NCS000093 Staff Report - 2008

NCS000093
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
STAFF REVIEW .AND EVALUATION
NPDES Stormwater Permit
Coleen H. Sullins Director
Division of Water Quality
Facility Name:
BRP US Inc.
NPDES Permit Number:
NCS000093
Facility Location:
Spruce Pine, NC (Mitchell County)
Type of Activity:
Aluminum Foundry
SIC Code:
3365
Receiving Streams:
See. Figure 1
River Basin:
French Broad River Basin, Sub -basin 04-03-06
Stream Classification:
C; Tr
Proposed Permit Requirements:
See attached draft permit.
Monitoring Data:
See Table 1
Facility Location:
See Figure 1
Response Requested by (Date):
Due date for Region
Central Office Staff Contact:
Brian Lowther, [phone]
Special Issues:
Issue '°
Ration ` Scale. -A eas to 10 and
Compliance history
4
Benchmark exceedance
1
Location (TMDL, T&E
species, etc
4
Other Challenges:
• Contacting
Permittee
6
Di culty Rating:
15140
Special Issues Explanation:
• On the application the permittee asked for the monitoring of methylene chloride to be removed because
it is not used insufficient quantity. The permittee also wanted to not sample the last year if limits were not
exceeded the first three years. Finally, they wanted to make sure only Outfall 1 was to be monitored.
Outfall l is the only outfall associated with industrial activity and is the outfall of a stormwater pond
overflow.
Description of Onsite Activities:
• Make headboards for boat engines. Spruce Pines, North Carolina is a lost foam casting facility which
produces engine parts for OMC.
• Lost foam casting is an advanced technique in which very complex parts can be produced by casting,
reducing the amount of subsequent machining needed to create a finish part. The technique involves use of a
styrofoam mold in the shape of the desired part, which is then surrounded with sand. Molten aluminum is
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NCS000093
poured onto the mold, the metal taking the shape of the part and the foam burning off.
Documents Reviewed:
• SPU File
• Central DWQ File
• 2005 French Broad Basinwide Plan
• 2008 draft 303(d) list
• National Heritage Program's T&E database
• EPA draft 2006 Sector -Specific permit, Sector F "Primary Metals"
History:
• 10101194: Permit first issued to Outboard Marine Corporation. Analytical monitoring included Methylene
Chloride. Monitoring required annually.
• 09/21101: Date Permit re -issued to Bombardier Motor Corporation of America. Analytical monitoring
included Methylene Chloride. Monitoring required annually for first 3 years and quarterly for the 4`h year.
• 08/18106: Sent letter for need to renew permit to permittee
• 10/26/06: Permittee submitted renewal application
• • 09/22/08: Sent Reviewing Application Letter to permittee
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NCS000093
Figure 1: Map of Facility
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NCS000093
BRP US Inc.
Latitu& 350 54' 48" N
i1'.'.. t'
Longitude: 820 5' 2211 W
Coun Kitchell
Receiving Stream: Endish
Stream Gass: C; Tr
S
Sub -basin: 04-03-06 (French Broad River Basin)
M9nScale 1:210,000
Facility Location
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NCS000093
Central Office Review Summary:
1. Owner's Other Permits: There are no other permits in BIMs.
FRS 11001281627 Bombardier Motor Corporation of America -- Spruce Pine, CAA AFS 3712100088 BRP US Inc.,
NCR000137158 BRP US Inc., TRI 28777MCSR1 025 G BRP US Inc.
2. General Observations:,
• Outfall I is supposedly the only one with industrial activities. This outfall is the discharge of a
detention pond onsite.
3. Impairment: English Creek is not on the 303(d) and is not in the 2005 French Broad Basinwide Plan.
4. Threatened and Endangered: Based on the Natural Ileritage Workroom there is one species that is state
protected. Glyptemys muhlenbergii (Bog Turtle) Threatened. There are no Federally protected species within 2
miles of the site.
5. Location.: The outfall flows to a classified C; Tr stream.
6. Industrial Changes Since Previous Permit:
• 4t' Qtr 2001- Addition of CNC machines using water soluble cutting fluid.
• 4`'' Qtr 2001- Addition of chrome conversion coating process using alkaline cleaner, acidic deoxidizer, acidic
chromate conversion bath and polymer seal (all water diluted in process with the process wastewater
discharged to the Town of Spruce Pine POTW per IUP Permit No. 002)
• 4 O Qtr 2001- Addition of porosity sealing process using methacrylate based sealant.
• 4d` Qtr 2001- Addition of dry filter spray painting booth using high solids two-part epoxy paint/catalyst and
methyl n -amyl ketone.
• 4" Qtr 2001- Addition of wastewater pre-treatment system using sulfuric acid, sodium metabisulfite, caustic
soda Iiquid, aluminum sulfate and flocculant.
• 2 d Qtr 2004 — Replaced catalytic oxidizer with regenerative thermal oxidizer.
• 3rd Qtr 2006 — Installed new shotblast machine and dust collector — replaced existing units.
• 3rd Qtr 2006 — Addition of two CNC machines using water soluble cutting fluid.
7. Analytical Monitoring Notes: Monitoring was done at one outfall seven times froze. 9/14/02 to 9129105. The
parameter sampled was Methylene Chloride.
In the 2008 EPA Sector -Specific General permit the SIC code 3365 is in the section Nonferrous Foundries (SIC
3363.3369) which recommends monitoring for Cu and Zn. This site's primary process is aluminum, though.
