES Stormwater Permit NCS000332
EXTERNAL:This message is from an EXTERNAL SENDER-be CAUTIOUS,particularly
Good morning,
Attached is the draft NPDES stormwater permit for Hexion, Inc. Morganton Facility(NCS000332).A hard copy of this
draft permit will be placed in the mail to Jeff McDaniel. Please provide any comments on the draft permit by June 10,
2024.
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](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
1

Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
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.
This message,including attached files,is confidential and intended for the addressees.It may contain information that is proprietary,privileged or exempt for
disclosure under applicable law.Any unauthorized use and dissemination of the information or copying of this message is strictly prohibited.Anyviews,opinions or
conclusions expressed in this message are those of the individual sender and do not necessarily reflectthe views of Hexion or its affiliates.If you received this message
in error,please immediately advise the sender by reply email,delete all copies of this message and refrain from printing,copying,or disseminating this message or
otherwise using the information in it.Thank you.
Although Hexion routinely screens incoming and outgoing mail messages for viruses,addressees should scan this a-mail and any attachments for viruses themselves.
Hexion does not guarantee in any way the absence of viruses in this a-mail or any attachments and disclaims any liability in case of security problem that this message
may cause to any system.
2

Young, Brianna A
From: Brown, Mike <[e-mail]>
Sent: Monday, April 29, 2024 9:48 AM
To: McDaniel, Jeffrey;Young, Brianna A
Subject: [External] RE: [External]RE: NPDES stormwater permit NCS000332
IYou don't often get email from [e-mail]. Learn why this is important
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.
Brianna,
Please see our responses to your questions below.
Please contact me for any additional questions.
Thanks,
• Description of chemicals stored onsite;
1,4-Butanediol Lactic Acid, 88% Tech
Acetic Acid, 56% Maleic Anhydride
Aminoalcohol Melamine, dry
Ammonia Aqua 20.75 Be Methaform 55A(formaldehyde/methanol
solution)
Ammonium Chloride Treated Methane Sulfonic Acid, 70%
Arbocel B800 Methanol
ARBOCEL BE 600-30PU Nitric Acid 42'BE
Bentonite (Optigel CK) Ortho Para Toluenesulfonamide
Borax 10 MOL Phthalic Anhydride
Caprolactam Reclaimed/Reused Process water,toxic&/or
flammable
Catalyst,Acid based Resin, Laminating, liquid, non-hazardous
Cellulose Resin, Methylated, liquid, non-hazardous
Cimsil A-55 (Sepiolite) Resin, P/F flammable
De-foamer Rhoplex Acrylic polymer
Dicyandiamide Soda Ash, Light
DIETHANOLAMINE (DEA) Sodium Chloride
Diethylene Glycol Splicing Fluid,flammable liquid
Diethylethanolamine STANTEX (Alkylamine, ethoxylated)
Distillate,flammable Sugar
Ethal DNP-8 Sulfamic Acid
Ether Phenoxyethanol Sulfuric Acid 25%
Ethylene Glycol Thiourea
Ethylene vinyl acetate polymer Toluenesulfonic Acid catalyst
Ethyleneurea, 40% Triethanolamine LFG
1

Formaldehyde Solutions (44%, 52%) Triton Surfactant
Formic Acid 90% TSA(Toluenesulfonic Acid)
Glycerin Urea (Prilled)
Glyoxal 40% Urea/Formaldehyde Concentrate
Hydrochloric Acid 31.S% Xanthan Gum TNAS
Isopropyl Alcohol
• Description of what is stored in the two trailer storage areas;
Trailer Storage Area A is is shown by the diagram below and green/blue shading to be split between outfall 001 and 002.
• Trailers in that storage are primarily raw materials(formaldehyde) and some resins.
• Trailer Storage Area B -Trailers in that storage area will be empties returned by carrier and some pre-loaded non-haz
resins.
• Confirmation of where the trailer storage area on the east side of the property drains to;
B drains off-site and co-mingles with the non-contact cooling water that flows into Little Silver Creek.
i
t p,kL >I TRp tLER STORAGE
OUTFALL 002
Ate
ALL 001
2

• Confirm description of industrial activity in each drainage area: No comments
o Outfall SW001: Drainage area consists of a bermed tank farm, tanker truck loading pad,
15,000-gallon containment pit, covered trash roll box, loading docks, flammable material and
hazardous waste storage building, tote and drum storage area,part of the trailer storage area,
and the production and office building.
o Outfall SW002: Drainage area consists of a material storage area, construction boneyard, and
part of the trailer storage area. Potential pollutants include TSS, COD, and stainless or
galvanized piping.
Mike Brown
Sr. Environmental Leader—North America
[phone] MOBILE
From: McDaniel,Jeffrey<[e-mail]>
Sent:Wednesday,April 24, 2024 8:57 AM
To:Young, Brianna A<[e-mail]>
Cc: Hamilton,Jeff<jeff.ham [e-mail]>; Brown, Mike<[e-mail]>
Subject: RE: [External]RE: NPDES stormwater permit NCS000332
Good morning Brianna,
I apologize for the delayed response. We have had some reorganization in the EHS group so let me check on the status
of getting that information together and getting it over to you. We will be back in touch as soon as possible.
Thanks,
Jeff
From:Young, Brianna A<[e-mail]>
Sent:Wednesday,April 24, 2024 9:08 AM
To: McDaniel,Jeffrey<[e-mail]>
Cc: Hamilton,Jeff<[e-mail]>
Subject: [External]RE: NPDES stormwater permit NCS000332
messageEXTERNAL:This • be CAUTIOUS,particularly with links and attachments.
Good morning,
I am following up on my previous email.To date I have not received any response.This information is required in order
to proceed with reviewing the permit renewal application. Please let me know if you have any questions about this
request.
Thank you,
3

Brianna Young, MS (she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](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.
From: Young, Brianna A
Sent: Wednesday, March 27, 2024 10:25 AM
To: McDaniel,Jeffrey<[e-mail]>
Cc: Hamilton,Jeff<][e-mail]>
Subject: NPDES stormwater permit NCS000332
Good afternoon,
I am working on renewing the individual stormwater permit for Hexion, Inc. Morganton Facility (NCS000332).
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:
• Description of chemicals stored onsite;
• Description of what is stored in the two trailer storage areas;
• Confirmation of where the trailer storage area on the east side of the property drains to;
• Confirm description of industrial activity in each drainage area:
o Outfall SW001: Drainage area consists of a bermed tank farm, tanker truck loading pad,
15,000-gallon containment pit, covered trash roll box, loading docks, flammable material and
hazardous waste storage building, tote and drum storage area, part of the trailer storage area,
and the production and office building.
o Outfall SW002: Drainage area consists of a material storage area, construction boneyard, and
part of the trailer storage area. Potential pollutants include TSS, COD, and stainless or
galvanized piping.
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
4

• Facility address only: Email Bethany oulias
• 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)
[e-mail](e-mail preferred)
919-707-3647(office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, INC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
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.
This message,including attached files,is confidential and intended for the addressees.It may contain information that is proprietary,privileged or exempt for
disclosure under applicable law.Any unauthorized use and dissemination of the information or copying of this message is strictly prohibited.Anyviews,opinions or
conclusions expressed in this message are those of the individual sender and do not necessarily reflectthe views of Hexion or its affiliates.If you received this message
in error,please immediately advise the sender by reply email,delete all copies of this message and refrain from printing,copying,or disseminating this message or
otherwise using the information in it.Thank you.
Although Hexion routinely screens incoming and outgoing mail messages for viruses,addressees should scan this e-mail and any attachments for viruses themselves.
Hexion does not guarantee in any way the absence of viruses in this e-mail or any attachments and disclaims any liability in case of security problem that this message
may cause to any system.
5

