NCG060230_Email RE TSS Benchmark Exceedance_20220325

McDonnell, Jesse M
From: Khan, Zahid
Sent: Friday, March 25, 2022 9:52 AM
To: McDonnell, Jesse M
Subject: FW: [External] Innospec NCG060230 Stormwater TSS benchmark exceedance
From: Roxanne Fincher [mailto:[e-mail]]
Sent: Wednesday, March 16, 2022 5:19 PM
To: Khan, Zahid <[e-mail]>
Cc: Allen Robey <[e-mail]>
Subject: [External] Innospec NCG060230 Stormwater TSS benchmark exceedance
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Resort Sparn,
Mr. Khan,
Thank you for your prompt return call this afternoon. Per your request, I have summarized key points from our
conversation today.
Our general stormwater permit number is NCG060230. We have one outfall 001 from a stormwater retention pond on -
site.
Our site stormwater run-off either is routed to our on -site wastewater treatment plant which is permitted under the City
of Salisbury, or run-off that is not directly impacted by our industrial activities is routed to our stormwater retention
pond. This pond doubles as a fire pond and as a non -contact cooling water pond. There is a small portion of the
property that does not go through outfall 001, but that has no industrial activity exposed to stormwater.
Historically, our stormwater analyses for TSS were well below 100 mg/L.
Within the past 2 years, we have begun several construction projects of which Rowan County has approved the E&SC
Plans, routinely inspects those construction areas, and will make note of required actions we must take and respond
when complete.
We have identified that we will be required to have post -construction permits for the construction areas once the E&SC
Plans are "closed". We are actively working with a consultant on the physical stormwater pollution control measures
which may be required for those post -construction permits.
We have exceeded the TSS benchmark from the discharge of the stormwater retention pond in December 2020, June
2021, and February 2022, which we associate with the run-off from the construction areas.
We have not exceeded our other applicable permit benchmarks; in the past, oil and grease was non -detect, COD below
the benchmark, and pH within benchmark range.

I have copied my boss Allen Robey, SHE Director North America on this message. He wants to attend the on -site
inspection and be part of our discussions. Based on his travel schedule, he asks, if possible, that our on -site visit be
scheduled a day March 21-25 or anytime April 6 or after.
Lastly, we have had a recent issue exceeding our TSS benchmark at our High Point plant, permit number NCG060359,
which we associate with dust from our prepared (not paved) driveways. You had offered to provide a contact for me in
the Central Office so we may discuss that separate subject.
Again, we appreciate your consideration for a solution or a possible exemption.
`µ'Roxy Fincher
Senior SHE Officer NC
Innospec Performance Chemicals
Roxanne.Finc.her(A)imnnosp cinc.com
Tel: [phone]
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