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HomeMy WebLinkAboutNCS000084_Fact sheet binder_20221202DEQ/DEMLR FACT SHEET FOR NPDES INDUSTRIAL INDIVIDUAL STORMWATER PERMIT DEVELOPMENT Basic Information for Permit Issuance and Renewals: Permit Writer / Date Brianna Young 10/24/2022 Permit Number NCS000084 Owner / Facility Name South Atlantic Services, Inc. / SAS Solar SIC Code / Category 2899 / Chemicals & chemical preparations not elsewhere classified Basin Name / Sub -basin number Ca e Fear / 03-06-23 Receiving Stream / HUC 001, 002, 003: UT to NE Cape Fear River / 030300070809 004: UT to NE Cape Fear River / 030300050501 Stream Classification / Stream Segment C; Sw / 18-74- 52.5 Is the stream impaired [on 303(d) list]? No Any TMDLs? No Any threatened and/or endangered species? See Section 2 below Any compliance concerns? See Section 2 below Any permit mods since lastpermit? See Section 1 below New expiration date 12/31/2027 Comments on Draft Permit? See Section 6 below Section 1. Facility Activities and Process: SAS Solar is a dyked tank farm facility that packages antifreeze and tobacco sucker control products as well as repackaging hydrochloric acid for bulk distribution. The facility blends, processes, and packages liquid and dry product/chemicals. Dry storage and transportation via rail, truck, and ship is also performed. Potential pollutants exposed to stormwater include: • Antifreeze • Sodium hydroxide 50% • Potassium hydroxide 45% • Phosphoric acid 75% • Sodium tolyltriazole 50% • Tween 20 • Tween 80 • Maleic anhydride • Sulfuric acid • Hydrazine 40% • Ethylene glycol • 2-Ethylhexoic acid • Mixtures of octanol, decanol, maleic hydrazide and water Page 1 of 8 Significant changes at the site since the last permit renewal include: • Installed new blending kettle/area under the covered loading dock shed in 2013. This new blending area is completely covered and is totally enclosed within a concrete dyke wall. The product to be stored and blended in this area is antifreeze. • Installed new tank farm in 2013 containing 5 new tanks beside Building #6 for use with the new blending area described in 1) above. • Discontinued the storing and packaging of DEF (Diesel Exhaust Fluid) into drums and totes in 2014. This product was a mixture of water and urea and stored in an above ground tank. This tank was moved to our Texas facility. • Constructed a new main office building in 2017 in close proximity to the old office building and then completely removed the old office building. This new building changed the pervious and impervious areas and a new site map was drawn up to identify this. • Began packaging of motor oil in Building #6 in 2017. Initial packaging was from drum/totes into filling machine and then into quart bottles. Packaging was increased to include 5 gallon HDPE bottles and a new oil tank farm containing 3 new tanks was installed behind Building #6 near the railroad track in 2017. This new tank farm is completely dyked and the pump area is completely covered. A separate SPCC plan was developed to specifically cover this process. • Stopped blending and packaging of Lithium Hydroxide in Building #2 in 2016 due to customer business decision. • Stopped storing Phosphoric Acid 75% in above ground storage tank in 2015 due to volume usage and this product in now being managed/supplied in totes. Per the inspection report for a site visit conducted in June 2019, two areas of concern were the sump pump usage and the used oil storage. The sump pumps discharge to secondary containment. Some is collected for reuse, some discharged to outfall 002, but there was no evidence of contamination at outfall 002. The stormwater inspector suggested documenting sump pump use. The inspection report also stated the used oil room is inside a warehouse but there is capability for leaking totes to go outside. The stormwater inspector suggested developing a plan for this area. Outfall 001: Drainage area includes Building #8. Outfall 002: Drainage area includes Building #3, Building #4, Building #6, paved surface areas, and storage containers. Outfall 003: Drainage area includes the Main Office, Building #1, Building #2, Building #4, Building #7, paved surface lots, and storage containers. =FRUIT1111 Drainage area includes the containment pit, storage tanks, solar array, infiltration basin, Building #5, paved roads, and grassy areas. Why Industrial Sites with Stormwater are Subject to a Permit: Federal NPDES regulations define stormwater discharge associated with industrial activity in 40 CFR Page 2 of 8 §122.26 (b)(14) as: "the discharge from any conveyance that is used for collecting and conveying storm water and that is directly related to manufacturing, processing or raw materials storage areas at an industrial plant. The term does not include discharges from facilities or activities excluded from the NPDES program under this part 122. For the categories of industries identified in this section, the term includes, but is not limited to, storm water [sic] discharges from industrial plant yards; immediate access roads and rail lines used or traveled by carriers of raw materials, manufactured products, waste material, or byproducts used or created by the facility; material handling sites; refuse sites; sites used for the application or disposal of process waste waters (as defined at part 401 of this chapter); sites used for the storage and maintenance of material handling equipment; sites used for residual treatment, storage, or disposal; shipping and receiving areas; manufacturing buildings; storage areas (including tank farms) for raw materials, and intermediate and final products; and areas where industrial activity has taken place in the past and significant materials remain and are exposed to storm water. For the purposes of this paragraph, material handling activities include storage, loading and unloading, transportation, or conveyance of any raw material, intermediate product, final product, byproduct or waste product. The term excludes areas located on plant lands separate from the plant's industrial activities, such as office buildings and accompanying parking lots as long as the drainage from the excluded areas is not mixed with storm water [sic] drained from the above described areas." Section 2. Monitoring Information and Compliance History: • June 2015 to September 2021, benchmarks exceeded for (only SW002 data provided): o pH: Minimum not reached 3 times Documentation of ROS was not found in the permit file (only 1 outfall reported monitoring, but 4 outfalls exist). Permittee was instructed in 2018 to apply for NCG500000 coverage for boiler blowdown, but no permit application or issuance was found in BIMS. Enforcement action may be needed (defer to WiRO). Per an email from Brian Lambe (WiRO) on 10/24/2022, the facility needs to apply for ROS. They have been sampling Outfall #2, but not the other three outfalls because they do not discharge on a regular basis. The permittee will need to document no discharge to be able to apply. There are three (3) boiler outfalls that blowndown every day, with minor amounts of discharge that soak into the ground. DEMLR staff have reached out to DWR staff concerning this. Additionally, the discharge of the secondary containment may need greater explanation. Most of the contents of the secondary containment around the tank farm is pumped to a waste tote. The permittee will need to document discharges of the containment to the outfall #2 on a quantitative basis. Threatened/endangered species: There are several threatened/endangered species in the vicinity of the facility. These include the Northern long-eared bat (threatened), Eastern big -eared bat (special concern), Sandhills Milk -vetch (special concern-V), southern hognose snake (threatened), eastern Page 3 of 8 coral snake (endangered), Xeric Sandhill Scrub (Typic Subtype), Tidal Freshwater Marsh (Giant Cordgrass Subtype), Tidal