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HomeMy WebLinkAboutNCS000386_Permit Renewal Application_20131025ROHM AND HAAS CHEMICALS LLC Charlotte Operations Certified Mail October 25, 2013 Stormwater Permitting Program Individual Permit Renewal 1612 Mail Service Center Raleigh, NC 27699-1612 To Whom It May Concern: The current NPDES Stormwater Discharge Permit for Rohm and Haas Chemicals LLC in Charlotte (Permit # NCS000386) expires on 4/30/2014. The plant wishes to renew the permit, and is submitting this application for permit renewal prior to the required date as indicated in the permit. Enclosed you will find the Permit Renewal Application Form, Stormwater Pollution Prevention Plan Certification and the Supplemental Information as required by the form. I have marked "Don't Know" on the application form for the question concerning whether the site discharges into impaired waters. The receiving stream (Brier Creek) is not listed on the 2012 North Carolina 303(d) List and it is not depicted on the NCDWQ Impaired Waters Map. Several miles Southwest of the facility, Brier Creek joins the Little Sugar Creek, which is on the 2012 NC 303(d) List. Please feel free to contact me if you have any questions or need additional information. My phone number is (704) 596-3021, Extension 3050 and my email address is jwatts@dow.com. Enclosures Sincerely, mie Watts Site Environmental, Health and Safety Leader N�� 0 1 2313 ve p osw+�st°�R�cH 6101 Orr Road ♦ Charlotte, North Carolina 28213 ♦ 704-596-3021 ♦ Fax 704-598-0909 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. MV) 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 storm event data. 11 3M►' 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. TM t'✓ 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. TM N/ 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. Mui 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) ©� Permit Coverage Permit Number Renewal Application Form NCS000386 NCDENR National Pollutant Discharge Elimination System Stormwater Discharge Permit The following is the information currently in our database for your facility. Please review this information carefully and make all corrections/additions as necessary in the space provided to the right of the current information. Owner Affiliation Information Owner / Organization Name: Owner Contact: Mailing Address: Phone Number: Fax Number: E-mail address: ' Reissued Permit will be mailed to the owner address Rohm And Haas Chemicals LLC Jamie Watts 6101 Orr Road Charlotte, NC 28213 Facility/Permit Contact Information Facility Name: Rohm And Haas Chemicals LLC Facility Physical Address: 6101 Orr Rd Charlotte, NC 28213 Facility Contact: Mailing Address: Phone Number: Fax Number: E-mail address: Discharge Information Receiving Stream Brier Creek Stream Class: Basin: Sub -Basin: Number of Outfalls: C Catawba River Basin 03-08-34 7oI-5116-3021 XIaSo 17 O+ - S98- ogoq 7'Wa ff5 N_ Dow, Com z Impaired Waters/TMDL Does this facility discharge to waters listed as impaired or waters with a finalized TMDL? ❑ Yes ❑ No X Don't Know ( for information on these waters refer to http://hZo.enrstate.nc.us/su/Impaire(tWaters_TMDL/ ) CERTIFICATION p@mueimp NOV 0 1 ?013 I certify that I am familiar with the information contained in the application and that to the best of my knowledge and belief such information is true, complete and accurate. DDNR•WMERWAM NIMANWAND STOWOTER BRANCH Signature c Date /0/2S// 3 n/.C1�-, 7, 51k. _ Lea4-e� Print or type name of person signing above Title Stormwater Permitting Program Please return this completed renewal application form Individual Permit Renewal and other required suppl ,mental information to: 1612 Mail Service Center Ralciali, North Carolina 27699-1612 STORMWATER POLLUTION PREVENTION PLAN DEVELOPMENT AND IMPLEMENTATION CERTIFICATION North Carolina Division of Energy, Mineral, and Land Resources - Stormwater Permitting Facility Name: Rohm And Haas Chemicals LLC Permit Number: NCS000386 Location Address: 6101 Orr Rd Charlotte, NC 28213 County: Mecklenburg 9 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 or type name of person signing above Date /0/ ZS—/l Sim L�— Title SPPP Certification 10/13 000-000-0000-00-000 LEGEND APPROX. BOUNDARY UMITS FOR DRAINAGE AREAS AREA BOUNDED DRAIN TO Wff AREA TO SDO JOD2 STORM WATER POLLUTION PREVENTION PLAN LEGEND: NOTES: A 110/28/131 SWPPP UPDATE RJB emseo. rnom r.