HomeMy WebLinkAboutNCS000093_Renewal application_20230829 Bombardier Recreational Products BRP Us Inc.
1211 Greenwood Road
Spruce Pine,North Carolina
USA 28777
7 828,766.1100 P 828.765.2391
www.brp.com
August 23, 2023
Ms. Brianna Young, Individual Permit Coordinator
NCDEQ -Division of Energy,Mineral,and Land.Resources
G�V �Raleigh Central Office , G
1612 Mail Service Center
Raleigh,NC 27699-1612 f,
919.707.3647
brianna.young@ncdenr.gov
SUBJECT: BRP US Inc. - Spruce Pine,NC
NPDES Individual Stormwater Permit NCS000093
NPDES Permit Renewal Application
Dear Ms. Young:
BRP US Inc. (BRP) operates a lost foam aluminum casting facility in Spruce Pine, Mitchell
County,North Carolina under the NPDES (National Pollutant Discharge Elimination System)
Industrial Stormwater Program,Permit Number NCS000093. Part III,Section B, General
Condition 1 requires that the NPDES permit renewal application be submitted no later than 180
days prior to the expiration date; however, this renewal application is being submitted less than
180 days prior to the permit expiration of 8/31/23. We apologize for the late submittal, and
any missing data noted in the application will be submitted as soon as additional Stormwater
samples can be collected and analyzed.
As outlined in the NPDES Permitting Program application forms, this renewal includes the
following information:
• Application Form 1 "General Information," including Sections 1 through 11 and related
attachments as noted on page 4 of Application Form 1;
• Application Form 2F "Stormwater Discharges Associated with Industrial Activity,"
including Sections 1 through 10 and related attachments as noted on page 6 of
Application Form 2F;
• Two copies of the completed"Supplemental Information Required for Renewal of
Individual NPDES Stormwater Permit" Form; and
• A signed "Stormwater Pollution Prevention Plan Development and Implementation
Certification" Form.
With this renewal application, BRP requests authorization to discharge after the permit
expiration date such that the BRP facility can continue to operate under the terms of our
existing permit. If you have any questions regarding this renewal request, please contact Aaron
Jenkins, EHS Manager,at (828) 766-1185 or Judy Hoff of ERM NC, Inc. at (615) 319-4284.
ZurtsTaylor
Plant Manager ski-000
Lynx
Enclosures: Enclosure 1,Application Form 1 including Attachments Sea-Dae
Enclosure 2,Application Form 2F including Attachments Johnson
Enclosure 3,AdditionaI Copy of Supplemental Information Rosax
Bombardier AN
i
Enclosure 1
Application Form 1 including Attachments
,, 1.
EPA Identification Number NPOES Permit Number Facility Name Form Approved 03105119
EPA Registry Id:110012281627 NC5000093 BRP US Inc. OMB No.2040-0004
Form U.S.Environmental Protection Agency
1 •vEPA Application for NPDES Permit to Discharge Wastewater
NPDES GENERAL INFORMATION
SECTION • •D I
1.1 Applicants Not Required to Submit Form 1
1 1 1 Is the facility a new or existing publicly owned 1 1 2 Is the facility a new or existing treatment works
treatment works? treating domestic sewage?
If yes,STOP.Do NOT complete No If yes,STOP.Do NOT 0 No
Form 1.Complete Form 2A, complete Form 1.Complete
Form 2S.
1.2 Applicants Required to Submit Form 1
1.2.1 Is the facility a concentrated animal feeding 122 Is the facility an existing manufacturing,
operation or a concentrated aquatic animal commercial,mining,or silvicultural facility that is
a production facility? currently discharging process wastewater?
LU ❑ Yes 4 Complete Form 1 No Yes 4 Complete Form 0 No
n and Form 2B. 1 and Form 2C.
z
1.2.3 is the facility a new manufacturing,commercial, 1.2.4 Is the facility a new or existing manufacturing,
mining,or silvicultural facility that has not yet commercial, mining,or silvicultural facility that
commenced to discharge? discharges only nonprocess wastewater?
a Yes 4 Complete Form 1 0 No ❑ Yes 4 Complete Form 0✓ No
and Form 2D. 1 and Form 2E.
1.2.5 Is the facility a new or existing facility whose
: discharge is composed entirely of stormwater
associated with industrial activity or whose
discharge is composed of both stormwater and
non-stormwater?
0 Yes 4 Complete Form 1 ❑ No
and Form 2F
unless exempted by
40 CFR
122.26(b)(14)(x)or
SECTION
DD• • • i
2.1 Facility Name
BRP US Inc.
0 2.2 EPA Identification Number
U
J EPA Registry ID:110012281627(from FRS database)
cu 2.3 Facility Contact
Name(first and last) Title Phone number
Aaron Jenkins EFTS Manager (828)766-1185
Email address
aaron.jenkins@brp.com
2.4 Facility Mailing Address
Street or P.O.box
1211 Greenwood Road
City or town State ZIP code
Spruce Pine NC 28777
EPA Form 3510-1(revised 3-19) Page 1
EPA Identification Number NPDES Permit Number Facility Name Form Approved 03105119
EPA Registry Id:110012281627 NCS000093 BRP US Inc. OMB No.2040-0004
2.5 Facility Location
.� Street,route number,or other specific identifier
0 1211 Greenwood Road
�U
0 County name County code(if known)
Mitchell
0
E --' City or town State ZIP code
z 0 Spruce Pine NC 28777
SECTION • 1 I
3.1 SIC Code(s) Description(optional)
3365 Aluminum Foundries
3471 Electroplating,Plating,Polishing,Anodizing,and Coloring
di
m
0
U
U
Z 3.2 NAICS Code(s) Description(optional)
331524 Aluminum Foundries(except Die-Casting)
U
W
332813 Electroplating,Plating,Polishing,Anodizing,and Coloring
SECTIONOPERATOR INFORMATION1
4.1 Name of Operator
BRP US Inc.
0 4.2 Is the name you listed in Item 4.1 also the owner?
0 0 Yes ❑ No
= 4.3 Operator Status
ro ❑ Public—federal ❑ Public—state ❑ Other public(specify)
0 0 Private ❑ Other(specify)
4.4 Phone Number of Operator
(828)766-1100
C 4.5 Operator Address
Street or P.O.Box
1211 Greenwood Road
City or town State ZIP code
0 c0 Spruce Pine NC 28777
Q Email address of operator
curtis.taylor@brp.com
SECTION1 1 I
Is the facility located on Indian Land?
C " ❑ Yes No
EPA Form 3510.1 (revised 3-19) Page 2
EPA Identification Number NPOES Permit Number Facility Name Form Approved 03105119
EPA Registry Id:110012281627 NCS000093 BRP US Inc. OMB No.2040-0004
SECTION 'f I
ro 6.1 Existing Environmental Permits(check all that apply and print or type the corresponding permit number for each)
❑✓ NPDES(discharges to surface ❑✓ RCRA(hazardous wastes) ❑ UIC(underground injection of
a water) fluids)
o ��— NCS000093 NCR0001371SS
.5: E
w K ❑� PSD(air emissions) ❑ Nonattainment program(CAA) ❑ NESHAPs(CAA)
CM
05331T25
❑ Ocean dumping(MPRSA) ❑ Dredge or fill(CWA Section 404) ❑ Other(specify)
JUP Number 002
SECTION1
T1 Have you attached a topographic map containing all required information to this application?(See instructions for
C specific requirements.)
❑ Yes ❑ No ❑ CAFO—Not Applicable(See requirements in Form 213.)
SECTION 8.NATURE OF BUSINESS i
8.1 Describe the nature of your business.
BRP is a last foam foundry,which manufactures aluminum castings used as components for the manufacture of
various finished products including outboard engine parts,fuel filter housings,tamping devices,etc. Molten
aluminum is cast into foam molds,which are fabricated on-site from polystyrene beads,surrounded by sand.
Z Aluminum castings are cleaned in a series of grinding and cleaning steps. High pressure blasting is used to remove
m burrs and to shape the parts to requisite tolerances. On certain machines,the grinding process is aided with the use
of a surfactant material. Finishing operations include impregnation,chrome conversion coating,and limited wet
g Pg�
machining. During impregnation,critical parts are exposed to pressure and porosity sealing compounds to seal
z porous areas of some castings. Chrome conversion coating occurs in a series of process tanks in which aluminum
castings are exposed to an alkaline wash,a deoxidizing bath,a chromic acid bath,and a polymer seal bath. Minimal
machining is performed using a soluble oil cutting fluid and high speed tooling that is mounted in CNC machines.
