NCG100000_DRAFT Fact Sheet_20180806

DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF ENERGY, MINERAL, AND LAND RESOURCES
FACT SHEET
GENERAL PERMIT NCG100000
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
PERMIT TO DISCHARGE STORMWATER
Permit No. NCG100000 Date: August 6, 2018
1. TYPES OF DISCHARGES COVERED
a. Industrial Activities Covered by this General Permit
Coverage under this general permit is applicable to all owners or operators of
stormwater point source discharges associated with activities classified as
establishments primarily engaged in activities classified as Used Motor Vehicle Parts
[Standard Industrial Classification (SIC) 5015] and Automobile Wrecking for Scrap (a
portion of SIC 5093). Coverage is also applicable to point source discharges from like
industrial activities deemed by the Division of Energy, Mineral, and Land Resources
(DEMLR) to be similar to these operations in the process, or the discharges, or the
exposure of raw materials, intermediate products, by-products, products, or waste
products.
Except when DEMLR deems activities or discharges to be similar as described above,
the following activities are excluded from coverage under this General Permit:
establishments primarily engaged in the wholesale trade of metal waste and scrap, iron
and steel scrap, and nonferrous metal scrap (hereafter referred to as the metal waste
recycling industry).
b. Types of Operations Covered
The Used Motor Vehicle Parts category includes facilities primarily engaged in the
distribution at wholesale or retail of used motor vehicle parts. This industry includes
establishments primarily engaged in dismantling motor vehicles for the purpose of
selling parts.
Activities which are conducted in the Used Motor Vehicle Parts category are probably
best described by the following:
Wholesale or retail distribution of used automobile engines
Wholesale or retail distribution of used automobile parts
Wholesale or retail distribution of used motor vehicle parts
The Automobile Wrecking for Scrap category includes facilities primarily engaged in
automobile dismantling for scrap metal.
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NCG100000 Fact Sheet - NC DENR
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Activities which are conducted in the Automobile Wrecking for Scrap category are
probably best described by the following:
. Wholesale automobile wrecking for scrap
According to the Environmental Protection Agency, dismantlers are a major source for
replacement parts for motor vehicles in service. Their primary activity involves the
dismantling or wrecking of used motor vehicles. Typically, automobile dismantling
facilities receive vehicles that are either uneconomical to run or wrecks that are
uneconomical to repair. The nature of operations generally depends on the size and
location of the facility. In urban areas where land is more valuable, vehicles are
typically dismantled upon arrival, parts are segregated, cleaned, and stored. Remaining
hulks are sold to scrap dealers rather than stored on site due to limited space. In more
rural areas, discarded vehicles are typically stored on the lot and parts removed as
necessary. Remaining hulks are sold to scrap dealers less frequently.
Once a used vehicle is brought to the site, fluids may be drained and the tires, gas tank,
radiator, engine and seats may be removed. The dismantler may separate and clean
parts. Such cleaning may include steam cleaning of the engine and transmission as well
as the use of solvents to remove oil and grease and other residues. Usable parts are
then inventoried and stored for resale. The remaining car and/or truck bodies are
stored on site for future sale of the sheet metal and glass. Stripped vehicles and parts
that have no resale value are typically crushed and sold to a steel scrapper. Some
operations may, however, convert used vehicles and parts into steel scrap as a
secondary operation. This is accomplished by incineration, shearing (bale shearer),
shredding, or baling.
Significant materials include automobile parts (e.g., engine blocks, mufflers, batteries),
solvents, oils, cleaning agents (e.g., detergents), used equipment, and junked
automobiles. In junkyards, the condition of materials and junked vehicles may
contribute to significant losses of fluids, which are sources of toxic metals, oil and
grease, etc. Weathering of plated and non -plated metal surfaces may result in
contributions of toxic metals to stormwater.
Because of the nature of the industrial activities at these facilities, pollutants of concern
include: oil and grease, ethylene glycol, heavy metals, petroleum hydrocarbons,
solvents, suspended solids, acid/alkaline wastes, detergents, phosphorus, and salts.
c. Characteristics of Discharged Stormwater
The renewal permit proposes the same parameters be regularly monitored in
stormwater discharges. However, in the 2012 renewal. Oil and Grease (0&G) was
replaced by Total Petroleum Hydrocarbons (TPH), or "Non -polar Oil and Grease."
