NCS000037_Compliance_20091103

NCS00003"7
Recommendations. Dased on the documents i eviewed, lie application information submitted on October 29, 2007
sufficient to issue an Individual SStormw*ater Permit.
Pr . area b (Signature.) / � ' Date 1 1
Stormwater Permitting Unit Sup sMfi-Be!nnett
'� Date 0`
Concurrence by Regional Office' Date
RO Water Quality Supervisor t Date t' 0
Regional Office Staff' Comments (attach additional pages as necessary,)
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Page 6 of 6
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h1 CS000037
Beverly Faves Perdue, Governor
Dee Freeman, 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:
Clariant Corporation, Mount Holly East Facility
NPDES Permit Number:
NCS000037
Facility Location:
11701 Mount Holly Rd., Charlotte, NC (Mecklenburg County)
Type of Activity:
organic chemical manufacturing (previous)
SIC Code:
2865 (previous)
Rectiving Slieauts.
Long Creek & Catawba River, See Figure 1
River Basin:
Catawba River Basin, Sub -basin 03-08-34 & 03-08-33
Stream Classification:
WS-IV; CA
Proposed Permit Requirements:
See attached draft permit.
Monitoring Data:
See attached renewal application
Response Requested by (Date):
February 27, 2009
Central Office Staff Contact:
Return to: Robert Patterson, [phone]
Special Issues:
Issue
Rating Scale: 1(easy) to 10 hard
Compliance history
1
Benchmark exceedance
4
location (TMD1., T&F,
species, etc)
5
Other Challenges:
10
Difficulty Rating:-20/40
Special I.vsues Explanation:
• Owner and two lessees have vat ious activities on this site. Large portion of the site drains to an onsiite
WWTP.
Description of Onsite Activities:
• Clariant leases space to two companies. Both areas drain to the onsite WWTP. There is a WW sludge
landfill associated with the WWTP that is within the stormwater area. One lessee is a waste management
company, the other regenerates catalyst modules for pollution control systems used at power plants.
Documents Reviewed:
• NPDES Stormwater Permit Application Materials
• National Heritage Program (NHP) Threatened and Endangered Species Database
• SPU File
• Central Files, 2003, 2006-2008
• EPA Sector -Specific Permit, 2008
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NCS000037
• 303(d) List, 2006 final
• 2004 Catawba Dasinwide Plan
History:
• Date permit first issued: August 31, 1994
• Date permit reissued to resolve adjudication: January 11, 1995
• Date permit modification (name changed from Sandoz Chemicals Corp. to Clariant Corp.): September 22,
1995
• Date permit modification (revised permit cover due to omission of receiving stream and incorrect expiration
date): March 21, 1996
• Date permit re -issued: May 12, 2003
• Date permittee submitted renewal application: October 29, 2007
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SCk00037
Figure 1: Map of Facility
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Clarjant Corporation
MOLInt Holly East (MHE) Facility
Latitude: 350 17' 46" N-
Longitude: 80" 59'55" W
Counbl: Nfecklenbui-g
Receiving Stream: Long Creek & Catawba River
Strearn Class, WS-IV; CA
Sub -Basin: 03-08-34 & 03-0&-33 (Catawba River Basin)
Facility Location
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NCS000037
Central Office Review Suinnimy:
Owner's Other Permits:
• RCRA - NCD001810365
• WW - NC0004375
2. General Observations:
• A large portion of the site stormwater drains directly to the WWTP. Most of the current activities drain
to the WWTP and not to the SDOs.
• There are 13 stormwater outfalls.
Part of the site drains to the Catawba River, and part to Long Creek.
3. Impairment: Neither receiving water is listed on the 303(d) list. The Long Creek stream segment that this
facility discharges to is impaired for turbidity. There is a TMDL for turbidity for this segment of Long Creek.
This segment of the Catawba River is not rated.
4. Threatened and Endangered: No federal T&E species.
Industilal Changeds Shico Pievious Poiniit: Significaut changes have occurred at [he facility. The previous
organic chemical activities by Clariant have stopped. The facility is now leased to two other companies.
Numerous buildings on the site have been demolished, soil pile removed, and inost of [lie equipment in the
Salvage Yard has been removed. The 350 gallon diesel tank NE of Bldg 37 has been removed. Most of the
current activities drain to the WWTP and not to the SDOs. See the Hart & Hickman letter dated October 26,
2007 in the renewal package for all details.
6. Analytical Monitoring Notes: Sampling was performed annually at each of the 13 SDOs as per the previous
permit term. There were a total of 3 results over the current benchmark for COD that occurred at SDO 1 and
3D. There were a total of 10 results over the current benchmark for TSS A handfid of those ranged from 2 to
27 times the benchmark value. This is important since there is a TMDL for turbidity in Long Creek. There were
no detections of phenols; removing from monitoring. - or s /A1 LG.K, cetA NT`{ H4vr, /W'f D1 T14 J DR2
"i 5 S I-n?
The results from sampling done in 1995, 1996, 1997, and 2004 were similar to the more recent results.
7. Qualitative Monitoring Notes: Monitoring was to be performed twice per year. The permittee stated that results
for fall 2004 and spring 2005 could not be located. Color ranged from none to brown. Clarity ranged from clear
to muddy. A little foam was noted a few times. A very slight oil sheen was noted office at SDO 3D.
Revised Permit Recommendations: Analytical Monitoring:
1. Remove Phenols; keep TSS and COD.
2. pll has been added to the analytical inonitoiing iequiiements.
3. All analytical monitoring has been set to semi-annually during a representative storm event as defined in Part II
Section 13. The permittee must also document [lie 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 permit, 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 f6r all parameters at every outfall
wheie a samplhig result exceeded the benchmark value for two consecutive samples.
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NCS000037
5. The permittee is required to collect all of the analytical and qualitative monitoring samples during representative
storm events as defined in Part II 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:
1. 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 list of significant
spills that have occurred in the past three years and also must certify that the outfalls have been inspected to
eiisuie that they do iiot contain non-stounwatet discharges. Additional hifounation is hiovided hi Pail 11 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 II 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. Lifoiination iegaiding 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.
Discussions with permittee: Bill Archer, 704-822-2702, 1/21/09
1. Q: What do the two leasees do? SIC codes?
a. ANSWER: One is a waste management company that cleans out ww tanks and treats waste in the onsite
v,twtp. Almost all of the activities of these companies are in the area that drains to the wwtp. There are
2 builds being used by one company that they use for indoor storage and lab space. Mr. Archer is gohig
to liy acid feud out the SIC codes foi the two lessees.
2. Q: What "was" in the empty trailers kept in the storage area?
a. ANSWER: they've been moved now to an area that drains to the wwtp.
3. Q: Has the rest of the site been "cleaned up" from Clariant's previous activities?
a. ANSWER: For the most part. The main exception is the area around the landfill.
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NCS000037
Recommendations: Based on the documents reviewed, the application information submitted on October 29, 2007
sufficient to issue an Individual Stormwater Permit.
Prepared by (Signature) v' Date 1 21
Stormwater Permitting Unit SuperV�sor €�? _ / 'W i Date ' �j
�-� V -
for Bradley Bennett
Concurrence by Regional Office Date
RO Water Quality Supervisor Date
Regional Office Staff Comments (attach additional pages as necessary)
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