SECTION • • I
9.1 Does your facility use cooling water?
L d 0 Yes El No 3 SKIP to Item 10.1.
ti; a 9.2 Identify the source of cooling water.(Note that facilities that use a cooling water intake structure as described at
40 CFR 125,Subparts I and J may have additional application requirements at 40 CFR 122.21(r).Consult with your
Q Y NPDES permitting authority to determine what specif c information needs to be submitted and when.)
c07 c Town of Spruce Pine Public Works
11050 South 226 Highway,Spruce Pine,NC 28777
(828)765-3000
SECTION t I 1
10.1 Do you intend to request or renew one or more of the variances authorized at 40 CFR 122.21(m)?(Check all that
N apply.Consult with your NPDES permitting authority to determine what information needs to be submitted and
when.)
❑ Fundamentally different factors(CWA ❑ Water quality related effluent limitations(CWA Section
Section 301(n)) 302(b)(2))
❑ Non-conventional pollutants(CWA ❑ Thermal discharges(CWA Section 316(a))
Section 301(c)and(g))
Not applicable
EPA Form 3510-1(revised 3-19) Page 3
EPA Identification Number NPDES Permit Number Facility Name Form Approved 03105119
EPA Registry Id:110012281627 NCS000093 BRP US Inc. OMB No.2040-0004
SECTION • 1
11 A In Column 1 below, mark the sections of Form 1 that you have completed and are submitting with your application.
For each section,specify in Column 2 any attachments that you are enclosing to alert the permitting authority.Note
that not all applicants are required to provide attachments.
Column 1 Column 2
0 Section 1:Activities Requiring an NPDES Permit ❑ wl attachments
Section 2: Name, Mailing Address,and Location ❑ wl attachments
❑✓ Section 3: SIC Codes ❑ wl attachments
✓❑ Section 4:Operator Information ❑ wl attachments
0 Section 5: Indian Land ❑ wl attachments
0 Section 6:Existing Environmental Permits ❑ wl attachments
d [D Section 7: Map ❑ atopographic 0 wl additional attachments
0 0 Section 8:Nature of Business ❑ wl attachments
0 Section 9:Cooling Water Intake Structures ❑ wl attachments
w
❑ Section 10:Variance Requests ❑ wl attachments
❑ Section 11:Checklist and Certification Statement wl attachments
11.2 Certification Statement
U
I certify under penalty of late that this document and all attachments were prepared under my direction or supervision
in accordance with a system designed to assure that qualified personnel properly gather and evaluate the
information submitted. Based on my inquiry of the person or persons who manage the system,or those persons
directly responsible for gathering the information, the information submitted is,to the best of my knowledge and
belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fine and imprisonment for knowing violations.
Name(print or type first and last name) Official title
Curtis Taylor Plant Manager
Signature Date signed
EPA Form 3510-1 (revised 3-19) Page 4
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N
0 0.3 o.6 0.9 1.2 1.5 km
C 0.2 0.4 0.6 0.8 1 mi
Map center is 351 54' 30"N, 82" 05' 30"W (WGS84/NAD83)
Projection is UTM Zone 17 NAD83 Datum
Source:TopoZone
Spruce Pine,NC USGS Quadrangle Map
FIGUi k
SITE LOCATION MAP
ERM NC, PC BRP US Inc.
ERM SPRUCE PINE,NC
BRPSrrE.DWG 5/7/10 1=90 LRM/LRM
METAL STORAGE CANOPY
I EQUIPMENT, EMPTY DRUMS,
\ OOTFALL NO. 1 ALUMINUM CHIPS, SPENT SAND
(2) WATER 300,000—GAL
`!L / BATH VAPORIZERS WATER STORAGE
PROPANE BOTTLE FILL 30 CU YD TRASH i
ROLL—OFF
FIR 20 CU YD SAND
PU P OU ROLL—OFF
DETENTION
OUTFALL NO. 3 POND
_+ O ELECTRIC
SUBSTATION
TRASH COMPACTOR
OUTFACE N0. 6
0
O OUTFALL 140. 2 GHOUS
OFFICE
PROPANE DDMODTRON
TANK FARM I
.(3) 30,000—GAL TANKS DUST C01_[.ECTORS
do SAND PRIJTREATMENT
BULK PROPANE
UNLOAD AREA
MAIN
STACK
PARKING
AREAS
RTO
NOTES: SHIPPING &
1. OUTFALL NO. 1 RUNOFF AREA ~ RECEMNG OUTFALL NO. 5
TOTAL AREA : 305,045 SQ FT
IMPERVIOUS 24-4.418 SQ FT ~
PERVIOUS - 61,427 SQ FT
RUNOFF COEF = 0.503
OUTFALL
2. DETENTION POND WILL HOLD A ONE INCH RAINFALL NO. 4 ti
3. OUTFALLS NO. 2 & 3 RUNOFF IS FROM UNDEVELOPED AREAS.
SCALE !N FEET
4. OUTFALLS NO. 4 & 5 ARE PART OF EMPLOYEE PARKING AREA
�
0 90 180
SITE PLAN AND DRAINAGE PATTERN
FIGURE
ERM NC, PC IIRP GIs INC. 2
ERM SPRUCE PINE, NORTH CAROLNA
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
l. 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.
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.
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.
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.
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.
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)
BRP-SPPP.DWG 10/23/14 1=90 LRM/LRM
\ STORMWATER EXPOWK
I 1, 500-GAL HYD. OIL TANK (UNDER ROOF)
2, 250-GAL HYD. OIL TANK (UNDER ROOF)
\ 3. SCRAP TUBING/SHEET METAL
4. MISC, STORAGE
5. LOADING DOCK
6, TRASH COMPACTOR (ENCLOSED?
I 7. 30 CU YARD TRASH ROLL-OFF (DPEN)
\ OUTFALL NO. 1 y B. ( 28$-GAL DIESEL YANKS
IN
IN PUMP HOUSE
9. COVERED CANOPY AREA
-FLUOR SWEEPER/20 YD SPENT SAND
WATER STORMS ROLL OFF
-METAL CHIP DUMPSTER AND
Raj \� COOLANT RECYCLING PROCESS
�� (2)yuTM -EMPTY DRUM STORAGE
09
Q
ni vAaoagF3s _ 10, MAX, HAZ WASTE, CILS, COOLANTS,
6WNTENMCEe N. PAM cmB 11. MI SC,
PALLET STORAGE GE CONTAINMENT SLUGS
C f Q 12, METAL PARTS IN WIRE BASKETS
LxJ LJ 13. COOLING TOWER
( 114.RPPOND ON 0 15. RTOTSTACKECTORS, SAND PRETREAT.
OUTFALL NO. 3 16' RTO DAGHOUSE
ELECTRIC
f -O f 17. SHIPPING AND RECEIVING
�/ SUBSTATION
OUTF NO. 6
0 4
o0 OUTFALL NO. ,1
OFFICE
PROPANE DDTTION
TANK FARM 1
(3) 30,000—GAL. TANKS
BULK PROPANE
UNLOAD AREA
PARKING
f
AREAS \
NOTES:
1. OLI FALL NO. 1 RUNOFF AREA OUTFALL NO, 5
TOTAL AREA = 305,845 SO FT
IMPERVIOUS — 244,418 SO FT
PERVIOUS = 61,427 SO FT -
RUNOFF COEF = 0.603
OUTFALL NO. 4
2. DETENTION POND WILL HOLD A ONE INCH RAINFALL -
3. OUTFALLS NO. 2 & 3 RUNOFF IS FROM UNDEVELOPED AREAS. ~ '
~ SCALE IN FEET
4. OUTFALS NO. 4 & 5 ARE PART OF EMPLOYEE PARKING AREA
5. OUTFALL NO. 6 CONSISTS OF ROOF DRAINAGE. 0 90 180
ERM NC, INC. SITE PLAN AND DRAINAGE PATTERNS FIGURE
BRP US INC. 2
ERM SPRUCE PINE, NORTH CAROLINA
EPA Identification Number NPDES Permit Number Facility Name
110012281627 NCS000093 BRP US Inc.
NPDES Permit Renewal Application
Analytical Analytical Analytical
Results Results Results
Greater than
Discharge Discharge Discharge Discharge Measurement Sample Benchmark
Date Characteristic Characteristic Characteristic Characteristic Frequency Type Values?
