NCS000088_CEI_20201030

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
BRIAN WRENN
Director
Hexion, Inc.
Attn: Ben Tyler, Site Leader
1411 Industrial Drive
Fayetteville, NC 28301
NORTH CAROLINA
Environmental Quality
October 30, 2020
Subject: COMPLIANCE EVALUATION INSPECTION
NPDES Stormwater Permit NCS000088
Hexion, Inc.
Cumberland County
Dear Mr. Tyler:
On October 28, 2020, a site inspection was conducted for the Hexion, Inc. facility located at 1411 Industrial Drive,
Fayetteville, Cumberland County, North Carolina. A copy of the Compliance Inspection Report is enclosed for your review.
Mr. Caleb Stoker, Site EHS Leader, was also present during the inspection and his time and assistance is greatly
appreciated. The site visit and file review revealed that the subject facility is covered by NPDES Stormwater Permit
NCS000088. Permit coverage authorizes the discharge of stormwater from the facility to receiving waters designated as
Cape Fear River, a class C water in the Cape Fear River Basin.
As a result of the inspection, the facility was found to be compliant with the conditions of NPDES Stormwater Permit
NCS000088. Please refer to the enclosed Compliance Inspection Report for additional comments and observations made
during the inspection.
Please be advised that violations of the NPDES Stormwater Permit are subject to a civil penalty assessment of up
to $26,000 per day for each violation. If you or your staff have any questions, comments, or needs assistance with
understanding any aspect of your permit, please contact me at [phone] or via e-mail at [e-mail].
Enclosure: Compliance Inspection Report
ec: Caleb Stoker, Site EHS Leader — Hexion, Inc.
cc: FRO — DEMLR, Stormwater Files
Sincerely,
Michael Lawyer, CPSWQ
Environmental Program Consultant
Division of Energy, Mineral and Land Resources
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North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
Fayetteville Regional Office 1 225 Green Street, Suite 7141 Fayetteville, North Carolina 28301
910.433.3300

Compliance Inspection Report
Permit: NCS000088 Effective: 06/01/11 Expiration: 05/31/16 Owner: Hexion Inc
SOC: Effective: Expiration: Facility: Hexion Inc.
County: Cumberland 1411 Industrial Dr
Region: Fayetteville
Fayetteville NC 28301
Contact Person: Caleb Stoker Title: Site EHS Leader Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
On -site representative
Related Permits:
Certification: Phone:
Caleb Stoker 910-485-9229
Inspection Date: 10/28/2020 Entry Time 09:30AM
Primary Inspector: Mike Lawyer/ i
Secondary Inspector(s):
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: N Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Exit Time: 12:20PM
Phone: [phone]
Inspection Type: Compliance Evaluation
Page 1 of 3

Permit: NCS000088 Owner - Facility: Hexion Inc
Inspection Date: 10/28/2020 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Application for permit renewal received by the Division in December of 2015. Permit has been administratively extended with
the same conditions until the Division issues a new permit. Monitoring records from 2015 through 2020 for the facility's three
stormwater discharge outfalls indicate that monitoring has been conducted and recorded per permit conditions. Tier Two
monthly monitoring was conducted in 2015 and again in 2017/18 for outfall 001 due to consecutive exceedances of the
benchmark value for COD. Per the Tier Two monitoring conditions, facility able to return to the semi-annual monitoring
frequency for outfall 001 beginning with the second half of 2018. Facility's Stormwater Pollution Prevention Plan contains all
required components as well as associated documentation related to semi-annual facility inspections and the annual review
and update requirements. After the records review, site observations were made including the stormwater outfalls, secondary
containment of ASTs and overall site conditions. At the time of inspection, facility in compliance with permit conditions and
the site appeared to be well operated and maintained.
Page 2 of 3

Permit: NCS000088 Owner - Facility: Hexion Inc
Inspection Date: 10/28/2020 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan?
N ❑ ❑ ❑
# Does the Plan include a General Location (USGS) map?
0 ❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
N ❑ ❑ ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
0 ❑ ❑ ❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
0 ❑ ❑. ❑
# Has the facility evaluated feasible alternatives to current practices?
0 ❑ ❑ ❑
# Does the facility provide all necessary secondary containment?
0 ❑ ❑ ❑
# Does the Plan include a BMP summary?
❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
❑ ❑ ❑
# Does the Plan include a Preventative Maintenance and.Good Housekeeping Plan?
0 ❑ ❑ ❑
# Does the facility provide and document Employee Training?
0 ❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
0 ❑ ❑ ❑
# Is the Plan reviewed and updated annually?
E ❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
E ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
0 ❑ ❑ ❑
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? 0 ❑ ❑ ❑
Comment:
Analytical Monitoring
Yes No NA NE
Has the facility conducted its Analytical monitoring? E ❑ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ N ❑
Comment:
Permit and Outfalls
Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? N ❑ ❑ ❑
# Were all outfalls observed during the inspection? 0 ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ❑
# Has the facility evaluated all illicit (non stormwater) discharges? 0 ❑ ❑ ❑
Comment:
Page 3 of 3