The proposed parameters continue to be useful as stormwater pollution indicators for
this industrial sector.
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Non -polar Oil and Grease can be analyzed cost effectively with the same method used to
measure 0&G: EPA Method 1664 (SGT -HEM). The permit does not require the more
elaborate and typically more expensive TPH analysis with gas chromatography. The
basis of this change was that 0&G is composed of fatty matter from animal and
vegetable sources and hydrocarbons of petroleum origin. Because TPH targets the
family of chemical compounds that originally come from crude oil such as gasoline,
diesel, kerosene, etc., TPH is more suited for vehicle maintenance activities. A lower
benchmark also applies. Instead of the 30 mg/10&G benchmark, the TPH benchmark is
15 mg/1, which is consistent with other States' benchmarks and/or limits (see
Appendix A). We would only expect in discharges associated with significant oil
contamination to exceed this benchmark. DEMLR also found lab costs to be
comparable to 0&G analysis and reasoned the change would not pose a significant
burden on permittees (see Appendix B).
DEMLR reviewed data from these industrial permittees that submitted monitoring data
during the previous cycle of NCG100000 (see Appendix D). Over 100 facilities
submitted 435 samples that DEMLR could consider for general permit development.
See Appendix D for data analysis information, as well as Sections 3 and 6 of this fact
sheet for discussion and rationale in support of proposed monitoring.
d. GeographicArea(s) Covered by this General Permit
Discharges covered by this general permit are located at any place within the political
boundary of the State of North Carolina. Discharges located on the Cherokee Indian
Tribal Reservation are subject to permitting by the U.S. Environmental Protection
Agency and are not covered by this general permit.
e. Receiving Waters
Receiving waters include all surface waters of North Carolina or municipal separate
storm sewer systems conveying stormwater to surface waters.
2. PROPOSED DISCHARGE CONTROLS AND LIMITATIONS
Stormwater Discharges
The renewal permit incorporates benchmark concentrations for stormwater discharges to
provide facilities with a tool with which to assess the effectiveness of best management
practices (BMPs). These benchmark concentrations are not effluent limits, but provide
guidelines for the facility's Stormwater Pollution Prevention Plan (SPPP or Plan).
Exceedances of benchmark values require the permittee to increase monitoring, increase
management actions, increase record keeping, and/or install stormwater BMPs in a tiered
program. Four (4) benchmark exceedances trigger notification to the Regional Office and
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NCG100000 Fact Sheet - NC DENR
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may prompt additional requirements ("Tier 3"). This general permit first incorporated
stormwater benchmarks and tiered responses in the 2007 renewal.
Some parts of the Stormwater Pollution Prevention Plan (SPPP or Plan) have been
expanded or modified. The draft permit also integrates the Solvent Management Plan,
which a facility may elect to implement in lieu of monitoring total toxic organics (TTO), into
the SPPP components:
10. Solvent Management Plan. Facilities that implement a Solvent Management Plan may so
certify, and the requirement for Total Toxic Organics (TTO) monitoring in Part II, Section B.
may be waived. The Solvent Management Plan shall include:
(a) an annually updated and quantified inventory of the total toxic organic compounds
present on site during the previous three years;
(b) a narrative description of the in -plant locations and uses of the toxic organic
compounds, the method of disposal including quantities disposed on- and off-site;
(c) the management procedures and engineering measures for assuring that toxic
organics do not spill or leak into stormwater.
DEMLR may at its discretion require submittal, review, and approval of the Solvent
Management Plan as a condition of continuing the TTO sampling waiver. For those facilities
electing to employ the TTO sampling waiver, the permittee shall include the following signed
certification statement on each discharge monitoring report: 'Based upon my inquiry of the
person or persons directly responsible for managing compliance with the permit monitoring
requirement for total toxic organics (TTO), I certify that to the best of my knowledge and belief, no
leak, spill, or dumping of concentrated toxic organics into the stormwater or onto areas which are
exposed to rainfall or stormwater runoff has occurred since filing the last discharge monitoring
report. 1 further certify that this facility is implementing all the provisions of the Solvent
Management Plan included in the Stormwater Pollution Prevention Plan."
For the remaining proposed requirements of the SPPP, please refer to the proposed draft
General Permit NCG100000.