Stormwater Total Total TSS 50
Discharge Outfall Suspended Recoverable pH 6-9
Location Solids(TSS) pH Aluminum(Al) Total Rainfall AI None
mg/L Standard ug/L inches
Year 5 Period 2,January 1-June 30,2018
6/13/2018 Outfall1 13.7 7.2 373 0.64 Semiannual Grab No
Year 1 Period 1,July 1-December 31,2018
12/14/2018 Outfall1 3.6 6.7 181 1.22 Semiannual Grab No
Year 1 Period 2,January 1-June 30,2019
5/2/2019 Outfall1 ND 6.5 ND 1.36 Semiannual Grab No
Year 2 Period 1,July 1-December 31,2019
Not available in facility files Outfall 1 Not available Not available Not available Not available Semiannual Grab Unknown
Year 2 Period 2,January 1-June 30,2020
6/4/2020 Outfall1 3.2 6.4 ND 0.26 Semiannual Grab No
Year 3 Period 1,July 1-December 31,2020
10/24/2020 Outfall1 3.0 6.5 ND 0.52 Semiannual Grab No
Year 3 Period 2,January 1-June 30,2021
5/25/2021 Outfall1 5.8 5.4 ND 0.17 Semiannual Grab No
Year 4 Period 1,July 1-December 31,2021
11/11/2021 Outfall1 7.3 6.8 213 0.83 Semiannual Grab No
Year 4 Period 2,January 1-June 30,2022
6/8/2022 Outfall 1 6.2 6.2 116 Not available Semiannual Grab No
Year 5 Period 1,July 1-December 31,2022
Not available in facility files Outfall 1 Not available Not available Not available Not available Semiannual Grab Unknown
Year 5 Period 2 January 1-June 30,2023
6/20/2023 Outfall1 13.6 6.6 328 1.81 Semiannual Grab No
Year 6 Period 1,July 1-December 31,2023
Not yet Not yet Not yet Not yet Not yet
Not yet available Outfall1 available available available available Semiannual Grab available
AVERAGE 6.1 6.4 209.5
MAXIMUM 13.6 6.8 328
Notes:
ND=Not detected
Rainfall amounts available from facility rain gauge or from NCDC Daily Summaries for Spruce Pine,NC,climate station.
Records of samples for Year 2 Period 1 and Year 5 Period 1 have not been found in facility files,perhaps due to employee turnover.
Samples for Year 6 Period 1 have not been collected yet.
EPA Identification Number NPDES Permit Number Facility Name
110012281627 NCS000093 SRP US Inc.
NPDES Permit Renewal Application
Qualitative Qualitative Qualitative Qualitative Qualitative Qualitative Qualitative Qualitative Qualitative Qualitative Qualitative
Results Results Results Results Results Results Results Results Results Results Results
Discharge Discharge Discharge Discharge Discharge Discharge Discharge Discharge Discharge Monitoring
Date Characteristic Characteristic Characteristic Characteristic Characteristic Characteristic Characteristic Characteristic Characteristic Frequency Sample Type
Other obvious
Erosion or indicators of
Stormwater Discharge Outfall Suspended deposition at stormwater
Location Color Odor Clarity Floating Solids Solids Foam Oil Sheen the outfall pollution
Year 5 Period 2,January 1-June 30,2018
6/13/2018 SDO 1-6 Not available Not available Not available Not available Not available Not available Not available Not available Not available Semiannual Grab
Year 1 Period 1,July 1-December 31,2018
12/14/2018 SOO 1-6 Not available Not available Not available Not available Not available Not available Not available Not available Not available Semiannual Grab
Year 1 Period 2,January 1-June 30,2029
5/2/2019 SDO 1-6 Not available Not available Not available Not available Not available Not available Not available Not available Not available Semiannual Grab
Year 2 Period 1,July 1-December 32,2019
Not available in facility files SDO 1-6 Not available Not available Not available Not available Not available Not available Not available Not available Not available Semiannual Grab
Year 2 Period 2,January 1-June 30,2020
6/4/2020 SOO 1-6 Not available Not available Not available Not available Not available Not available Not available Not available Not available Semiannual Grab
Year 3 Period 1,July 1-December 31,2020
10/24/2020 SOO 1-6 Not available Not available Not available Not available Not available Not available Not available Not available Not available Semiannual Grab
Year 3 Period 2,January 1-June 30,2021
5/25/2D21 SDO 1-6 Not available Not available Not available Not available Not available Not available Not available Not available Not available Semiannual Grab
Year 4 Period 1,July 1-December 31,2021
11/11/2021 SDO 1-6 Not available Not available Not available Not available Not available Not available Not available Not available Not available Semiannual Grab
Year 4 Period 2,January 1-June 30,2022
6/8/2022 SDO 1-6 Not available Not available Not available Not available Not available Not available Not available Not available Not available Semiannual Grab
Year 5 Period 1,July 1-December 32,2022
Not available in facility files SDO 1-6 Not available Not available Not available Not available Not available Not available Not available Not available Not available Semiannual Grab
Year 5 Period 2,January 1-June 30,2023
6/20/2023 SDO 1.6 Not available Not available Not available Not available Not available Not available Not available Not available Not available Semiannual Grab
Year 6 Period 1 July 1-December 32,2023
Not yet Nat yet Not yet Not yet Not yet Not yet Not yet
Not yet available SDO 1-6 available available available Not yet available available available available available Not yet available Semiannual Grab
Notes:
Records of visual samples have not been found in facility files,perhaps due to employee turnover.
Samples for Year 6 Period 1 have not been collected yet.
EPA Identification Number NPDES Permit Number Facility Name
110012281627 NCS000093 BRP US Inc.
NPDES Permit Renewal Application
Stormwater Discharge Outfall
Location Stormwater Exposure Item Location Best Management Practices(BMPs) Additional BMPs
SDO 1 500-gal Hydraulic oil tank SE of Production Bldg Tank located under roof,secondary containment -
250-gal Hydraulic oil tank SE of Production Bldg Tank located under roof,secondary containment
Scrap tubing/sheet metal SE of Production Bldg Stored outside Store inside building
Miscellaneous storage SE of Production Bldg Stored outside Store inside building
Loading dock E side of Production Bldg Covered
Scrap metal roll-off E side of Production Bldg Sweep around roll-off on a frequent basis Cover the roll-off
Trash compactor E side of Production Bldg Enclosed
30-Cubic yard trash roll-off E side of Production Bldg Sweep around roll-off on a frequent basis Cover the roll-off
Two 288-gal Diesel tanks E side of Production Bldg Tanks located inside Pump House Bldg -
Spent sand roll-off E side of Production Bldg Covered by a canopy and equipped with curbing
Metal chip dumpster E side of Production Bldg Covered by a canopy and equipped with curbing
Equipment storage E side of Production Bldg Covered by canopy and equipped with curbing
Containment Bldgs for storage
of waste,oil,coolants NE of Production Bldg Enclosed
Pallets NE of Production Bldg Stored outside Limit number of pallets stored outside
Metal parts NE of Production Bldg Stored outside Store inside building
Monitor use of chemicals in cooling tower water
Cooling tower NE of Production Bldg and monitor containment for leaks
Dust collectors and sand Routinely sweep and properly dispose of dust
pretreatment area NE side of Production Bldg (particulates)
Regenerative thermal oxidizer Routinely sweep and properly dispose of dust
(RTO)stack and baghouse NE side of Production Bldg (particulates)
Shipping/Receiving Dock NE side of Production Bldg Monitor by BRP employee
Sand hopper E side of Production Bldg Sweep around hopper on a frequent basis
SDO 2 Propane unloading area NE side of Production Bldg Pressurized unloading
SDO 3 Propane tanks NE side of Production Bldg Pressurized tanks
SDO 4 Employee parking area SW of Production Bldg SPPP,training,etc.
SDO 5 Employee parking area SW of Production Bldg SPPP,training,etc.
SDO 6 Roof SE of Production Bldg Use of control equipment(dust collectors,RTO)
Notes:
Best Management Practices(BMPs)are described in the BRP Stormwater Pollution Prevention Plan(SPPP)in facility files.
EPA Identification Number NPDES Permit Number Facility Name
110012281627 NCS000093 BRP US Inc.
NPDES Permit Renewal Application
Changes Since Previous Permit Issuance Description of Changes Location Best Management Practices(BMPs) Suggested Improvements to BMPs
No changes related to stormwater have
occurred None None None None
Notes:
No changes related to stormwater have occurred at the facility since the previous NPDES permit was issued.
Minor modifications to operations(more related to air quality)have included or will include the following:
Replaced the CD-1 bagfilter because the existing bagfilter was underrated and at the end of its service life.The replacement bagfilter is a Donaldson DFE 4-32 Dust Collector,which contains
32 ultra-web cartridge filters with a filter area of 8,128 square feet,a differential pressure meter,and an effective cleaning system.
