NCS000321_2019 Staff Report_12272019

NC Division of Energy, Mineral and Land Resources
Review for Permit — NCS000321
Lubrizol Advanced Materials Inc
Facility Activities and Processes:
• SIC Code 2821— Plastics Materials and Resins
• The facility is a chemical manufacturer that produces latex resins and coatings. Noveon Inc.,
Textile Coatings based in Gastonia, NC offers Acrylic Polymers, Laminating Adhesives,
Polyurethane (PU) Adhesives, Water Based Adhesives, PVC Resins and Polyurethane (PU) Resin.
Monitoring Information:
• Noncontact cooling water (NCCC) and boiler blowdown (BB) wastewaters are comingled with
the stormwater prior to discharge. The NCCC and BB are discharged into the facility's
stormdrains at separate locations throughout the facility. All stormwater and NCCC/BB are
collected in an initial concrete holding basin (221,228-gallon capacity) and is then pumped into
an adjacent concrete holding basin (418, 160 gallon capacity). The staff initiate a recirculation
pump (that pulls from the bottom) to thoroughly mix this basin prior to collecting samples for
process control to ensure the water meets appropriate limits and detect any possible
leakages/spills that could have happened in the plant. This recirculation also provides some
aeration int eh water. An on -site lab performs these process control analyses and if all
parameters are within levels, then a discharge event will occur. When this happens, they
contract a certified lab (twice per year) to perform all required analysis (Wastewater and
Stormwater) on the discharge.
• The NCCC/BP permit requires sampling prior to comingling with stormwater; however, it is not
currently feasible to collect a representative sample prior to the basins. In addition, the NCCC
and BB units are located throughout the facility and it would be quite an ordeal (economically)
to attempt to pipe all these together to get an isolated sample prior to comingling with the
stormwater. The individual stormwater permit (expires 6/30/14) requires more sampling
parameters than the NCCC permit.
Impairment:
• Crowders Creek is an impaired water body experiencing issues with fish community and fish
tissue mercury.
• Crowders Creek is on the 2006 303(d) list for biological integrity and fecal coliform. Basin wide
Plan indicates the entire 15.8-mile creek is listed as impairment in the stat's 303(d) list due to
high fecal coliform concentrations from urban runoff, storm sewers and point source discharges.
Data also indicate the biological community is Impaired. There is a fecal coliform TMDL
approved in 2004. The TMDL evaluates the contribution of both point and nonpoint sources and
attempts to determine the percentage by which various types of sources (urban, agriculture,
WWTP, etc) contribute to the degradation of Crowders Creek. Initial results show that urban
runoff contributes nearly two-thirds of the total fecal coliform load, versus one-third by
agriculture and WWTPs combined. This finding indicated that Crowders Creek would like benefit
from a management plan that reduces the detrimental effects of urbanization. Additionally, DEQ
encourages implementation of agriculture BMPs wherever possible. (2009 Staff Report).