Shurtape Comments on Proposed NCG050000

Shurtape
TECHNOLOGIE
16 May 2023
Via Email [brittany.cookgnncdenr.gov]
Brittany Cook
Stormwater Program
NCDEQ — DEMLR
1612 Mail Service Center
Raleigh, NC 27699-1612
RE: Comments on Draft NC DEQ General Storm Water Permit No. NCG050000
Dear Ms. Cook:
Shurtape Technologies ("SHURTAPE") appreciates this opportunity to provide comment on the draft
General Storm Water Permit No. NCG050000 (the "Draft Permit"), which covers establishments
primarily engaged in activities classified as Converted Paper and Paperboard products (SIC 267 &
NAISC 322220). Shurtape operates facilities under this SIC code potentially covered by the proposed
Draft Permit located in Alexander, Caldwell, and Catawba Counties. Shurtape directly employs
approximately 900 workers at these locations.
1. Comments on Draft Part EA — Required Baseline Monitoring
SHURTAPE requests the following revisions to Part E.1 of the Draft Permit:
• Remove quarterly baseline parameter monitoring of Non-Polar Oil & Grease & reduce
frequency of Non-Polar Oil & Grease sampling from quarterly to annual.
The required baseline parameter monitoring requirements proposed in the Draft Permit
appear to largely rely upon and reflect USEPA's 2021 Multi-Sector General Permit
("MSGP"), which incorporated recommendations from a study by the National Research
Council of the National Academies of Sciences, Engineering, and Medicine. However,
USEPA's 2021 MSPG does not include a baseline parameter monitoring requirement for
oil and grease.
NCDEQ has proposed more stringent requirements in the Draft Permit than what is in
USEPA's 2021 MSGP, or in recent permit renewals issued by other states in USEPA
Region IV. Georgia,for example, issued a MSGP permit impacting these industrial sectors
in 2022 which only requires annual sampling without benchmark monitoring. We do not
believe that baseline monitoring for oil and grease is appropriate for these industrial
sectors.
To bring the Draft Permit in line with the USEPA and Georgia MSGPs, SHURTAPE
requests that NCDEQ replace the proposed quarterly sampling and parameter monitoring
requirement in Part EA with an annual "report only' monitoring requirement.

SHURTAPE Comments on Draft Permit No. NCG050000
Ms. Brittany Cook
Page 2
• Limit the requirements to track new motor oil and hydraulic oil usage and conduct
sampling of non-polar oil and grease to vehicle maintenance areas with potential
exposures to stormwater (e.q., outdoor and uncovered activities)and include a definition
of"vehicle maintenance areas" in the Draft Permit.
As proposed, the Draft Permit would require that facilities; (1) track average monthly
usage of new motor and hydraulic oil use for vehicle maintenance; and (2)for that facilities
with vehicle or equipment maintenance areas in which more than 55 gallons of new motor
oil and hydraulic fluid is used per month when averaged over the calendar year, conduct
quarterly non-polar oil and grease sampling and benchmark parameter monitoring. As
drafted, it appears that these proposed requirements would apply regardless of whether
a facility's vehicle maintenance areas are located entirely covered or indoors or otherwise
lack potential exposure to stormwater.
Applying these requirements to vehicle maintenance areas without potential exposure to
stormwater goes beyond the scope of the permitting stormwater discharges associated
with industrial activity. SHURTAPE therefore requests that these requirements be limited
to vehicle maintenance areas with potential exposure to industrial stormwater.
SHURTAPE also requests that a definition of vehicle maintenance areas be added to the
Draft Permit that clarifies that the affected areas are limited to outdoor/exposed areas,
similar to the definition of vehicle maintenance activities in NCDEQ's 2018 General Permit,
as shown below:
Vehicle Maintenance Activity. Vehicle rehabilitation, mechanical repairs,
painting, fueling, lubrication, vehicle cleaning operations, or airport deicing
operations. For the purposes of this permit, vehicle maintenance activity
includes equipment maintenance that uses hydraulic oil and that is stored or
used outside, or otherwise exposed to stormwater. [Emphasis added]
A proposed definition of Vehicle Maintenance Area follows:
Vehicle Maintenance Area. For the purposes of this permit a Vehicle
Maintenance Area is an area dedicated to vehicle rehabilitation, mechanical
repairs, painting, fueling, lubrication, vehicle cleaning operations, or airport
deicing operations that is located outside, or otherwise exposed to stormwater.
2. Comments on Draft Part E.2— Baseline Sampling Benchmarks
SHURTAPE requests the following revisions to Part E.2 of the Draft Permit:
• Remove benchmark values for Total Suspended Solids ("TSS"), pH, and Chemical
Oxygen Demand ("COD").