3. MONITORING AND REPORTING REQUIREMENTS
This permit specifies monitoring and reporting requirements for both quantitative and
qualitative assessment of the stormwater discharge and operational inspections of the
entire facility. Specific pollutant parameters for which sampling must be performed and
the frequency of the sampling are based on the types of materials used, stored, and
transferred at these sites, and on the potential for contamination of the stormwater runoff
from these facilities.
The draft renewal permit proposes specific monitoring requirements for the following
parameters for stormwater discharges: Total Rainfall, pH, Total Petroleum
Hydrocarbons (TPH) [EPA Method 1664 (SGT -HEM), also called "Non -polar Oil &
Grease"], Total Suspended Solids (TSS), Ethylene Glycol, Lead, Copper, Zinc, and Total
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NCG100000 Fact Sheet - NC DENR September 1, 2012
Toxic Organics (TTO)—unless the facility is waived from TTO monitoring through a
Solvent Management Plan. The only change in the suite of parameters is that TPH replaces
0&G. The rationale for retaining these parameters in the renewal permit was based in part
on data submitted by permittees, but also on their utility as stormwater pollution
indicators for these industry types.
The draft permit incorporates a modified definition of what storm event should be
sampled. Previous permits required sampling during a "representative storm event." The
proposed NCG100000 permit renewal now requires permittees to sample the
"measurable storm event," a new term for North Carolina stormwater permits. The
"measurable storm event" is an event that results in an actual discharge, rather than an
event with a rainfall measuring 0.1 inches or more. To qualify as a measurable storm
event, the previous storm event must have been at least 72 hours prior. Last year the
NCG140000 Ready -Mixed Concrete General Permit was the first permit to implement this
new storm event definition.
The proposed general permit allows the permittee to forgo sampling if adverse weather
conditions prevent sample collection (see the Definitions section of the draft permit).
Inability to sample because of adverse weather conditions must be documented in the SPPP
and recorded on the data monitoring forms (DMRs). The proposed draft maintains the
requirement to separate semi-annual sampling events by a minimum of 60 days.
As before, the renewal permit specifies qualitative (visual) monitoring of each stormwater
outfall for the purpose of evaluating the effectiveness of the Stormwater Pollution
Prevention Plan and assessing new sources of stormwater pollution. Qualitative
monitoring parameters include color, odor, clarity, floating and suspended solids, foam, oil
sheen, and other obvious indicators of stormwater pollution. Qualitative monitoring
should be performed during the analytic sampling event.
The draft permit proposes more specific direction to the permittee about how to respond
to qualitative monitoring. If qualitative monitoring indicates that existing stormwater
BMPs are ineffective, or that significant stormwater contamination is present, the
permittee must investigate potential causes, evaluate the feasibility of corrective actions,
and implement those corrective actions within 60 days. A written record of the permittee's
investigation, evaluation, and response actions must be kept in the SPPP. The draft permit
also includes a Qualitative Monitoring Response, establishing actions for when a
permittee repeatedly fails to respond effectively to correct problems, or if the discharge
causes or contributes to a water quality standard violation.
4. COMPLIANCE SCHEDULE
The proposed compliance schedule in Part III, Section A was modified to address facilities
that are renewing coverage under this new permit. The permittee shall comply with
Limitations and Controls specified for stormwater discharges in accordance with the
following schedule:
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Existing Facilities already operating but applying for permit coverage for the first time: The
Stormwater Pollution Prevention Plan shall be developed and implemented within 12 months of the
effective date of the Certificate of Coverage and updated thereafter on an annual basis. Secondary
containment, as specified in Part II, Section A, Paragraph 2(b) of this general permit, shall be
accomplished within 12 months of the effective date of the issuance of the Certificate of Coverage.
New Facilities applying for coverage for the first time: The Stormwater Pollution Prevention Plan
shall be developed and implemented prior to the beginning of discharges from the operation of the
industrial activity and be updated thereafter on an annual basis. Secondary containment, as specified
in Part II, Section A, Paragraph 2(b) of this general permit shall be accomplished prior to the
beginning of discharges from the operation of the industrial activity.
