NCS000179_Draft Permit Cover Letter_20201023

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
BRIAN WRENN
Acting Director
Tom Buller
Low & Bonar Inc.
Post Office Box 1057
Enka, NC 28728
SENT ELECTRONICALLY
Mr. Buller:
NORTH CAROLINA
Environmental Quality
October 23, 2020
Subject: Draft NPDES Stormwater Permit
Permit No. NCS000179
Low & Bonar Inc.
Buncombe County
The Division of Energy, Mineral, and Land Resources' Stormwater Permitting Program
acknowledges receipt of your renewal application for coverage under NPDES Permit
No. NCS000179 on April 9, 2014. Enclosed with this letter is a copy of the DRAFT
stormwater permit for your facility. Please review the draft carefully to ensure
thorough understanding of the conditions and requirements it contains.
The draft permit contains the following significant changes from the facility's current
permit:
1. You are required to collect analytical and qualitative monitoring samples
during "measurable storm events" as defined in Part J. This term is
different from the "representative storm event" in earlier permits.
2. Requirements for the Stormwater Pollution Prevention Plan (SWPPP) have
been updated in Part B.
3. Changes have been made to two monitoring parameters, with an added
benchmark for one parameter. Stormwater benchmarks are not permit
limits, but rather guidelines for implementing the SWPPP. A benchmark
exceedance is not a permit violation; however, the permittee must respond
to exceedances as directed in Part D.
• Nonpolar Oil and Grease per EPA Method 1664 has been added as
a monitoring parameter. The benchmark for this parameter is 15
mg/L.
Q17--A� North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
E512 North Salisbury Street 1 1612 Mail Service Center I Raleigh, North Carolina 27699-1612
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Estimated average Monthly Oil Usage at the Facility (gallons) has
been added as a parameter. There is no benchmark for this
parameter; its intent is merely to track the monthly oil usage.
4. Tiered responses have been added to this 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 in accordance with
Part D of this permit.
5. New requirements on reporting have been added in Part E to comply with
federal regulations requiring electronic submittal of discharge monitoring
reports. Additionally, this permit contains requirements for future reporting
via eDMR when the forthcoming eDMR internet application is finalized.
6. Civil and administrative penalties have been updated to reflect current
federal law in Part I.
Please review the draft permit and submit any comments to me no later than 30 days
following your receipt of the draft. Comments may be emailed to me at
[e-mail] or mailed to my attention at NC DEMLR, Stormwater Permitting
Program, 1612 Mail Service Center, Raleigh, NC 27699-1612. If you have any questions,
please email me or call me at [phone].
Sincerely,
Aana Gamble
DEMLR Stormwater Division
Attachment: Draft Permit NCS000179
cc: Tom Buller, Low & Bonar Inc., [e-mail]
Isaiah Reed, DEMLR Asheville Regional Office, isaiah.reedOncdenr.gov
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