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HomeMy WebLinkAboutNCS000332_Email_20191011Garcia, Lauren V From: McDaniel, Jeffrey <jeffrey.mcdaniel@hexion.com> Sent: Friday, October 11, 2019 5:06 PM To: Garcia, Lauren V Subject: Re: [External] RE: [External]NCS000332 NPDES Stormwater Permit Renewal External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to reOMrt.spam@nc.gov Thanks Lauren. Have a good weekend. Get Outlook for Android From: Garcia, Lauren V <lauren.garcia@ncdenr.gov> Sent: Friday, October 11, 2019 2:22:36 PM To: McDaniel, Jeffrey <jeffrey.mcdaniel@hexion.com> Cc: kdrennan@trccompanies.com <kdrennan@trccompanies.com> Subject: RE: [External] RE: [External]NCS000332 NPDES Stormwater Permit Renewal This message is from an EXTERNAL SENDER - be CAUTIOUS, particularly with links and attachments. Hi Jeff! That is correct. Our supervisor wanted the new monitoring schedule to match up with the facility inspections (referenced in Part II, Section A, Item 5). All of our permittees are being put on the same monitoring schedule with these renewals. Since we are in the second quarter of the year currently, it would have been unfair for us to require you to expedite your monitoring. So the first monitoring event of your new permit will begin in Period 1 on January 1, 2020. So you guys have a nice break until then! Thanks, Lauren From: McDaniel, Jeffrey <jeffrey.mcdaniel@hexion.com> Sent: Friday, October 11, 2019 11:58 AM To: Garcia, Lauren V <lauren.garcia@ncdenr.gov> Cc: kdrennan@trccompanies.com Subject: RE: [External] RE: [External]NCS000332 NPDES Stormwater Permit Renewal • External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to re am nc. ov Good morning Lauren, Can you please clarify for me the following? Based on the highlighted footnote from the permit below our next stormwater sampling event should be for the period of January 1-June 30, 2020. I'm just going through each of our permits and making sure we have the appropriate compliance tasks on our compliance calendar. Thanks, Jeff Table 2. Mnnitori...... duly Se,ni.pnnual StarMite Und Date Mouitering $VentsW (All Yeairs][, - -]an (Ail Years)a -- --- Period 11 uary t dune 30 Perlod2 July 1 Neember3l Footnatcs: t Mal main semi-annual monitoringundlertheranotkler permit Islieued forth Is Facility &ruTkklI khis permit Isrev4edurresr_inderi.ThepermittermustsubnriLariappl]vjtrgnkm- rGncrrylpr erugr befei*die suWoWaI deadline [180 iy3 be" e&plrAtrpty].bo be c�naMderbdfurrWMwed cnveraitc antler thfi permit 'nie pitrmittte mutt Cohdrlae ww"red mon:roring throughout the pcnnll renewal Process• eren ifa Tenewal permit ;s not issued until after mpiradan of this permit- 2 rrnodlschargeanumckkNngthesemp:IggperlodrdWpErmitteemustSubmit arnanHonngrepat IndRahng"No Flow'or'No ulvl a roe' wiLhLrk 30 dayseRheew gfdw samprnaperlast 3 rdonrroHngperlods reraatn wnsis#ent th:augh thept`Trrtlt bran and thraueh the rdnewal process. The first samplk%period begjn: In peripd 1 90 IMii=Y 1, ZOZU4 Failure to Motiltor semi-annually perpermitoondikions may rasultin the Mvision reguiring imonthly monitoring for all parameters for a spedfied time period, `No discharge' "man outU during a monitoring period does not cnmstltuto Failure to monloar, as ]gag as it Ls properly reoardad and rapo rtcti. Jeff McDaniel Site Leader 114Industrial Blvd Morganton, NC 28655 Office: 828.219.3503 Mobile: 336.362.4030 rw E Responsible Chemistry www.hexion.com From: Garcia, Lauren V <lauren.garcia@ncdenr.gov> Sent: Monday, September 9, 2019 2:29 PM To: McDaniel, Jeffrey <ieffrey.mcdaniel@hexion.com> Cc: kdrennan@trccompanies.com Subject: RE: [External] RE: [External]NCS000332 NPDES Stormwater Permit Renewal This message is from an EXTERNAL SENDER - be CAUTIOUS, particularly with links and attachments. Hello, I have attached the updated cover with the correct CEO. The hard copy was sent in the mail today. Thank you for your patience! Lauren From: McDaniel, Jeffrey <ieffrey.mcdaniel@hexion.com> Sent: Monday, August 26, 2019 2:43 PM To: Garcia, Lauren V <lauren.garcia@ncdenr.gov> Cc: kdrennan@trccompanies.com Subject: RE: [External] RE: [External]NCS000332 NPDES Stormwater Permit Renewal External email. Do not click links or open attachments unless you verify. Send all suspi report.spam@nc.gov i Ok Lauren, no problem. Thanks for letting