Existing facilities previously permitted and applying for renewal under this General Permit:
All requirements, conditions, limitations, and controls contained in this permit (except new SPPP
elements in this permit renewal) shall become effective immediately upon issuance of the Certificate
of Coverage. New elements of the Stormwater Pollution Prevention Plan for this permit renewal
shall be developed and implemented within 6 months of the effective date of this general permit and
updated thereafter on an annual basis. Secondary containment, as specified in Part III, Paragraph
2(b) of this general permit shall be accomplished prior to the beginning of discharges from the
operation of the industrial activity.
5. SPECIAL CONDITIONS WHICH WILL HAVE A SIGNIFICANT IMPACT ON THE
DISCHARGE
If a facility that is required to perform the total toxic organics (TTO) monitoring develops a
solvent management plan and makes the certification detailed in the permit, the facility
may not be required to perform TTO monitoring.
In addition, the proposed draft does add Special Conditions in Part II, Section D. that
address electronic reporting requirements mandated by the federal NPDES Electronic
Reporting Rule. When the agency's electronic reporting system is able to accept NPDES
stormwater permit monitoring data, the permittee must report discharge monitoring data
electronically using NC Division of Water Resources' Electronic Discharge Monitoring
Report (eDMR) internet application. NC DEMLR will notify permittees when eDMR is ready
to accept data.
6. BASIS FOR CONTROLS AND LIMITATIONS
Stormwater Discharges
The conditions of this general permit has been designed using best professional judgment
to achieve water quality protection through compliance with the technology-based
standards of the Clean Water Act (Best Available Technology [BAT] and Best Conventional
Pollutant Control Technology [BCT]). Where the Director determines that a water quality
violation is occurring and water quality -based controls or effluent limitations are required
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to protect the receiving waters, coverage under the general permit shall be terminated and
an individual permit will be required. Based on a consideration of the appropriate factors
for BAT and BCT requirements, and a consideration of the factors discussed below in this
fact sheet for controlling pollutants in stormwater discharges associated with the activities
as described in Item 1 (Types of Discharge Covered), this permit retains a set of
requirements for developing and implementing stormwater pollution prevention plans,
and specific requirements for monitoring and reporting on stormwater discharges.
The permit conditions reflect the Environmental Protection Agency's (EPA) and North
Carolina's pollution prevention approach to stormwater permitting. The quality of the
stormwater discharge associated with an industrial activity will depend on the availability
of pollutant sources. This renewal permit still reflects the Division's position that
implementation of Best Management Practices (BMPs) and traditional stormwater
management practices which control the source of pollutants meets the definition of BAT
and BCT. The permit conditions are not numeric effluent limitations, but rather are
designed to be flexible requirements for developing and implementing site specific plans to
minimize and control pollutants in the stormwater discharges associated with the
industrial activity.
Title 40 Code of Federal Regulations (CFR) Part 122.44(k)(2) authorizes the use of BMPs in
lieu of numeric effluent limitations in NPDES permits when the agency finds numeric
effluent limitations to be infeasible. The agency may also impose BMP requirements which
are "reasonably necessary" to carry out the purposes of the Act under the authority of 40
CFR 122.44(k)(3). The conditions of the renewal permit are retained under the authority
of both of these regulatory provisions. The pollution prevention requirements (BMP
requirements) in this permit operate as limitations on effluent discharges that reflect the
application of BAT/BCT. The basis is that the BMPs identified require the use of source
control technologies which, in the context of these general permits, are the best available of
the technologies economically achievable (or the equivalent BCT finding).
All facilities covered by this General Permit must prepare, retain, implement, and (at a
minimum of annually) update a Stormwater Pollution Prevention Plan (SPPP). The term
"pollution prevention" distinguishes this source reduction approach from traditional
pollution control measures that typically rely on end -of -pipe treatment to remove
pollutants in the discharges. The plan requirements are based primarily on traditional
stormwater management, pollution prevention and BMP concepts, providing a flexible
basis for developing site-specific measures to minimize and control the amounts of
pollutants that would otherwise contaminate the stormwater runoff.
The pollution prevention approach adopted in the SPPP in this renewal permit still focuses
on two major objectives: 1) to identify sources of pollution potentially affecting the quality
of stormwater discharges associated with industrial activity from the facility; and 2) to
describe and ensure that practices are implemented to minimize and control pollutants in
stormwater discharges associated with industrial activity from the facility and to ensure
compliance with the terms and conditions of the permit.
