NCS000251 Permit Renewal Package_20200729

McCoy, Suzanne
From:Riddick, Timothy A <[e-mail]>
Sent:Wednesday, July 29, 2020 5:26 PM
To:McCoy, Suzanne
Subject:\[External\] Georgia-Pacific Chemicals LLC - NCS000251 Permit Renewal Package -
2020
Attachments:Georgia-Pacific Chemicals LLC - NCS000251 Permit Renewal 2020 - NPDES-
NCSRenewal-Form-Package.pdf
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Ms. McCoy,

Attached is a pdf copy of Georgia-Pacific Chemical LLC's NCS000251 Permit Renewal Package and supporting documents
as required. One hardcopy of this application along with the supporting data was also submitted to the Stormwater
Permitting Program Office (to your attention) at the 1612 Mailer Service Center, Raleigh mailing address today, July
28th, 2020.

I believe that the attached information will meet the required expectations. Should you have any questions, please feel
free to contact me at your convenience. My contact information is listed below.

Regards,

Tim Riddick

Facility Environmental Manager
Georgia-Pacific Chemicals LLC
Conway, NC 27820
Office Phone: [phone]
Cell Phone: [phone]
VOIP 853819

1

Georgia-Pacific Chemicals LLC
Conway Resins Plant
P.O. Box 368
Conway, NC 27820
Phone: [phone]
Fax [phone]
July 27, 2020
Certified Mail — 7014 2120 0004 5521 0077
SW Individual Permit Coverage Renewal
Stormwater Permitting Program
1612 Mail Service Center
Raleigh, NC 27699-1612
RE: NPDES Stormwater Permit Coverage Renewal
Conway Resins Plant
NPDES Stormwater Permit No.: NCS000251
Northampton County
To Whom It May Concern,
Please find enclosed the completed NPDES stormwater permit renewal application for our Conway, NC facility
located in Northampton County. The permit application includes the following information in duplicate at your
request.
1. A current site map from Al Stormwater Pollution Prevention Plan that includes the location of industrial
activities, drainage structures, drainage areas for each outfall, building locations and impervious surfaces.
2. A summary of Analytical Monitoring results during the term of the existing permit.
3. A summary of the Visual Monitoring Results during the term of the existing permit.
4. A summary of our facility's Best Management Practices.
5. There have been no significant changes in industrial activities at this facility during the existing term of this
permit.
6. Signed Certification of the development and implementation of the Stormwater Pollution Prevention Plan
at this facility.
REQUESTED PERMIT MODIFICATIONS
We are requesting a modification to the permit to clarify the concentration of formaldehyde that triggers spray
irrigation from [he stormwater detention basin (SWDB). In Section B, Table 3 (Benchmark Values for Analytical
Monitoring) of the permit, the benchmark concentration for formaldehyde is set at 0.49 ppm. However, Table 4
(Threshold Values requiring Spray Irrigation from the SWDB) in Section B establishes a land application
benchmark of 1.0 ppm. The gap between the Analytical Benchmark concentration (0.49 ppm) and the Spray
Irrigation Benchmark concentration (1.0 ppm) creates uncertainty as to how stormwater in the SWDB with a
concentration between 0.50 ppm and 0.99 ppm should be managed. The facility's standard operating procedure is to
land apply any stormwater in the SWDB with a concentration greater than 0.49 ppm. We are requesting the
following modifications and clarifications:
1) Remove the Spray Irrigation benchmark for formaldehyde from Table 4 and make it a requirement that any
stormwater with a formaldehyde concentration greater than 0.49 ppm be land applied in the spray field.
Modify footnote #4 of Table 1 to reflect this change as well.
2) Clarify that Tier I and Tier 11 requirements are only triggered in the event of a discharge of stormwater with
a formaldehyde concentration greater than 0.49 ppm.