me know. From: Garcia, Lauren V <lauren.garcia@ncdenr.gov> Sent: Monday, August 26, 2019 2:00 PM To: McDaniel, Jeffrey <jeffrey.mcdaniel@hexion.com> Subject: RE: [External] RE: [External]NCS000332 NPDES Stormwater Permit Renewal This message is from an EXTERNAL SENDER - be CAUTIOUS, particularly with links and attachments. Hi Jeff, My supervisor has been out of town and I have been unable to have her resign the cover of the permit. I will be able to send you a cover copy with the correct CEO and address upon her return. Like you said, this does not affect the coverage of the permit as the Certificate of Coverage is the cover page of the permit. The permit is to become effective on September 1, 2019. Thanks! Lauren From: McDaniel, Jeffrey <jeffrey.mcdaniel@hexion.com> Sent: Monday, August 19, 2019 11:51 AM To: Garcia, Lauren V <lauren.garcia@ncdenr.gov> Subject: RE: [External] RE: [External]NCS000332 NPDES Stormwater Permit Renewal External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to report.spam@nc.gov Good morning Lauren, I have reviewed the permit that was attached. A couple of items of note: 1- Craig Morrison is no longer with Hexion. He retired as CEO last year. Our new CEO is Craig Rogerson, if the CEO is the appropriate name/title to have on the permit. 2- The address listed at the bottom of the permit is 115 Industrial Drive which is incorrect. It is 114 Industrial Drive and is correct at the top of the permit. I don't think either are relevant to this years' copy, just wanted to let you know for future reference. Let me know if you have any questions. Thanks, Jeff Jeff McDaniel Site Leader 114Industrial Blvd Morganton, NC 28655 Office: 828.219.3503 Mobile: 336.362.4030 Responsible h m fr www.hexion.com From: Garcia, Lauren V <lauren.garcia@ncdenr.gov> Sent: Friday, August 16, 2019 11:50 AM To: McDaniel, Jeffrey <jeffrey.mcdaniel@hexion.com> Cc: kdrennan@trccompanies.com Subject: RE: [External] RE: [External]NCS000332 NPDES Stormwater Permit Renewal This message is from an EXTERNAL SENDER - be CAUTIOUS, particularly with links and attachments. Good afternoon! I have your signed permit ready for you. The permit will be on the way to the facility by mail, but I wanted to make sure a copy got to you! Thanks, Lauren From: McDaniel, Jeffrey <jeffrey.mcdaniel@hexion.com> Sent: Tuesday, July 30, 2019 1:08 PM To: Garcia, Lauren V <lauren.garcia@ncdenr.gov> Cc: kdrennan@trccompanies.com Subject: RE: [External] RE: [External]NCS000332 NPDES Stormwater Permit Renewal External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to report.spam@nc.gov A Thanks Lauren, appreciate the update. Have a great day. Jeff From: Garcia, Lauren V <lauren.garcia@ncdenr.gov> Sent: Tuesday, July 30, 2019 1:06 PM To: McDaniel, Jeffrey <jeffrey.mcdaniel@hexion.com> Subject: RE: [External] RE: [External]NCS000332 NPDES Stormwater Permit Renewal This message is from an EXTERNAL SENDER - be CAUTIOUS, particularly with links and attachments. Hey Jeff, That is correct. The permit is being reviewed one final time in the regional office. Once I get the go ahead from them, I can get it signed and in the mail for you! Lauren From: McDaniel, Jeffrey <jeffrey.mcdaniel@hexion.com> Sent: Tuesday, July 30, 2019 1:03 PM To: Garcia, Lauren V <lauren.garcia@ncdenr.gov> Cc: Drennan, Kathryn <KDrennan@trccompanies.com> Subject: RE: [External] RE: [External]NCS000332 NPDES Stormwater Permit Renewal External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to report.spam@nc.gov Good afternoon Lauren, We were discussing last week and had a question about the stormwater permit renewal. When you get a chance can you please give us an updated status on that? Based on the previous emails the 30-day comment period should be over, is that correct? Thanks for your help, Jeff Jeff McDaniel Site Leader 114Industrial Blvd Morganton, NC 28655 Office: 828.219.3503 Mobile: 336.362.4030 Im Responsible Chemistry www.hexion.com From: Garcia, Lauren V <lauren.garcia@ncdenr.gov> Sent: Monday, May 20, 2019 8:50 AM To: Drennan, Kathryn <KDrennan@trccompanies.com>; McDaniel, Jeffrey <jeffrey.mcdaniel@hexion.com> Subject: RE: [External] RE: [External]NCS000332 NPDES Stormwater Permit Renewal This message is from an EXTERNAL SENDER - be CAUTIOUS, particularly with links and attachments. Hey Kathryn, The results