SHURTAPE Comments on Draft Permit No. NCG050000
Ms. Brittany Cook
Page 3
USEPA's 2021 MSGP does not set benchmark values for TSS, pH, and COD, but rather
establishes "report only" requirements for these parameters. Nor have other states (such
as Georgia in its 2022 MSPG) established benchmark values for these parameters.
SHURTAPE requests that the proposed benchmark values for these parameters be
removed from the Draft Permit.
SHURTAPE also offers the comment that NCDEQ does not provide sufficient rationale to
support the proposed levels of the benchmark values in the Draft Permit. The values for
TSS, COD and Oil and Grease are unreasonably low and inconsistent with benchmarks
established in other states beyond Region IV. For example, in California (which, unlike
USEPA's 2021 MSPG, establishes benchmark values for TSS), the benchmark value for
TSS is 400 mg/L. Therefore, California's established benchmark value for TSS is 4 times
greater than the proposed benchmark value of 100 mg/L in NCDEQ's Draft Permit.
According the Fact Sheet that NCDEQ provided in support of the Draft Permit, the
proposed TSS benchmark of 100 mg/L is based on a study from the National Urban Runoff
Program ("NURP") in 1983, and NCDEQ takes the position that this study serves as a
basis for benchmarks in other industrial stormwater permits that include TSS monitoring.
SHURTAPE does not believe that applying this 40-year-old study is appropriate for setting
the proposed TSS limits. To date, SHURTAPE has not identified a benchmark value as
low as 100 mg/L in any other state's stormwater permits for paperboard containers and
boxes (SIC 265). Further, most state MSGPs covering these industry sectors (including
the 2022 MSGP issued by Georgia) do not include TSS monitoring limits at all.
NCDEQ's Fact Sheet also indicates that the proposed benchmark value for COD of 120
mg/L in the Draft Permit is based on wastewater limits. The Fact Sheet does not provide
further clarification of what type of wastewater limits were used as the basis for the
proposal. SHURTAPE offers this comment on the basis that applying industrial
wastewater limits to stormwater discharges is not an appropriate way to establish baseline
values, as these are distinct media with different characteristics and treatment options.
Further, in our experience, industrial wastewater limits for industry sectors covered by SIC
265 are far higher than 120 mg/L. Lastly, consistent with Georgia, Facilities identifying
under SIC codes 2611, 2621, 2652-2657, and 2671-2679, have no Indicator Thresholds
or Benchmark values established. They are subjected to monitoring only, unless there
are material storage piles present.
For the reasons stated herein, SHURTAPE requests that the proposed baseline values
be removed from the Draft Permit until more representative data is obtained from these
industry sectors to establish proper baseline limits. Importantly, we believe this proposed
rationale is consistent with the intent of USEPA's 2021 MSGP and also consistent with
MSGPs in other states that are using this permit cycle to gather data on pH, TSS, and
COD values in the stormwater discharge for these industrial sectors.
3. Comments on Draft Parts E-6 through E-8 —Tiered Responses:
SHURTAPE requests the following revisions to the Parts E-6 through E-8 of the Draft Permit:
• Remove Tiered Responses for Monitored Benchmark Values Until Appropriate
Benchmark Values Are Established.