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NCG100000 Fact Sheet - NC DENR September 1, 2012
The Division believes that it is not appropriate, at this time, to require a single set of
effluent limitations or a single design or operational standard for all facilities which
discharge stormwater associated with industrial activity. This permit instead establishes a
framework for the development and implementation of site-specific stormwater pollution
prevention plans. This framework provides the necessary flexibility to address the variable
risk for pollutants in stormwater discharges associated with the industrial activities that
are addressed by this permit, while ensuring procedures to prevent stormwater pollution
at a given facility are appropriate given the processes employed, engineering aspects,
functions, costs of controls, location, and age of facility (as discussed in 40 CFR 125.3). This
approach allows flexibility to establish controls which can appropriately address different
sources of pollutants at different facilities.
The EPA and NPDES States have, on a case-by-case basis, imposed BMP requirements in
NPDES permits. The EPA has also continued to review and evaluate case studies involving
the use of BMPs and the use of pollution prevention measures associated with spill
prevention and containment measures for oil. The development of the NPDES permit
application requirements for stormwater discharges associated with industrial activity
resulted from the evaluation and identification of the potential contaminants and the
resultant water quality impacts of stormwater discharges from industrial sites. Public
comments received during the rule making provided additional insight regarding
stormwater risk assessment, as well as appropriate pollution prevention and control
measures and strategies. During that time EPA again reviewed stormwater control
practices and measures. These experiences have shown the Division that pollution
prevention measures such as BMPs can be appropriately used and that permits containing
BMP requirements can effectively reduce pollutant discharges in a cost-effective manner.
BMP requirements are imposed in general permits in lieu of numeric effluent limitations
pursuant to 40 CFR 122.44(k)(2).
There has been no significant change to this rationale since the previous General
Permit NCG100000.
Stormwater Benchmarks
The proposed pH benchmark range is based on N.C. Water Quality Standards in 15A NCAC
0213 .0211 and is consistent with other renewed general stormwater permits. The TPH
benchmark of 15 mg/l is consistent with other States' benchmarks and/or limits and
reflects a value we would associate only with significant oil contamination. See Appendix
A for more information on TPH.
The standard total suspended solids (TSS) benchmark of 100 mg/l is based on the
median concentration derived from the National Urban Runoff Program (NURP) study in
1983 and serves as a benchmark in most other industrial stormwater permits with TSS
monitoring. The lower TSS benchmark for ORW, HQW, trout, and primary nursery area
(PNA) waters of 50 mg/l reflects half that standard value and was set to flag potential
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NCG100000 Fact Sheet - NC DENR
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problems in discharges to waters with much lower water quality standards for TSS
concentrations (20 mg/1 for HQW and ORW; 10 mg/1 for trout and PNA waters).
In January 2012, the ethylene glycol benchmark was revised based on more recent
freshwater aquatic life data. The new value of 8,000 mg/1 is based on half the Final Acute
Value (1/2 FAV), a threshold that protects against impacts from short-term exposure. Only
one out of the more than 400 samples reported since 2007 for this group of permittees
exceeded 8,000 mg/l. Less than 15 percent of reported samples were a quantifiable level,
and of those, only four samples were over 200 mg/1. Therefore, the draft permit proposes
that "any amount detected" serve as the trigger for Tier One responses, but that Tier Two
and Tier Three actions are not prompted until levels exceed 8,000 mg/l. Because this fluid
is present in automobiles, the draft permit retains monitoring for ethylene glycol.
The benchmark for Lead (Pb) remains 0.030 mg/1 (or 30 µg/1). This value is the 1/2 FAV for
lead, based on current DEMLR calculation methodology for total recoverable lead. North
Carolina is proposing changes to water quality (WQ) metals standards that will establish
dissolved metals standards for the first time. If those WQ standards are finalized, acute
values for total recoverable metals will change as a result of a revised translation method
(for translating a dissolved value to a total recoverable value, which federal NPDES
regulations require to be used in a permit) and a different assumed water hardness.