you have for your October -March monitoring event will end up being the last monitoring event for your old permit. The good news is your new monitoring schedule (July -December) will overlap with the old April -September period and you will actually have a little extra time to complete the monitoring event. A bit of extra information (this is not as applicable to you because of your new permit going into effect at the end of June), in the past the monitoring schedule has coincided with the date the permit is issued. I have had several facilities ask to have their monitoring schedule edited to coincide with the schedule for facility inspections (page 5), so they can do their inspections and monitoring at the same time. It is up to you if you would like your permit term to cover June - November; December -May or to remain January -June; July -December. I picked the later as it gives you an extra month. For your second question, the language in the permit means this: If a facility is monitoring semi-annually, for example, and they decide to pull an extra sample during that 6-month period (say maybe one parameter was over benchmark, they fixed something, and they want to see how the discharge is now), they are required to report any extra sampling results on a DMR to the State. BUT, that "extra" sample is not what they use for directing tier responses and doesn't count toward the number of exceedances that might trigger another tier response. That first sample is what they have to use. In this scenario, maybe their extra sample shows TSS came back under benchmark, but they still have to count an exceedance for that monitoring period. If they are already monitoring monthly, maybe they decide to pull additional samples several times in a single month. Same thing applies. The first valid sample is the one they use to compare to benchmarks (and determine if there's another step, like notify the RO because they hit their "any four exceedances"), but they still have to send in DMRs for any subsequent weekly sampling. In other words, they can't keep their "extra data" a secret; they have to report it. And, they can't pull extra samples and just choose to report the one with values under benchmarks for that monitoring period. I hope this helps, let me know if you have any other questions! Lauren From: Drennan, Kathryn <KDrennan@trccompanies.com> Sent: Tuesday, May 14, 2019 4:30 PM To: Garcia, Lauren V <lauren.garcia@ncdenr.gov>; McDaniel, Jeffrey <jeffrey.mcdaniel@hexion.com> Subject: [External] RE: [External]NCS000332 NPDES Stormwater Permit Renewal External email. Do not click links or open attachments unless you verify. Se report.spam@nc.gov Hi Lauren, Please see attached for the updated analytical monitoring spreadsheet which includes data back to 2012. In addition, we reviewed the draft permit and have the following clarifying questions: The new permit will be effective June 24, 2019. We are retesting for formaldehyde to meet the requirements for October— March 2019 reporting period as per the current NPDES permit. Once this new permit is in effect, will our next sample be required to meet the July — December 2019 reporting period? "The permittee must report the results from each sample token within the monitoring period (see Port lll, Section E). However, for purposes of benchmark comparison and Tiered response actions, the permittee shall use the analytical results from the first sample with valid results within the monitoring period." Could you please elaborate on this requirement? Do we report all monthly sampling (if necessary) within one semiannual DMR as opposed to submitting a separate report per sampling event? Please let us know if the questions are unclear, or if you need additional information. Thank you! Katie Katie Drennan Associate Engineer KDrennan@trccompanies.com .