WQ0034775_Final Permit_20210729

July 29, 2021
R ONALD B AZINET S ITE L EADER
H EXION VAD LLC
333 N EILS E DDY R OAD
R IEGELWOOD, N ORTH C AROLINA 28456-9570
Subject: Permit No. WQ0034775
Hexion Riegelwood CLRS
Closed-Loop Recycle System
Columbus County
Dear Mr. Bazinet:
In accordance with your permit change of ownership request received May 3, 2021, we are
forwarding herewith Permit No. WQ0034775 dated July 29, 2021, to Hexion VAD LLC for the subject
wastewater treatment and closed-loop recycle facilities.
The following modifications to the subject permit are as follows: The closed-loop facilities have
been properly closed and have been removed from the permit. Consequently, no flow is permitted.
This permit shall be effective from the date of issuance through January 31, 2028, shall void Permit
No. WQ0034775 issued December 1, 2016, and shall be subject to the conditions and limitations therein.
The Permittee shall submit a renewal application no later than August 4, 2027.
Please pay attention to the monitoring requirements listed in Section IV and Attachment C. Failure
to establish an adequate system for collecting and maintaining the required operational information shall
result in future compliance problems.
The Division has removed the following permit conditions since the last permit issuance dated
December 1, 2016:
Old Condition II.4. This condition has been removed because the storage and treatment units
have been removed.
Old Condition III.6. This condition has been removed because the pond has been closed.
Old Condition III.7. This condition has been removed because the pond has been closed.
Old Condition IV.3. This condition has been removed because the pond has been closed.
Old Condition VI.2. This condition has been removed because the permit is not voidable.

Mr. Ronald Bazinet
July 29, 2021
Page 2 of 2
The following permit conditions are new since the last permit issuance dated December 1,
2016:
Condition I.1. Within 24 months of permit issuance, the Permittee shall submit a Comprehensive
Site Assessment (CSA) addressing the cause, significance, and extent of the groundwater
contamination in accordance with 15A NCAC 02L .0106(g).
Condition I.2. Upon approval of the Comprehensive Site Assessment (CSA), the Permittee may
be required to prepare and submit a Corrective Action Plan (CAP) for restoration of groundwater
quality in accordance with 15A NCAC 02L .0106(h).
Condition VI.10. This permit shall not be renewed if the Permittee or any affiliation has not paid
the required annual fee.
If any parts, requirements, or limitations contained in this permit are unacceptable, the Permittee
has the right to request an adjudicatory hearing upon written request within 30 days following receipt of
this permit. This request shall be in the form of a written petition, conforming to Chapter 150B of the North
Carolina General Statutes, and filed with the Office of Administrative Hearings at 6714 Mail Service
Center, Raleigh, NC 27699-6714. Otherwise, this permit shall be final and binding.
If you need additional information concerning this permit, please contact Poonam Giri at (919)
707-3656 or [e-mail].
Sincerely,
S. Daniel Smith, Director
Division of Water Resources
cc: Columbus County Health Department (Electronic Copy)
Wilmington Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Laserfiche File (Electronic Copy)
Digital Permit Archive (Electronic Copy)

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
RALEIGH
CLOSED-LOOP RECYCLE SYSTEM PERMIT

In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as
amended, and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
Hexion VAD LLC
Columbus County
FOR THE
site of a former 129,600 gallon per day (GPD) wastewater treatment and closed-loop recycle facility that
previously served the Hexion Riegelwood CLRS, with no discharge of wastes to surface waters, pursuant
to the application received May 3, 2021, and in conformity with the Division-approved plans and
specifications considered a part of this permit.
This permit shall be effective from the date of issuance through January 31, 2028, shall void Permit No.
WQ0034775 issued December 1, 2016, and shall be subject to the following conditions and limitations:
I. SCHEDULES
1. Within 24 months of permit issuance, the Permittee shall submit a Comprehensive Site Assessment
(CSA) addressing the cause, significance, and extent of the groundwater contamination pursuant to the
requirements of 15A NCAC 02L .0106(g). The site assessment shall include:
a. The source and cause of contamination;
b. Any imminent hazards to public health and safety, and any actions taken to mitigate them;
c. All receptors and significant exposure pathways;
d. The horizontal and vertical extent of soil and groundwater contamination and all significant factors
affecting contaminant transport; and
e. Geological and hydrogeological features influencing the movement, chemical, and physical
character of the contaminants.
Work that is within the scope of the practice of geology and engineering, which involves site
assessment, the interpretation of subsurface geologic conditions, preparation of conceptual corrective
action plans or any work requiring detailed technical knowledge of site conditions shall be performed
by persons, firms or professional corporations who are duly licensed to offer geological or engineering
services. The CSA and supporting documentation shall be sent to the Division of Water Resources,
Non-Discharge Branch, 1617 Mail Service Center, Raleigh, NC 27699-1617, or Non-
[e-mail]. \[15A NCAC 02L .0106(d)(2), 02L .0106(g), 02L .0111\]