Freshwater Marsh (Cattail Subtype). Section 3. Proposed Monitoring for Stormwater Discharges: The Division considered potential pollutants from past and present industrial activities and data was submitted for June 2015 to September 2021. Quantitative sampling included pH and COD. The Division is proposing a permit structure with outfall-specific monitoring for discharges. Parameters are based on potential pollutants in the drainage area, sampling results, and in some cases, dependent upon future activities (e.g., ash removal through the drainage area). Below is a table of the proposed monitoring for each outfall at the SAS Solar site. Outfalls SW001, SW002, SW003, and SWO04 Quarterly monitoring Total Suspended Solids BASIS: Potential pollutant from drainage area and BMP (TSS) effectiveness indicator. Quarterly monitoring p H BASIS: Pollutant indicator and previous benchmark exceedances in past monitoring. Quarterly monitoring Total Rainfall BASIS: Discharge potential indicator Quarterly monitoring Non -Polar Oil &Grease BASIS: Potential pollutant from lubricants; Method 1664 SGT-HEM targets petroleum -based O&G Quarterly monitoring Monthly Oil Usage BASIS: Potential pollutant indicator Quarterly monitoring COD BASIS: Pollutant indicator for variety of chemicals used onsite Stormwater Benchmarks and Tiered Response: Rather than limits, North Carolina NPDES Stormwater permits contain benchmark concentrations. Stormwater benchmarks are numerical action levels for stormwater monitoring. Benchmarks are not effluent limits, and benchmark exceedances are not permit violations. Benchmarks provide facilities a tool for assessing the significance of pollutants in stormwater discharges and the effectiveness of best management practices (BMPs). Benchmark concentrations are intended as guidelines for the facility's development and implementation of the Stormwater Pollution Prevention Plan (SWPPP). Page 4 of 8 Benchmark exceedances require the permittee to increase monitoring, increase management actions, increase record keeping, and/or install stormwater BMPs in a tiered program. The permit establishes a tiered approach to specify actions the permittee must take in response to analytical results above benchmark concentrations. The tiered structure of the permit provides the permittee and DEMLR wide flexibility to address issues that may arise with one or more parameters and/or outfalls. Metals benchmarks are calculated to mimic acute water quality standards and with the guidance of DWR. NC DWR follows established federal procedures for calculating acute standards when developing the benchmarks. Just like the acute standards, metals benchmarks normally reflect one half of the calculated Final Acute Value (the "1/2 FAV"). In most cases, translation into total recoverable values is based on an assumed hardness of 25 mg/L and a total suspended solids (TSS) concentration of 10 mg/L. Acute standards protect aquatic life from negative impacts of short-term exposure to higher levels of chemicals where the discharge enters a waterbody. The Stormwater Permitting Program applies this approach because of the ephemeral nature of rainfall events. The Division may evaluate results to determine if a smaller suite of parameters for some outfalls is adequate to characterize potential pollution or BMP effectiveness. For parameters that do not have a stormwater benchmark, the Division may develop a benchmark value if appropriate toxicity data become available or if rising trends in concentrations suggest a persistent source. A summary of the benchmarks in the draft permit, and their basis, is below: Parameter Benchmark Basis COD 120 mg/L BPJ; Generally found at levels 4x BOD5 in domestic wastewaters Total Suspended 100 mg/L National Urban Runoff Program (NURP) Study, Solids TSS 1983 H 6 s.u. — 9 s.u. NC Water Quality Standard (Range) Non -Polar Oil & Review of other state's daily maximum Grease, EPA 15 mg/L benchmark concentration for this more targeted Method 1664 O&G; NC WQS that does not allow oil sheen in SGT-HEM waters Stormwater Pollution Prevention Plan: The proposed permit conditions reflect the EPA and NC's pollution prevention approach to stormwater permitting. The Division's maintains that implementation of Best Management Practices (BMPs) and traditional stormwater management practices that control the source of pollutants meets the definition of Best Available Technology (BAT) and Best Conventional Pollutant Control Technology (BCT). The permit conditions are not numeric effluent limitations but are designed to be flexible requirements for implementing site -specific plans to minimize and control pollutants in stormwater discharges associated with the industrial activity. Title 40 Code of Federal Regulations (CFR) § 122.44(k)(2) authorizes the use of BMPs in lieu of numeric effluent limitations in NPDES permits when the agency finds numeric effluent limitations to be infeasible. The agency may also impose BMP requirements which are "reasonably necessary" to carry out the purposes of the Act under the authority of 40 CFR 122.44(k)(3). The conditions proposed in this draft permit are included under Page 5 of 8 the authority of both of these regulatory provisions. In essence, the pollution prevention and BMP requirements operate as limitations on effluent discharges that reflect the application of BAT/BCT. Flexibility in Tier Responses: Tier Two actions provide an opportunity for the permittee to propose an alternative monitoring plan for approval by the Region: • Alternatively, in lieu of steps 2 and 3, the permittee may, after two consecutive exceedances, exercise the option of contacting the DEMLR Regional Engineer as provided below in Tier Three. The Regional Engineer may direct the response actions on the part of the permittee as provided in Tier Three, including reduced or additional sampling parameters or frequency. • If pursuing the alternative above after two consecutive exceedances, the permittee may propose an alternative monitoring plan for approval by the Regional Engineer. The permit therefore allows the permittee to petition the Regional Office for monitoring changes sooner than Tier Three (upon any four benchmark exceedances) and gives guidance on one option to take. For example, the permittee may request that mercury only be monitored semi-annually under the tiers, or that only parameters over the benchmark be monitored more frequently. In this way, changes to the monitoring scheme for any outfall could be handled outside of a permit modification. Other Proposed Requirements: • It is standard for Stormwater Pollution Prevention Plan (SWPPP) requirements to include an annual certification that stormwater outfalls have been evaluated for the presence of non-stormwater discharges, and if any are identified, how those discharges are permitted or otherwise authorized. • Requirement to submit a request for permit modification if the facility identifies or creates any new outfalls, removes outfalls, or alters any drainage area that changes potential pollutants. • The Division expects the permittee to apply best professional judgment and consider the safety of its personnel in fulfilling sampling obligations under the permit. • Federal regulations require electronic submittal of all discharge monitoring reports (DMRs). If a state does not establish a system to receive such submittals, then permittees must submit DMRs electronically to the EPA. • Quarterly QualitativeNisual Monitoring to assure regular observation of outfalls throughout year. Section 4. Changes from previous permit to draft: • Monitoring increased from semi-annually to quarterly for all parameters (qualitative and quantitative) • "No discharge" clarifications made • 'No requirement added • Boilerplate language moved into body of the permit; boilerplate no longer attached Page 6 of 8 • Benchmarks updated for parameters per guidance from DWR Water Quality Standards staff