NCS000354_Draft Permit Cover Letter_20180321

Energy, Mineral
and Lmd Resources
E H YIRQNMEN TAL QUALITY
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
WILLIAM E. (TOBY) VINSON, JR.
Interim Director
March 21, 2018
Mr. Jason Greenwood
Starpet, Inc.
801 Pineview Road
Asheboro, NC 27203
Subject: Draft NPDES Stormwater Permit
Permit No. NCS000354
Starpet, Inc.
Randolph County
Dear Mr. Greenwood:
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 in the draft permit have changed. Monitoring is required for
BOD, COD, TSS and pH. After review of monitoring data from the past 10 years the results
for the other parameters have remained well below the previously established benchmark
level. The draft permit proposes to remove these parameters (Oil & Grease, Total
Phosphorous, Total Nitrogen, Ethylene Glycol, MBAS and Cobalt). Comments from our
regional staff or other information may result in maintaining iron if it is apparent that your
activities in some way have the potential to release this pollutant. 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
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

NCS000354 Draft Permit
Page 2
respond to exceedances. The draft permit has modified the 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.
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. Language has been added under Part II Section D to address potential responses to
qualitative monitoring issues.
6. 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.
7. 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. 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 NCS000354
cc: Matt Gantt, DEMLR Winston-Salem Regional Office — via email
Stormwater Permitting Program Files