Hr X I O flexion Inc.
C 114 Industrial Blvd.
Morganton,NC 28655
hexion.com
RECEI VED
1lTl
February 26, 2024 MAR Q
Brianna Young
Industrial Program Individual Permit Coordinator
NC Department of Environmental Quality
Division of Energy, Mineral and Land Resources
1612 MSC
Raleigh,NC 27699
RE: Individual Stormwater Permit Renewal Application
Hexion Inc.—Morganton Facility
NPDES Permit No. NCS000332
Dear Ms. Young:
Hexion, Inc. — Morganton Facility (flexion) is submitting the enclosed renewal application for
continued coverage under the permit NPDES Permit No. NCS000332 effective September 1, 2019.
As per Part Ill Section B.L of NPDES Permit No. NCS000332, the permittee must submit forms as
required by the agency no later than 180 days prior to the expiration date.Permit NCS000332 expires
August 31, 2024.This application includes required renewal forms and supporting documentation.
If you have any questions or require additional information, please do not hesitate to contact me at
[e-mail] or(828) 219-3503.
Sincerely,
HEXION INCq� .
d')
Jeff McDaniel
Site Leader

EPA Identifirallon Number NPDES Permit Number Facility Name Form Approved 03105/19
NCR000003111 NCS000332 LH,,i.n,Inc.-Morganton Facility OMB No.2040-0004
SECTION 11.CHECKLIST AND CERTIFICATION i
11 A 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
Section 1:Activities Requiring an NPDES Permit ❑ wl attachments
❑� Section 2:Name,Mailing Address,and Location ❑ wl attachments
0 Section 3:SIC Codes ❑ wl attachments
❑ Section 4:Operator Information ❑ wl attachments
0 Section 5: Indian Land ❑ wl attachments
�] Section 6:Existing Environmental Permits ❑ wl attachments
❑� Section 7:Map 0 wlatopographic ❑ wl additional attachments
U)
o ❑✓ Section 8:Nature of Business ❑ wl attachments
0 Section 9:Cooling Water Intake Structures ❑ wi attachments
a
❑✓ Section 10:Variance Requests ❑ wl attachments
0 Section 11:Checklist and Certification Statement ❑ wl attachments
11.2 Certification Statement
ca
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
Jeff McDaniel Site Leader
Signature Date signed
EPA Form 3510-1(revised 3-19) Page 4

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03105/19
NCRO00003111 NC5000332 Hexion,Inc.-Morganton Facility OMB Na.2040-0004
SECTION 5.NON STORMWATER i f
5.1 1 certify under penalty of taw that the outfalf(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
Jeff McDaniel Site Leader
Signature Date signed
5.2 Provi t e testing information requested in the table below.
uOnsite Drainage Points
Outfall Description of Testing Method used Date(s)of Testing Directly Observed
o Number
During Test
m
Refer to Appendix D of application
E
O
r
a
z
SECTION
OR t
6.1 Describe any significant leaks or spills of toxic or hazardous pollutants in the last three years.
`—" Hexion had an unplanned event on February 24,2022 involving a batch reactor in the resin manufacturing process.A
valve misalignment occurred on the resin reactor and resulted in a solution of water,formaldehyde and glycerin being
released into a concrete secondary containment area.A partial blockage of the piping into the secondary containment
Lo resulted in some of the solution also being released to the concrete/asphalt driveway.Hexion promptly recovered the
� material and secured it for proper disposition.Hexion preemtively notified the NRC and local agencies.After further
Jinvestigation,it was determined the release did not exceed the RCt for formaldehyde. It is anticipated approximately 10
c
pounds was unrecoverable due to releases to air and stormwater.
ca
U
C
tT
co
SECTION
See the instructions to determine the pollutants and parameters you are required to monitor and,in turn,the tables you must
a cam lete.Not all applicants need to complete each table.
E7.1 Is this a new source or new discharge?
o ❑ Yes 4 See instructions regarding submission of ❑ No 4 See instructions regarding submission of
rs,
estimated data. actual data.
m Tables A,B,C,and D
7.2 Have you completed Table A for each outfall?
Q ❑v Yes ❑ No
EPA Form 3510-21'(Revised 3.19) Page 3

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05119
NCR000003111 NCS000332 Hexion,Inc.-Morganton Facility OMB No.2040-0004
SECTION1 1 I
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.
Column t Column 2
r❑ Section 1 ❑ wl attachments(e.g.,responses for additional outfalls)
❑ Section 2 ❑ wl attachments
Section 3 El wl site drainage map
0 Section 4 ❑ wl attachments
❑ Section 5 ❑ wl attachments
c
0 Section 6 ❑ wl attachments
0 Section 7 ❑ Table A ❑ wl small business exemption request
W
o ❑ Table B r❑ wl analytical results as an attachment
❑ Table C ❑ Table I]
U ❑ Section S ❑ wlattachments
'a
N © Section 9 ❑ wlattachments(e.g., responses for additional contact laboratories or firms)
0 Section 10 ❑
10.2
Certification Statement
l certify under penalty of taw 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. 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
Jeff McDaniel Site Leader
Signature Date signed
h.a a�Z6�04
EPA Form 3510-2F(Revised 3-19) Fage 6

STORMWATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
North Carolina Division of Energy, Mineral, and Land Resources—Stormwater Program
Facility Name: Hellion,Inc.-Morganton Faclhty
Permit Number: NCS000332
Location Address: 114 Industrial BoWevaid
Morganton,NC 28655
County:
Burke
"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 passibility 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 14AElate
Jets McDaniel Site Leader
Print or type name of person signing above Title
SPPP Certification 10113

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 storin 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.
S. A short narrative describing any significant changes in industrial activities at the
permitted facility. Significant changes could include the addition or deletion of
work processes, changes in material handling practices, changes in material storage
practices, and/or changes in the raw materials used by the facility.
6. Certification of the development and implementation of a Stormwater Pollution
Prevention Plan for the permitted facility(Sign and return attached form).
If the final year analytical monitoring of the existing permit term has not been completed
prior to filing the renewal submittal, then the last years monitoring results should be submitted
within 30 days of receipt of the laboratory reports. (i.e. do not withhold renewal submittal
waiting on lab results)

Young, Brianna A
From: Smith, Mike M
Sent: Friday, March 22, 2024 8:45 AM
To: Young, Brianna A
Cc: Granger, T. Mack
Subject: RE: NCS000332 renewal in review
Brianna,
We have no concerns regarding this site.
Thankyou,
Michael Smith
Assistant Regional Engineer
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
828 296-4500 main
828 296-4621 office
[e-mail]
2090 US70 Highway
Swannanoa, NC 28778-8211
From:Young, Brianna A<[e-mail]>
Sent:Thursday, March 21, 2024 10:56 AM
To: Smith, Mike M <[e-mail]>
Subject: NCS000332 renewal in review
Good morning,
I have started reviewing the renewal application for the Hexion, Inc Morganton Facility (NCS000332). From what I see in
BIMS,the facility's last compliance inspection was in 2021. Please let me know if there are any concerns that need to be
addressed during the renewal and whether you feel the 2021 inspection is sufficient for the renewal.
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](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
1

Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
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.
2

Compliance Inspection Report
Permit:NCS000332 Effective: 09/01/19 Expiration: 08/31/24 Owner: Hexion Inc
SOC: Effective: Expiration: Facility: Hexion Morganton Facility
County: Burke 114 Industrial Blvd
Region: Asheville
Morganton NC 286558285
Contact Person:Jeff Hamilton Title: Phone:
Directions to Facility:
System Classifications: SWNC,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 03/01/2022 Entry Time 10:OOAM Exit Time: 11:OOAM
Primary Inspector:Mack Granger Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Other Inspection Type: Spill/Emergency Response
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 3

Permit: NCS000332 Owner-Facility:Hexion Inc
Inspection Date: 03/01/2022 Inspection Type:Spill/Emergency Response Reason for Visit: Other
Inspection Summary:
On March 1, 2022, this facility was inspected due to an emergency spill response. During the inspection I met with Site
Leader Jeff McDaniel and Site HS Leader Caleb Stoker. During the inspection, the following items were noted:
1)The spill originated from a valve-misalignment located inside the facility. The spill overwhelmed trench drains located
inside the facility, resulting in the spill migrating outside of the facility underneath an exterior door. It is recommended that
the facility reexamine BMPs pertaining to valve alignment as well as periodic trench drain cleaning and sump operation to
ensure proper containment and capacity. It is recommended that the facility adjust the SWPPP to include these practices
and to document all actions taken during the spill response in their SWPPP. At the time of inspection, appropriate spill
response actions were taken by the facility.
2)An additional outfall that was previously not monitored was observed during the inspection. The permittee is directed to
include the lower outfall discussed onsite in all future monitoring events.
Page 2 of 3

Permit: NCS000332 Owner-Facility:Hexion Inc
Inspection Date: 03/01/2022 Inspection Type:Spill/Emergency Response Reason for Visit: Other
Stormwater Pollution Prevention Plan Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan? ❑ ❑ ❑
#Does the Plan include a General Location (USGS) map? ❑ ❑ ❑
#Does the Plan include a"Narrative Description of Practices"? ❑ ❑ ❑
#Does the Plan include a detailed site map including outfall locations and drainage areas? ❑ ❑ ❑
#Does the Plan include a list of significant spills occurring during the past 3 years? ❑ ❑ ❑
#Has the facility evaluated feasible alternatives to current practices? ❑ ❑ ❑
#Does the facility provide all necessary secondary containment? ❑ ❑ ❑
#Does the Plan include a BMP summary? ❑ ❑ ❑
#Does the Plan include a Spill Prevention and Response Plan (SPRP)? ❑ ❑ ❑
#Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ❑ ❑ ❑
#Does the facility provide and document Employee Training? ❑ ❑ ❑
#Does the Plan include a list of Responsible Party(s)? 0 ❑ ❑ ❑
# Is the Plan reviewed and updated annually? 0 ❑ ❑ ❑
#Does the Plan include a Stormwater Facility Inspection Program? 0 ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented? 0 ❑ ❑ ❑
Comment:
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring? 0 ❑ ❑ ❑
Comment:
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? 0 ❑ ❑ ❑
#Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ 0 ❑
Comment:
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? 0 ❑ ❑ ❑
#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

Compliance Inspection Report
Permit:NCS000332 Effective: 09/01/19 Expiration: 08/31/24 Owner: Hexion Inc
SOC: Effective: Expiration: Facility: Hexion Morganton Facility
County: Burke 114 Industrial Blvd
Region: Asheville
Morganton NC 286558285
Contact Person:Jeff Hamilton Title: Phone:
Directions to Facility:
System Classifications: SWNC,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 02/10/2021 Entry Time 11:15AM Exit Time: 12:30PM
Primary Inspector:Isaiah L Reed Phone: [phone]
Secondary Inspector(s):
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: NCS000332 Owner-Facility:Hexion Inc
Inspection Date: 02/10/2021 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On February 10, 2021 this facility was inspected for compliance. I met with Jeff McDaniel on site. No major issues were
noted during the inspection.A current site plan could not be located during the inspection. However, a copy of the site map
was submitted through email. The permittee shall review the site plan and modify/complete the site plan to meet all
requirements in the Stormwater Permit.
If you have any questions, please contact this office at(828)296-4614
Page 2 of 3

Permit: NCS000332 Owner-Facility:Hexion Inc
Inspection Date: 02/10/2021 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan? ❑ ❑ ❑
#Does the Plan include a General Location (USGS) map? ❑ ❑ ❑
#Does the Plan include a"Narrative Description of Practices"? ❑ ❑ ❑
#Does the Plan include a detailed site map including outfall locations and drainage areas? ❑ ❑ ❑
#Does the Plan include a list of significant spills occurring during the past 3 years? ❑ ❑ ❑
#Has the facility evaluated feasible alternatives to current practices? ❑ ❑ ❑
#Does the facility provide all necessary secondary containment? ❑ ❑ ❑
#Does the Plan include a BMP summary? ❑ ❑ ❑
#Does the Plan include a Spill Prevention and Response Plan (SPRP)? ❑ ❑ ❑
#Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ❑ ❑ ❑
#Does the facility provide and document Employee Training? 0 ❑ ❑ ❑
#Does the Plan include a list of Responsible Party(s)? 0 ❑ ❑ ❑
# Is the Plan reviewed and updated annually? 0 ❑ ❑ ❑
#Does the Plan include a Stormwater Facility Inspection Program? 0 ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented? 0 ❑ ❑ ❑
Comment:
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? 0 ❑ ❑ ❑
Comment:
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? 0 ❑ ❑ ❑
#Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ 0 ❑
Comment:
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? 0 ❑ ❑ ❑
#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

Compliance Inspection Report
Permit:NCS000332 Effective: 10/01/09 Expiration: 09/30/14 Owner: Hexion Inc
SOC: Effective: Expiration: Facility: Hexion Morganton Facility
County: Burke 114 Industrial Blvd
Region: Asheville
Morganton NC 286558285
Contact Person:Jeffrey McDaniel Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 05/16/2019 Entry Time 01:OOPM Exit Time: 02:30PM
Primary Inspector:Isaiah L Reed Phone: [phone]
Secondary Inspector(s):
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: NCS000332 Owner-Facility:Hexion Inc
Inspection Date: 05/16/2019 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On May 16, 2019 this facility was inspected for compliance as well as for the pirpose of permit renewal. No issues were
observed during the inspection and the issues from the previous report have been addressed. Comments concerning the
permit renewal have been sent via email to permit writer.
If you have any questions, please contact this office at(828)296-4614
Page 2 of 3

Permit: NCS000332 Owner-Facility:Hexion Inc
Inspection Date: 05/16/2019 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan? ❑ ❑ ❑
#Does the Plan include a General Location (USGS) map? ❑ ❑ ❑
#Does the Plan include a"Narrative Description of Practices"? ❑ ❑ ❑
#Does the Plan include a detailed site map including outfall locations and drainage areas? ❑ ❑ ❑
#Does the Plan include a list of significant spills occurring during the past 3 years? ❑ ❑ ❑
#Has the facility evaluated feasible alternatives to current practices? ❑ ❑ ❑
#Does the facility provide all necessary secondary containment? ❑ ❑ ❑
#Does the Plan include a BMP summary? ❑ ❑ ❑
#Does the Plan include a Spill Prevention and Response Plan (SPRP)? ❑ ❑ ❑
#Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ❑ ❑ ❑
#Does the facility provide and document Employee Training? 0 ❑ ❑ ❑
#Does the Plan include a list of Responsible Party(s)? 0 ❑ ❑ ❑
# Is the Plan reviewed and updated annually? 0 ❑ ❑ ❑
#Does the Plan include a Stormwater Facility Inspection Program? 0 ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented? 0 ❑ ❑ ❑
Comment:
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ❑ ❑ ❑ ❑
Comment:
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? 0 ❑ ❑ ❑
#Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ 0 ❑
Comment:
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? 0 ❑ ❑ ❑
#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