Should you have any questions, please feel free to contact Tun Riddick at [phone],
Sincerely,
� I_ tVW4
Ronald E. Walls
Plant Manager / Regional Manufacturing Manager
2

Permit Coverage
®� Renewal Application Form
NCDENR National Pollutant Discharge Elimination System NPDES Permit Number
Stormwater Individual Permit NCS000251
Please provide your permit number in box in the upper right hand corner, complete the information In the space provided
below and return the completed renewal form along with the required supplemental information to the address indicated.
Owner Information * Address to which permit correspondence wll/be mailed
Owner I Organization Name: Georgia-Pacific chemicals, comayNC
Owner Contact: Mr. Ronald E.Walls
Mailing Address: RM Box 3H o y.No 27820
Phone Number:
2s2-sas-aeao
Fax Number:
252-585-1754
E-mail address:
ewalia�gaPa .o«n
Facility Information
Facility Name:
Conway Resin Plant
Facility Physical Address:
20OAmpacRd Conway,NG 27e20
Facility Contact:
rim Riddiok
Mailing Address:
P.o.BmcaaB com-,ay. Nc 27820
Phone Number:
252-585-3819
Fax Number:
252-585-1754
E-mail address:
[e-mail]
Permit Information
Permit Contact:
TimRiddick
Mailing Address:
P.O. Box Us o way, No 278M
Phone Number:
2523953819
Fax Number:
252s85-1754
E-mail address:
ada",a,at�m
Discharge Information
Receiving Stream:
Paddy's Delight Creek (Doolitge Mill Porch
Stream Class:
B: Nsw
Basin:
shoran River Basin
Sub -Basin:
os 01 g2
Number of Outfalls:
a
Facility/Activity
Changes
Please describe below any changes
to your facility or activities since Issuance
of your
permit. Attached a
separate
sheet if
necessary.
There have been no changes to the facility or activities since inssuance of our
CERTIFICATION
I certify that I am familiar with the information contained in the application and that to the best of my knowledge and belief
such information is truee, co� and oc/n1cu//r te.
Signature C Date 7/Zp-ZZZ
Mr. Ronald E. Walls Plant Manager Regional Manufacturing Manager
Print or type name of person signing above Title
SW Ind(vidual Permit Coverage Renewal
Please return this completed application form Stormwater Permitting Program
and requested supplemental information to: 1612 Mail Service Center
Raleigh, North Carolina 27699-1612

SUPPLEMENTAL INFORMATION REQUIRED FOR RENEWAL OF INDIVIDUAL
NPDES STORMWATER PERMIT
Two copies of each of the following shall accompany this submittal in order for the application
to be considered complete:
(Do not submit thes e Stormwater Pollution Prevention Plan)
Initials
1. A current Site Map from the Stormwater Pollution Prevention Plan. The location of
industrial activities (including storage of materials, disposal areas, process areas and
loading and unloading areas), drainage structures, drainage areas for each outfall,
building locations and impervious surfaces should be clearly noted.
/?&4/ 2. A summary of Analytical Monitoring results during the term of the existing permit
(if your permit required analytical sampling). Do not submit individual lab reports.
The summary can consist of a table including such items as outfall number,
parameters sampled, lab results, date sampled, and storm event data.
�W 3. A summary of the Visual Monitoring results. Do not submit individual monitoring
reports. The summary can consist of a table including such items as outfall number,
/ parameters surveyed, observations, and date monitoring conducted.
4. A summary of the Best Management Practices utilized at the permitted facility.
Summary should consist of a short narrative description of each BMP's in place at
the facility. If the implementation of any BMP's is planned, please include
information on these BMP's.
5. A short narrative describing any significant changes in industrial activities at the
permitted facility. Significant changes could include the addition or deletion of
work processes, changes in material handling practices, changes in material storage
practices, and/or changes in the raw materials used by the facility.
6. Certification of the development and implementation of a Stormwater Pollution
Prevention Plan for the permitted facility (Sign and return attached form).
If the final year analytical monitoring of the existing permit term has not been completed
prior to filing the renewal submittal, then the last years monitoring results should be submitted
within 30 days of receipt of the laboratory reports. (i.e. do not withhold renewal submittal
waiting on lab results)