�or STORM WATER POLLUTION PREVENTION PLAN 6101 ORR ROAD CHARLOTTE OPERATIONS ou.n� r mn.,n,. r nse®a ern.. r.ercn. DRAWING NUMBER r..a eur �,nr vn uumv 0000 00 SDO-001 Monitoring Results Notes: 1) Rainfall Sources: A=USGS Station CRN -27 Recorded Rainfall, B=Plant Rain Gauge 2) In December 2011, Clarity, Floating and Suspended Solids Observations Reported using Numeric Ratings from SDO Qaulitative Monitoring Report Rohm and Haas Chemicals, LLC, 6101 Orr Road, Charlotte, NC 28213 J. Watts, 10/28/2013 Analytical Monitoring Visual Monitoring v o 0o p cc o U O N c E +_ L d N O O Q v N O p a E °_�° c C v O c a o M 3 n E E w g �, E: Date C v'^i 2 'rp 'm O O O "p Mp MO_ '^ E M LL N _ NO O N Y O Comments D N d K = U O U LL n O w O N 10/5/2009 2.5 0.063 19 7.65 0.46 A None None Clear None None None Slight tion Dam E None 3/29/2010 2.8 0.020 66 7.45 0.51 A Muddy None Clear None None None Slight me at Culvi None Initial Investigation of High Zinc Results on 4/9/10 7/27/2010 0.031 1.99 A 8/26/2010 0.160 0.50 A 9/26/2010 5.4 0.099 32 6.45 0.83 A 1/26/2011 0.380 0.32 A 3/10/2011 0.059 0.18 A Muddy None Clear None None None I None None None 5/5/2011 0.020 1 1.20 B 9/21/2011 2.8 0.100 10 5.70 0.35 A dight Cloud None Jight Cloud None None None None None None 10/11/2011 0.041 0.61 A Lt Yellow None Clear None None None None None None Investigation Update on file, 10/3/11 11/10/2011 0.053 0.15 B ow Amber None Clear None None None None None None 12/7/2011 0.054 0.29 A ellow/Bro None 2 1 2 None None None None Investigation Update on file, 1/9/2012 2/16/2012 8 0.0381 4.3 7.31 1.10 B Light None 1 1 1 None Minor None Minor Sheen Numeric Ratings from SDO Qaulitative Monitoring Repo 3/23/2012 0.056 0.15 A Lt Amber None 2 1 1 None None None None 4/6/2012 0.150 0.22 A Lt Amber None 2 1 1 None None None None 5/13/2012 0.37 A Lt Amber None 2 2 1 None None None None 6/6/2012 5.4 0.027 7.8 7.16 0.72 A Light None 2 1 2 None None None None 7/13/2012 0.10 B Lt Amber Musty 2 2 2 None None None None 8/6/2012 6.65 1.97 A Clear None 1 1 1 None None None None Investigation Update on file, 8/8/12 11/13/2012 0.14 A Lt Amber None 3 3 2 None None None None 12/26/2012 2 0.160 130 6.77 1.43 A Amber None 3 2 3 None None None None 2/7/2013 0.088 7.121 0.59 A Amber None 2 2 1 None None None None 4/4/2013 7.13 1.15 A Gray None 2 1 1 None None None None 5/23/2013 7.19 0.40 A Amber Musty 3 1 1 None None None None 6/6/2013 2 0.067 100 7.43 '.79A Investigation Update on file, 6/19/13 7/3/2013 0.021 6.91 0.16 A Lt Amber Musty 2 1 1 None None None None 8/17/2013 0.0291 6.97 1.17 A Lt Amber None 2 2 3 None None None None Investigation Update on file, 8/5/13 Notes: 1) Rainfall Sources: A=USGS Station CRN -27 Recorded Rainfall, B=Plant Rain Gauge 2) In December 2011, Clarity, Floating and Suspended Solids Observations Reported using Numeric Ratings from SDO Qaulitative Monitoring Report Rohm and Haas Chemicals, LLC, 6101 Orr Road, Charlotte, NC 28213 J. Watts, 10/28/2013 SDO-002 Monitoring Results Notes: 1) Rainfall Sources: A=USGS Station CRN -27 Recorded Rainfall, B=Plant Rain Gauge 2) In December 2011, Clarity, Floating and Suspended Solids Observations Reported using Numeric Ratings from SDO Qaulitative Monitoring Report Rohm and Haas Chemicals, LLC, 6101 Orr Road, Charlotte, INC 28213 J. Watts, 10/28/13 Analytical Monitoring Visual Monitoring ° c O °` u c O c N p - C =_ H ani '^ _ p O 0 a v _ '^ O a � m V1 E ` ` Date m ` o ° o ° n ' E o ° ° U U o o Comments 10/5/2009 < 2 0.140 30 8.22 0.46 A Clear None Clear None None None None It at Outfall None 3/29/2010 < 21 0.160 30 7.90 0.51 A Clear None Clear None None None None None None Initial Investigation of High Zinc Results on 4/9/10 4/24/2010 3.5 0.066 3.7 7.25 0.16 A 7/27/2010 0.073 1.99 A 8/26/2010 