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2. Upon Division-approval of the Comprehensive Site Assessment (CSA), the Permittee may be required
to prepare and submit a Corrective Action Plan (CAP) for restoration of groundwater quality pursuant
to 15A NCAC 02L .0106(h). Work which involves design of remedial systems or specialized
construction techniques shall be performed by persons, firms or professional corporations who are duly
licensed to offer engineering services. If the Division requires a CAP, it shall include:
a. A description of the proposed corrective action and reasons for its selection;
b. Specific plans, including engineering details where applicable, for restoring groundwater quality;
c. A schedule for the implementation and operation of the proposed plan; and
d. A monitoring plan for evaluating the effectiveness of the proposed corrective action and the
movement of the contaminant plume.
The CAP and supporting documentation shall be sent to the Division of Water Resources, Non-
Discharge Branch, 1617 Mail Service Center, Raleigh, NC 27699-1617, or Non-
[e-mail]. \[15A NCAC 02L .0106(d)(2), 02L .0106(h), 02L .0111\]
3. The Permittee shall request renewal of this permit on Division-approved forms no later than August 4,
2027. \[15A NCAC 02T .0105(b), 02T .0109\]
II. PERFORMANCE STANDARDS
1. The Permittee shall maintain and operate the subject non-discharge facilities so there is no discharge to
surface waters, nor any contravention of groundwater or surface water standards. In the event the
facilities fail to perform satisfactorily, including the creation of nuisance conditions due to improper
operation and maintenance, the Permittee shall take immediate corrective actions, including Division
required actions, such as the construction of additional or replacement wastewater treatment or recycle
facilities. \[15A NCAC 02T .0108(b)(1)(A)\]
2. This permit shall not relieve the Permittee of their responsibility for damages to groundwater or surface
water resulting from the operation of this facility. \[15A NCAC 02T .0108(b)(1)(A)\]
3. Groundwater monitoring wells shall be constructed in accordance with 15A NCAC 02C .0108
(Standards of Construction for Wells Other than Water Supply), and any other jurisdictional laws and
regulations pertaining to well construction. \[15A NCAC 02C .0108\]