3/14/24, 3:07 PM North Carolina Secretary of State Search Results
• File an Annual Report/Amend an Annual Report • Upload a PDF Filing • Order a Document Online -
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an Amended a Annual Report form
Business Corporation
Legal Name
Hexion Inc.
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Information
Sosld: 0018906
Status: Current-Active O
Date Formed: 10/6/1936
Citizenship: Foreign
State of Incorporation: NJ
Fiscal Month: December
Annual Report Due Date: April 15th
Currentgnnual Report Status:
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Young, Brianna A
From: Young, Brianna A
Sent: Wednesday, March 20, 2024 12:32 PM
To: [e-mail]
Cc: [e-mail]; Hamilton, Jeff
Subject: NPDES stormwater permit NCS000332
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 NCS000332.
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 let me know if you have any questions in
the interim.
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](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.
1

Hexion Inc.
H E X I O N' 114 Industrial Blvd.
MorWtcq-,NO 28655
trexlonxom
February 26,2024
iormwatPrProju-,-,
Brianna Young
Industrial Program Individual Permit Coordinator
NC Department of Environmental Quality
Division of Energy, Mineral and Land Resources
1612 MSC
Raleigh,NC 27699
RE: Individual Stormwatei•Permit Renewal Application
Hexion Inc.—Morganton Facility
NPDES Permit No.NCS000332
Dear Ms. Young:
Hexion, Inc. — Morganton Facility (Hexion) is submitting the enclosed renewal application for
continued coverage under the permit NPDES Permit No. NCS000332 effective September 1, 2019.
As per Part III Section B.1. of NPDES Permit No.NCS000332, the permittee must submit forms as
required by the agency no later than 180 days prior to the expiration date. Permit NCS000332 expires
August 31,2024.This application includes required renewal forms and supporting documentation.
If you have any questions or require additional information, please do not hesitate to contact me at
jeffrey.mcdaniel rr hexioii.com or(828)219-3503.
Sincerely,
HEXION INC.
Jeff McDaniel
Site Leader
i
i

Y ='` TRC
NPDES Individual Stormwater
Permit Renewal Application
Hexion, Inc.
Morganton, North Carolina
February 29, 2024

MW
am
Table of Contents
1. Introduction.......................................................................................................................1-1
2. Supplemental Information.................................................................................................2-1
2.1 Best Management Practices...................................................................................2-1
2.2 Significant Changes................................................................................................2-2
2.3 Used or Manufactured Toxics.................................................................................2-2
3. Proposed Changes...........................................................................................................3-1
,m 3.1 Removal of Ammonia Testing.................................................................................3-1
3.2 Addition of Outfall 002.............................................................................................3-1
am
List of Figures
fm
Figure 1 Facility Location Map...................................................................................3-2
Figure2 Site Map......................................................................................................3-3
RM
List of Appendices
so
Appendix A EPA Forms 1 and 2F
Appendix B NC DEQ SPPP Certification Form
Appendix C NC DEQ Supplemental Information Form
Appendix D Summary of Monitoring Results
FM
fan
mm Hexion, Inc.—Morganton Facility
NPDES Permit Renewal Application H
I IEMPLOYEES.ROOT.LOCAL I ENVI ECCI GR££NVILLEtiWPGVL I P1T21581579I00011R5815790000-001-HEXLON MORGANTON NPDES RENEWAL APPLICATION.DOOt
February 29, 2024
SO

mm
Section 1
lam Introduction
Hexion, Inc. (Hexion) owns and operates a manufacturing facility located in Morganton, North
Carolina (Facility). The Facility fabricates methylated resins and other specialty chemicals used
in the laminating, corrugating and textile industries. Hexion is currently authorized under
o, Individual Stormwater Permit NCS000332. As per Part III Section B.1. of the NPDES Permit
No. NCS000332, Hexion must submit the required forms to North Carolina Department of
Environmental Quality (NC DEQ) no later than 180 days prior to the expiration date. Permit
NCS000332 expires August 31, 2024. As such, the following documents are enclosed:
■ EPA Forms 1 and 2F (Appendix A);
■ NC DEQ Stormwater Pollution Prevention Plan (SPPP) Certification Form (Appendix B);
■ NC DEQ Supplemental Information Required for Renewal of Individual NPDES Stormwater
Permit Form (Appendix C);
■ Facility Location Map (Figure 1) and Site Map (Figure 2);
^� ■ Summary of analytical and visual monitoring results during the term of the existing permit
(Appendix D);
■ Summary of best management practices (Section 2);
■ Narrative describing significant changes in industrial activities (Section 2); and
■ Requested permit changes (Section 3).
Hexion, Inc.—Morganton Facility
NPDES Permit Renewal Application 1-1
I IEMPLOYEES.ROOT.LOCALlENV1ECCIGREENVILLEIWPGVL1P1T2 15 815 791OOO11R581579O000.O01_HEXION MORGANTON NPOES RENEWAL APPLICATION.DOCK
February 29, 2024

Section 2
Supplemental Information
The following sections contain supplemental information required by NC DEQ and EPA.
2.1 Best Management Practices
The facility employs the following structural and non-structural best management practices
(BMPs) to eliminate exposure of potential pollutants to stormwater:
■ All aboveground storage tanks (ASTs) located outside the main facility building are stored
within concrete containment areas equipped with sumps. Stormwater which accumulates
inside the diked tank farm walls is pumped into the plant for use as process water, visually
screened for pollutants before being discharged to the stormwater system, or containerized
for proper off-site disposal.
■ A trench system and 15,000-gallon containment vault are used to collect any spills/leaks at
the tanker truck bulk liquid loading/unloading area. Liquids that accumulate inside the
containment pit are pumped into the plant for recovery and used as process water, visually
screened for pollutants before being discharged to the stormwater system, or containerized
for proper off-site disposal. The tanker truck loading/unloading area is covered with a
,- canopy to limit stormwater exposure to the area. A level indicator and high-level alarm is
also installed at the containment vault system. The purpose of this device is to constantly
monitor the level inside the containment and provide notification to personnel if the level
meets/exceeds the high-level set point. This monitor ensures enough containment capacity
for tanker trucks in the event of a catastrophic spill event within the contained area.
,�, ■ A trench drain collection system and sump are used to collect any spills/leaks in the
flammable materials/hazardous waste storage area. Materials collected in the sump are
pumped into the plant for material recovery or pumped into totes and transported off-site for
proper disposal. The storage area is enclosed by three sides and a roof.
■ An outdoor tote storage area is located to the west and south of the flammable storage
�+ shed area. This area is contained by a concrete dike and a spill collection control
basin/sump. An installed explosion-proof pump (within the basin) must be manually
activated to pump out any spilled material (including contaminated stormwater) into totes or
tanker and transported off-site for proper waste disposal.
■ Non-paved areas at the facility are vegetated to reduce soil erosion.
RM ■ All facility manufacturing processes are conducted inside the main facility building.
Hexion, Inc.—Morganton Facility
NPDES Permit Renewal Application 2-1
IIEMPLOYEES.ROOTLOCALIENVIECCIGREENVILLEIWPGVLIPJT2I58157910O01IR581575O000-001-HEXION MORGANTON NPDES RENEWAL APPLICATION.DOCX
February 29, 2024
fm