on stormwater benchmarks • Clarification made that monitoring for TSS, non -polar O&G, and new motor oil usage required for all outfalls Section 5. Changes from draft to final: • None Section 6. Discussions with the Facility and Regional Office: • Initial contact with facility made: 4/1/2022 • Initial contact with Regional Office: 4/1/2022 • Draft sent to CO peer review: 5/26/2022 • Draft sent to Mooresville Regional Office: 9/19/2022 • Final permit sent for supervisor signature: 11/8/2022 Section 7. Comments received on draft permit: • Brian Lambe (WiRO; via email 4/4/2022): Concern to be addressed is potential pumping out of the secondary containment for the process area. Permittee previously argued that documenting this would be difficult. o Bethany Georgoulias (CO; via email 9/19/2022): How big is the secondary containment area? We treat secondary containment for tanks > 1 MGD for petroleum storage as wastewater and issue WW permits instead of the NCG08 SW permit. If it's a huge area and very contaminated, could be a WW issue. • Brian Lambe (WiRO; via email 10/24/2022): o The permittee may need to send an SOP for secondary containment discharging to the outfall #2. o The used oil area is under cover, the permittee has installed a metal barrier but it needs to be contained better as there are gaps at the corners. Permittee said they would continue to work on it. There is a drain in the room as well. o Recommend issuing the permit, these are issues that can be worked on. I don't think they are contributing to offsite pollution at this time. • Vaughn Rizzo (permittee; via email 9/27/2022): o Draft Permit changes #2 —table #1 benchmarks on page 13 are mg/L, not ug/L? ■ DEMLR response: The cover letter erroneously included a common changed in other permits. You may disregard this comment on the cover letter o Draft Permit Page #13 footnote #3 — onsite rain gauge is required. Final Permit #NCS000084 issued in 2015, page #5 states "An onsite rain gauge or local rain gauge reading must be recorded". I prefer government Page 7 of 8 sponsored webpage [NOAA (weather.gov)] for rainfall totals? Draft Permit Footnote #2 on page 13, mentions "local precipitation data". ■ DEMLR response: The permit requires an onsite rain gauge is required unless an isolated site is frequently unmanned. This is a standard requirement in all stormwater permits, therefore, this condition will not change. o The draft permit requires samples to be taken at all outfalls, Final Permit # NCS000084, issued in 2015, requires samples to be taken at outfall #2, this is the only location on -site that falls under vehicle maintenance activities. Page #5 table #1. ■ DEMLR response: Unless representative outfall (ROS) status is granted, samples must be taken at all outfalls. If you wish to request ROS, please see the instructions from our website. Page 8 of 8 RECEIVED LOCAL 1 0 p-i 1, R-Stormwater Program StarNews I The Dispatch PO Box 631245 Cincinnati, OH 45263-1245 Times -News PROOF OF PUBLICATION Ncdenr/DemIC/Stormwater 1612 MAIL SERVICE CTR RALEIGH NC 27699 STATE OF NORTH CAROLINA, COUNTY OF NEW HANOVER The Wilmington Star -News, a newspaper printed and published in the city of Wilmington, and of general circulation in the County of New Hanover, State of North Carolina, and personal knowledge of the facts herein state and that the notice hereto annexed was Published in said newspapers in the issue dated: 09/23/2022 and that the fees charged are legal. Sworn to and subscribed before on 09/23/2022 Publication Cost: $178.20 Order No: 7813347 # of Copies: — Customer No: 490620 -1 PO #: TI [IS IS NOT AN INVOICE! Please do not use thisform fir paryment remittance. SARaH ,TELSEiV \!nary r^ublic State of ''lsconsin NORTH CAROLINA ENVIRON- MENTAL MANAGEMENT COMMISSION INTENT TO ISSUE NPDES STORMWATER DISCHARGE PERMITS The North Carolina Environmen- tal Management Commission proposes to issue NPDES stormwater discharge Permit(s) to the Person(s) listed below. Public comment or obiection to the -draft per�its-is invited. Writ- ten comments regarding the Proposed Permit will be accepted until 30 days after the publish date of this notice and considered in the final determination regard- ing permit issuance and Permit Provisions. The Director of the NC Division of Energy, Mineral, and Land Resources (DEMLR) may hold a Public hearing should there be a significant degree of public interest. Please mail comments and/or information requests to DEMLR at 1612 Mail Service Center, Raleigh, NC 27699-1612. • South Atlantic Services, Inc. (PO Box 1886, Wilmington, NC 28402-18861 has requested renewal of Permit NCS000084 for the SAS Solar facility in New Hanover County. This facility discharges to Northeast Cape Fear River in the Cape Fear River Basin. Interested Persons may visit DEMLR at 512 N. Salisbury Street, Raleigh, NC 27604 to review information on file. Addi- tional information on NPDES permits and this notice may be found on our website: hffps://deq.nc.gov/about/divisions/ energy-mineral-and-land- resou rces/stormwater/stormwo- terprogram/stormwater-publ ic- notices, or by contacting Brianna Young at brlanna.young®ncdenr.gov or- 919-707-3647. September 20, 2022 Pagel of 1 Young, Brianna A From: Lambe, Brian Sent: Monday, October 24, 2022 12:05 PM To: Young, Brianna A Subject: FW: NCS000084 draft permit for public notice Attachments: NCS000084_B I M S_20221021.pdf I left my phone at home. The pics will clarify the secondary containment issue about discharging to the outfall #2. They may need to send us a SOP for that activity. The boiler blowdown should not effect the stormwater discharges. The flow is minor and infiltrates. The used oil area is under cover, they have installed a metal barrier but it needs to be contained better as there are gaps at the corners. Rizzo said he would continue to work on it. There is a drain in the room as well. Recommend issuing the permit, these are issues that can be worked on. I don't think they are contributing to offsite pollution at this time. Brian Lambe Environmental Specialist 910-796-7313 919-268-1678 cell State of North Carolina I Environmental Quality I Energy, Mineral and Land Resources 127 Cardinal Drive Extension I Wilmington, NC 28405 910 796 7215 T 1910 350 2004 F I ht!R://i)ortal.ncdenr.org/web/Ir/ From: Young, Brianna A <Brianna.Young@ncdenr.gov> Sent: Friday, October 21, 2022 9:10 AM To: Lambe, Brian <brian.lambe@ncdenr.gov> Subject: RE: NCS000084 draft permit for public notice Hello Brian, Have you had a chance to review the NCS000084 draft and questions? The public comment period is coming to a close on Monday and I'd like to move forward finalizing the permit. Thanks, Brianna Brianna Young, MS (she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program INC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov (e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging time. From: Young, Brianna A Sent: Wednesday, October 12, 2022 2:36 PM To: Lambe, Brian <brian.lambe@ncdenr.gov> Subject: RE: NCS000084 draft permit for public notice Hello Brian, I wanted to follow up and see if you'd had a chance to review the draft permit and fact sheet for NCS000084 SAS Solar. Are you able to provide any assistance on the questions mentioned in my previous email? Thanks, Brianna Brianna Young, MS (she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR) Brlanna.Young@ncdenr.gov (e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging time. From: Lambe, Brian <brian.lambe@ncdenr.gov> Sent: Monday, September 19, 2022 5:00 PM To: Young, Brianna A <Brianna.Young@ncdenr.gov> Subject: RE: NCS000084 draft permit for public notice I will aim for next week. Brian Lambe Environmental Specialist 910-796-7313 919-268-1678 cell State of North Carolina I Environmental Quality I Energy, Mineral and Land Resources 127 Cardinal Drive Extension I Wilmington, NC 28405 910 796 7215 T 1910 350 2004 F I httn://12ortal.ncdenr.or web/Ir/ From: Young, Brianna A <Brianna.Young@ncdenr.gov> Sent: Monday, September 19, 2022 2:58 PM To: Lambe, Brian <brian.lambe@ncdenr.gov>; Sams, Dan <dan.sams@ncdenr.gov> Subject: NCS000084 draft permit for public notice Hello Brian, Please find attached the draft NPDES stormwater permit for the South Atlantic Services, Inc. SAS Solar site (NCS000084) in New Hanover County. This draft permit will be public noticed hopefully by next week. Please provide any comments by October 27, 2022. During your review, I request WiRO provide feedback on notes under Sections 2 and 7 of the fact sheet (see attached) concerning ROS, NCG500000 coverage, and the secondary containment area. I would appreciate any follow up or feedback you can provide on these items. Let me know if you need anything else to complete review of this draft permit. Thanks, Brianna Brianna Young, MS (she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov (e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 , �: D E " �� NORTH CAROLINA - Department of Environmental Quality Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging time. Young, Brianna A From: Vaughn Rizzo <VRizzo@sas-na.com> Sent: Wednesday, October 12, 2022 11:26 AM To: Young, Brianna A; Frank Hamilton Cc: Jeff Grizzle Subject: RE: [External] RE: Draft NPDES stormwater permit for SAS Solar (NCS000084) CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Ms. Young Please proceed with the permit process, SAS Solar will not be requesting Representative Outfall Status. Regards, Vaughn Rizzo HSE Coordinator South Atlantic Services, Inc. 3527 Hwy 421 N. Wilmington, NC 28401 (910)763-3496 ext. 4131 vrizzo(cDsas-na.com SA� $Q0�ffWATL"nYC3ERWk5 MK From: Young, Brianna A <Brianna.Young@ncdenr.gov> Sent: Wednesday, September 28, 2022 2:13 PM To: Vaughn Rizzo <VRizzo@sas-na.com>; Frank Hamilton <FHamilton@sas-na.com> Cc: Jeff Grizzle <Jgrizzle@sas-na.com> Subject: RE: [External] RE: Draft NPDES stormwater permit for SAS Solar (NCS000084) CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Vaughn, Please see below for responses to your questions. 1. Draft Permit changes #2 — table #1 benchmarks on page 13 are mg/L, not ug/L? The cover letter erroneously included a common changed in other permits. You may disregard this comment on the cover letter. 1 Draft Permit Page #13 footnote #3 — on site rain gauge is required. Final Permit # NCS000084, issued in 2015, page #5 states " An on -site rain gauge or local rain gauge reading must be recorded". I prefer government sponsored webpage , NOAA (weather.gov) https://wl.weather.gov/data/obhistory/KILM.htmi for rainfall totals? Draft Permit Footnote #2 on page 13, mentions "local precipitation data". The permit requires an onsite rain gauge is required unless an isolated site is frequently unmanned. This is a standard requirement in all stormwater permits, therefore, this condition will not change. 3. The draft permit requires samples to be taken at all outfalls, Final Permit # NCS000084, issued in 2015, requires samples to be taken at outfall #2, this is the only location on -site that falls under vehicle maintenance activities. Page #5 table #1. Unless representative outfall (ROS) status is granted, samples must be taken at all outfalls. If you wish to request ROS, please see the instructions from our website below: Complete the Representative Outfall Status (ROS) Request Form. Mail one hard copy of the form and supporting documents directly to the appropriate Regional Office (see form). In addition, e-mail the form and supporting documents to Bethany Georgoulias. There is no fee for a representative outfall status request. Thank you, Brianna Young, MS (she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov (e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging time. From: Vaughn Rizzo <VRizzo@sas-na.com> Sent: Tuesday, September 27, 2022 1:51 PM To: Young, Brianna A <Brianna.Young@ncdenr.gov>; Frank Hamilton <FHamilton@sas-na.com> Cc: Jeff Grizzle <Jgrizzle@sas-na.com> Subject: [External] RE: Draft NPDES stormwater permit for SAS Solar (NCS000084) CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Ms. Young I have three questions on the draft. Draft Permit changes #2 — table #1 benchmarks on page 13 are mg/L, not ug/L? Draft Permit Page #13 footnote #3 — on site rain gauge is required. Final Permit # NCS000084, issued in 2015, page #5 states " An on -site rain gauge or local rain gauge reading must be recorded". I prefer government sponsored webpage , NOAA (weather.gov) https://wl.weather.gov/data/obhistory/KILM.html for rainfall totals? Draft Permit Footnote #2 on page 13, mentions "local precipitation data". The draft permit requires samples to be taken at all outfalls, Final Permit # NCS000084, issued in 2015, requires samples to be taken at outfall #2, this is the only location on -site that falls under vehicle maintenance activities. Page #5 table #1. Thank you for your help, Vaughn Rizzo HSE Coordinator South Atlantic Services, Inc. 3527 Hwy 421 N. Wilmington, NC 28401 (910)763-3496 ext. 4131 vrizzoC@sas-na.com SAS SOOT" ATLANTK SWAM. RK From: Young, Brianna A <Brianna.Young@ncdenr.gov> Sent: Monday, September 26, 2022 8:20 AM To: Frank Hamilton <FHamilton(o)sas-na.com> Cc: Jeff Grizzle <Jgrizzle@sas-na.com>; Vaughn Rizzo <VRizzo@sas-na.com> Subject: Draft NPDES stormwater permit for SAS Solar (NCS000084) CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Good morning, Please find attached the draft NPDES stormwater permit for the South Atlantic Services, Inc. SAS Solar site (NCS000084) in New Hanover County. Please provide any comments on this draft permit by October 27, 2022. Thank you, Brianna Young, MS (she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov (e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 D b z - ��� - E_ tjp� NORTH CAROLINA Department of Environmental Quality Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging time. Young, Brianna A From: Vaughn Rizzo <VRizzo@sas-na.com> Sent: Wednesday, May 25, 2022 11:55 AM To: Young, Brianna A Cc: Frank Hamilton; Jeff Grizzle Subject: RE: [External] FW: Permit Contact Update Confirmation for NCS000084 CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Brianna, All the information is correct and no further changes since the application was filed. The contact information was changed from Walter Kennedy to me on 4/1/2022. Thank You, Vaughn Rizzo HSE Coordinator South Atlantic Services, Inc. 3527 Hwy 421 N. Wilmington, NC 28401 (910)763-3496 ext. 4131 vrizzo(CDsas-na.com SAS- 5*VTW ATLiLWTK$E/i4PU& W*[ From: Young, Brianna A <Brianna.Young@ncdenr.gov> Sent: Wednesday, May 25, 2022 11:26 AM To: Vaughn Rizzo <VRizzo@sas-na.com> Cc: Frank Hamilton <FHamilton@sas-na.com>; Jeff Grizzle <Jgrizzle@sas-na.com> Subject: RE: [External] FW: Permit Contact Update Confirmation for NCS000084 CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Good morning, I apologize for the delay in getting back to you. Please find attached a copy of the renewal application for NCS000084 that was submitted to the Stormwater Program in 2018. Please let me know if I can be of further assistance. Thank you, Brianna Young, MS (she/her/hers) Industrial Individual Permits Coordinator Stormwater Program NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov (e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging time. From: Young, Brianna A Sent: Tuesday, May 17, 2022 8:47 AM To: Vaughn Rizzo <VRizzo@sas-na.com> Cc: Frank Hamilton <FHamilton@sas-na.com>; Jeff Grizzle <Jgrizzle@sas-na.com> Subject: RE: [External] FW: Permit Contact Update Confirmation for NCS000084 Vaughn, I am not in the office this week and do not have an electronic copy available. When I am back in the office next week, I can scan and send a copy of the application to you. Thank you, Brianna Young, MS (she/her/hers) Industrial Individual Permits Coordinator Stormwater Program NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov (e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging time. From: Vaughn Rizzo <VRizzo@sas-na.com> Sent: Monday, May 16, 2022 10:41 AM To: Young, Brianna A <Brianna.Young@ncdenr.gov> Cc: Frank Hamilton <FHamilton@sas-na.com>; Jeff Grizzle <JRrizzle@sas-na.com> Subject: RE: [External] FW: Permit Contact Update Confirmation for NCS000084 CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Brianna, Can you please provide me a copy of the renewal application, my predecessor did not leave me a copy of the application? Regards, Vaughn Rizzo HSE Coordinator South Atlantic Services, Inc. 3527 Hwy 421 N. Wilmington, NC 28401 (910)763-3496 ext. 4131 vrizzoC@sas-na.com SAS SOMTH ATLANTK 3ERYK45 M From: Young, Brianna A <Brianna.Young@ncdenr.gov> Sent: Thursday, May 12, 2022 12:27 PM To: Vaughn Rizzo <VRizzo@sas-na.com> Cc: Frank Hamilton <FHamilton@sas-na.com>; Jeff Grizzle <JRrizzle@sas-na.com> Subject: RE: [External] FW: Permit Contact Update Confirmation for NCS000084 CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Vaughn, Thank you for forwarding this information. Please note that I have not received additional information that was also requested. This includes: • Coordinates for each outfall; • An electronic spreadsheet summarizing all of the monitoring data that has been collected since the effective date of the current permit; • Verification that the information in the renewal application is still complete and correct; and • An explanation of any operational changes since the renewal application was submitted. Please let me know if you have any questions. Thank you, Brianna Young, MS (she/her/hers) Industrial Individual Permits Coordinator Stormwater Program NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov (e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging time. From: Vaughn Rizzo <VRizzo@sas-na.com> Sent: Thursday, May 12, 2022 8:31 AM To: Young, Brianna A <Brianna.Young@ncdenr.Rov> Cc: Frank Hamilton <FHamilton@sas-na.com>; Jeff Grizzle <Jgrizzle@sas-na.com> Subject: [External] FW: Permit Contact Update Confirmation for NCS000084 CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Brianna, Please see the attached Permit Contact Update for NCS000084. I am sorry I thought the update permit contact information would be forwarded to you. Please contact me with any questions. Regards, Vaughn Rizzo HSE Coordinator South Atlantic Services, Inc. 3527 Hwy 421 N. Wilmington, NC 28401 (910)763-3496 ext. 4131 vrizzo(a�sas-na.com SA� 500H AT"NTK j#ffieK $, jh[ From: laserfiche@ncdenr.gov <laserfiche@ncdenr.eov> Sent: Monday, April 4, 2022 8:16 AM To: Vaughn Rizzo <VRizzo@sas-na.com> Cc: Kieu.Tran@ncdenr.gov; bethany.eeoreoulias@ncdenr.gov Subject: Permit Contact Update Confirmation for NCS000084 CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Your Permit Contact Update Request for permit no. NCS000084 has been processed. Please wait 24-48 hours and then check the following link to verify the change(s) has been made: Permit Contact Summary Report Reviewer Comments (if recorded): If you included a billing contact update, our Program Billing Specialist has just been notified. Please check the summary report link above periodically to verify those changes were also made. If you have any questions about the status, please contact Bethany Georgoulias at bethany.georgoulias@ncdenr.gov or Kieu Tran at kieu.tran@ncdenr.gov The NC DEMLR Stormwater Program Young, Brianna A From: Vaughn Rizzo <VRizzo@sas-na.com> Sent: Monday, May 16, 2022 2:44 PM To: Young, Brianna A Cc: Frank Hamilton; Jeff Grizzle Subject: RE: [External] FW: Permit Contact Update Confirmation for NCS000084 Attachments: Stormwater Discharge # 002.xlsx CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Brianna, Attached is a spreadsheet of the monitoring data. The GPS coordinates for each outfall are: Outfa 11001: 34.292780 -77.973890 Outfa 11002: 34.292366 -77.971871 Outfa 11003: 34.291415 -77.973562 Outfa 11004: 34.290854 -77.973562 No operational changes since renewal application. Regards, Vaughn Rizzo HSE Coordinator South Atlantic Services, Inc. 3527 Hwy 421 N. Wilmington, NC 28401 (910)763-3496 ext. 4131 vrizzo(CDsas-na.com i6 WTH ATL ANTI€ %FT WIM, i `,K 1 From: Young, Brianna A <Brianna.Young@ncdenr.gov> Sent: Thursday, May 12, 2022 12:27 PM To: Vaughn Rizzo <VRizzo@sas-na.com> Cc: Frank Hamilton <FHamilton@sas-na.com>; Jeff Grizzle <Jgrizzle@sas-na.com> Subject: RE: [External] FW: Permit Contact Update Confirmation for NCS000084 CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Vaughn, Thank you for forwarding this information. Please note that I have not received additional information that was also requested. This includes: • Coordinates for each outfall; • An electronic spreadsheet summarizing all of the monitoring data that has been collected since the effective date of the current permit; • Verification that the information in the renewal application is still complete and correct; and • An explanation of any operational changes since the renewal application was submitted. Please let me know if you have any questions. Thank you, Brianna Young, MS (she/her/hers) Industrial Individual Permits Coordinator Stormwater Program NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR) Brlanna.Young@ncdenr.gov (e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging time. From: Vaughn Rizzo <VRizzo@sas-na.com> Sent: Thursday, May 12, 2022 8:31 AM To: Young, Brianna A <Brianna.Young@ncdenr.gov> Cc: Frank Hamilton <FHamilton@sas-na.com>; Jeff Grizzle <Jgrizzle@sas-na.com> Subject: [External] FW: Permit Contact Update Confirmation for NCS000084 CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Brianna, Please see the attached Permit Contact Update for NCS000084. I am sorry I thought the update permit contact information would be forwarded to you. Please contact me with any questions. Regards, Vaughn Rizzo HSE Coordinator South Atlantic Services, Inc. 3527 Hwy 421 N. Wilmington, NC 28401 (910)763-3496 ext. 4131 vrizzo(@sas-na.com SA� UM" ATLANTKUk4y U jh[ From: laserfiche@ncdenr.gov <laserfiche@ncdenr.eov> Sent: Monday, April 4, 2022 8:16 AM To: Vaughn Rizzo <VRizzo@sas-na.com> Cc: Kieu.Tran@ncdenr.gov; bethany.eeoreoulias@ncdenr.gov Subject: Permit Contact Update Confirmation for NCS000084 CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Your Permit Contact Update Request for permit no. NCS000084 has been processed. Please wait 24-48 hours and then check the following link to verify the change(s) has been made: Permit Contact Summary Report Reviewer Comments (if recorded): If you included a billing contact update, our Program Billing Specialist has just been notified. Please check the summary report link above periodically to verify those changes were also made. If you have any questions about the status, please contact Bethany Georgoulias at bethany.georgoulias@ncdenr.gov or Kieu Tran at kieu.tran@ncdenr.gov The NC DEMLR Stormwater Program Table #5 Summary of Stormwater Discharge Sampling Data (outfall # 002) Total Rainfall COD Date (in) (mg/L) pH 6/9/2015 1.2 29 6.2 12/18/2015 0.6 < 25.0 6.7 6/15/2016 0.8 < 25.0 7 12/6/2016 0.4 < 25.0 6.5 12/7/2017 0.4 37 7.2 12/20/2018 0.6 63.7 7 6/24/2019 0.3 N.D. 7.4 2/7/2020 0.97 27.5 6.8 11/13/2020 0.74 N.D. 5.5 3/6/2021 0.88 N.D. 5.2 9/24/2021 0.68 N.D. 4.3 Benchmarks are 120 mg/L for COD and 6 - 9 for pH Young, Brianna A From: Lambe, Brian Sent: Monday, April 4, 2022 9:09 AM To: Young, Brianna A; Sams, Dan Subject: RE: SAS Solar (NCS000084) Nothing major. I recall something about pumping out of the secondary containment for the process area and documenting this. They argued that documenting this would be difficult. Brian Lambe Environmental Specialist 910-796-7313 919-268-1678 cell State of North Carolina I Enviromnental Quality I Energy, Mineral and Land Resources 127 Cardinal Drive Extension I Wihnington, NC 28405 910 796 7215 T 1 910 350 2004 F I hM://uortal.ncdenr.org/web/Ir/ From: Young, Brianna A Sent: Friday, April 1, 2022 10:51 AM To: Lambe, Brian <brian.lambe@ncdenr.gov>; Sams, Dan <dan.sams@ncdenr.gov> Subject: SAS Solar (NCS000084) Good morning, I am beginning to review the SAS Solar renewal application (NCS000084). Please let me know if there are any concerns that need to be addressed during this renewal. Thank you, Brianna Young, MS (she/her/hers) Industrial Individual Permits Coordinator Stormwater Program NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov (e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging time. Compliance Inspection Report Permit: NCS000084 Effective: 08/01/10 Expiration: 07/31/15 Owner: South Atlantic Services Inc SOC: Effective: Expiration: Facility: SAS Solar County: New Hanover 3527 US Hwy 421 N Region: Wilmington Wilmington NC 28401 Contact Person: Jeff W Grizzle Title: Vice President Phone: 910-763-3496 Directions to Facility: System Classifications: SWNC, Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: SW8961220 South Atlantic Services Inc - SAS Solar Inspection Date: 10/21/2022 Entry Time 01:OOPM Primary Inspector: Brian P Lambe Secondary Inspector(s): Reason for Inspection: Routine Permit Inspection Type: Stormwater Discharge, Individual Facility Status: Compliant ❑ Not Compliant Question Areas: Storm Water (See attachment summary) Exit Time: 02:OOPM Phone: Inspection Type: Compliance Evaluation Page 1 of 3 Permit: NCS000084 Owner - Facility: South Atlantic Services Inc Inspection Date: 10/21/2022 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: The SPPP was not available until Vaught Rizzo returned to the office after lunch. He claimed the regular receptionest is knowledgeable about the copy available in the adjacent office. Upon review of the SPPP, all elements of the permit requirements are included and regularly updated. Spill reporting and inspection of secondary containment is found in the SPCC. Employee training is conducted on a regular basis. The SPPP is certified yearly. The facility needs to apply for ROS. They have been sampling Outfall #2. They have not been sampling the other three outfalls because they do not discharge on a regular basis. Rizzo will need to document no discharge to be able to apply. Observed the three boiler outfalls. Contacted DWR Tom Tharrington regarding any needed involvement from DWR. They are blowndown every day, with minor amounts of discharge that soak into the ground. Sampling results are typically non detect for COD, sometimes low on the pH (5.5). The discharge of the secondary containment may need greater explaination. Most of the contents of the secondary containment around the tank farm is pumped to a waste tote. They will need to document discharges of the containment to the outfall #2 on a quantitative basis. This is not the large containment area seen on the map. Page 2 of 3 Permit: NCS000084 Owner - Facility: South Atlantic Services Inc Inspection Date: 10/21/2022 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? 0 ❑ ❑ ❑ # Does the Plan include a General Location (USGS) map? ❑ ❑ ❑ # Does the Plan include a "Narrative Description of Practices"? ❑ ❑ ❑ # Does the Plan include a detailed site map including outfall locations and drainage areas? ❑ ❑ ❑ # Does the Plan include a list of significant spills occurring during the past 3 years? ❑ ❑ ❑ # Has the facility evaluated feasible alternatives to current practices? ❑ ❑ ❑ # Does the facility provide all necessary secondary containment? ❑ ❑ ❑ # 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? ❑ ❑ ❑ # 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? 0 ❑ ❑ ❑ # Does the Plan include a Stormwater Facility Inspection Program? ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? ❑ ❑ ❑ Comment: Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring? ❑ ❑ ❑ ❑ Comment: Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? 0 ❑ ❑ ❑ # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ 0 ❑ Comment: Permit and Outfalls Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? 0 ❑ ❑ ❑ # Were all outfalls observed during the inspection? ❑ ❑ ❑ # 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: Facility has been conducting sampling on outfall #2 only. They will apply for ROS upon initial sampling period for the new permit. Other sampling points do not discharge on regular basis. Page 3 of 3 4/1/22, 10:43 AM North Carolina Secretary of State Search Results • File an Annual Report/Amend an Annual Report • Upload a PDF Filing • Order a Document Online - Add Entity to My Email Notification List • View Filings • Print a Pre -Populated Annual Report form • Print an Amended a Annual Report form Business Corporation Legal Name South Atlantic Services, Inc. Information Sosld: 0135753 Status: Current -Active O Date Formed: 11/23/1970 Citizenship: Domestic Fiscal Month: December Annual Report Due Date: April 15th Currentgnnual Report Status: Registered Agent: Hamilton III, Frank H Addresses Principal Office 3527 Highway 421 North Wilmington, NC 28401-9019 Mailing PO Box 1886 Wilmington, NC 28402-1886 Officers Vice President Nicole Grindstaff PO Box 1886 Wilmington NC 28402 Reg Office 3527 Highway 421 North Wilmington, NC 28401-9019 Vice President Jeff Grizzle PO Box 1886 Wilmington NC 28402 Reg Mailing 3527 Highway 421 North Wilmington, NC 28401-9019 Secretary Berta Hamilton PO Box 1886 Wilmington NC 28402 https://www.sosnc.gov/online_services/search/Business_Registration_ResuIts 1 /2 4/1/22, 10:43 AM North Carolina Secretary of State Search Results President FRANK H. HAMILTON, III PO Box 1886 Wilmington NC 28402 Stock Class: Series A Voting Common Stock Shares: 10000 No Par Value: Yes Class: Series B Nonvoting Common Stock Shares: 90000 No Par Value: Yes https://www.sosnc.gov/online_services/search/Business_Registration_ResuIts 2/2 Permit Coverage Renewal Application Form National Pollutant Discharge Elimination System Fnviranmenral Stormwater Individual Permit Qualify NPDES Permit Number NCS 0000e4 Please provide your permit number in box in the upper right hand corner, complete the information in the space provided below and return the completed renewal form along with the required supplemental information to the address indicated. Owner Information Owner / Organization Name: Owner Contact: Mailing Address: Phone Number Fax Number. E-mail address. Facility Information Facility Name: Facility Physical Address Facility Contact: Mailing Address: Phone Number: Fax Number: E-mail address: Permit Information Permit Contact: Mailing Address: Phone Number: Fax Number: E-mail address: Discharge Information Receiving Stream: Stream Class: Basin: Sub -Basin: Number of Outfalls * Address to which permit coimsporrdence will be mailed South Atlantic Services Inc. -Frank Hamilton, III PO Box 1886 Wilmington, NC 28402-1886 PO Box 1886 Wilmington, NC 28402-1886 910-7833469 910-251-1103 FHamiltonCilsas-na.com SAS Solar 3527 US FWy 421 N Mraing1m, NC 28401 Walter Kenne y PO Box 1886 W lmington, NC 28402-1886 910-7633496 910.251-1103 WKennedy@s na.com Jeff W Griale PO Box 1866 Winninglon, NC 28402-1886 910-7633496 916251-11W JGrizzlo@ s-na.com NE Cape Fear River C; Sv Cape Fear River Basin WA Four(4) RECEIVED APR 02 2016 DENR•LAND QUALITY STORMWATER PERMITTING Facility/Activity Changes Please describe below any changes to your facility or activities since issuance of your permit Attached a separate sheet if necessary. See attached Worn document descrit ng changes over the last 5 years. I certify that I am familiar with the information contained in the application and that to the hest of my knowledge and belief such information is true, complete an accurate. Signature -V1 Date r� 1 V�+O.