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III. OPERATION AND MAINTENANCE REQUIREMENTS
1. The Permittee shall operate and maintain the subject facilities as a non-discharge system. \[15A NCAC
02U .0101\]
2. The Permittee shall maintain an Operation and Maintenance Plan, which shall include operational
functions, maintenance schedules, safety measures, and a spill response plan. \[15A NCAC 02U
.0801(a)\]
3.
classification of the subject non-discharge facilities, the Permittee shall designate and employ a certified
operator in responsible charge (ORC), and one or more certified operators as back-up ORCs. The ORC
or their back-up shall operate and visit the facilities as required by the WPCSOCC. \[15A NCAC 02T
.0117\]
4. The Permittee shall prohibit public access to the wastewater treatment, storage, and closed-loop recycle
facilities. \[15A NCAC 02U .0404(b)(1)\]
5. The Permittee shall dispose or utilize generated residuals in a Division-approved manner. \[15A NCAC
02U .0802, 02T .1100\].
6. The Permittee shall not divert or bypass untreated or partially treated wastewater from the subject
facilities. \[15A NCAC 02T .0108(b)(1)(A)\]
7. A protective vegetative cover shall be established and maintained on all berms, pipe runs, erosion
control areas, surface water diversions, and earthen embankments (i.e., outside toe of embankment to
maximum allowable temporary storage elevation on the inside of the embankment). Trees, shrubs, and
other woody vegetation shall not be allowed to grow on the earthen dikes or embankments. Earthen
embankments shall be kept mowed or otherwise controlled and accessible. \[15A NCAC 02U .0801(g)\]
IV. MONITORING AND REPORTING REQUIREMENTS
1. The Permittee shall conduct and report any Division required monitoring necessary to evaluate this
on groundwater and surface water. \[15A NCAC 02T .0108(c)\]
2. A Division-certified laboratory shall conduct all analyses for the required effluent, groundwater, and
surface water parameters. \[15A NCAC 02H .0800\]
3. The Permittee shall maintain a record of all residuals removed from this facility. This record shall be
maintained for five years, and shall be made available to the Division upon request. This record shall
include:
a. Name of the residuals hauler;
b. Non-Discharge permit number authorizing the residuals disposal, or a letter from a municipality
agreeing to accept the residuals;
c. Date the residuals were hauled; and
d. Volume of residuals removed.
\[15A NCAC 02U .0802(b)\]
4. A maintenance log shall be kept at this facility. This log shall be maintained for five years, and shall
be made available to the Division upon request. This log shall include:
a. Visual observations of the plant and plant site; and
b. Record of preventative maintenance (e.g., changing of equipment, adjustments, testing, inspections
and cleanings, etc.).
\[15A NCAC 02U .0801(h)\]
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5. Monitoring wells MW-1 and MW-2 shall be sampled at the frequencies and for the parameters specified
in Attachment C. All mapping, well construction forms, well abandonment forms and monitoring data
shall refer to the permit number and the well nomenclature as provided in Attachment C and Figure 1.
\[15A NCAC 02T .0105(m)\]
6. Two copies of the monitoring well sampling and analysis results shall be submitted on a Compliance
Monitoring Form (GW-59), along with attached copies of laboratory analyses, on or before the last
working day of the month following the sampling month. The Compliance Monitoring Form (GW-59)
shall include this permit number, the appropriate well identification number, and one GW-59a
certification form shall be submitted with each set of sampling results. All information shall be
submitted to the following address:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
\[15A NCAC 02T .0105(m)\]
7. Noncompliance Notification:
The Permittee shall report to the Wilmington Regional Office, telephone number [phone],
within 24 hours of first knowledge of the following:
a. Treatment of wastes abnormal in quantity or characteristic, including the known passage of a
hazardous substance.
b. Any process unit failure (e.g., mechanical, electrical, etc.) rendering the facility incapable of
adequate wastewater treatment.
c. Any facility failure resulting in a discharge to surface waters.
d. Any time self-monitoring indicates the facility has gone out of compliance with its permit
limitations.
Emergencies requiring reporting outside normal business hours shall call
Response personnel at telephone number [phone], [phone], or [phone]. All
noncompliance notifications shall file a written report to the Wilmington Regional Office within five
days of first knowledge of the occurrence, and this report shall outline the actions proposed or taken to
ensure the problem does not recur. \[15A NCAC 02T .0108(b)(1)(A)\]
V. INSPECTIONS
1. The Permittee shall perform inspections and maintenance to ensure proper operation of the wastewater
treatment and recycle facilities. \[15A NCAC 02U .0801(i)\]
2. The Permittee shall inspect the wastewater treatment and recycle facilities to prevent malfunctions,
facility deterioration, and operator errors that may result in discharges of wastes to the environment,
threats to human health, or public nuisances. The Permittee shall maintain an inspection log that
includes the date and time of inspection, observations made, and maintenance, repairs, or corrective
actions taken. The Permittee shall maintain this inspection log for a period of five years from the date
of the inspection, and this log shall be made available to the Division upon request. \[15A NCAC 02U
.0801(h), 02U .0801(i)\]
3. Division authorized representatives may, upon presentation of credentials, enter and inspect any
property, premises, or place related to the wastewater treatment and recycle facilities permitted herein
at any reasonable time for determining compliance with this permit. Division authorized
representatives may inspect or copy records maintained under the terms and conditions of this permit,
and may collect groundwater, surface water, or leachate samples. \[G.S. 143-215.3(a)(2)\]
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VI. GENERAL CONDITIONS
1. Failure to comply with the conditions and limitations contained herein may subject the Permittee to a
Division enforcement action. \[G.S. 143-215.6A, 143-215.6B, 143-215.6C\]
2. This permit is effective only with respect to the nature and volume of wastes described in the permit
application, and Division-approved plans and specifications. \[G.S. 143-215.1(d)\]
3. Unless specifically requested and approved in this permit, there are no variances to administrative codes
or general statutes governing the construction or operation of the facilities permitted herein. \[15A
NCAC 02T .0105(n)\]
4. The issuance of this permit does not exempt the Permittee from complying with all statutes, rules,
regulations, or ordinances that other jurisdictional government agencies (e.g., local, state, and federal)
may require. \[15A NCAC 02T .0105(c)(6)\]
5. If the permitted facilities change ownership, or the Permittee changes their name, the Permittee shall
submit a permit modification request on Division-approved forms. The Permittee shall comply with
all terms and conditions of this permit until the permit is transferred to the successor-owner. \[G.S. 143-
215.1(d3)\]
6. The Permittee shall retain a set of Division-approved plans and specifications for the life of the facilities
permitted herein. \[15A NCAC 02T .0105(o)\]
7. The Permittee shall maintain this permit until the proper closure of all facilities permitted herein, or
until the facilities permitted herein are permitted by another authority. \[15A NCAC 02T .0105(j)\]
8. This permit is subject to revocation or modification upon 60-day notice from the Division Director, in
whole or part for:
a. violation of any terms or conditions of this permit or Administrative Code Title 15A Subchapter
02T;
b. obtaining a permit by misrepresentation or failure to disclose all relevant facts;
c. esentation of credentials:
i. to enter the where a system is located or where any records are required
to be kept;
ii. to have access to any permit required documents and records;
iii. to inspect any monitoring equipment or method as required in this permit; or
iv. to sample any pollutants;
d. ee for administering and compliance monitoring; or
e. a Division determination that the conditions of this permit are in conflict with North Carolina
Administrative Code or General Statutes.
\[15A NCAC 02T .0110\]