0.073 0.50 A 9/26/2010 4.8 0.130 77 6.51 0.83 A 1/26/2011 0.097 0.32 A 3/10/2011 0.056 0.18 A Clear None Clear None None None None None None 5/5/2011 0.020 1.20 B 9/21/2011 2 0.086 5 6.80 0.35 A Clear None Clear None None None Slight None None 10/11/2011 0.140 0.61 A Clear None Clear None None None None None None Investigation Update on file, 10/3/11 11/10/2011 0.160 0.15 B Clear None Clear None None None Sheen None None 12/7/2011 0.400 8.85 0.29 A Brown Tint None 4 3 3 None Sheen None None Numeric Ratings from SDO Qaulitative Monitoring Report 1/17/2012 0.160 7.15 0.58 A Lt Amber None Clear None None None None None None Investigation Update on file, 1/9/2012 2/16/2012 8.2 0.170 34 7.931 1.10 B Medium None 2 1 2 None Sheen None None 3/23/2012 0.320 0.15 A Lt Amber None 2 1 1 None None None None 4/6/2012 0.032 0.22 A Lt Amber None 2 2 2 None None None None 5/13/2012 0.330 0.37 A I Lt Amber Musty 2 2 2 None None None None 6/6/2012 3.2 0.071 13 7.87 0.72 A Clear None 1 1 1 None None None None 7/13/2012 0.160 8.50 0.10 B Lt Amber Musty 2 3 3 None None None None 8/6/2012 0.045 1.97 A Clear None 1 1 1 None None None None Investigation Update on file, 8/8/12 9/18/2012 0.330 0.50 A 11/13/2012 1 0.170 0.14 A Lt Amber None 3 3 2 None None None None 12/26/2012 21 0.069 20 7.18 1.43 A Lt Amber None 2 2 2 None None None None 1/16/2013 0.450 8.30 0.19 A Gray Musty 4 3 3 None None None None 2/7/2013 0.120 0.59 A Lt Amber None 2 2 1 2 None None None None 3/12/2013 0.069 8.15 1.12 A Light None 2 1 1 Light None None None 4/4/2013 0.034 1.15 A Lt Gray None 1 1 1 None None None None 5/23/2013 0.130 1 7.831 0.40 A Lt Amber None 2 2 1 None None None None 6/6/2013 2 0.150 62 8.38 1.79 A Investigation Update on file, 6/19/13 7/3/20131 1 0.610 8.41 0.16 A Gray Musty 4 2 3 None None None None 8/17/201310.190 8.45 1.17 A Amber None 2 2 2 None None None None Investigation Update on file, 8/5/13 9/21/20131 0.029 7.36 1.741 A Notes: 1) Rainfall Sources: A=USGS Station CRN -27 Recorded Rainfall, B=Plant Rain Gauge 2) In December 2011, Clarity, Floating and Suspended Solids Observations Reported using Numeric Ratings from SDO Qaulitative Monitoring Report Rohm and Haas Chemicals, LLC, 6101 Orr Road, Charlotte, INC 28213 J. Watts, 10/28/13 Summary of Best Management Practices Rohm and Haas Chemicals, LLC Charlotte Plant The following Best Management Practices have been implemented to protect stormwater discharge from contamination at the Rohm and Haas Charlotte Plant. Good Plant Rounds are conducted to identify areas in need of housekeeping. A recurring Housekeeping task list is used to ensure basic housekeeping is accomplished on a routine basis. Maintenance is performed under roof where feasible. Preventive The plant has an extensive preventive maintenance program to extend the life of Maintenance operating equipment and to minimize the potential for leaks. This includes a mechanical integrity program that complies with the requirements of OSTIA PSM. No additional controls are considered necessary. Inspections / Several areas of the plant require periodic inspections because of their potential for Outfall Sampling Requirements serious environmental, operations, or personal consequences in the event of a failure or malfunction. Plant areas must be frequently inspected for spills or leaks which could lead to a release of chemicals to the environment or a threat to human health. Inspections must be performed often enough to identify problems in time to correct them before they cause any damage or harm. These inspections are accomplished via plant rounds. Plant rounds procedures have been developed which identify areas and equipment to be inspected, types of problems to look for during the inspection, personnel or department responsible for the inspections, and the inspection frequency. The Stormwater discharge outfall and all associated conveyance and storage facilities shall be inspected semi-annually per the stormwater permit conditions (November — April, and May -October). Written records of these inspections are maintained on site. Sampling and analysis