�VCrr 1'LQ VI Q.'1ti/ COf q.v 'fe JCl�iLj &'4 Print or type name of person E49ning above 13 Title Please return this completed application form Dept. - Stvironm n Program and requested supplemental information to: Dept, of Environmental Cent Quality �1 PP 1612 Mail Service Center Raleigh, North Carolina 27699-1612 SIGNIFICANT CHANGES IN INDUSTRIAL ACTIVITY Listed below are significant changes over the past 5 years at the facility: 1) Installed a new blending kettle/area under the covered loading dock shed in 2013. This new blending area is completely covered and is totally enclosed within a concrete dyke wall. The product to be stored and blended in this area is antifreeze. 2) Installed new tank farm in 2013 containing 5 new tanks beside Building #6 for use with the new blending area described in 1) above. 3) Discontinued the storing and packaging of DEF (Diesel Exhaust Fluid) into drums and totes in 2014. This product was a mixture of water and urea and was stored in an above ground tank. This tank was moved to our Texas facility. 4) Constructed a new main office building in 2017 in close proximity to the old office building and then completely removed the old office building. This new building changed the pervious and impervious areas and a new site map was drawn up to identify this. 5) Began .packaging of motor oil in Building #6 in 2017. Initial packaging was from drum/totes into filling machine and then into quart bottles. Packaging was increased to include 5 gallon HDPE bottles and a new oil tank farm containing 3 new tanks was installed behind Building #6 near the railroad track in 2017. This new tank farm is completely dyked and the pump area is completely covered. A separate SPCC plan was developed to specifically cover this process. 6) Stopped blending and packaging of Lithium Hydroxide in Building #2 in 2016 due to customer business decision. 7) Stopped storing Phosphoric Acid 75% in above ground storage tank in 2015 due to volume usage and this product is now being managed/supplied in totes. SUPPLEMENTAL INFORMATION REQUIRED FOR RENEWAL OF INDIVIDUAL NPDES STORMWATER PERMIT Two copies of each of the following shall accompany this submittal in order for the application to be considered complete: (Do not submit the site Stormwater Pollution Prevention Plan) Initials GOolZ 1. A current Site Map from the Stormwater Pollution Prevention Plan. The location of industrial activities (including storage of materials, disposal areas, process areas and loading and unloading areas), drainage structures, drainage areas for each outfall, building locations and impervious surfaces should be clearly noted. ECG 2. A summary of Analytical Monitoring results during the term of the existing permit (if your permit required analytical sampling). Do not submit individual lab reports. The summary can consist of a table including such items as outfall number, parameters sampled, lab results, date sampled, and storm event data. IOWt —3. A summary of the Visual Monitoring results. Do not submit individual monitoring reports. The summary can consist of a table including such items as outfall number, parameters surveyed, observations, and date monitoring conducted. AGif, 4. A summary of the Best Management Practices utilized at the permitted facility. Summary should consist of a short narrative description of each BMP's in place at the facility. If the implementation of any BMP's is planned, please include information on these BMP's. WGX-5. A short narrative describing any significant changes in industrial activities at the permitted facility. Significant changes could include the addition or deletion of work processes, changes in material handling practices, changes in material storage practices, and/or changes in the raw materials used by the facility. _tAW-'6. Certification of the development and implementation of a Stormwater Pollution Prevention Plan for the permitted facility (Sign and return attached form). If the final year analytical monitoring of the existing permit term has not been completed prior to filing the renewal submittal, then the last years monitoring results should be submitted within 30 days of receipt of the laboratory reports. (i.e. do not withhold renewal submittal waiting on lab results) d4 c J anaJUN @ P P P f P iy{ a V Vnrtlirxsi L'apr�Icnr liivar P r � 4 �' r ��� N �����•,_p � � r ��4 i P y ��p � _ _ r — ' or�rnn ;-01 p0 3i �G•. Z �� pl '(Y�') b .8p I d P APPROXIMATE LOCATION OF N EXISTING STORMITATER INFILTRATIONO VANAPPROVED _ - UNDER NCDENR SIORMWATER / PERFN No. MR ONIM NORMAL S E - DATED OCTOOER 12, 30EA. OUTPALL NO. 00R \ DRAINAGE AREA NO.80i LOCATION MAP DRAwEDGY CUE ALL NO, BLDG. #5 MOTTO SCALE O01 1 m I i I 5 o a SO CONTAINNENTPIE I I a RAILROAOSPMR DRAINAGE AREA SUMMARY DR AGEAREINO.0)1: COVERED UNDER MPDES STU"AATM PERMIT NLS MMSI ORMMEDHYOUIFALL MO. 01 TOTAL DRAINAGE AREA: 1.A AC TOTAL EMSRNO IWEM". AREA: E.AC TOTLLEbS11NGPERVbUSAREA: OJ1 AC FACF)rt1NPEVERY%WH AREA: 7S IRAPIAM AREA ME AG` COVSPED UNDER FREES STORYW NITER PERMIT NCS OtlbF ORAINE0 HV OUIFALL NO.. TOTLL DRAINAGE MEA: .1 AC TOTAL EMOTING MflERNOUS AREA "'AC TOTALEMSTNGPERVgVSMEA: 88EAC PERCEMIMPSVERNOUSAREA: RBAY ORAINAGEMIU MpIt CaVEAEDUNDERMPOFS STORYWATERPETUMMLH OPM GRADED HV OUIFALL NQ0" TOTAL DRAINAGE MEA: 0.W AC TOTAL EXURPRO AMUSTgUB AREA: LTS AC TOTAL EXISTING PERVId1H AREA: ETS AC PMCEM WPERVpUSMEA: )1.09Y ORAMAGE ABEAM. WE NOTE: DRAINAGE AREANOON MM NO OMFALL. NO STURNIATER RUNOFF DRAINS OR DISCHARGES OFESITE APPROXIMATELY US ACRES DRAINS TO AN EXISTING VONMWAYEN INFILTRATION EARN APPROVED URDER MOUNT STORNWATER PERMIT ME SVIE 961 M RENEWAL DATE. aC .. 17, EO). COVERED UNDER FACES WORMOVATER PERMIT NCH FROM AN AC COVERED UNDER NCOENR STORYVIATER PERMIT NO. TONS 9812M FORMAL TOTAL TRACT AREA: I.. AC TOTAL DRAINAGE ARE A TO EXTUNG I WRTRATION BASIN: 4.9E AC TOTAL EMOTING IMPERVIOUS AREA OWNING TO ME EXISTING STORIMATER INRLTRATONHAHm: 3Ol AC TOTAL EXISTING PERVIOUS AREA UGANDA TO ME EXISTING SPoRY .."FILTRATION EACH ]9N AC PMCFM IYPERMUS AREA TOME MET IC HTORARY.I. 066.. HARM.RMMAGEMEA: b.YY4 COMRADE AREA NOTES: . CANNERS AMA RAW REMAINS UNCHANGED WMM TIE ADq.ON OF 1NE HEW M PLOIPN4 MO OIL STORAGE iANN FARM COXTAMIENT MEA REFERENCED N RENRON NI. TIME S NO HEY MCREAY OR DEGREASE N NPEIMOUS AREA MOTION DRAINAGE AREA MO, WL 0 0 OUTPACE NO.002 FIB\ LFtg BLDG.I #6 BLDG. #7 1 ORAINAOE AREA DRAINAGE AREA NO.003 NO, 003 DRAINEDOY DRAINED EY OUTFALL N0. 111 OUTFALL NO.003 0 I s EH I 0 G#4 © 0 v DNMNAGEAREA tl9 NG. ms DRUMMED OY OUTFALL N0.003 I o G. #1 BLDG. �y BLDG. #3 1Fl A. 1 MEEMSTWOSNECpOINASEGO ME1 RAMS ANAMALMW RAILROAD SPUR SURVEY. L HOMOMYERMOUXEMIROWOIMIEPIREECTLWrtA MAIN US RAILROAD LINE IXG E THE OMER M RESPONASLE FOR ORTAM MY LCCAL. STATE AND FEDERAL RIUMANDAPPROVAL9MREOUPEU. LEGEND _y rt M46165 AWIb'�S!" FOII.SO 9QE OMYEG C..TD EUMAN A DOER ® UNCOVEREOPARUMACIMCERSTATMN WASIVEM WIMENMCERNLDIN. ® PEAMUS AREAS � . DRARMC EACNFAIL. ® IIXAMIR OF ORANAOE MEA CUEALL ® TMNAHOTAFKNUMBER ®®® OLYTONGE iAKK NYYHER YPMWXISARFA9.ASRYLiICdNIIEIE z a U9 6 Z z ZS Z ow 5 A, N v I w D ED Z ¢ S C W On i C1 RESULTS OF VISUAL MONITORING FOR YEARS 2016 AND 2017 Outfall No. 1 Outfall No. 2 Outfall No. 3 Outfall No. 4 Outfall No. 1 Outfall No. 2 Outfall No. 3 Outfall No. 4 Parameter Checked and Date Checked 6/15/16 12/6/16 6/15/16 12/6/16 6/15/16 12/6/16 6/15/16 12/6/16 7/18/17 12/7/17 7/18/17 12/7/17 7/18/17 12/7/17 7/18/17 12/7/17 Color Pass Pass Pass Pass Pass Pass Pass Pass Pass Pass Pass Pass Pass Pass Pass Pass Odor None None None None None None None None None None None None None None None None Clarity Clear Clear Clear Clear Clear Clear Clear Clear Clear Clear Clear Clear Clear Clear Clear Clear Floating Solids None None None None None None None None None None None None None None None None Suspended Solids None None None None None None None None None None None None None None None None Foam None None None None None None None None None None None None None None None None Oil Sheen None None None None None None None None None None None None None None None None Other indicators of Pollution None present None present None present None present None present None present None present None present None present