Venting the following insignificant natural gas-fired ovens through the building roof rather than exhausting inside the manufacturing building,both to meet National Fire Protection
Association(NFPA)requirements and to improve indoor air quality:
*ES-17,Heat Treat No.1 Solution Oven for Cast Line No.1,3.0 MMBtu/hr capacity;
*ES-18,Heat Treat No.3 Solution Oven for Cast Line No.2,3.0 MMBtu/hr capacity;
*ES-30,Age Oven No.1(AO-01),1.0 MMBtu/hr capacity;
*ES-31,Age Oven No.2(AO-02),1.0 MMBtu/hr capacity;and
*ES-38,Age Oven No.3(AO-03),1.0 MMBtu/hr capacity.
Removed ES-47,Paint Spray Booth and Associated Bake Oven(3.0 MMBtu/hr capacity),since painting is done off-site by a vendor.As a result,this source has been removed from the facility.
Added Dehumidifiers#1 and#2 for the Styrofoam Drying ovens.
Replaced the Emergency Generator.
Replaced the CD-16 bagfilter because the existing bagfilter was underrated and at the end of its service life.
Removed ES-44,Boiler#2(14.7 MMBtu/hr capacity),since Boiler#1 is larger and sufficient for plant operation.
STORMWATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
North Carolina Division of Energy, Mineral, and Land Resources— Stormwafer Program
Facility Name: BRPUSInc.
Permit Number: NGSOODO93
Location Address: 1211 Greenwood Road
Spruce Pine,NC 28777
County: Mitchell
"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 Date N26CZ,
Curtis Taylor Plant Manager
Print or type name of person signing above Title
SPPP Certification 10/13
Enclosure 2
Application Form 2F including Attachments
EPA Identification Number NPDES Permit Number Facility Name Farm Approved 03105119
EPA Registry Id:110012281627 NC5000093 BRP US Inc. OMB No.2040-0004
Form U.S Environmental Protection Agency
2F \.EPA Application for NPDES Permit to Discharge Wastewater
NPDES STORMWATER DISCHARGES ASSOCIATED WITH INDUSTRIAL ACTIVITY
SECTIONOUTFALL LOCATION
1.1 Provide information on each of the facTty's outfalls in the table below
Outfall Receiving Water Name Latitude Longitude
Number
SDO 1 English Creek 35' 54' 38.88" 82° 5' 25.8"
0
SDO 2 English Creek 35' 54' 39.6" 82° 5' 30.84"
0
m SDO3 English Creek 350 54' 41.76" 82' 5' 27.96"
SDO4 English Creek 35' 54' 32.4" 82* 5' 32.28"
SDO 5 English Creek 35' 54' 32.4" 82' 5' 30.34"
SDO 6 English Creek 3S' 54' 30.96" 82' 5' 28 68"
SECTION " • I
2.1 Are you presently required by any federal, state,or local authority to meet an implementation schedule for constructing,
upgrading,or operating wastewater treatment equipment or practices or any other environmental programs that could
affect the discharges described in this application?
❑ Yes El No 4 SKIP to Section 3.
2.2 Briefly identify each applicable project in the table below.
Brief Identification and Affected Outfalis Source(s)of Discharge Final Compliance Dates
Description of Project (list cutfall numbers)
Required Projected
Not applicable, N/A
a
E
m
a
0
E
2.3 Have you attached sheets describing any additional water pollution control programs(or other environmental projects
that may affect your ftcharges)that you now have underway or planned?(Optional Item)
❑ Yes El No
EPA Form 3510-2F(Revised 3-19) Page 1
EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
EPA Registry Id:110012281627 NCS000093 BRP US Inc. OMB No.2040-0004
SECTION 3.SITE D- !
m
3 1 Have you attached a site drainage map containing all required information to this application?(See instructions for
Q specific guidance.)
o ® Yes ❑ No
SECTION 4.POLLUTANT SOURCES !
4.1 Provide information on the facility's pollutant sources in the table below.
Outfall Impervious Surface Area Total Surface Area Drained
Number (vAthin a mile radius of the facility) (within a mile radius of the facility)
specify units specify units
SDO 1 244,000 sq ft 306,000 sq ft
specify units specify units
SDO 2 25,200(road,undeveloped) sq ft S0,400 sq ft
specify units specify units
SDO 3 9,500(undeveloped) sq ft 189,000 sq ft
specify units specify units
SDO 4 17,200(parking area) sq ft 28,700 sq ft
specify units specify units
SDO 5 22,300(parking area) sq ft 44,600 sq ft
specify units specify units
SDO 6 33,300(roof drainage) sq ft 111,10o sq ft
4.2 Provide a narrative description of the facility's significant material in the space below.(See instructions for content
requirements.)
Two hydraulic oil aboveground storage tanks(ASTs)are located under roof outside the production building. Totes and
drums are stored inside buildings or inside storage containment buildings located east of the production building. A
oloading dock is located at the southeastern building wall,and a shipping/receiving area is located at the northeastern
building wall. Six(6)dust collectors are located along the northeastern building wall: one for the aluminum casting
lines;one associated with sand storage for each casting line(two lines);one for the regenerative thermal oxidizer
(RTO);one for the sand reclamation system;and one for shot blast machines and sand blast units. The facility has an
a open trash roll-off,an enclosed trash compactor,an open scrap metal dumpster,a spent sand roll-off under canopy,
and a metal chip dumpster under canopy. Fertilizers,pesticides,herbicides are used by knowledgable landscapers.
4.3 Provide the location and a description of existing structural and non-structural control measures to reduce pollutants in
stormwater runoff. See instructions forspecificguidance.)
Stormwater Treatment
Codes
Outfall from
Number Control Measures and Treatment Exhibit
2F-1
list
SDO 1 Plant activities-docks and equipment storage-covered, retention pond(structural) N/A
5130 2 Undeveloped area with propane unloading-pressurized propane(non-structural) N/A
SDO 3 Undeveloped area with propane tanks-pressurized tanks(non-structural) N/A
SDO 4 Parking areas-SPPP,training,housekeeping(non-structural) N/A
SDO 5 Parking areas-SPPP,training,housekeeping(non-structural) N/A
SDO 6 Building roof-SPPP,training,housekeeping(non-structural) N/A
EPA Form 3510.217(Revised 3-19) Page 2
EPA Identification Number NPDES Permit Number Facility Name Form Approved 03105119
EPA Registry Id:110012281627 NCS000093 BRP US Inc. OMB No.2040-0004
SECTIONiN STORMWATER 1 r
5.1 1 certify under penalty of law that the outfall(s) covered by this application have been tested or evaluated for the
presence of non-stormwater discharges. Moreover, l certify that the outfalls identified as having non-stormwater
discharges are described in either an accompanying NPDES Form 2C, 2D, or 2E application.
Name(print or type first and last name) Official title
Curtis Taylor Plant Manager
Signature Date signed
a7 5.2 Provide the testing information requested in the table below.
Onsite Drainage Points
Outfall Description of Testing Method Used Date(s)of Testing Directly Observed
Number
During Test
ca
ca
�
SDO 1 Visual evaluation 07/26/2023 Outfall 1
`o
c SDO 2 Visual evaluation 07/26/2023 Outfall 2
0
Z
SDO 3 Visual evaluation 07/26/2023 Outfall 3
SDO4 Visual evaluation 07/26/2023 Outfal14
SDO 5 Visual evaluation 07/26/2023 Outfall 5
SDO 6 Visual evaluation 07/26/2023 Outfall 6
SECTION 6.SIGNIFICANT LEAKS OR r
6.1 Describe any significant leaks or spills of toxic or hazardous pollutants in the last three years.
m No leaks or spills have occurred during the last three(3)years.
`o
W
Y
SECTION 7.
f9
07
J
C
fC
U
.0
O1
DISCHARGE INFORMATION
See the instructions to determine the pollutants and parameters you are required to monitor and,in turn,the tables you must
o com fete,Not all applicants need to complete each table.
7.1 Is this a new source or new discharge?
o El estimated
4 See instructions regarding submission of ID actual
4 See instructions regarding submission of
estimated data. actual data.
Tables A, B,C,and D
7.2 Have you completed Table A for each outfall?
is
❑ Yes ❑ No
EPA Form 3510-2F(Revised 3-19) Page 3
EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05119
EPA Registry Id:1100122111627 NCS000093 BRP US Inc. OMB No.2040-0004
7.3 Is the facility subject to an effluent limitation guideline(ELG)or effluent limitations in an NPDES permit for its process
wastewater?