of stormwater discharges will be required s specified in the facility stormwater permit. Results of these sampling events (SDO Monitoring Report) should be submitted to the Central Files, Division of Water Quality, Raleigh, North Carolina, and maintained in the Appendix to this Plan. Spill Prevention All employees are actively encouraged to report both spills and potential spills and Response through our LOPC (Loss of Primary Containment) reporting process. Reports are actively reviewed and ranked by likelihood and potential impact. Pre-emptive actions are taken to prevent spills before they occur. This is part of an ongoing effort to eliminate all spills at the site. A Consolidated Emergency Response Plan is maintained by the site with instructions on Spill Response. It includes specific instructions on spills to stormwater systems, including notification of NCDENR. Management of Runoff from Areas II, III and IV is discharged through SDO #001 only after it has Runoff been assessed for the presence of non-stormwater discharges. This is done by written procedure, and includes a record of sampling results. October 2013, J. Watts Summary of Best Management Practices Rohm and Haas Chemicals, LLC Charlotte Plant Employee Personnel handling chemicals or who are involved in environmental protection and Training product safety activities at the site receive training in the safe handling of oils, hazardous substances/wastes, and in spill and release prevention and response as required by their assigned jobs. Employees involved directly in releasing stormwater from SDO #001 or in sampling stormwater for compliance monitoring receive training on those topics. Employee training records are maintained by the Training Coordinator. General Employee Training topics include a general overview of chemical use in the plant, how to Awareness recognize problems (i.e., potential and actual spills and leaks), and procedures for addressing releases. All employees are made aware of the Emergency Response Plan, and are encouraged to read and understand the purpose and contents of the Plan. Employee training records are maintained by the Training Coordinator. Emergency Because the Plant will evacuate in the event of a significant spill or release, no formal Response Team Emergency Response Team exists. All plant personnel are trained on their roles in implementing the Emergency Response Plan, including specific roles of certain job functions. These roles are identified in the Emergency Response Plan. The following topics are covered in training: • First aid (appropriate job titles) • Evacuation plans • Recognition of nature of spills (i.e., flammable, etc.) • Spill control, containment, and clean-up procedures • Use of various types of fire extinguishers • Documentation of training and proficiency Facility Security The Charlotte Plant is enclosed by a security fence (6' to 8' high) and is manned continuously. The facility is illuminated at night. Lighting is sufficient to allow visible detection of leaks, spills or releases during darkness. Access to the operations area of the site is gained through key -coded electronic security gates. Recordkeeping All records of inspection, certifications, incident reports, and training documentation and Reporting are maintained on site. The Storm Water Pollution Prevention Plan and all associated documentation are retained for a period of five years. October 2013, J. Watts Significant Industrial Activity Changes Rohm and Haas Chemicals, LLC Charlotte Plant The last Stormwater permit application for the Rohm and Haas Charlotte Plant was submitted in February of 2006. Since then, the following significant changes have been made: • Installation of a new Reactor Train and associated Processing and Storage Vessels • Completion of several Mechanical Integrity Driven Projects including replacement of monomer feed lines from the Tank Farm to the Reactor Deck Neither of these changes increase the likelihood of non-stormwater discharges or required changes to our established Best Management Practices. October 2013, J. Watts