Ma
00
MR ■ Stormwater structures (i.e., catch basins, swales) are cleaned periodically and maintained
to ensure proper operation.
■ Regular pickup and disposal of refuse and other debris is completed around the facility.
■ Routine inspections for materials that may be exposed and come in contact with
stormwater. Any exposed materials would immediately be moved or addressed.
■ Regular indoor floor sweeping is conducted to reduce the likelihood of transporting potential
contaminants on forklift tires to outdoor areas.
2.2 Significant Changes
Although the Facility has not had significant changes related to industrial activities since the last
permit issuance, the Facility is requesting the addition of an outfall due to an existing outdoor
material storage area. Further information is provided in Section 3.2.
2.3 Used or Manufactured Toxics
The Facility reviewed the list of pollutants in Exhibits 2F-2 through 2F-4 of EPA Form 2F. It was
determined that approximately 19 pollutants are used in the manufacturing process at the
Facility at concentrations greater than 0.1 percent. However, only one pollutant, formaldehyde,
is expected to have the potential to be present in stormwater discharge as the material is stored
in outside aboveground storage tanks. All other materials may be used in the process but are
not expected to be in stormwater runoff as they are not stored or transferred outside. A list of
the chemicals used at the facility but not expected in stormwater discharge are as follows:
■ Acetic acid ■ Maleic anhydride
■ Ammonium chloride ■ Nitric acid
■ Ammonium hydroxide ■ Phenol
■ Amyl acetate ■ Phosphoric acid
■ Diethanolamine ■ Resorcinol
■ Ethylbenzene ■ Sulfuric acid
�+ ■ Formic acid ■ Toluene
■ Hydrochloric acid ■ Triethanolamine
® ■ Maleic acid ■ Xylene
Analytical results for formaldehyde and associated storm event information are included in
RM
Appendix D.
Hexion, Inc.—Morganton Facility
NPDES Permit Renewal Application 2-2
IIEMPLOYEES.ROOT.LOCALIENVIECCIGREENVILLEIWPGVLIPIT215815791O0O11R581579O00O-0O1_HEXION MORGANTON NPOES RENEWAL APPLICATION.DOCX
February 29, 2024

Section 3
Proposed Changes
The Facility is requesting the following changes be implemented to Stormwater Permit
NCS000332.
3.1 Removal of Ammonia Testing
The Facility is currently required to test for ammonia at Outfall 001 on a semiannual basis. The
Facility historically manufactured more acid-based catalysts which used ammonia in the
process. Business production has shifted, and less ammonia is used at the Facility. Analytical
records from October 2014 to present were reviewed and indicated that the Facility has not
exceeded the benchmark value in that time. The highest result of ammonia recorded was
1.1 mg/L compared to a benchmark of 7.2 mg/L.
Hexion does not believe that ammonia is likely to impact stormwater discharge as a result of
current facility operations. Additionally, due to historic records indicating that ammonia is not a
potential pollutant from outdoor industrial activity at the site, Hexion requests that the pollutant
be removed from the required testing. A copy of the analytical results during the permit term are
provided in Appendix D.
3.2 Addition of Outfall 002
The Facility maintains a material storage area at the northeast corner of the main production
" building. The storage area is not covered and stormwater discharges south into a culvert, under
the paved drive, and into a swale. The potential pollutants from this area are expected to be
total suspended solids (TSS) and chemical oxygen demand (COD). The area serves as a
construction boneyard and in addition, may store stainless or galvanized piping. The Facility will
not store any material that comes in contact with the process or has the potential to result in any
oil and grease.
As such, the Facility requests that Outfall 002 be added to the permit. The SPPP will be updated
to reflect the change accordingly.
Hexion, Inc. —Morganton Facility
NPDES Permit Renewal Application 3-1
II EMPLOYEES ROOT LOCALIENVIECCIGREENVILLEIWPGVL1PJT2158157910001{R5815790000-001_HEXION MORGANTON NPOES RENEWAL APPLICATION.DOCX
February 29, 2024

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Figure 1 0 0.5 1 2 km
Facility Location Map Copyright:©2013 National Geographic Society, i-cubed
USG:
2021 USG:

LEGEND
OUTFALL
® CATCH BASIN -
�— RUN-OFF FLOW DIRECTION
- BERMED TANK FARM
BERM DRAINAGE PIPE
DRAINAGE PIPE
^mow SWALE DRAINAGE DITCH - MOBILE OFFI
SW001 -- gUILD►NG
SWO02
MPINTENPNGE
Potentially Exposed Material Locations: wqw-RAW,
1. Bermed Tank Farm
2. Tanker Truck Loading Pad -
3. 15,000 Gallon Containment Pit
4. Covered Trash Roll Box TION p`ND t ;�
5. Loading Docks PRODUC ING
6. Flammable material and Haz Waste OFFICE gU1LD i
Storage Building 's
7. Tote and Drum Storage Area
F 8. Material Storage Area
1 � -�•s
a DRAINAGEAREA OUTFALL DRAINAGEAREA PERCENT
NUMBER (ACRES) IMPERVIOUS
I swoo1 4.16 72 -y 4
II SW002 .59 7s 'ter TRAILER STORAGE
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SSORP
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NOTE: PROJECT: DRAWN BY: K STARK
2 HEXION, INC-MORGANTON FACILITY CHECKED BY: K DRENNAN
N x 1)AERIAL IMAGERY COURTESY OF MICROSOFT BING,2024. 114 INDUSTRIAL BOULEVARD
- y 2)ALL LOCATIONS ARE APPROXIMATE. - APPROVED BY: K DRENNAN
F_ Tric MORGANTON, NC 28655
N DATE: FEBRUARY 2024
w 0 80 160 TITLE:
i PROJ.NO.: 581579
c= SITE DRAINAGE MAP FILE: 581579 Hexion Morgonton SWPPP.dwg
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Im Appendix A
EPA Forms 1 and 2F
Hexion, Inc. -Morganton Facility
NPDES Permit Renewal Application
IIEMPLOYEES.ROOT.LOCALIENVIECCIGREENVILLEI WPGVL IPJT2IS8l5791000]IRSSL5790000-001_HEXION MORGANTON NPDES RENEWAL APPLICATION.DOCX
February 29, 2024

