NCS000064 Draft Permit Cover Letter

Energy, Mineral
and Land Resources
ENVIRONMENTAL QUALITY
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
WILLIAM E. (TOBY) VINSON, JR.
Interim Director
February 13, 2018
Ms. PEM Carter
CNA Holdings, LLC—Ticona Plant
2525 Blacksburg Road
Grover, NC 28073
Subject: Draft NPDES Stormwater Permit
Permit No. NCS000064
CNA Holdings, LLC—Ticona Plant
Cleveland County
Dear Ms. Carter:
Enclosed with this letter is a copy of the draft stormwater permit for your facility. Please review
the draft carefully to ensure thorough understanding of the conditions and requirements it
contains.
The draft permit contains the following significant changes from the facility's current permit:
1. You are required to collect analytical and qualitative monitoring samples during
"measurable storm events" as defined in Part II, Section B. This term is different from the
"representative storm event" in earlier permits.
2. Requirements for the Stormwater Pollution Plan (SPPP) have been updated in Part II,
Section A.
3. Monitoring requirements remain very similar in the permit with required monitoring for
TSS, BOD, COD and pH. Stormwater benchmarks remain in the permit as before. Keep in
mind that benchmarks are not permit limits, but rather guidelines for implementing the
Stormwater Pollution Prevention Plan (SPPP). A benchmark exceedance is not a permit
violation; however, the permittee must respond to exceedances. The draft permit has
added a tiered response process for benchmark exceedances consistent with other
permits in our program. Please become familiar with the tiered process as proper
response under the tiers may be enforceable items under your permit. Response to the
tiered process may include review of onsite conditions, installation of BMPs or
requirements for more frequent monitoring.
State of North Carolina I Environmental Quality I Energy, Mineral and Land Resources
1612 Mail Service Center 1512 North Salisbury Street I Raleigh, NC 276 99-16 12
919 707 9200 T

NCS000064 Draft Permit
Page 2
4. Vehicle maintenance (Tables 4 & 5) monitoring parameters have been revised. Non -Polar
Oil & Grease [EPA Method 1664 (SGT -HEM)] replaces Oil & Grease/TPH. The benchmark
for Non -polar Oil & Grease using this method is 15 mg/L. This requirement appears in all
individual stormwater permits; however, it only applies to facilities that perform onsite
vehicle maintenance activities. If the facility begins vehicle maintenance during the permit
cycle, the requirements shall apply. Also, pH monitoring is no longer required for
discharges only associated with vehicle maintenance activities.
5. A new section on Special Conditions has been added in Part II, Section E to comply with
federal regulations requiring electronic submittal of discharge monitoring reports. Our
electronic submittal process is not available for use at this time, but we will continue to
provide feedback on when this process will be available.
6. Civil and administrative penalty amounts have been updated to reflect current federal
law in Part III, Section A, 2(b) and (g).
Please review the draft permit and submit any comments to me no later than 30 days following
your receipt of the draft. Comments may be emailed to meat [e-mail] or
mailed to my attention at NC DEMLR, Stormwater Permitting Program, 1612 Mail Service Center,
Raleigh, NC 27699-1612.
If you have any questions, please email me or call me at [phone].
Sincerely,
Bradley Bennett
Stormwater Permitting Program
Attachment: Draft Permit NCS000064
cc: Zahid Khan, DEMLR Mooresville Regional Office — via email
Stormwater Permitting Program Files