0 Yes ❑ No 4 SKIP to Item 7.5.
7.4 Have you completed Table B by providing quantitative data for those pollutants that are(1)limited either directly or
indirectly in an ELG and/or(2)subject to effluent limitations in an NPDES permit for the facility's process wastewater?
❑✓ Yes [:1 No
7.5 Do you know or have reason to believe any pollutants in Exhibit 2F-2 are present in the discharge?
0 Yes ❑ No 4 SKIP to Item 7.7.
7.6 Have you listed all pollutants in Exhibit 2F-2 that you know or have reason to believe are present in the discharge and
provided quantitative data or an explanation for those pollutants in Table C?
R] Yes ❑ No
7.7 Do you qualify for a small business exemption under the criteria specified in the Instructions?
❑ Yes 4SKIP to Item 7.18. 0 No
7.8 Do you know or have reason to believe any pollutants in Exhibit 2F-3 are present in the discharge?
❑ Yes ❑ No 4 SKIP to Item 7.10.
7.9 Have you listed all pollutants in Exhibit 2F-3 that you know or have reason to believe are present in the discharge in
c Table C?
C ❑ Yes ❑ No
c)
0 7.10 Do you expect any of the pollutants in Exhibit 2F-3 to be discharged in concentrations of 10 ppb or greater?
CU
€ ❑ Yes ❑ No 4 SKIP to Item 7.12.
= 7.11 Have you provided quantitative data in Table C for those pollutants in Exhibit 2F-3 that you expect to be discharged in
rn concentrations of 10 ppb or greater?
_ ❑ Yes ❑ No
7.12 Do you expect acrolein,acrylonitrile,2,4-dinitrophenol,or 2-methyl4,6-dinitrophenol to be discharged in concentrations
of 100 ppb or greater?
❑ Yes ❑✓ No 4 SKIP to Item 7.14.
7.13 Have you provided quantitative data in Table C for the pollutants identified in Item 7.12 that you expect to be
discharged in concentrations of 100 ppb or greater?
❑ Yes ❑ No
7.14 Have you provided quantitative data or an explanation in Table C for pollutants you expect to be present in the
discharge at concentrations less than 10 ppb(or less than 100 ppb for the pollutants identified in Item 7.12)?
❑ Yes ❑✓ No
7.15 Do you know or have reason to believe any pollutants in Exhibit 2F-4 are present in the discharge?
❑ Yes ❑✓ No 4 SKIP to Item 7.17.
7.16 Have you listed pollutants in Exhibit 2F-4 that you know or believe to be present in the discharge and provided an
explanation in Table C?
❑ Yes ❑ No
7.17 Have you provided information for the storm event(s)sampled in Table D?
❑ Yes No
EPA Form 3510-2F(Revised 3-19) Page 4
EPA Identification Number NPDES Permit Number Facility Name Form Approved 03105119
EPA Registry Id:1100122$1627 NCS000093 BRP US Inc. OMB No.2040-0004
Used or Manufactured Toxics
7.18 Is any pollutant listed on Exhibits 2F-2 through 2F-4 a substance or a component of a substance used or
manufactured as an intermediate or final product or byproduct?
a
S Yes ❑ No 4 SKIP to Section 8.
0
7.19 List the pollutants below,including TCDD if applicable.
1=
L
O
1'Total Recoverable Aluminum 4. 7.
a
2. 5. 8.
U
0 L31
6. 9.
SECTIONBIOLOGICAL T• DATA
8.1 Do you have any knowledge or reason to believe that any biological test for acute or chronic toxicity has been made on
any of your discharges or on a receiving water in relation to your discharge within the last three years?
a
❑ Yes 0 No 4 SKIP to Section 9.
8.2 Identify the tests and their purposes below.
Test(s) Purpose of Test(s) Submitted to NPDES Date Submitted
x _ Permitting Authori
0
1- ❑ Yes ❑ No
ca
o ❑ Yes ❑ No
0
m
❑ Yes ❑ No
SECTION • ANALYSIS INFORMATION1
9.1 Were any of the analyses reported in Section 7(on Tables A through C)performed by a contract laboratory or
consulting firm?
❑ Yes ❑ No 4 SKIP to Section 10.
9.2 Provide information for each contract laboratory or consulting firm below.
Laboratory Number 1 Laboratory Number 2 Laboratory Number 3
Name of laboratory/firm Pace Analytical Services,LLC N/A N/A
c
0
0
Laboratory address 110 Technology Parkway
Peachtree Corners,GA 30092
U
i0
o Phone number
U (770)734-7420
Pollutant(s)analyzed
Total Recoverable Aluminum
EPA Form 3510-2F(Revised 3-19) Page 5
EPA Identification Number NPDES Permit Number Facility Name Form Approved 03105119
EPA Registry Id: 110012281627 NCS000093 BRP US Inc. OMB No.2040-0004
SECTIONI CHECKLIST AND CERTIFICATION STATEMENT(40
10.1 In Column 1 below,mark the sections of Form 2F that you have completed and are submitting with your application.For
each section,specify in Column 2 any attachments that you are enclosing to alert the permitting authority.Note that not
all applicants are required to complete all sections or provide attachments.
Column 1 Column 2
0 Section 1 ❑ wl attachments(e.g.,responses for additional outfa[Is)
Section 2 ❑ wl attachments
0 Section 3 ❑ wl site drainage map
0 Section 4 ❑ wl attachments
❑ Section 5 ❑ wl attachments
;r
0 Section 6 ❑ wl attachments
d ❑ Section 7 0 Table A ❑ wl small business exemption request
[l Table B ❑ wl analytical results as an attachment
0
[�] Table C 0 Table D
L) ❑✓ Section 8 ❑ wlattachments
0 Section 9 ❑ wlattachments(e.g.,responses for additional contact laboratories or firms)
x
s 0 Section 10 ❑
ca 10.2
Certification Statement
1 certify under penalty of law that this document and all attachments were prepared under my direction or supervision in
accordance with a system designed to assure that qualified personnel properly gather and evaluate the information
submitted. Based on my inquiry of the person or persons who manage the system or those persons directly responsible
for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and
complete. 1 am aware that thero are significant penalties for submitting false information, including the possibility of fine
and imprisonment for knowing violations.
Name(print or type first and last name) Official title
Curtis Taylor Plant Manager
Signatur� Date signed
EPA Form 3510-2F(Revised 3-19) Page B
EPA Identification Number NPDES Permit.Number Facility Name Ouifall Number Farm Approved 03105/19
EPA Registry Id:110012281627 NCS000093 BRP U5 Inc. SDO 1(Representative) OMB No.2040-0004
TABLE A.CONVENTIONAL AND NON • • !
You must provide the results of at least one anal sis for every pollutant in this table.Complete one table for each outfall,See instructions for additional details and re uirements,
Maximum Daily Discharge Average Daily Discharge Source of
(specify units) (specify units) Number of Storm Information
Pollutant or Parameter Grab Sample Taken Grab Sample Taken (new sourcelnew
During First Flow-Weighted ed During First Flow-Weighted Events Sampled dischargers only;use
30 Minutes Composite 30 Minutes Composite codes in instructions)
1. Oil and grease Not yet available Nat yet available None To Be Determined
2. Biochemical oxygen demand(BOD5) Not applicable Comp.not regd. Not applicable Comp.not regd. None N/A
1Chemical oxygen demand(COD) Not aooFcable Comp.not regd. Not applicable Comp.not regd. None N/A
4, Total suspended solids(TSS) 13.6 mg/L Comp.not reqd. 6.1 mg/L Comp.not reqd, 8 5-Actual data
5. Total phosphorus Not yet available Comp.not reqd. Not yet available Comp.not reqd. None To Be Determined
6. Total Kjeldahl nitrogen(TKN) Not yet available Comp.not reqd. Not yet available Comp.not regd. None To Be Determined
7. Total nitrogen (as N) Not yet available Comp.not regd. Not yet available Camp.not reqd. None To Be Determined
pit(minimum) 5.4 6.4 8 5-Actual data
B.
pH(maximum) 7.2 6.4 8 5-Actual data
Sampling shall be conducted according to sufficiently sensitive test procedures(i.e.,methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or
required under 40 CFR chapter I,subchapter N or 0.See instructions and 40 CFR 122.21(e)(3).
