NCS000292_Staff Report_20070305

NCS 000292
SOF w A rF90 Michael F. Easley, Governor
William G. Ross Jr., Secretary
�0 (r North Carolina Department of Environment and Natural Resources
CO
j r Alan W. Klimek, P. E. Director
4 Y Division of Water Quality
Coleen H. Sullins, Deputy Director
Division of Water Quality
STAFF REVIEW AND EVALUATION
NPDES Stormwater Permit
Facility Name:
Resinall Corporation
NPDES Permit Number:
NCS000292
Facility Location:
Severn, NC (Northampton County)
Type of Activity:
Resin Manufacturing
SIC Code (if applicable):
Paints, varnishes, enamels and allied products (SIC 2851)
Receiving Streams:
Kirbys Creek, See Figure I
River Basin:
Chowan River Basin, Sub -basin 03-01-02
Stream Classification:
C, NSW
Proposed Permit Requirements:
See attached draft permit.
Monitoring Data:
See Tables I & 2
Facility Location:
See Figure I
Response Requested by (Date):
Central Office Staff Contact:
Kelly Johnson, [phone], ext. 376
Previous Permit Cycle: 1 April 2000 — 31 March 2005
Description of Activities Onsite:
This facility manufactures three types of products, (1) Rosin resins which are modified rosin esters, (2)
Hydrocarbon resins which are aromatic and aliphatic hydrocarbon resins, and (3) Other specialty resin
products which are typically a combination of resin and hydrocarbons. The facility also has a research and
development lab for new product development. This facility does not manufacture materials for
rotogravure inks, which would require toluene. This industry is often required to test for toluene because
many plant manufacture rotogravure ink materials, but this facility should not be subject to those
requirements.
Documents Reviewed:
• NPDES Stormwater Permit Application Materials
• Stormwater Permit File
• Chowan Basinwide Plan
• Draft 2006 303(d) List
• EPA Sector -Specific Permit, 2006 draft
QM;
YCDEN;t
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 [phone] Customer service
1-877-623-6748

NCS000292
Figure 1: Map of Facility
Resinall
Sampling Data:
The applicant submitted the application in September 2004.
Figure 2: Color Coded Key for Tables:
Required data was not submitted
Data above or below benchmark
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NCS 000292
Central Office Review Summary:
1. General Observations: Since the previous permit was issued in 2000, the facility has had several changes:
o New process control room outside of the process building
o New covered truck loading/unloading station (south side of production area)
o High speed blender added to the process (inside building)
o Purchased adjacent land. Will use the farm pond for plant fire protection. This included
installation of a fire protection system
o Improved VOC-containing tanks to limit emissions
o Added a new "slam" gate for environmental protection (south of spill control box)
2. Impairment: The receiving stream for this facility is non 303(d) listed. It is also not listed as a concern in
the Chowan Basinwide Plan.
3. Inspection: Myrl Nisely (RRO) and Kelly Johnson inspected this facility on 1 March 2007. The site was
clean, and the records were in order. There are two ditches draining this facility, and there are two
outfalls. As shown on the map, one of the ditches runs internally to the site, and then meets up with the
other ditch at Outfall 001. The other ditch drains afield outside of the permittee's property. Outfall 001
has a large sediment basin to still water before an overflow weir. This sediment basin is cleaned out
approximately once each year. Samples are taken as the water flows out of the weir. Outfall 001 was
inspected for signs of sediment, as one of the samples for this outfall was high in sediment. There was no
evidence of significant sediment collection in the stream. The adjacent property sharing the outside stream
draining to Outfall 001 is agricultural land. The permittee reports that on at least one occasion the stream
was bright orange, but not sediment. The permittee believes that this was fertilizer in the stream, which is
a problem for NSW waters. DWQ advised the permittee that they could choose to sample the ditch
internal to their site before it reaches Outfall 001 in addition to what is required in their permit if they were
concerned about liability for nitrogen loading from the farm.
4. Vehicle Maintenance: No vehicle maintenance equaling 55 gallons per month is done onsite.
Qualitative Monitoring:
The facility has slightly brown and unclear water leaving the sight.
Analytical Monitoring:
1. pH has been added for analytical monitoring. The permittee submitted pH monitoring for the previous
cycle, but was not required to do so.
2. Total nitrogen has been added because the receiving water is classified NSW.
3. Toluene has been removed from requirements after discussion with plant personnel about the nature of
toluene usage onsite.
4. Due to a potential lag time between the expiration of this permit and its renewal, the reviewer has specified
in the permit that the permittee is responsible for all monitoring until the renewal permit is issued. See
Footnote 1 of Tables 1, 4, and 5. This approach is recommended because the applicant has failed to
submit most of the required data from the previous cycle and has also not continued adequate monitoring
since the permit expiration. During the site inspection, the permittee said that these samples were not
collected because there were no significant rain events.
5. Benchmarks have been added to this draft permit.
RUM
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 [phone] Customer Service
1-877-623-6748

NCS000292
6. All analytical monitoring has been changed to semi-annually.
7. The flow reporting requirement has been removed per DWQ revised strategy. (The total rainfall and event
duration parameters have been retained.)
8. The permittee is required to collect all of the analytical monitoring samples during representative storm
events as defined in this permit. This is not a change from their previous permit. Qualitative monitoring
does not have to be performed during a representative storm event.
Other Proposed Changes to the Previous Permit:
1. Part II Section A has been revised. It now specifies all of the items to include on the site map.
2. Vehicle maintenance has been revised to semi-annually in order to coincide with analytical and qualitative
monitoring.

NCS000292
Recommendations: Based on the documents reviewed, the application information first submitted on September
30, 2004 is sufficient to issue an Individual Stormwater Permit. An inspection has been scheduled. Kelly Johnson
will determine during the site visit whether or not additional analytical monitoring is needed. The draft EPA
Sector -Specific permit requires total recoverable zinc. It does not require toluene, which was required by the
previous permit. These two materials will be the considered for analytical sampling requirements. Additional
analytical monitoring requirements may be identified during the inspection if new chemicals are found onsite as a
result of recent expansion.
Prepared by (Signature) U / ' Date
-a 49 -
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Stormwater Permitting Unit Supeervvii`sor .tic Date 20 02
Concurrence by Regional Office 9£ LI'7 LWS) 099th Date
Water Quality Supervisor
Regional Office Staff Comments
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RRO Staff Report Resinall
Subject: RRO Staff Report Resinall
From: "[e-mail]" <[e-mail]>
Date: Wed, 14 Mar 2007 07:52:43 -0400 (EDT)
To: [e-mail]
CC: [e-mail]
Kelly,
Please consider this email to be RRO's staff report for Resinall
permit NCS000292. The detailed staff report you created before our
visit was verified by our inspection. The company is following their
permit quite well, and I did not uncover anything new or different to
be added to the renewed permit, unless you want to add a reminder to
continue sampling after a permit expires, until they receive a new
one. In other NPDES permits, that continuation clause is in the boiler
plate language, but not stated as explicitly covering sampling.
Any comments or questions, please contact me.
Thanks,
Myrl
of 1 1/1 4/9nn7 '7•1e A