NCS000259_Draft Permit Cover Letter_20201103

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
BRIAN WRENN
Director
William Teasdale
Nouryon Surface Chemistry LLC
485 Cedar Springs Road
Salisbury, NC 28147
SENT ELECTRONICALLY
Mr. Teasdale:
NORTH CAROLINA
Environmental Quality
November 3, 2020
Subject: Draft NPDES Stormwater Permit
Permit No. NCS000259
Nouryon Surface Chemistry LLC
Rowan County
The Division of Energy, Mineral, and Land Resources' Stormwater Permitting Program
acknowledges receipt of your renewal application for coverage under NPDES Permit
No. NCS000259 on December 30, 2013. 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 the monitoring parameters and benchmarks.
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 for outfalls with drainage areas where
D E Q North Carolina Department of Environmental Quality Division of Energy, Mineral and Land Resources
512 North Salisbury Street 1 1612 Mail Service Center Raleigh, North Carolina 27699-1612
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industrial activities include the use of >55 gallons of oil per month on
average (see Part D of the draft permit). The benchmark for this
parameter is 15 mg/L.
• Estimated average Monthly Oil Usage at the Facility (gallons) has
been added as a parameter. There is no benchmark for this parameter.
• Total Suspended Solids (TSS) monitoring is no longer required for
outfalls with drainage areas where vehicle maintenance takes place.
4. Tiered responses are included in 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 NCS000259
cc: William Teasdale, Nouryon Surface Chemistry LLC, [e-mail]
Chris Fleming, Nouryon Surface Chemistry LLC, [e-mail]
Lily Kay, DEMLR Mooresville Regional Office, [e-mail]
James Moore, DEMLR Mooresville Regional Office, [e-mail]