* llkTIRC ♦� 3 Walden Ridge Drive, Suite 250, Asheville, NC 28803 T: (828) 237-2691 From: Garcia, Lauren V[mailto:lauren.garcia@ncdenr.gov] Sent: Tuesday, May 07, 2019 8:51 AM To: McDaniel, Jeffrey <ieffrey.mcdaniel@hexion.com> Cc: Drennan, Kathryn <KDrennan@trccompanies.com> Subject: RE: [External] RE: [External]NCS000332 NPDES Stormwater Permit Renewal Hi Jeff, Thanks so much for sending me this information! Here is your updated permit draft. This will begin your 30-day comment period where I will be able to address any comments or concerns you have with the permit. The permit has been reformatted to be more concise and easier to read through. There have not been any changes made as far as existing information goes, it will just look a little different. Changes are also outlined in the cover letter in the draft. A quick question, do you happen to have any monitoring data from the beginning of the permit term (circa 2009-2014)? Thanks for your help, Lauren From: McDaniel, Jeffrey <ieffrey.mcdaniel@hexion.com> Sent: Monday, May 06, 2019 3:16 PM To: Garcia, Lauren V <lauren.garcia@ncdenr.gov> Cc: kdrennan@trccomoanies.com Subject: RE: [External] RE: [External]NCS000332 NPDES Stormwater Permit Renewal External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to ILeport.spam@nc.gny Hi Lauren, Please see the response to your questions in red below and attached. Please let us know if you need any additional information. A spreadsheet summarizing all of the monitoring data that has been collected since the effective date of the current permit; Please see the attached spreadsheet for this information. The last Discharge Monitoring Report was submitted Wednesday, May 1, 2019. A verification that the information in the renewal application is still is still complete and correct; and The information from the last renewal application signed February 26, 2014 is correct; however, the Site leader who signed the report is no longer at the facility. The contact information has been updated using the links you provided below. Please let us know if you would like the facility to submit an updated Renewal Application Form. An explanation of any operational changes since the renewal application was submitted. There have not been any significant operational changes in industrial activities at the facility. The facility added secondary containment around non -hazardous waste totes on the east side of the main building in 2016. In addition, a gravel truck tanker parking lot was added to the east side of the property in 2017. Thanks and have a great day. Jeff Jeff McDaniel Site Leader 114Industrial Blvd Morganton, NC 28655 Office: 828.219.3503 Mobile: 336.362.4030 X HEXIN www.hexion.com From: Garcia, Lauren V <lauren.garcia@ncdenr.gov> Sent: Tuesday, April 30, 2019 1:31 PM To: McDaniel, Jeffrey <jeffrey.mcdaniel@hexion.com> Cc: kdrennan@trccompanies.com Subject: RE: [External] RE: [External]NCS000332 NPDES Stormwater Permit Renewal This message is from an EXTERNAL SENDER - be CAUTIOUS, particularly with links and attachments. Hi Jeff, I just received your voicemail. I did get exactly what I needed from your e-mail. I left several messages last week just hoping someone would call me back. That must be what the new message was from. I'm sorry you have had network challenges and I hope things are able to be fixed for you soon. If Katie is able to access that information in my first email for you, that would be great. If not, you may end up with your draft permit for review before I have it. If I need to adjust the permit based on the monitoring information, I will send you an updated copy. The Hexion draft permit is scheduled to be published for public notice on May 8, 2019, so things are moving along well. Thanks, Lauren From: McDaniel, Jeffrey <jeffrey.mcdaniel@hexion.com> Sent: Thursday, April 25, 2019 2:50 PM To: Garcia, Lauren V <lauren.garcia@ncdenr.gov> Cc: kdrennan@trccompanies.com Subject: [External] RE: [External]NCS000332 NPDES Stormwater Permit Renewal External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to report.spam@nc.gov Hi Lauren, I did receive your voicemail as well, thanks for contacting me. Randy Beets told me he also received a voicemail, so you have (2) good contacts now, he mentioned you had a couple obsolete contacts. We have had some turnover over the past 4 years so you may have some inaccurate information. I have also copied Katie Drennan on this email, she is consulting with us right now as we are filling the environmental position on a permanent basis. We've had some network challenges over the past month as we have a total blackout for approximately 3 weeks and are in the process now of coming back online fully. I attempted to access the links below and also tried copy/paste in my browser but can't get them to go through. My