EPA Form 3510-2F(Revised 3-19) Page 7
This page intentionally left blank.
t
EPA Identification Number NPDES Permit Number Facility Name Outfall Number Form Approved 03/05/19
EPA Registry Id:110012281627 NCS000093 BRP US Inc. SDO 1(Representative) OMB No.2040-0004
TABLE B.CERTAIN CONVENTIONAL AND NON CONVENTIONAL POLLUTANTS(40 CF R 122.26(c)(1)(1)(E)(4)and 40 CFR 122.21(g)(7)(vi)(A))'
List each pollutant that is limited in an effluent limitation guideline (ELG)that the facility is subject to or any pollutant listed in the facility's NPDES permit for its process wastewater(if the
facility is operating under an existing NPDES permit). Complete one table for each eutfall. See the instructions for additional details and requirements.
Maximum Daily Discharge Average Daily Discharge Source of
(specify units) (specify units) Number of Storm Information
Pollutant and CAS Number(if available) Grab Sample Taken Grab Sample Taken (new sourcelnew
During First Flo Composite
Flow-Weighted During First Flo Composite
Events Sampled dischargers only;use
30 Minutes Composite 30 Minutes Composite codes in Instruc?ions)
Total Suspended Solids(TSS) No permit limitation Comp,riot regd. No permit limitation Comp.not reqd. Semiannually N/A
pH 6-9 Comp,not reqd. 6-9 Comp. not reqd. Semiannually N/A
Total Recoverable Aluminum(AI) No permit limitation Comp,not reqd. No permit limitation Comp,not reqd. Semiannually N/A
Sampling shall be conducted according to sufficiently sensitive test procedures(i.e., methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or
required under 40 CFR chapter I,subchapter N or 0.See instructions and 40 CFR 122.21(e)(3).
EPA Form 3510.2F(Revised 3-19) Page 9
This page intentionally left blank.
EPA Identification Number NPOES Permit Number Facility Name outfall Number Form Approved 03/05/19
EPA Registry Id: 110012281627 NCS000093 BRP US Inc. Si 1(Representative)7 OMB No.204NO04
TABLE C.TOXIC POLLUTANTS,CERTAIN HAZARDOUS SUBSTANCES,AND ASBESTOS(40 CFR 1122.26(c)(1)(1)(11i and 40 CFR 122.21[g)(7)(vii)(B)and(viii))'
List each pollutant shown in Exhibits 2F--2,2F-3,and 2F-4 that you know or have reason to believe is present. Complete one table for each outfall. See the instructions for additional
details and requirements.
Maximum Daily Discharge Average Daily Discharge Source of
s eci units s eci units Number of Storm Information
Pollutant and CAS Number(if available) Grab Sample Taken Flow-Weighted Grab Sample Taken new sourcelnew
DuringFirst DuringFirst Flow-Weighted Events Sampled (
Composite Composite dischargers only;use
30 Minutes 30 Minutes codes in instructions)
Total Recoverable Aluminum 328 ug/L Comp. not read. 209.5 ug/L Comp.not recid. 8 5-Actual data
Sampling shall be conducted according to sufficiently sensitive test procedures(i.e., methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or
required under 40 CFR chapter I,subchapter IN or D. See instructions and 40 CFR 122.21(e)(3).
EPA Form 3510-2F(Revised 3-19) Page 11
This page intentionally left blank.
EPA Identification Number NPDES Permit Number Facility name Outfall Number Form Approved 03105/19
EPA Registry to:110012211127 NC5000093 BRP US Inc. SDO 1(Representative) OMB No.2040-0004
STORMTABLE D. • ` • i
Provide data for the storm event(s)that resulted in the maximum daily discharges for the flow-weighted composite sample.
Number of Hours Between
Total Rainfall During Maximum Flow Rate
Duration of Storm Event Beginning of Storm Measured and Total Flow from Rain Event
Date of Storm Event tin hou (in Inches) (in gpm or specify units)hours} (in
Event End of Previous Measurable Rain During Rain Even) (in gallons orspecify units)
Event
08/23/2023
N/A composite not regd. N/A composite not regd. N/A composite not regd. N/A comp,not reqd. N/A comp. not reqd.
Provide a description of the method of flow measurement or estimate.
Flow-weighted composite samples are not required.
EPA Form 3510-2F(Revised 3-19) Page 13
Enclosure 3
Additional Copy of Supplemental Information
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
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.
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,
a parameters sampled, lab results, date sampled, and storm event data.
f 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.
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.
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.
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)
BRP-SPPP.DWG 10/23/14 1=90 LRM/LRM
\ STORMWATER EXPOSURE
I 1, 500-GAL HYD, OIL TANK (UNDER ROOF)
2, 250-5AL HYD, UIL TANK (UNDER ROOF)
\ 3. SCRAP TUBING/SHEET METAL
4. MISC. STORAGE
5. LOADING DOCK
6. TRASH COMPACTOR (ENCLOSED)
\
I OUTFALL N0. I 7. 30 CU YARD TRASH ROLL-OFF (OPEN)y y B. ( PUB-GAL DIESEL TANKS
IN
L IN PUMP HOUSE
9, COVERED CANOPY AREA
/ -FLOOR SWEEPER/20 YD SPENT SAND
WATER SMR�E ROLL OFF
-METAL CHIP DUMPSTER AND
COOLANT RECYCLING PROCESS
(21 wAme / -EMPTY DRUM STORAGE
m VAPIII s 10. MAK, HAZ WASTE, OILS. COOLANTS,
WJ
QQ NTENANCE SHOP STORAGE CONTAINMENT DLDGS
/ Q(� & LWN. PARTS CRIB 11. MISC. PALLET STORAGE
0O 12. METAL PARTS IN WIRE BASKETS
13. COOLING TOWER
RETENTION I 14, DUST COLLECTORS, SAND PRETREAT.
OUTFALL NO. 3 POND 15, RTO STACK
16. RTO BAGHCUSE
ELECTRIC 17. SHIPPING AND RECEIVING
SUBSTATION
DO OUTFALL NO. 6
4
OUTFACE N0. 2 1 f
O OFFICE
PROPANE L DDMDN
TANK FARM 1
.(3) 30,000--GAL TANKS 1
BULK PROPANE
UNLOAD AREA
PARKING
% AREAS
NOTES: 1
1. OUTFALL NO. 1 RUNOFF AREA OUTFALL NO. 5
TOTAL AREA - 305,845 SO FT _
IMPERV10US m 244.418 SO FT
PERNOUS - 61,427 SO FT
RUNOFF COEF = 0.603 4
Il
2. DETENTION POND WILL HOLD A ONE INCH RAINFALLOUTFALL NO. 4�
3. OUTFALLS NO. 2 & 3 RUNOFF IS FROM UNDEVELOPED AREAS. ~
SCALE IN FEET
4. OUTFALLS NO. 4 & 5 ARE PART OF EMPLOYEE PARKING AREA iiiia
~
5. OUTFALL NO. 6 CONSISTS OF ROOF DRAINAGE. 0 90 ISO
ERM NC, INC. SITE PLAN AND DRAINAGE PATTERNS FIGURE
BRP US INC. 2
ERM SPRUCE PINE, NORTH CAROLINA
EPA Identification Number NPDES Permit Number Facility Name
110012281627 NC5000093 BRP US Inc.
NPDES Permit Renewal Application
Analytical Analytical Analytical
Results Results Results
Greater than
Discharge Discharge Discharge Discharge Measurement Sample Benchmark
Date Characteristic Characteristic Characteristic Characteristic Frequency Type Values?
Stormwater Total Total TSS 50
Discharge Outfall Suspended Recoverable pH 6-9
Location Solids(TSS) pH Aluminum(AI) Total Rainfall AI None
mg/L Standard ug/L inches
Year 5 Period 2,January 1-June 30,2018
6/13/2018 Outfall1 13.7 7.2 373 0.64 Semiannual Grab No
Year 1 Period 1,July 1-December 31,2018
12/14/2018 Outfall1 3.6 6.7 181 1.22 Semiannual Grab No
Year 1 Period 2,January 1-June 30,2019
5/2/2019 Outfalll ND 6.5 ND 1.36 Semiannual Grab No
Year 2 Period 1,July 1-December 31,2019
Not available in facility files Outfall 1 Not available Not available Not available Not available Semiannual Grab Unknown
Year 2 Period 2,January 1-June 30,2020
6/4/2020 Outfall1 3.2 6.4 ND 0.26 Semiannual Grab No
Year 3 Period 1,July 1-December 31,2020
10/24/2020 Outfall1 3.0 6.5 ND 0.52 Semiannual Grab No
Year 3 Period 2,January 1-June 30,2021
5/25/2021 Outfall1 5.8 5.4 ND 0.17 Semiannual Grab No
Year 4 Period 1,July 1-December 31,2021
11/11/2021 Outfail1 7.3 6.8 213 0.83 Semiannual Grab No
Year 4 Period 2,January 1-June 30,2022
6/8/2022 Outfall 1 6.2 6.2 116 Not available Semiannual Grab No
Year 5 Period 1,July 1-December 31,2022
Not available in facility files Outfall 1 Not available Not available Not available Not available Semiannual Grab Unknown
Year 5 Period 2 January 1-June 30,2023
6/20/2023 Outfall1 13.6 6.6 328 1.81 Semiannual Grab No
Year 6 Period 1,July i-December 31,2023
Not yet Not yet Not yet Not yet Not yet
Not yet available OutfallI available available available available Semiannual Grab available
AVERAGE 6.1 6.4 209.5
MAXIMUM 13.6 6.8 328
Notes:
ND=Not detected
Rainfall amounts available from facility rain gauge or from NCDC Daily Summaries for Spruce Pine,NC,climate station.