Pon
ban
EPA Identificafion Number NPOES Permit Number Facility Name Form Approved 03/05/19
NCROOD003111 NC5000332 Hexion,Inc.-Morganton Facility OMB No.2040-0004
Form U.S.Environmental Protection Agency
1 \— EPA Application for NPDES Permit to Discharge Wastewater
NPDES GENERAL INFORMATION
SECTIONACTIVITIES REQUIRING •• 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? 1.1.2 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.
FW
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,
operation or a concentrated aquatic animal commercial, mining,or silvicultural facility that is
a production facility? currently discharging process wastewater?
cYes 4 Complete Form 1 ❑✓ No Yes 4 Complete Form 0✓ No
z and Form 213. 1 and Form 2C.
rM R 1.2.3 Is the facility a new manufacturing,commercial, 1.2.4 Is the facility a new or existing manufacturing,
c mining,or silvicultural facility that has not yet commercial, mining,or silvicultural facility that
commenced to discharge? discharges only nonprocess wastewater?
d ❑- Yes 4 Complete Form 1 No Yes 4 Complete Form No
DER and Form 2D. 1 and Form 2E.
N
' 1.2.5 Is the facility a new or existing facility whose
discharge is composed entirely of stormwater
associated with industrial activity or whose
discharge is composed of both stonmwater and
non-stormwater?
Yes 4 Complete Form 1 No
and Form 2F
unless exempted by
40 CFR
122.26(b)(14)(x)or
b 15).
SECTION 2. NAME, MAILING ADDRESS,AND LOCATION(40 CFR 122.21(f)(2))
2.1 Facility Name
Hexion,Inc.-Morganton Facility
0 2.2 EPA Identification Number
R
U
J NCR000003111
v
0 2.3 Facility Contact
i Name(first and last) Title Phone number
v
Jeff McDaniel Site Leader [phone]
Q
Email address
[e-mail]
2.4 Facility Mailing Address
ZStreet or P.O.box
114Industrial Boulevard
City or town State ZIP code
Morganton NC 28655
EPA Form 3510-1(revised 3-19) Page 1

W EPA Identification Number NPDES Permit Number Facility Name Form Approved 43r05+19
NCR000003111 NC5000332 Hexion, Inc.-Morganton Facility OMB No.2040-0004
2.5 Facility Location
a Street,route number,or other specific identifier
Q o 114 Industrial Boulevard
�U
0 County name County code(if known)
Burke
0
E _j City or town State ZIP code
z R Morganton NC 28655
SECTION •D I
3.1 SIC Code(s) Description(optional)
2821 Plastics Materials,Synthetic Resins,and Nonvulcanizable Elastomers
a>
0
U
t!�
U
r z 3.2 NAICS Code(s) Description(optional)
a
c
ro
U
SECTIONOPERATOR INFORMATION(40
4.1 Name of 0 erator
Hexion,Inc.
0 4.2 Is the name you listed in Item 4.1 also the owner?
o 21 Yes ❑ No
4.3 Operator Status
0
L ❑ Public—federal ❑ Public—state ❑ Other public(specify)
o ❑✓ Private ❑ Other(specify)
4.4 Phone Dumber of Operator
n [phone]
4.5 Operator Address
Street or P.O. lox
114Industrial Boulevard
c •= City or town State ZIP code
0 v Morganton NC 28655
Q Email address of operator
0 [e-mail]
SECTION
51 Is the facility located on Indian Land?
❑ Yes 0 No
EPA Form 3510-1(revised 3-19) Pag,2

T EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05119
NCR000003111 NC5000332 Hexian,Inc.-Morganton Facility OMB No.2040-0004
SECTION '• 1
61 Existing Environmental Permits(check all that apply and print or type the corresponding permit number for each)
w m NPDES(discharges to surface m RCRA(hazardous wastes) ❑ UIC(underground injection of
c y water) fluids)
.— NC5000332;NCG500212 NCR000003111
'5; E
w W ❑ PSD(air emissions) ❑ Nonattainment program(CAA) ❑ Ni(CAA)
❑ Ocean dumping(MPRSA) ❑ Dredge or fi0(CWA Section 404) Other(specify) minor air permit
UJ NC0000003701200123
SECTION1
7.1 Have you attached a topographic map containing all required information to this application?(See instructions for
specific requirements.)
t ❑✓ Yes ❑ No ❑ CAFO—Not Applicable(See requirements in Form 213.)
SECTIONOF 1
8.1 Describe the nature of your business.
The Hexion,Inc.-Morganton Facility fabricates methylated resins and other specialty chemicals used in the
laminating,corrugating and textile industries.
m
Co
cc
L
cc
Z
SECTION •• 1 CFR 122.21
F9,
Does your facility use cooling water?
L ❑✓ Yes El -+ SKIP to Item 10.1.
Identify the source of cooling water. (Note that facilities that use a cooling water intake structure as described at
cn t, 40 CFR 125, Subparts I and J may have additional application requirements at 40 CFR 122,211 Consult with your
a n NPDES permitting authority to determine what specific information needs to be submitted and when.)
tow Cooling water is received from the City of Morganton
SECTION1 VARIANCE REQUESTSI 1
10.1 Do you intend to request or renew one or more of the variances authorized at 40 CFR 122.21(rn)?(Check all that
apply.Consult with your NPDES permitting authority to determine what information needs to be submitted and
w when.)
❑ Fundamentally different factors(CWA [] Water quality related effluent limitations(CWA Section
Section 3011 31
❑ 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 Identifiealion Number NPDES Permit Number Faality Name Form Approved 03/05119
NCR000003111 NCS000332 Hexion,Inc..Morganton Facility 0YB No.2040.0004
CERTIFICATIONSECTION 11.CHECKLIST AND i
11.1 In Column 1 below,mark the sections of Form f 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 re uired to provide attachments.
Column'I Column 2
❑✓ Section 1:Activities Requiring an NPDES Permit ❑ wl attachments
[✓� Section 2:Name,Mailing Address,and Location ❑ wl attachments
Section 3:SIC Codes ❑ wlattachments
Section 4:Operator Information ❑ tvl attachments
❑✓ Section 5:Indian Land ❑ w!attachments
Section 6:Existing Environmental Permits ❑ wl attachments
x � 0 Section 7:Map ❑ atopagraptlic ❑ w-I additional attachments
w
o ❑✓ Section 8:Nature of Business ❑ wl attachments
❑� Section 9:Cooling Water intake Structures ❑ tal attachments
0 Section 10:Variance Requests ❑ wlattachments
Section 11:Checklist and Certification Statement ❑ w/attachments
Y
01 11.2 Certification Statement
r
U
!certify under penalty of late that this document and all attachments were prepared under my direction or supervision
in accordance with a system designed to assure that qualified personnel property 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 forsubmilting false information,
including the possibility of fine and imprisonment for knowing violations.
Name(print or type first and last name) Official fide
Jeff McDaniel Site Leader
Signature Date signed
z�2ta[Zo�
EPA Form 3510-1(revised 3-19) Page 4

EPA Ident'ficatlon Number NPDES Permit Number Facility Name Form Approved 03/05/19
NCROOD003111 NCS000332 Hexion,Inc.-Morganton Facility CUB No.2040-0004
Form U.5 Environmental Protection Agency
2F COMA Application for NPDES Permit to Discharge Wastewater
NPDES / "► STORMWATER DISCHARGES ASSOCIATED WITH INDUSTRIAL ACTIVITY
SECTIONOUTFALL LOCATIONI
-T 1.1 Provide information on each of the faciI t 's out falls in the table below
Outfall Receiving Water Name Latitude Longitude
Number
001 Little Silver Creek 35' 43' 50.01" -81° 45' 29.99"
a
002 Little Silver Creek 35° 43' 46.92" -81° 44' 51.55"
U
O
0 n v a
MSECTION '• I
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 nJ No 4 SKIP to Section 3.
2.2 Briefly identify each applicable project in the table below.
Brief Identification and Affected Outfalls Final Compliance Dates
Description of Project (list outfEll numbers} Sources)of Discharge
Required Projected
v,
c
m
E
m
0
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 3510-217(Revised 3.19) Page 1