Their secondary SIC code is 3471 which is identified as "Plating and Polishing." Subsector AAl in the EPA
Multi -Sector Permit, "Fabricated Metal Products except coating," includes monitoring for Total Al, Total Fe,
Total Zn, and Nitrate plus Nitrite Nitrogen,
Methylene Chloride did not show up in the monitoring, and there is no source on site. Therefore, the renewal
permit will remove methylene chloride from the current permit.
Potential pollutants for this site would be from aluminum chips on site and sand that is outside. The aluminum
chips are covered and have secondary containment but could be a stormwater problem with poor maintenance.
Al will be added to the analytical monitoring. Also, sand is stored outside so TSS will be added to the
monitoring.
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NCS000093
8. Qualitative Monitoring Notes: Visual monitoring was done at each of the six outfalls. Eleven events were
monitored from 4/25/01 to 4/28/06. Much of the reporting is the same with none for color, odor, suspended
solids, clear for clarity, and no for foam and oil sheen. Outfall 4 and 5 had some oil sheen.
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NCS000093
Revised Permit Recommendations: Analytical Monitoring:
1. Removing Methylene Chloride from the monitoring and adding Al and TSS.
2. pH has been added to the analytical monitoring requirements.
3. All analytical monitoring has been set to semi-annually during a representative storm event as defined in Part II
Section B. The'permittee must also document the total precipitation for each, event. If no discharge occurs
during the sampling period, the permittee must submit a monitoring report indicating "No Flow" within 30 days
of the end of the six-month sampling period. Additionally, samples must be taken a minimum of 60 days apart,
as specified in Table 2.
4. Benchmarks for analytical monitoring have been added to this draft permit. Exceedances of benchmark values
require the permittee to increase monitoring, increase management actions, increase record keeping, and/or
install stormwater Best Management Practices (BMPs) in a tiered program. If the sampling results are above a
benchmark value, or outside of the benchmark range, for any parameter at any outfall then the facility shall
follow the Tier 1 guidelines which require a facility inspection within two weeks and implementation of a
mitigation plan within two months. If during the term of this peirnit, the sampling results are above the
benchmark values, or outside of the benchmark range, for any specific parameter at a specific discharge outfall
two times in a row (consecutive), then the facility shall follow the Tier 2 guidelines which require a repetition of
the steps listed for Tier 1 and also immediately institute monthly monitoring for all parameters at every outfall
where a sampling result exceeded the benchmark value for two consecutive samples.
5. The permittee is required to collect all of the analytical and qualitative monitoring samples during representative
storm events as defined in Part H Section B. Qualitative monitoring is required regardless of representative
outfall status.
6. The permittee is responsible for all monitoring until the renewal permit is issued. See Footnote 1 of Tables 1, 4,
and 5.
7. The flow reporting requirement has been removed per DWQ revised strategy. (The total rainfall parameter is in
this permit, however.)
8. 'Vehicle maintenance monitoring has been revised to semi-annually in order to coincide with analytical and
qualitative monitoring.
Other Proposed Changes to the Previous Permit:
I . Additional guidance is provided about the Site Plan requirements. The site map must now identify if the
receiving stream is impaired and if it has a TMDL established. It must also describe potential pollutants in each
outfall. The map requirements are stated more explicitly. And, the site plan must contain a Iist of significant
spills that have occurred in the past three years and also must certify that the outfalls have been inspected to
ensure that they do not contain non-stormwater discharges. Additional information is provided in Part H Section
A.
2. Additional requirements for the Stormwater Management Plan have been specified in Part II Section A. More
details regarding secondary containment are provided.
3. Additional requirements for the Stormwater Pollution Prevention Plan have been specified in Part H Section A.
The plan must also be updated annually to include a list of significant spills and to certify that the outfalls do not
contain non-stormwater discharges.
4. The facility must now implement a semi-annual Facility Inspection Program of the site's stormwater
management controls as specified in Part II Section A.
5. Information regarding the No Exposure Exclusion has been added to this draft permit. If industrial materials and
activities are not exposed to precipitation or runoff as described in 40 CFR § 122.26(g), the facility may qualify
for a No Exposure Exclusion from NPDES stormwater discharge permit requirements. Additional information
is provided in Part I Section A.
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NCS000093
Discussions with permittee: Bernice Wilson, 828-766-1185 [e-mail], 10/10/08
1. General description of industrial activities? Aluminum Foundry primarily with some other small operations.
2. Have there been any changes since filing the application? No
3. What chemicals or materials are stored outside? Aluminum Chips under cover with secondary containment.
Used sand waiting to be hauled off.
4. What is the methylene chloride used for? Is it stored outside? No source ofinethylene chloride.
5. Do you have vehicle maintenance onsite? No, but there is some vehicle maintenance.
6. What is ,you SIC code? 3365
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Recommendations: Based on the documents reviewed, the application information submitted on October 26, 2006
sufficient to issue an Individual Stormwater Permit.
Prepared by (Signature) /�--~ Za Date t I r 31 a d
Stor:mwater Permitting Unit Supervisor � "(� Date � ? 1Q
for Bradley B nnett
Concurrence by Regional Office Date
Regional Water Quality Supervisor Date
Regional Office Staff Comments
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NCS000093
Recommendations: Based on the documents reviewed, the application information submitted on October 26, 2006
sufficient to issue an Individual Stormwater Permit.
Prepared by (Signature) Date to lag
Stormwater Permitting Unit Supervisor D Date AiLo -0
fof• B Adley B rCiett
Concurrence by Regional Office Date / Fk
�
Regional Water Quality Supervisor t Date 1 / r'
Regional Office Staff Comments
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