Records of samples for Year 2 Period 1 and Year 5 Period 1 have not been found in facility files,perhaps due to employee turnover.
Samples for Year 6 Period 1 have not been collected yet.
EPA Identification Number NPDES Permit Number Facility Name
110012281627 NCSO00093 8RP US Inc.
NPDES Permit Renewal Application
Qualitative Qualitative Qualitative Qualitative Qualitative Qualitative Qualitative Qualitative Qualitative Qualitative Qualitative
Results Results Results Results Results Results Results Results Results Results Results
Discharge Discharge Discharge Discharge Discharge Discharge Discharge Discharge Discharge Monitoring
Date Characteristic Characteristic Characteristic Characteristic Characteristic Characteristic Characteristic Characteristic Characteristic Frequency Sample Type
Other obvious
Erosion or indicators of
Stormwater Discharge Outfall Suspended deposition at stormwater
Location Color Odor Clarity Floating Solids Solids Foam Oil Sheen the outfall pollution
Year 5 Period 2,January 1-June 30,2018
6/13/2018 5001-6 Not available Not available Not available Not available Not available Not available Not available Not available Not available Semiannual Grab
Year 1 Period 1,July 1-December 31,2018
12/14/2018 SDO 1-6 Not available Not available Not available Not available Not available Not available Not available Not available Not available Semiannual Grab
Year 1 Period 2,January 1-June 30,2019
5/2/2019 SDO 1-6 Not available Not available Not available Not available Not available Not available Not available- Not available Not available Semiannual Grab
Year 2 Period 1,July 1-December 31,2019
Not available in facility files SDO 1-6 Not available Not available Not available Not available Not available Not available Not available Not available Not available Semiannual Grab
Year 2 Period 2,January 1-June 30,2020
6/4/2020 SDO 1•6 Not available Not available Not available Not available Not available Not available Not available Not available Not available Semiannual Grab
Year 3 Period 1,July 1-December 32,2020
10/24/2020 SDO 1-6 Not available Not available Not available Not available Not available Not available Not available Not available Not available Semiannual Grab
Year 3 Period 2,January 1-June 30,2021
5/25/2021 SD0 1-6 Not available Not available Not available Not available Not available Not available Not available Not available Not available Semiannual Grab
Year 4 Period 1,July 1-December 32,2021
11/11/2021 SDO 1-6 Not available Not available Not available Not available Not available Not available Not available Not available Not available Semiannual Grab
Year 4 Period 2,January 1-June 30,2022
6/8/2D22 SOO 1-6 Not available Not available Not available Not available Not available Not available Not available Not available Not available Semiannual Grab
Year 5 Period 1,July 1-December 31,2022
Not available in facility files SDO 1-6 Not available Not available Not available Not available Not available Not available Not available Not available Not available Semiannual Grab
Year 5 Period 2,January 1-June 30,2023
6/20/2023 SDO 1-6 Not available Not available Not available Not available Not available Not available Not available Not available Not available Semiannual Grab
Year 6 Period 1 July 1-December 31,2023
Not yet Not yet Not yet Not yet Not yet No[yet Not yet
Not yet available SDO 1-6 available available available Not yet available available available available available Not yet available Semiannual Grab
Notes:
Records of visual samples have not been found in facility files,perhaps due to employee turnover.
Samples for Year 6 Period 1 have not been collected yet.
EPA Identification Number NPDES Permit Number Facility Name
110012281627 NCS000093 BRP US Inc.
NPDES Permit Renewal Application
Stormwater Discharge Outfall
Location Stormwater Exposure Item Location Best Management Practices(BMPs) Additional BMPs
SDO 1 500-gal Hydraulic oil tank SE of Production Bldg Tank located under roof,secondary containment -
250-gal Hydraulic oil tank SE of Production Bldg Tank located under roof,secondary containment -
Scrap tubing/sheet metal SE of Production Bldg Stored outside Store inside building
Miscellaneous storage SE of Production Bldg Stored outside Store inside building
Loading dock E side of Production Bldg Covered -
Scrap metal roll-off E side of Production Bldg Sweep around roll-off on a frequent basis Cover the roll-off
Trash compactor E side of Production Bldg Enclosed -
30-Cubic yard trash roll-off E side of Production Bldg Sweep around roll-off on a frequent basis Cover the roll-off
Two 288-gal Diesel tanks E side of Production Bldg Tanks located inside Pump House Bldg -
Spent sand roll-off E side of Production Bldg Covered by a canopy and equipped with curbing -
Metal chip dumpster E side of Production Bldg Covered by a canopy and equipped with curbing -
Equipment storage E side of Production Bldg Covered by canopy and equipped with curbing -
Containment Bldgs for storage
of waste,oil,coolants NE of Production Bldg Enclosed
Pallets NE of Production Bldg Stored outside Limit number of pallets stored outside
Metal parts NE of Production Bldg Stored outside Store inside building
Monitor use of chemicals in cooling tower water
Cooling tower NE of Production Bldg and monitor containment for leaks
Dust collectors and sand Routinely sweep and properly dispose of dust
pretreatment area NE side of Production Bldg (particulates)
Regenerative thermal oxidizer Routinely sweep and properly dispose of dust
(RTO)stack and baghouse NE side of Production Bldg (particulates)
Shipping/Receiving Dock NE side of Production Bldg Monitor by BRP employee
Sand hopper E side of Production Bldg Sweep around hopper on a frequent basis
SDO 2 Propane unloading area NE side of Production Bldg Pressurized unloading
SDO 3 Propane tanks NE side of Production Bldg Pressurized tanks
SDO 4 Employee parking area SW of Production Bldg SPPP,training,etc.
SDO 5 Employee parking area SW of Production Bldg SPPP,training,etc. -
SDO 6 Roof SE of Production Bldg Use of control equipment(dust collectors,RTO)
Notes:
Best Management Practices(BMPs)are described in the BRP Stormwater Pollution Prevention Plan(SPPP)in facility files.
EPA Identification Number NPDES Permit Number Facility Name
110012281627 NCS000093 BRP US Inc.
NPDES Permit Renewal Application
Changes Since Previous Permit Issuance Description of Changes Location Best Management Practices(BMPs) Suggested Improvements to BMPs
No changes related to stormwater have
occurred None None None None
Notes:
No changes related to stormwater have occurred at the facility since the previous NPDES permit was issued.
Minor modifications to operations(more related to air quality)have included or will include the following:
Replaced the CD-1 bagfilter because the existing bagfilter was underrated and at the end of its service life.The replacement bagfilter is a Donaldson DFE 4-32 Dust Collector,which contains
32 ultra-web cartridge filters with a filter area of 8,128 square feet,a differential pressure meter,and an effective cleaning system.
Venting the following insignificant natural gas-fired ovens through the building roof rather than exhausting inside the manufacturing building,both to meet National Fire Protection
Association(NFPA)requirements and to improve indoor air quality:
"ES-17,Heat Treat No.1 Solution Oven for Cast Line No.1,3.0 MMBtu/hr capacity;
'ES-18,Heat Treat No.3 Solution Oven for Cast Line No.2,3.0 MMBtu/hr capacity;
*ES-30,Age Oven No.1(A0-01),1.0 MMBtu/hr capacity;
•ES-31,Age Oven No.2(AO-02),1.0 MMBtu/hr capacity;and
'ES-38,Age Oven No.3(AO-03),1.0 MMBtu/hr capacity.
Removed ES-47,Paint Spray Booth and Associated Bake Oven(3.0 MMBtu/hr capacity),since painting is done off-site by a vendor.As a result,this source has been removed from the facility.
Added Dehumidifiers#1 and#2 for the Styrofoam Drying ovens.