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9. Unless the Division Director grants a variance, expansion of the facilities permitted herein shall not
occur if any of the following apply:
a. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has been convicted of
environmental crimes under G.S. 143-215.6B, or under Federal law that would otherwise be
prosecuted under G.S. 143-215.6B, and all appeals of this conviction have been abandoned or
exhausted.
b. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has previously abandoned
a wastewater treatment facility without properly closing the facility.
c. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has not paid a civil
penalty, and all appeals of this penalty have been abandoned or exhausted.
d. The Permittee or any parent, subsidiary, or other affiliate of the Permittee is currently not compliant
with any compliance schedule in a permit, settlement agreement, or order.
e. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has not paid an annual
fee.
\[15A NCAC 02T .0120(b), 02T .0120(d)\]
10. This permit shall not be renewed if the Permittee or any affiliation has not paid the required annual fee.
\[15A NCAC 02T .0120(c)\]
th
Permit issued this the 29 day of July 2021
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
____________________________________________
S. Daniel Smith, Director
Division of Water Resources
By Authority of the Environmental Management Commission
Permit Number WQ0034775
WQ0034775 Version 2.1 Shell Version 200201 Page 6 of 6

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Page

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1, 61, 2
Version:
1, 4, 51, 2, 3
Footnotes
suring points (top of
urally occurring TOC

75

7

34

GrabGrabGrabGrabGrabGrabGrabGrabGrab
Calculated
Sample Type

MONITORING REQUIREMENTS
Regional Office supervisor, telephone number (

shall be conducted to identify the individual constituents comprising

rom the surveyed point on the top of the casing. The measurement of
Permit Number: WQ00

measuring point for each monitoring well. The mea
Wilmington
3 x Year3 x Year3 x Year3 x Year3 x Year3 x Year3 x Year3 x Year3 x Year
Annually
and this attachment.

1
be subject to the additional sampling and analysis as described above.
Frequency Measurement

g/L
su
feet
µ
mg/Lmg/Lmg/Lmg/Lmg/Lmg/L

Present: Yes/No

up analyses required.
Attachment C
-

Daily Maximum

8.5

-
10
1.5
600500250
6.5

GROUNDWATER STANDARDS

November; Annual monitoring shall be conducted in November.
r less that shall be supported by laboratory proficiency studies as required by the DWR Laboratory Certification Unit. Any c

2
-
ncentration as measured in the background monitor well exceeds 10 mg/L, this concentration will be taken to represent the nat

In November only, analyze by one of the following methods:

-

180 ºC
Description

MW
-

)
4
and

SO
1
-
Parameter
GROUNDWATER MONITORING AND LIMITATIONS

ic compounds (VOC) are detected as a result of monitoring as provided in Attachment C, then the
MW
2.1
ells:

W
Carbon, Tot Organic (TOC)Methanol (formaldehyde) Whole Water Nitrogen, Ammonia Total (as N)Nitrogen, Nitrate Total (as N)pHPhosphorus, Total (as P)Solids, Total Dissolved Sulfate, Total
(as Volatile Compounds (GW)Water Level, Distance from measuring point
Version
od used shall meet the following qualifications:

GROUNDWATER CHARACTERISTICS

Another method with prior approval by the Water Quality Permitting Section ChiefA laboratory shall be DWR certified to run any method used.The method used shall include all the constituents
listed in Table VIII of Standard Method 6230D.
shall be made after purging and prior to sampling for the remaining parameters.

34775

3 x Year monitoring shall be conducted in March, July, and The measurement of water levels shall be made prior to purging the wells. The depth to water in each well shall be measured
fpHThe measuring points (top of well casing) of all monitoring wells shall be surveyed to provide the relative elevation of the casing) of all monitoring wells shall be surveyed relative
to a common datum.Volatile Organic Compounds (VOC) a.b.c.d.e.Any metha.b.c.If any volatile organshall be contacted immediately for further instructions regarding any additional followIf
TOC concentrations greater than 10 mg/L are detected in any downgradient monitoring well, additional sampling and analysisthis TOC concentration. If the TOC coconcentration. Any exceedances
of this naturally occurring TOC concentration in the downgradient wells shall Monitoring wells shall be reported consistent with the nomenclature and location information provided in
Figure
006807699500610006200040000665703000094582546
GWVOC
PCS Code

ATTACHMENT C Monitoring 1.2.3.4.5.6.7.WQ00