However, the proposed metals standards will not be finalized for some time. Because those
changes are not final, DEMLR is not proposing a new stormwater benchmark for lead at
this time. DEMLR also notes that EPA's NDPES Stormwater Multi -Sector General Permit
(applies in states with no delegated program) imposes a lead benchmark for Automobile
Salvage Yards that is hardness dependent and ranges from 0.023 mg/1 (25-50 mg/1
hardness) to 0.045 mg/1 (50-75 mg/1 hardness). The 0.030 mg/1 benchmark falls within
that range; a lower hardness assumption would mean a more stringent lead benchmark for
facilities under EPA's MSGP.
The draft general permit retains lead monitoring because of its presence in the metal scrap
on these industrial sites. Also, 35 percent of all reported lead samples for NCG100000
since 2007 (241 samples) were above 0.030 mg/l, and over 20 percent of all samples were
above 0.075 mg/l. There were 39 samples reported above 0.100 mg/1 (see Appendix D).
These numbers suggest that the majority of facilities permitted under NCG100000 are able
to meet the current lead benchmark.
Total toxic organics (TTO) is a parameter representing the sum total of multiple organic
compounds (depending on the industry). The same benchmark from the current permit,
1.0 mg/l, is proposed. Please refer to Appendix C for an explanation of the TTO
benchmark and footnote development for this permit.
The TPH [EPA Method 1664 (SGT -HEM)] benchmark of 15.0 mg/1 is discussed earlier in
Section 1 c. of this fact sheet.
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NCG100000 Fact Sheet - NC DENR September 1, 2012
7. REQUESTED VARIANCES OR ALTERNATIVES TO REQUIRED STANDARDS
There are no requested variances or alternatives to required standards. Facilities
requesting variances to required standards will not be covered under this General Permit
but will instead be required to seek coverage under an individual permit.
8. THE ADMINISTRATIVE RECORD
The administrative record, including application, draft permits, fact sheet, public notice,
comments received, and additional information is available by writing to:
Stormwater Program
Division of Energy, Mineral, and Land Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
The above documents are available for review and copying at:
Archdale Building, 9th Floor
DEMLR Stormwater Program
512 N. Salisbury Street
Raleigh, North Carolina
between the hours of 8:00 AM and 5:00 PM Monday through Friday. Copies will be
provided at a charge of 10 cents per page.
9. STATE CONTACT
Additional information about the draft permit may be obtained at the above address
between the hours of 8:00 AM and 5:00 PM Monday through Friday by contacting:
Annette Lucas at [phone].
10. SCHEDULE OF PERMIT ISSUANCE
Draft Permit Public Notice - Statewide Notice to publish September 4, 2018;
Draft available on-line by September 4, 2018;
Comment Period Ends October 5, 2018
Permit Scheduled to Issue - October 15, 2018;
Effective November 1, 2018
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NCG100000 Fact Sheet - NC DENR September 1, 2012
11. PROCEDURE FOR THE FORMULATION OF FINAL DETERMINATIONS
a. Comment Period
The Division of Energy, Mineral, and Land Resources proposes to issue an NPDES
General Permit for the above described stormwater discharges subject to the outlined
effluent limitations, management practices, and special conditions. These
determinations are open to comment from the public.
Interested persons are invited to submit written comments on the permit applications
or on the Division of Energy, Mineral, and Land Resources' proposed determinations to
the following address:
Stormwater Program
Division of Energy, Mineral, and Land Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Attn: Annette Lucas
All comments received within thirty days following the date of public notice are
considered in the formulation of final determinations.
b. Public Meeting
The Director of the Division of Energy, Mineral, and Land Resources may hold a public
meeting if there is a significant degree of public interest in a proposed permit or group
of permits. Public notice of such a meeting will be circulated in newspapers in the
geographical area of the discharge and to those on the Division of Energy, Mineral, and
Land Resources mailing list at least thirty days prior to the meeting.
c. Appeal Hearing
An applicant whose permit is denied, or is granted subject to conditions he deems
unacceptable, shall have the right to a hearing before the Commission upon making
written demand to the Office of Administrative Hearing within 30 days following
issuance or denial of the permit.
d. Issuance of a Permit When no Hearing is Held
If no public meeting or appeal hearing is held, after review of the comments received,
and if the Division of Energy, Mineral, and Land Resources determinations are
substantially unchanged, the permit will be issued and become effective on the first day
of the month following the issuance date. This will be the final action of the Division of
Energy, Mineral, and Land Resources.
