NCS000386_Review Document_20180806

NC Division of Energy, Mineral and Land Resources
Review of Permit Renewal — NCS000386
Rohm and Hass Chemicals, LLC
August 6, 2018
• SIC 2821— Chemical Manufacturing — Bulk latex polymer manufacturer. Finished product — water based acrylic
polymers. Majority ends up being used in paints.
• Monitoring — The facility has been monitoring for TSS, BOD, Zn and pH. Previous permit did have tier system.
o Reviewed data from 2010 through 2018. Facility had continual exceedance of Zn benchmark and sampled
monthly for this at one outfall. Was only sampling for that parameter instead of for all.
o Don't appear to be any exceedances of BOD or pH at either outfall. BOD removed from draft. pH
maintained as a baseline parameter.
o Only a couple of exceedances of TSS benchmark at the 001 outfall. Maintain TSS.
o Zn — exceeded 8 times from 2010 to 2013 but not since then at outfall 001. Zn exceeded at most sampling
events at outfall 002. See discussion below.
o Parameters remaining in the permit — TSS, Zn and pH.
o Tier structure adjusted to have the three levels as in current permits.
o Parameter codes added to permit.
• Discussed site issues with facility contact —Jamie Watts (6/4/18).
This is an acrylic emulsion facility. Finished product is a water based acrylic polymer. Looks like white paint. 75% of
what is in paint is this product. A few hazardous materials in their raw materials, but not final product. Three
reaction train converts to final polymer material that is not a toxic or flammable material.
Facility overview — Facility site plan shows five drainage areas and two outfalls. On the west side there is a high
point at the plant entrance. Flow splits from here and drainage around the side of the building around to visitor
parking flows to SDO#002 (Warehouse). Loading/unloading area is contained and pumped to wastewater. The
warehouse itself (roof) drains to a location that is routed to the wastewater system. Area with finished product is
diked and goes to wastewater. Number of areas under roof but with open walls have containment and are
evaluated and either released or pumped to wastewater. Stormwater flow goes to small pond near their
wastewater monitoring location. It is evaluated and if it hits all checks is pumped to the larger detention pond on
the east side of the facility. This pond has a gate valve and water is detained here, evaluated and released manually.
Mr. Watts indicated it takes significant rain amounts or multiple events before they release flow. Drainage areas I, II
and IV go through the pond system
Discussed the Zinc numbers with Mr. Watts. These issues have mainly been at Outfall 002 which only drains the
apron around the building. They have taken a number of steps to try and reduce the levels of Zn including
redirecting the warehouse roof drains. They feel the Zn results may be due to material from truck tires from truck
traffic into the loading/unloading area. There were a number of Zn benchmark exceedances at outfall 001 between
2009 and 2013. May be that the rerouting of the warehouse roof drain impacted these numbers? The Zn
benchmark has increased since the previous permit (from 0.067 to 0.125mg/L) so they might not hit the higher
benchmark as often.
• Facility drains to UT to Brier Creek in the Catawba River Basin, a class C stream. 2014 Assessment Report 11-137-8-2
shows no impairment of concern for this facility in this area. Statewide Hg listing, but this facility does not appear to
be potential source in these problems.
• NC National Heritage review — NHP report shows no aquatic resources of concern.
• MRO —Draft permit to Regional Office and Charlotte -Mecklenburg Stormwater Services on June 11, 2018. Site visit
on 6/26/2018, email from James that region is okay to issue — 6/28/2018. Inspection report included notes that
recommendations were made to the permitee from MRO/CMSWS for more monitoring and for die testing of inlets
to confirm where things drain — wastewater system, stormwater pond, etc. Add language about this to the cover
letter for the permit. MRO and CMSWS approved language for letter 8/6/2018.