Signed Cover Letter - 2-28-18

Energy, Mineral
and Land Resources
ENVIRONMENTAL QUALITY
ROY COOPER
MICHAEL S. REGAN
ce,„-mn
WILLIAM E. (TOBY) VINSON, JR.
February 28, 2018
Mr. Bill Lewis
Resinall Corporation
302 N. Water Street
Severn, NC 27877
Subject: Draft NPDES Stormwater Permit
Permit No. NCS000292
Resinall Corporation
Northampton County
Dear Mr. Lewis:
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, COD and pH. After review of monitoring data from the past 10 years the results for
TN and TP have remained well below benchmark levels. The draft permit proposes to
remove these parameters. Comments from our regional staff or other information may
result in maintaining these if it is apparent that your activities in some way have the
potential to release these pollutants. 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
State of North Carolina I Environmental Quality I Energy, Mineral and Land Resources
1612 Mail Service Center 1512 North Salisbury Street I Raleigh NC 27699-1612
919 707 9200 T

NCS000292 Draft Permit
Page 2
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.
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 ll, 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 maybe emailed tome at [e-mail] or
mailed to my attention at NC DEMLR, Stormwater Permitting Program, 1612 Mail Service Center,
Raleigh, NC 27699-1612. With this notification the Division will solicit comment on this draft by
publishing a notice in a local newspaper. Following the 30 day public comment period, the
Division will review comments and take appropriate action prior to issuance of the final permit.
If you have any questions, please email me or call me at [phone].
Sincerely,
Bradley Bennett
Stormwater Permitting Program
Attachment: Draft Permit NCS000292
cc: Bill Denton, DEMLR Raleigh Regional Office—via email
Stormwater Permitting Program Files