EPA Identiricatior Number NPDES Permit Number Facility Name Form Approved 03/05/19
NCR000003111 NC5000332 Hexion,Inc.-Morganton Facility OMS No.2040-0004
DRAINAGESECTION 3.SITE
3.1 Have you attached a site drainage map containing ail required information to this application?(See instructions for
0 c rL specific guidance.)
® Yes ❑ No
SECTION 4. -O r
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 approx.3.0 acres approx.4.2 acres
specify units specify units
002 approx.0.5 acres approx,0.6 acres
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.)
Water,formaldehyde,methanol,melamine,methaform,diethylene glycol and are the primary bulk raw materials used
at the plant. Other chemicals,such as isopropanol,caustics,and acids,are used and stored in smaller quantities.
` Finished goods(melamine resin and auxiliaries)are stored inside in small containers(5-gal pales,55-gal drums and
275/330-gal totes)and various-sized aboveground storage tanks.Bulk loading/unloading activitites are conducted
rn under cover and material drains to a 15,000 gallon pit. Hazardous waste generated at the facility is stored in a covered
— three-sided building located on the east side of the main facility building.Non-hazardous wastes are stored generally in
totes and adjacent to south of the three-side building. Hexion employees ensure that the lids of the totes are closed
and secure prior to storage. General trash is placed in a trash compactor that is fully contained.An outdoor material
storage area is used as a contractor boneyard used to stare stainless or galvanized piping.No chemicals will be stored
in this area.
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)
Refer to Section 2 of application
EPA Form 3510-2F(Revised 3-19) Page 2

EPA Identification Number NPDE5 Permit Number Facility Name Form Approved 0305119
NCR000003111 NCS000332 Hexion,Inc.-Morganton Facility GM8 No,2040-0004
SECTION1N STORMWATER 1 I
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, t certify ]hat the ouffells 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
Jeff McDaniel Site Leader
Signature Date signed
�*4
T �+ 5.2 Provi t e testing information requested in the table below.
Qutfall Onsite Drainage Points
o Number Description of Testing Method Used Dale(s)of Testing Directly Observed
During Test
m
Refer to Appendix D of application
`o
to
C
_ O
SECTIONOR I CFR 122.26(c)(1)(i)(D))
6.1 Describe any significant leaks or spills of toxic or hazardous pollutants in the Iasi three years.
�' Hexion had an unplanned event on February 24,2022 involving a batch reactor in the resin manufacturing process.A
Q valve misalignment occurred on the resin reactor and resulted in a solution of water,formaldehyde and glycerin being
— U' released into a concrete secondary containment area.A partial blockage of the piping into the secondary containment
resulted in some of the solution also being released to the concrete/asphalt driveway.Hexion promptly recovered the
Y material and secured it for proper disposition.Hexion preemtively notified the NRC and local agencies.After further
investigation,it was determined the release did not exceed the RQfor formaldehyde.It is anticipated approximately 10
pounds was unrecoverable due to releases to air and stormwater.
u
ao
in
SECTIONDISCHARGE INFORMATIONI
See the instructions to determine the pollutants and parameters you are required to monitor and,in turn,the tables you must
o complete.Not all applicants need to complete each table.
E 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
estimated data. actual data.
Tables A,6,C,and D
S 7.2 Have you completed Table A for each outfall?
❑✓ Yes ❑ No
EPA Form 3510.2F(Revised 3.19) Page 3

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
�+ NCROOO003111 NC5O00332 Hexion,Inc.-Morganton Facility OMB No.204OZ04
7.3 Is the facility subject to an effluent limitation guideline(ELG)or effluent limitations in an NPDES permit for its process
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 ❑✓ 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?
❑ Yes ❑ No
7.7 Do you quality for a small business exemption under the criteria specified in the Instructions?
❑ Yes 4SKIP 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.
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
c Table C?
❑ Yes ❑ No
0 7.10 Do you expect any of the pollutants in Exhibit 2F-3 to be discharged in concentrations of 10 ppb or greater?
_ M
€ ❑ Yes ✓❑ No 4 SKIP to Item 7.12.
0
S 7.11 Have you provided quantitative data in Table C for those pollutants in Exhibit 2F-3 that you expect to be discharged in
M concentrations of 10 ppb or greater?
*AElYes ❑ 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 ❑ 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 [21 No
7.15 Do you know or have reason to believe any pollutants in Exhibit 2F-4 are present in the discharge?
❑✓ Yes ❑ No 4 SKIP to Item 7.17.
7.16 Have you listed pollutants in Exhibit 2F-4 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?
0 Yes ❑ No
EPA Form 3510-217(Revised 3-19) Page 4

Me
EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NCR000003111 NCS000332 Hexion,Inc.-Morganton Facility OMB No.2040-0004
Used or Manufactured Toxics
7.18 Is any pollutant listed on Exhibits 2F-2 through 217-4 a substance or a component of a substance used or
cmanufactured as an intermediate or final product or byproduct?
❑✓ Yes ❑ No 4 SKIP to Section 8.
c
0
�+ M 7.19 List the pollutants below,including TCDD if applicable.
0
- c 1.Refer to Section 2 of application 4. 7.
cu
r
2. 5. 8.
0 3. 6. 9.
FM SECTION 8. BIOLOGICAL TOXICITY TESTING DATA(40 CFR 122.21(g)(1 1))
8.1 Do you have any knowledge or reason to believe that any biological test for acute or chronic toxicity has been made on
any of your discharges or on a receiving water in relation to your discharge within the last three years?
o
❑ Yes 0 No 4 SKIP to Section 9.
ca
8.2 Identify the tests and their purposes below.
Submitted to NPDES
y Test(s) Purpose of Test(s) PermittingAuthority?
Date Submitted
x
0
~ ❑ Yes ❑ No
A
F� C"
c ❑ Yes ❑ No
a
❑ Yes ❑ No
SECTION 9.CONTRACT ANALYSIS INFORMATION (40 CFR 122.21(g)(12))
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 1 Laboratory Number 2 Laboratory Number 3
Name of laboratory/firm Pace Analytical
c
.°
H Laboratory address 9800 Kincery Ave.Suite 200
a) Huntersville,NC 28078
c
a
U
t+s9
c Phone number
V [phone]
Pollutant(s)analyzed COD,ammonia,formaldehyde
MR
sm
EPA Form 3510-21'(Revised 3-19) Page 5
FM

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03i05119
NCR000003111 NC5000332 Flexion,Inc.-Morganton Facility 0MR No.204MG04
i CHECKLIST AND CERTIFICATION STATEMENT(40 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.
Column f Column 2
0 Section 1 ❑ wl attachments(e.g.,responses for additional outfalls)
❑ Section 2 ❑ wl attachments
EJ Sectlon 3 El wl site drainage map
0 Section 4 ❑ wl attachments
❑ Section 5 ❑ wl attachments
El Section 6 ❑ wl attachments
E ❑ Section 7 ❑ Table A ❑ wl small business exemption request
❑ Table B ❑ wl analytical results as an attachment
0
w ❑ Table C ❑ Table D
r
❑ Section S ❑ wlattachmenls
N_ 0 Section 9 ❑ wlattachments(e.g.,responses for additional contact laboratories or firms)
Y
" Section 10 ❑
10.2 Certification Statement
f 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. t 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
Jeff McDaniel Site Leader
Signature Date signed
Ll r�r�
EPA Form 3510.2F(Revised 3-19) Page 6