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If a public meeting or appeal hearing is not held, but there have been substantial
changes, public notice of the Division of Energy, Mineral, and Land Resources revised
determinations will be made. Following a 30 -day comment period, the permit will be
issued and will become effective on the first day of the month following the issuance
date. This will be the final action of the Division of Energy, Mineral, and Land Resources
unless a public meeting or appeal hearing is granted.
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NCG100000 Fact Sheet - NC DENR September 1, 2012
APPENDIX A
Comparison of Other States' TPH Stormwater Benchmarks and/or Limits:
Page 13 of 16
Benchmark, Limit,
Agency
Media
Criteria, etc
Value mg/L)
Notes
CT
grountlwater
protection cnlena
0.5
EPA Method 418.1
NV
groundwater
discharge limit
1.0
Technology-based limit
VA
groundwater
reporting limit
1.0
Virginia Petroleum Storage Tank Program
KS
groundwater
cleanup standard
0.5
Risk-based standard
TX
groundwater
MCL
1.1
Maximum Contaminant Leel
OK
groundwater
MCL
3.0
May require cleanup down to 0.1 mg/L if near well
Ta.oma, WA
stormwater
performance goal
10.0
24 -hr average
Tacoma, WA
stormwater
performance goal
15.0
Grab sample
Port of Seattle NPDES permit technology-based limit for construction
areas; 5.0 mg/L typically used for all construction sites in state; plus no
WA
stormwater
ax daily limit
5.0
tisible sheen non -numerical limit.
WA
stomiwaler
max daily limit
8.0
Port of Seattle NPDES permit for deicing areas _
WA
stoimwater
max daily limit
15.0
Port of Seattle NPDES permit for roadways
24 -hr average, EPA Method 1664A, NJPDES NJO132721 (hot -mix asphalt
NJ
stornwater
mo. Ave. limit
10.0
plants)
Grab sample, EPA Method 1664A, NJPDES NJO132721 (hot -mix asphalt
NJ
stor_mater
max daily limit
15.0
plants)
Grab sample, TPDES permit TXG340000 (petroleum bulk stations and
TX
I stormwater
max daily limit
15.0
terminals)
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NCG100000 Fact Sheet - NC DENR
APPENDIX B
Comparison of TPH Analysis Costs vs. 0&G Analysis:
Notes:
HEM = n -hexane extractable material
SGT -HEM = silica gel treated n -hexane extractable material
GRO = gasoline range organics
DRO = diesel range organics
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September 1, 2012
O&G/HEM
TPH as SGT -HEM
TPH-GRO
TPH-DRO
LABORATORY
EPA 1664A
SW -846 EPA
8015B
EmAronmental Chemists Inc.
$50
$50
$50
$50
Pace Analytical Services, Inc.
$50
$60
$40
$40
Microbac Laboratories, Inc.
$55
$55
na
na
Cameron Testing Services
S45
$60
$43
$43
Endronmental Conse-tion Laboratories, Inc.
$75
$75
$40
$45
Water Tech Labs, Inc.
$50
na
$60
$60
DWQ Lab
$34
na
$87
$87
Mertech, Inc.
$45
$68
$50
$50
Charotte-Mecklenburg Utilities Laboratory
$30
$43
na
na
Avg(TPH-GRO+TPH-DRO)
cost to capture full range
of TPH
Average Cost
$48
$59
$53
$54
$106
Notes:
HEM = n -hexane extractable material
SGT -HEM = silica gel treated n -hexane extractable material
GRO = gasoline range organics
DRO = diesel range organics
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NCG100000 Fact Sheet - NC DENR September 1, 2012
APPENDIX C
NPDES Stormwater General Permits NCG030000 and NCGl00000
Total Toxic Organics (TTO) Benchmark Development
No changes proposed to 2007 basis for TTO benchmark
1. Reference: Subchapter N - Effluent Guidelines and Standards, 40CFR433.10ff, Part 433 - Metal
Finishing Point Source Category. Forty-six types of metal finishing operations are listed,
appearing to be a comprehensive list of the types of activities that might be labeled, 'metal
finishing.'