North Caro/ina Division of Energy, Minera,, and an Resources -Storm water Permitting
Facility Name: conway Reain Plant
Permit Number: NCS000251
Location Address: zoo Ampac Rd Conway. NC 27820
County:
"I certify, under penalty of law, that the Stormwater Pollution Prevention Plan (SPPP) document and all
attachments were developed and implemented under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gather and evaluate the information required by the SPPP.
Based on my inquiry of the person or persons who manage the system, or those persons directly responsible
for gathering the information, the information gathered is, to the best of my knowledge and belief, true,
accurate and complete."
►frT.i
"I certify that the SPPP has been developed, signed and retained at the named facility location, and the SPPP
has been fully implemented at this facility location in accordance with the terms and conditions of the
stormwater discharge permit."
And
'I am aware that there are significant penalties for falsifying information, including the possibility of fines and
imprisonment for knowing violations."
Sign (according to permit signatory requirements) and return this Certification. 'DO NOT.
SEND STORMWATER POLLUTION PREVENTION PLAN WITH THIS CERTIFICATION.
Signature Date
Mr. Ronald E. Walls Plant
Print or type name of person signing above Title
/ Regional Manutactudng Manager
SPPP Certification 10/13

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Required Item #4
(Pagel of3)
BEST MANAGEMENT PRACTICES
All material and process storage areas that pose a reasonable potential for
stormwater pollution at the Conway Resins facility have been placed inside
buildings or sheds. All bulk liquid storage tanks, loading/unloading areas, and
manufacturing areas are provided with secondary containment and/or are roofed to
minimize stormwater contact and to collect any stormwater that comes into
contact with manufacturing operations. All technical and economically feasible
means to eliminate and/or reduce exposure of materials and processes to
stormwater have been implemented.
Good HousekeeuinE Measures and Controls
Good housekeeping practices are designed to maintain a clean and orderly work
environment. At this facility, the following types of good housekeeping measures
are implemented in an effort to prevent pollutants from entering storm water
discharges.
Operation and Maintenance
• Floors and ground surfaces are kept dry and clean by using brooms,
shovels, vacuum cleaners, or cleaning machines.
• Garbage and waste materials are regularly picked up and properly disposed.
• All spillage is promptly removed.
• Equipment is routinely inspected to make sure it is maintained in working
order.
• The importance of spill cleanup procedures is communicated to employees
through routine meetings.
Materials Storage Practices
• Adequate aisle space is provided to facilitate material transfer and easy
access for inspections.
• Containers, drums, and bags of material are stored away from direct traffic
routes to prevent accidental spills.
• Containers are stacked according to manufacturers' instructions.
• Containers are stored on pallets to prevent corrosion.

Required Item #4
(Page Z of 3)
Material Inventory Procedures
• An up-to-date inventory of all hazardous and non -hazardous materials kept
at the facility is maintained.
• All containers are labeled showing the name of the materials.
• Storage areas where hazardous materials are stored have been specially
designed to contain spills.
Employee Participation
• Information on good housekeeping practices are distributed during
employee training sessions.
• Good housekeeping measures are discussed at routine employee meetings.
• Good housekeeping tips and reminders are noted around the plant.
Preventive Maintenance
The facility's preventive maintenance program includes:
• Timely inspections and maintenance of storm water management devices.
• Regular inspection and testing of facility equipment and systems to uncover
conditions that could cause breakdowns or failures resulting in discharges
of pollutants to surface waters.
• Proper maintenance of facility equipment and systems.
• The facility has an active preventive maintenance program under the
guidance of the maintenance supervisor.
Equipment Repair or Replacement
• Defective equipment found during inspections and testing shall be promptly
repaired or replaced.
Records on Preventive Maintenance
The facility has a records system that indicates when inspections are to be
conducted. Inspection and testing records are maintained at maintenance
planner's office.

Required Item #4
(Page 3 of 3)
VlSual InSPeCtlonS
• Visual inspections are conducted on a routine basis. The inspections shall
be performed periodically and after storm events. The following areas are
inspected:
1. areas around all equipment
2. areas where spills and leaks have occurred in the past
3. material storage areas (tank farms and drum storage)
4. outdoor material processing,areas
5. material handling areas (loading, unloading, and transfer)
6o waste generation, storage, treatment, and disposal areas

Required Item # 5
This requirement does not apply for our facility as there have been no significant
changes in industrial activities at this facility during the existing term of the
current permit.