1 1 1 1 1 I 1 1 I 1 1 I 1 I 1 1 1 1 1
EPA Identification Number NPQES Permit Number Facility Name Outfall Number Form Approved 03/05119
NCR000003111 NC5000332 Hexion,Inc.-Morganton Facility 001 OM9 No.2040-0004
CONVENTIONALTABLE A. A NON
You must provide the results of at least one anal sis for every pollutant in this table. Campfete one table far each out fall.See instructions for additional details and re uirements.
Maximum Daily Discharge Average Daily Discharge Source of
(specify uaits) (specify units) Number of Storm Information
Pollutant or Parameter Grab Sample Taken Flow-Weighted Grab Sample Taken Flow-Weighted Events Sampled (new source/new
During First During First dischargers only;use
Composite Composite codes in instructions
30 Minutes 30 Minutes )
1. Oil and grease
2. Biochemical oxygen demand(BODs)
3. Chemical oxygen demand(COD) Refer to Appendix D
4. Total suspended solids(TSS)
5. Total phosphorus
6, Total Kjeldahl nitrogen(TKN)
7. Total nitrogen(as N)
pH(minimum)
8.
rpH(maximum)
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 Facility Name Outfall Number Form Approved 03105/19
NCR000003111 NCS000332 Hexion,Inc.-Morganton Facility 001 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.
Maximum Daily Discharge Average Daily Discharge Source of
s eci units s . units Number of Storm Information
Pollutant and CAS Number(if available) Grab Sample Taken Grab Sample Taken (new sourcelnew
During First Flo Composite
Flow-Weighted During First Flo Composite
Events Sampled dischargers only;use
30 Minutes Composite 30 Minutes Composite codes in instructions)
Not applicable
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

EPA Identification Number NPDES Permit Number Facility Name Outfall Number Form Approved 03/05l19
NCROOD003111 NCS000332 Hexion,Inc.-Morganton Facility 001 OMB No.2040-0004
TABLE C.TOXIC 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(vii))'
List each pollutant shown in Exhibits 2F-2,2F-3,and 2F4 that you know or have reason to believe is present.Complete one table for each outfall,See the instructions for additional
details and requirements.
Maximum Daily Discharge Average Daily Discharge Source of
s eci units s e . units Number of Storm Information
Pollutant and CAS Number(f available) Grab Sample Taken Grab Sample Taken (new source/new
During First Flo Composite
Flow-Weighted During First Flo Composite
Events Sampled dischargers only;use
30 Minutes Composite 30 Minutes Composite codes in instructions)
Formaldehyde-50-000 Refer to Appendix D
No other pollutants expected in stormwater
' 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 3510-21'(Revised 3-19) Page 11

EPA Identification Number NPDES Permit Number Facility name Outfall Number Form Approved 03/05/19
NCR00O003111 NCSO0O332 Hexion,Inc.-Morganton Facility 001 OMB No.2040-0004
TABLE D. STORM EVENT INFORMATION1
Provide data for the storm event(s)that resulted in the maximum daily discharges for the flow-weighted composite sample.
Number of Hours Between
Total Rainfall During Maximum Flow Rate
Duration of Storm Event Beginning of Storm Measured and Total Flow from Rain Event
Date of Storm Event (in hours) Storm Event End of Previous Measurable Rain During Rain Event (n gallons or specify units)
(in inches) Event (in gpm or specify units)
Provide a description of the method of flow measurement or estimate.
Refer to Appendix D of application
EPA Form 3510-21'(Revised 3-19) Page 13

Appendix 6
NC DEQ SPPP Certification Form
® Hexion, Inc.—Morganton Facility
NPDES Permit Renewal Application
S IEMPLOYEES.ROOT LOCAL I ENV}ECCI GREENVILLE�WPGVL`P1T2�581579}0001�1?5815790000-001_HEXION MORGANTON NPDES RENEWAL APPLICATION.DOCX
February 29, 2024
s

STORMWATER POLLUTION PREVENTION PLAN
_ DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
North Carolina Division of Energy, Mineral, and Land Resources— Stormwater Program
.—^ facility Name: HexSon.M..hiaganionfao'.ty
Permit Number: NC-1;"332
Location Address: 114 Wus%rzai EOW.evw4
morgmtCn,NC 2M5
-� County:
"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 10Date °
Jeff hkDa" SAa teach
Print or type name of person signing above Title
SPPP Certification 10/13

FED
fm&,
Appendix C
® NC DEQ Supplemental Information Form
Nexion, Inc.—Morganton Facility
NPDES Permit Renewal Application
1IEMPLOYEES.ROOT.LOCALIENVIECCIGREENVILLEI WPGVLIPJT215 81 5 79100011R5815790000-001_H£XICN MORGANTON NPDES RENEWAL APPLICATICN.DOCX
February 29, 2024

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 frorn 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 surnmary 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.
Sumrtrary should consist of a short narrative description of each BMW'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.
G. 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 perinit terra 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)

rim
Appendix D
PAM Summary of Monitoring Results
A'+ Hexion, Inc.—Morganton Facility
NPDES Permit Renewal Application
1 tEMPLOYEES.ROOT.LOCALIENVIECCIGREENVILLEIWPGVLIPIT2158157910001 JR581579O00O-OO1_HEXION MORGANTON NPDES RENEWAL APPLIU TION.DOIX
February 29, 2024

Hexion Inc. - Morganton Plant
Morganton, NC
NPDES Permit No. NCS000332
Summary of Visual Monitoring Results
Outfall 001
a
F d —
o ; 5
o e o N f o 0 0
u y ? d N E o q
rpp £
0 C N Z N N 6 z W £ N 9 6 r 0
Month Sample Date g 'o LL o s
Jun-20 6/14/2020 Light None 3N ~1 2 No No No None
brown/grey
Dec-20 12/14/2020 Very lightbrown None 2 1 1 No No Yes None
se
Jun-21 6/3/2021 Light brownto light grey None 3 2 3 No No Yes None
Dec 21 12/11/2021 Light brown/ None 2 2 2 No No No None grey
May-22 5/23/2022 Grey-brown None 5 4 5 No No Yes Mild erosion from road runoff.No visible evidence of stormwater
light tint I I pollution
Dec-22 12/14/2022 Medium tint/color None 3 1 3 No No Yes None
sr
Jun-23 6/19/2023 Grey-brown None 2 2 2 No No Yes None
light tint
Nov-23 11/21/2023 Grey brown;light tint None 2 2 Z No No Yes None
wiA
ma
r�
MM
0-90
r�

SW
Hexion Inc. - Morganton Plant
® Morganton, NC
NPDES Permit No. NCS000332
FW Summary of Analytical Monitoring Results
rim Outfal 1001
Rainfall H COD Ammonia Formaldehyde
Month Sample Date (inches) P (mg/L) (mg/L) (mg/L)
Jun-20 6/14/2020 0.67 6.35 122 1.5 0.29
Dec-20 12/14/2020 1.14 6.72 ND 0.13 BRL
Jun-21 6/3/2021 0.12 7.14 174 0.77 BRL
Dec-21 12/11/2021 0.22 6.15 49.9 <0.1 0.46
May-22 5/23/2022 0.83 7.15 37.6 0.15 0.12
Dec-22 12/14/2022 1.91 6.82 104 1 0.15 1 BRL
Jun-23 6/19/2023 0.38 6.58 122 0.25 0.08
Nov-23 11/21/2023 1.27 6.68 41.8 1.1 BRL
Notes
ND= Non detect
BRL= Below Reporting Limit
F

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