SHURTAPE Comments on Draft Permit No. NCG050000
Ms. Brittany Cook
Page 4
The Draft Permit appears to base the proposed tiered responses on USEPA's additional
implementation measures ("AIM") for benchmark exceedances. However, the 2018
General Permit does not establish benchmark values TSS, pH, or COD for operations in
these industrial sectors (other than for vehicle maintenance areas with potential exposure
to stormwater), and it is SHURTAPE's position that the Draft Permit should establish report-
only indicator monitoring without tiered responses and benchmark values, consistent with
USEPA's 2021 MSGP.
Consistent with the request that benchmark values be removed from the DRAFT Permit,
the tiered responses for monitored benchmark values proposed in Parts E-6 through E-8
of the Draft Permit also should be removed.As further described above, establishing tiered
responses for monitored parameter values is not consistent with USEPA's 2021 MSGP or
other states (e.g., Georgia), which establish indicator monitoring (as opposed to
benchmark monitoring)for TSS, pH, and COD for these industry sectors.
SHURTAPE also notes that, where other states have established benchmark values and
associated tiered responses for these industry sectors (such as in California), the tiered
responses are far less burdensome than what is proposed in this Draft Permit. In California,
for example, before a permitted facility triggers the tiered response requirements, it must
have two exceedances of the benchmark at a single outfall or an exceedance of an annual
average benchmark for the entire facility (all outfalls included), and the tiered response
does not require agency notification or an increased frequency of sampling. In comparison,
the proposed Tier One Response in North Carolina's Draft Permit would be triggered by a
single benchmark value exceedance at any single outfall and would require notification to
NCDEQ. Further, the proposed Tier Two Response would require increasing the
monitored frequency from quarterly to monthly.
SHURTAPE requests that the proposed tiered responses be removed from the Draft Permit
along with the proposed benchmark values or, in the alternative,that the Tiered Responses
be revised to be less burdensome on the regulated community (e.g., remove notification
requirements, modify triggers for tiered response, and reduce the increased frequency
requirements).
4. Comments on Draft Part E—ANALYTICAL MONITORING OF
STORMWATER DISCHARGES
The Draft Permit's Analytical Monitoring requirements represent a significant change to
facilities previously covered by this General Permit. As such, many of these facilities do
not have the resources or the processes in place to implement these requirements upon
issuance of the permit. The significant change to Analytical Monitoring Requirements
will result in a significant number of new eDMR registrants. SHURTAPE requests
NCDEQ amend applicability of Analytical Monitoring requirements to no earlier than the
end of the first FULL quarter occurring 12 months after the issuance of the permit or
initiate analytical monitoring no later than 15 months after issuance of the permit. This
period provides time to develop a sampling plan, obtain the necessary resources to
support this requirement, and provides NCDEQ sufficient time to process and issue
eDMR accounts.

SHURTAPE Comments on Draft Permit No. NCG050000
Ms. Brittany Cook
Page 5
5. Comments on Draft Part B-10 —Solvent Management Plan.
SHURTAPE requests the following revisions to Part B-10 of the Draft
Permit:
• Remove the Requirement for a Solvent Management Plan.
NCDEQ's Fact Sheet does not include a rationale for the proposed addition of a
requirement to prepare and implement a solvent management plan in the Draft Permit.
SHURTAPE requests that this proposed requirement be removed because,where solvents
are stored and used exclusively indoors, such use poses an insignificant risk of exposure
or impact to stormwater. SHURTAPE believes the proposed requirement is beyond the
scope of the stormwater permitting program and is duplicative in this information is
contained in SPCC and NC Oil Terminal Registrations. This represents an unduly
burdensome duplication of efforts on the regulated community.
SHURTAPE respectfully requests NCDEQ's kind consideration of the comments provided herein. IF
you have any questions concerning Shurtape's comments, please contact me at 828.267.8428 or
via email at [e-mail].
Respectfully,
Mark E. Hawes, P.E.�
Director of Environment, Safety, & Product Compliance
cc: Kathleen Fortney