guess is that it is on our end as things aren't back to normal yet. My contact info is below, if you can email me any other information that is needed I can email that back. Thanks very much. Katie, are you able to access this information on our behalf? We do have our server files back as of yesterday so we can research records on our end if needed. Please advise. Thanks. Jeff McDaniel Site Leader 114Industrial Blvd Morganton, NC 28655 Office: 828.219.3503 Mobile: 336.362.4030 X HEXION www.hexion.com From: Garcia, Lauren V <lauren.garcia@ncdenr.gov> Sent: Thursday, April 25, 2019 9:50 AM To: McDaniel, Jeffrey <jeffrey.mcdaniel@hexion.com> Subject: [External]NCS000332 NPDES Stormwater Permit Renewal This message is from an EXTERNAL SENDER - be CAUTIOUS, particularly with links and attachments. Good morning Jeffrey, I left you a voicemail explaining that I am working on renewing your facility's individual stormwater permit (Permit No. NCS000332). There is some information I am required to ask you for to (1.) confirm that the information I have is correct and (2.) make sure the permit adequality serves the needs of the facility. What I need from you: • A spreadsheet summarizing all of the monitoring data that has been collected since the effective date of the current permit; • A verification that the information in the renewal application is still is still complete and correct; and • An explanation of any operational changes since the renewal application was submitted. The following link will take you to an online search box where you will be able to enter your permit number and review the facilities information to make sure it is correct: https://reports.ncdenr.org/BOE/Open Document/1703191515/CrystalReports/viewrpt.cwr?id=25212&apsuser=BIMS U &apspassword=blOMs cr%28ddnri59%29&apsauthtype=secEnterprise&cmd=EXPORT&EXPORT FMT=U2FPDF%3AO. Information can be updated using the links provided below, where applicable: Owner Update: https://edocs.deg.nc.gov/Forms/SW-Name-Change Owner Affiliation (i.e., someone with the company who is designated to represent the company per signatory requirements in the permit (e.g., CEO) or another authorized representative): https://edocs.deg.nc.gov/Forms/SW- Owner-Affiliation Company of Facility Name: https://edocs.deg.nc.gov/Forms/SW-Name-Change What happens next: • Once I have the above listed information, I will verify the "draft" permit information is correct; You will receive the draft for a 30-day comment period. During this time we will be able to address any comments or concerns you have about your permit draft. During the same 30-day period, the draft will be sent to an Asheville Regional Office staff member for review and the permit draft will be sent for Public Notice. • Once all comments and concerns are addressed, you will be issued the final permit. Feel free to contact me with any questions as well. Thanks, Lauren Lauren Garcia Environmental Specialist II Stormwater Program Division of Energy, Mineral, and Land Resources North Carolina Department of Environmental Quality 919-707-3648 (0) lauren.garcia@ncdenr.gov DEMLR Stormwater Program 512 N. Salisbury Street 1612 Mail Service Center Raleigh, NC 27699-1612 10 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. This message, including attached files, is confidential and intended for the addressees. It may contain information that is proprietary, privileged or exempt for disclosure under applicable law. Any unauthorized use and dissemination of the information or copying of this message is strictly prohibited. Any views, opinions or conclusions expressed in this message are those of the individual sender and do not necessarily reflect the views of Hexion or its affiliates. If you received this message in error, please immediately advise the sender by reply email, delete all copies of this message and refrain from printing, copying, or disseminating this message or otherwise using the information in it. Thank you. Although Hexion routinely screens incoming and outgoing mail messages for viruses, addressees should scan this e-mail and any attachments for viruses themselves. Hexion does not guarantee in any way the absence of viruses in this e-mail or any attachments and disclaims any liability in case of security problem that this message may cause to any system. 11