a. Subpart A presents wastewater and pretreatment effluent limitations in 433.13, 433.14,
433.15, 433.16, and 433.17 for BPT, BAT, PSES, NSPS, and PSNS respectively. These
paragraphs uniformly present a TTO effluent limitation of 2.13 mg/L maximum for any one
day. No monthly average effluent limitation is established.
b. TTO for the metal finishing category includes 111 toxic organics, including solvents,
chlorinated hydrocarbons, pesticides, PCBs, and dioxin. The reportable value for the TTO
analysis is the sum of all concentrations for the 111 analytes greater than 0.01 mg/L.
c. Paragraph 433.12(a) provides that in lieu of TTO monitoring the permitting authority may
allow the permittee to certify on each DMR that there has been no dumping of
concentrated TTO into the wastewater stream.
d. Further, 433.12(a) provides that if TTO monitoring is required, the permittee may'analyze
for only those pollutants that would reasonably be expected to be present.'
e. Paragraph 433.12(b) provides that if the permittee selects the certification alternative to
TTO monitoring, he must submit a solvent management plan to the permitting authority's
satisfaction, and that the plan shall be incorporated as a part of the permit.
2. DEMLR had established stormwater benchmark values for sixteen of the 111 toxic organics:
benchmark values of 0 ug/L for dioxin and for the 7 PCBs; anthracene - 0.005 mg/L;
pentachlorophenol - 0.019 mg/L; toluene - 0.055 mg/L and 0.0018 mg/L in trout waters; 1.0
mg/L for 2,4 -dimethylphenol and for naphthalene; acrylonitrile - 3.8 mg/L; phenol - 4.5 mg/L
in trout waters; and benzene - 6.7 mg/L.
The current draft permit provides as follows:
a. The permittee may elect to develop a solvent management plan and incorporate it in his
SPPP. All in imitation of the federal effluent guidelines for wastewater and pretreatment
discharges. Consistent with the previous version of the permit.
b. DEMLR is willing to work with the permittee on alternate analyses and/or benchmarks to
satisfy the TTO monitoring requirement (See Table 3 in Part II, Section B that notes TTO
contains multiple compounds with varying environmental impact). This provision is
parallel to, but not identical to, the federal provision establishing that wastewater
permittees need only analyze for the pollutants reasonably expected to be present.
c. The benchmark is set at 1.0 mg/L. This is not a limit value in the sense that an
exceedence constitutes a permit violation. This is more like an action level value. DEMLR
has benchmark values set for only a very small portion of the TTO suite. A value of 1.0
mg/L corresponds to our benchmarks for naphthalene and 2,4 -dimethylphenol. Three
benchmark values are above 1.0 mg/L, and 11 benchmark values are below 1.0 mg/L.
d. DEMLR may evaluate analysis results and determine if any chemicals are present at levels
of concern, even if below 1.0 mg/1, and require appropriate actions.
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NCG100000 Fact Sheet - NC DENR September 1, 2012
APPENDIX D
Data Analysis
Table 1: Data Reporting Summary 2007-2012
Sample Data from NCG100000 Permittees, 2007 -August 2012
Number of Facilities Reporting: 111
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TSS
Lead
O&G TTO** Ethylene Glycol
(mg/1)
pH (mg/1)
(mg/1) (mg/1) (mg/1)
Total no. samples reported
369
322 241
82 13 64
MAXIMUM
3100
10.5 102
243 624 14,900
MINIMUM
0
1 0
0 0 0
GEOMEAN
*
7.0
AVERAGE
135
1.401
11 50 257
Benchmark in 2007 Permit
100
6-9 0.030
30 1 14
No. samples over benchmark
108
pH>9:
6 84
5 2 13
pH<6:
30
Lead and ethylene glycol:
LPbd
Ethylene Glycol (EG)
>8,000 mg/1, revised EG benchmark for
Percent samples over benchmark
35%
No. samples -> 1
2012
No. samples -> 4
>200 mg/1
No. Pb samples above 75 ug/1
50
>75 ug/1
No. samples -> 57
>0 mg/1
No. Pb samples above 100 ug/1
39
>100 ug/1
30
No. of blanks in data set
405
Total reported samples (435 - blanks)
Note: majority of EG samples reported "<10 mg/1" or "ND"
*Geometric mean could not be calculated because
of several
entries below quantitation level.
**Several facilities do not monitor
TTO because they employ a Solvent Management Plan.
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