None present None present None present None present None present None present None present H NA NA 7.0 6.50 NA NA NA NA NA NA 6.5 7.20 NA NA NA NA COD NA NA <25.0. <25.0 NA NA NA NA NA NA <25.0 37.0 NA NA NA NA (NOTE: Monitoring data for other previous years is available upon request.) RESULTS OF VISUAL MONITORING FOR YEARS 2014 AND 2015 Outfall No. 1 Outfall No. 2 Outfall No. 3 Outfall No. 4 Outfall No. 1 Outfall No. 2 Outfall No. 3 Outfall No. 4 Parameter Checked and Date Checked 6/27/14 11/25/14 6/27/14 11/25/14 6/27/14 11/25/14 6/27/14 11/25/14 6/9/15 12/18/15 6/9/15 12/18/15 6/9/15 12/18/15 6/9/15 12/18/15 Color Pass Pass Pass Pass Pass Pass Pass Pass Pass Pass Pass Pass Pass Pass Pass Pass Odor None None None None None None None None None None None None None None None None Clarity Clear Clear Clear Clear Clear Clear Clear Clear Clear Clear Clear Clear Clear Clear Clear Clear Floating Solids None None None None None None None None None None None None None None None None Suspended Solids None None None None None None None None None None None None None None None None Foam None None None None None None None None None None None None None None None None Oil Sheen None None None None None None None None None None None None None None None None Other indicators of Pollution None present None present None present None present None present None present None present None present None present None present None present None present None present None present None present None present H NA NA 6.5 7.1 NA NA NA NA NA NA 6.20 6.70 NA NA NA NA COD NA NA <25.0 84.0 NA NA NA NA NA NA 29.0 <25.0 NA NA NA NA (NOTE: Monitoring data for other previous years is available upon request.) c Tf � it At �`.y r /,` J ,0� llJ J jjj i II iIN1AENT' �.` -. L� �'" BUILDING #6 OUTF, 02 BUILDING 0 P LLE. HIGHWFV 1 STORMWATER MANAGEMENT PLAN (BMPs) 1) Tanks a) All tanks have a retaining dyke wall around them in the event of a tank rupture or failure. The dykes are designed to hold 125% of the volume of the largest tank in the dyke. A table listing all the tanks by number, age, construction, and content is maintained. b) All tank levels are checked and inventoried daily. Any major discrepancies in the inventories are immediately investigated. Also, a visual inspection of the piping and overall assessment of the tank farm is performed daily. c) Any rainwater collected in the dyked areas is checked daily. Any rainwater collected in these dyked areas is, at a minimum, visually observed for color, foam, outfall staining, visible sheens and dry weather flow, prior to being discharged. If anything other than rainwater is present or suspected to be present as evidence from the visual inspection, a sample is pulled and checked by the lab for pH and other properties. If evidence of contamination is confirmed, the rainwater shall not be discharged but rather is collected in appropriate containers and held for further analysis. All water collected in dyked areas is recycled back into usable product when at all possible. d) No underground tanks on site. 2) Processes a) All process vessels and mixing vessels have a retaining dyke wall around them. b) All process areas and loading areas are covered where feasible. c) All bulk loading stations are dyked. d) Any outside operations, such as unloading from a rail car or filling drums from a rail car, will keep an employee or supervisor present at all times. In addition, they will keep absorbent material readily available in the event of any spills. e) Sand bag material is available on site if necessary to divert rain water from pits beneath the rail tracks. 3) Maintenance a) Any maintenance work performed on pumps or equipment will be done inside the shop or a covered area where feasible. 1 b) Any hydraulic oil and other maintenance fluids are collected in a waste drum and appropriately disposed of off -site. Any process fluids collected from maintenance work on equipment will be recycled into product when possible. c) It is the responsibility of the Maintenance Supervisor to develop a preventive maintenance schedule for all equipment and forklifts. 4) General Housekeeping a) All spills are cleaned up immediately when and if they happen. Any spilled product is recycled back into good product when not contaminated. b) An inventory of spill control products are kept on hand at all times. Absorbent material specific to oils, acids, and caustics and appropriate neutralizing agents are used when necessary. c) All outside areas are policed once a week for trash. d) Dumpsters maintained on site for plant trash and garbage. Picked up at least twice a week. e) Cardboard and plastic items are segregated and picked up by local recyclers. f) Any solid fugitive material will be swept up immediately and collected for disposal or reprocessing. 4 SIGNIFICANT CHANGES IN INDUSTRIAL ACTIVITY Listed below are significant changes over the past 5 years at the facility: 1) Installed a new blending kettle/area under the covered loading dock shed in 2013. This new blending area is completely covered and is totally enclosed within a concrete dyke wall. The product to be stored and blended in this area is antifreeze. 2) Installed new tank farm in 2013 containing 5 new tanks beside Building #6 for use with the new blending area described in 1) above. 3) Discontinued the storing and packaging of DEF (Diesel Exhaust Fluid) into drums and totes in 2014. This product was a mixture of water and urea and was stored in an above ground tank. This tank was moved to our Texas facility. 4) Constructed a new main office building in 2017 in close proximity to the old office building and then completely removed the old office building. This new building changed the pervious and impervious areas and a new site map was drawn up to identify this. 5) Began packaging of motor oil in Building #6 in 2017. Initial packaging was from drum/totes into filling machine and then into quart bottles. Packaging was increased to include 5 gallon HDPE bottles and a new oil tank farm containing 3 new tanks was installed behind Building #6 near the railroad track in 2017. This new tank farm is completely dyked and the pump area is completely covered. 6) Stopped blending and packaging of Lithium Hydroxide in Building #2 in 2016 due to customer business decision. 7) Stopped storing Phosphoric Acid 75% in above ground storage tank in 2015 due to volume usage and this product is now being managed/supplied in totes. STORMWATER POLLUTION PREVENTION PLAN - -DEVELOPMENT AND IMPLEMENTATION --_ _ CERTiFiCATION North Carolina Division of Energy, Mineral, and Land Resources — Stormwater Program Facility Name: SAS Solar Permit Number: NCS000084 Location Address: 3527US1-wy.421N WMngton, NC 28401 County: New Hanover "I certify, under penalty of law, that the Stormwater Pollution Prevention Plan (SPPP) document and all attachments were developed and implemented under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information required by the SPPP. Based on my inquiry of the person or persons who manage the system. or those persons directly responsible for gathering the information, the information gathered is, to the best of my knowledge and belief. true, accurate and complete." And "I certify that the SPPP has been developed, signed and retained at the named facility location, and the SPPP has been fully implemented at this facility location in accordance with the terms and conditions of the stormwater discharge permit." And "I am aware that there are significant penalties for falsifying information, including the possibility of fines and imprisonment for knowing violations." - Sign (according to permit signatory requirements) and return this Certification: DO NOT SEND STORMWATER POLLUTION PREVENTION PLAN WITH THIS CERTIFICATION. Signature _46 A)e ti LAe.r 2,e.v7vne_ Print or type name of person sig ' g above Date 3 I v6 11.5 Cefoveaec ZX Tee,\o r TitleQz``al & 4_rb l SPPP Certification 10/13