Replaced the Emergency Generator.
Replaced the CD-16 bagfilter because the existing bagfilter was underrated and at the end of its service life.
Removed ES-44,Boiler#2(14.7 MMBtu/hr capacity),since Boiler#1 is larger and sufficient for plant operation.
EPA Identification Number NPDES Permit Number Facility Name
110012281627 NCS000093 BRP US Inc.
Summary of Best Management Practices (BMPs) utilized at BRP US Inc.
The facility has provided structural and non-structural measures or practices to reduce the
amount of pollution entering surface waters. Structural best management practices employed at
the BRP facility include providing covers over bulk storage areas and secondary containment
features. Catch basins are provided to improve stormwater flow throughout the facility. Non-
structural best management practices include drainage ditches, semi-annual stormwater
inspections,monitoring loading/unloading operations,sweeping,and good housekeeping
procedures and inspections. A listing of the BMPs for the site is provided in the narratives and
table below.
Description of Storage, Loading, Dust Generating,and Waste Disposal Practices
Bulk Storage
All of the bulk above ground storage tanks (AST),totes, drums,and other storage containers are
compatible with the products stored and the conditions of storage such as pressure and
temperature. Totes and drums are stored either inside the buildings or inside the storage
containment buildings located east of the production building. Three (3) 30,000-gallon propane
tanks will not impact stormwater since the tanks are pressurized.
Loading and Unloading
The facility has a loading dock at the southeastern building wall and a shipping/receiving area at
the northeastern building wall. The loading dock area is paved, and spill control equipment is
located nearby. Facility personnel are equipped with internal communication equipment during
all bulk or drum transfers. A propane unloading area will not impact stormwater since propane is
a pressurized gas.
Dust or Particulate Generation
The facility has a total of six (6) dust collectors located along the northeastern building wall. One
dust collector is associated with the aluminum casting lines;one associated with sand storage for
each casting line (two lines); one for the regenerative thermal oxidizer (RTO);one for the sand
reclamation system; and one is associated with the shot blast machines and sand blast units. The
facility also uses an RTO,which utilizes its own baghouse for the pouring,cooling, shakeout, and
quench process. The area is routinely swept and inspected for particulates entering the
stormwater system. Dust collectors and control of particulate emissions limit the particulates on
the facility roof. The cooling tower,chemicals used,and containment area are monitored.
Waste Disposal Practices
All waste generated at this facility is segregated into non-hazardous or hazardous waste
containers. All hazardous waste is collected into appropriate containers (drums are labeled and
stored in the containment units). Non-hazardous waste is separated according to type and
collected in approved containers located throughout the facility before disposal or recycling. The
facility has one open trash roll-off,one enclosed trash compactor,one open scrap metal dumpster,
one spent sand roll-off (under canopy),and one metal chip dumpster (under canopy).
Miscellaneous Storage and Other Areas
Miscellaneous items are stored under the canopy area and south of the production building.
BMPs for employee parking areas include preparation and implementation of the Stormwater
Pollution Prevention Plan(SPPP) and training.
EPA Identification Number NPDES Permit Number Facility Name
110012281627 NCS000093 BRP US Inc.
A summary of the facility's stormwater exposure items and associated BMPs is listed in the table
below.
Table 1. Summary of Stormwater Exposure Item,Location,and Best Mana ement Practices (BMPs)
Stormwater Exposure Item Location BMPs
500-Gallon Hydraulic Oil Tank Southeast of The tank is located under roof
Production Building and is equipped with concrete
secondary containment.
250-Gallon Hydraulic Oil Tank Southeast of The tank is located under roof
Production Building and is equipped with concrete
secondary containment.
Scrap Tubing/Sheet Metal Southeast of Scrap tubing and sheet metal
Production Building are located on racks and on the
ground. Some items are stored
these items inside the building.
Miscellaneous Storage Southeast of Miscellaneous items are stored
Production Building on the ground east of the
production building. Some
items are stored under canopy
or inside the building.
Loading Dock East Side of The loading dock is covered.
Production Building
Scrap Metal Roll-Off(Open) East Side of The roll-off is open. The
Production Building facility sweeps around the roll-
off on a frequent basis.
Trash Compactor(Enclosed) East Side of The trash compactor is
Production Building enclosed. The facility sweeps
around the trash compactor on
a frequent basis.
30 Cubic Yard Trash Roll-Off(Open) East Side of The roll-off is open. The
Production Building facility sweeps around the roll-
off on a frequent basis.
(2)288-Gallon Diesel Tanks inside East Side of The tanks are single-walled
Pump House Production Building tanks but are located within the
Pump House Building. The
tanks are inspected on a
monthly basis.
EPA Identification Number NPDES Permit Number Facility Name
110012281627 NCS000093 BRP US Inc.
Stormwater Exposure Item Location Comments and BMPs
Covered Canopy Area Containing: East Side of The area is covered and is
- Floor Sweeper Production Building equipped with curbing.
- 20 Yd.Spent Sand Roll-Off The facility frequently monitors
- Metal Chip Dumpster the area.
- Cutting Fluid
Recycling Process
(Includes 300-
Gallon Recycled
Cutting Fluid Tote)
- Empty Drum Storage
Containment Buildings containing Northeast of The containment buildings are
MAK,Hazardous Waste,Oils, Production Building enclosed and secondarily
Coolants contained,which prevents
materials from entering the
stormwater system.
Pallets Northeast of Pallets are stored on the ground.
Production Building The facility limits the number of
pallets stored outside.
Metal Parts Northeast of Metal parts are stored in wire
Production Building baskets northeast of the
production building. Some
parts are stored inside.
Cooling Tower Northeast Side of The facility monitors the use of
Production Building chemicals in the cooling tower
and monitors the containment
for leaks.
Dust Collectors and Sand Northeast Side of The facility has four dust
Pretreatment Area Production Building collectors and a sand
pretreatment area. The facility
routinely sweeps and properly
disposes of particulates.
Regenerative Thermal Oxidizer Northeast Side of The facility has an RTO to reduce
(RTO)Stack and Baghouse Production Building toxins in the air emissions from
the pouring,cooling,shakeout,
and quench processes. The
facility routinely sweeps this area
and properly disposes of
articulates.
Shipping and Receiving Dock Northeast Side of Shipping and receiving is
Production monitored by a BRP employee.
Building
Propane Tanks Northeast Side of Small propane tanks are stored
Production Building at the rear of the facility. Three
and Plant 30,000-gallon propane tanks are
Drive located near the plant drive.
Releases from propane tanks
would not reach stormwater.
Sand Hopper(Open) East Side of The hopper is open. The
Production Building facility sweeps around the
hopper on a frequent basis.
EPA Identification Number NPDES Permit Number Facility Name
110012281627 NCS000093 BRP US Inc.
Changes Since Previous Permit Issuance
No changes related to stormwater have occurred at the facility since the previous NPDES permit
was issued.
Minor modifications to operations that are more related to air quality have included or will
include the following:
• Replaced the CD-1 bagfilter because the existing bagfilter was underrated and at the end of
its service life. The replacement bagfilter is a Donaldson DFE 4-32 Dust Collector,which
contains 32 ultra-web cartridge filters with a filter area of 8,128 square feet, a differential
pressure meter, and an effective cleaning system.
• Venting the following insignificant natural gas-fired ovens through the building roof rather
than exhausting inside the manufacturing building,both to meet National Fire Protection
Association(NFPA) requirements and to improve indoor air quality:
o ES-17,Heat Treat No. 1 Solution Oven for Cast Line No. 1,3.0 MMBtu/hr capacity;
o ES-18,Heat Treat No. 3 Solution Oven for Cast Line No. 2,3.0 MMBtu/hr capacity;
o ES-30,Age Oven No. 1 (AO-01), 1.0 MMBtu/hr capacity;
o ES-31,Age Oven No. 2 (AO-02),1.0 MMBtu/hr capacity;and
o ES-38,Age Oven No. 3 (AO-03), 1.0 MMBtu/hr capacity.
• Removed ES-47,Paint Spray Booth and Associated Bake Oven (3.0 MMBtu/hr capacity),
since painting is done off-site by a vendor. As a result,this source has been removed from
the facility. This reduces the amount of hazardous waste generated at the facility.
• Added Dehumidifiers #1 and #2 for the Styrofoam Drying ovens.
• Replaced the Emergency Generator.
• Replaced the CD-16 bagfilter because the existing bagfilter was underrated and at the end
of its service life.
• Removed ES-44,Boiler#2 (14.7 MMBtu/hr capacity),since Boiler#1 is larger and sufficient
for plant operation.