Terry Steinert Comments on NCG070000

N O Terry en
EaeCtrlC Glass Fiber America Environmental Manager
T: 704-434-2261 ext.22007
940 Washburn Switch Road,Shelby,NC 28150 Email: terry.steinert(a)nea-us.com
May 15, 2023
Brittany Cook
NC Department of Environmental Quality
Division of Energy, Mineral, and Land Resources - Stormwater Program
1612 Mail Service Center
Raleigh, NC 27699-1612
Re: Draft Industrial General Permit NCG070000
Dear Ms. Cook;
Thank you for this opportunity to comment on the draft Industrial General Permit No.
NCG070000 covering the Stone, Clay, Glass, and Concrete Products sector. Electric Glass Fiber
America, LLC (EGFA) operates production facilities in Shelby and Lexington that make fiberglass
products for the construction, automotive, energy, and other business sectors. These facilities
employ over 700 Carolinians.
To be profitable, fiberglass manufacturers must operate at scale, employing large storage and
material transfer systems that feed raw materials to the melting, refining and forming
operations. These operations are tightly regulated by major source air operating permits (Title
V) and Industrial wastewater discharge permits for onsite treatment. Storage silos and bins are
not open to the atmosphere, except for emergency pressure relief systems and material
transfer systems are enclosed with fabric filter controls at transfer points. Unloading
operations are conducted pneumatically with fabric filter controls and/or in unloading sheds.
Grounds are checked daily and any solids that may have dislodged from rail cars or trucks are
removed.
EGFA understands the rationale of the Division of Energy, Mineral and Land Resources (DEMLR)
to include much of the conditions in the US Environmental Protection Agency (EPA) Multi-
Sector General Permit (MSGP). Knowing that the MSGP was developed to cover a broad range
of industries with footprints, raw, intermediate and finished materials, material transport
systems, chemicals and fuels, etc. that are very different from fiberglass manufacturing plants,
EGFA offers the following comments:
1. The requirement for quarterly monitoring is excessive and represents and undue
burden. There is no indication that stormwater discharges from fiberglass
manufacturing contribute to the failure to meet water quality standards. For sites with
multiple outfalls, qualitative and quantitative monitoring within the first 30 minutes of
discharge with one or two personnel is burdensome. Adding field measurement of pH
makes this effort even more challenging. To have additional personnel on hand for an
anticipated runoff event each quarter that may or may not occur because of changing
weather is expensive and adds no value. EGFA requests the DEMLR remove the
quarterly qualitative and quantitative monitoring requirement and keep the qualitative
monitoring requirement, including the semi-annual frequency, of the existing permit.

Brittany Cook
May 15, 2023
Page 2 of 2
If quantitative monitoring is to be retained, please consider that the Department of
Environmental Quality's (DEQ) industrial wastewater program recognizes two seasons
as demonstrated by summer/winter limits for ammonia, biological oxygen demand and
total suspended solids. These limits are derived from seasonal temperature and
biological activity differences that influence treatment efficiency and the assimilative
capacity of receiving waters and demonstrate that DEQ believes discharges can be
adequately characterized by semi-annual monitoring in lieu of quarterly monitoring.
2. There is some confusion as to when monitoring should begin. The first paragraph on
Page 5 of the Fact Sheet states that monitoring should begin in the fourth quarter of
2023. In section 3.a of the Fact Sheet, also on page 5, it states that sampling shall not
commence until the next sampling period following initial issuance of the Certificate of
Coverage (CoC). Depending on when the General permit and CoCs are issued, these two
statements may not align. EGFA believes the language of section 3.a to be more
adaptable to the schedule of permit issuance and should be retained.
3. The relationship between Tier 3 status and the other two statuses is not clear.
Conceivably, a facility could be in multiple statuses at the same time. If a facility enters
Tier 1 or Tier 2 status, then it is possible the event that resulted in this entry also triggers
Tier 3 status. In such case, it is not clear which Tier is controlling. Also, given that Tier 3
is triggered by four benchmark exceedances within 5 years, it is not clear that Tier 3 can
be cleanly exited because any additional exceedance within the 5 year period
immediately draws the outfall back into Tier 3. EGFA requests that Tier 3 be removed
from the permit with Tiers 1 and 2 left to address benchmark exceedances.
Thank you again for the consideration of these comments. If you have any questions, please
contact me.
Respectfully Submitted,
Terry Steinert, Environmental Manager
Electric Glass Fiber America, LLC
704-434-2261
[e-mail]