NCS000251_Fact sheet binder_20240327

DEQ / DEMLR
FACT SHEET FOR NPDES INDUSTRIAL INDIVIDUAL
STORMWATER PERMIT DEVELOPMENT
Basic Information for Permit Issuance and Renewals:
Permit Writer/Date Brianna Young 3/22/2024
Permit Number NCS000251
Owner/Facility Name Bakelite Chemicals,LLC/ConwayResins Plant
SIC(NAICS)Code/Category SIC Code: 2869 and 2821
NAICS Codes : 325199 and 325211
Basin Name/Sub-basin number Chowan/03-01-02
Receiving Stream/HUC UT to Paddys Delight Creek(Dolittle Millpond)/
030102040805
Stream Classification/Stream Segment B;NSW/25-4-8-2- 1
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? No
New expiration date 4/30/2029
Comments on Draft Permit? See Section 6 below
Section 1. Facility Activities and Process:
The Conway Resins Plant produces resin and formaldehyde. All water collected in process area drains
and truck wash area is reused or hauled off-site. Outfall SW001 is permitted under wastewater certificate
of coverage (COC)NCG500065 (two stormwater-only outfalls flow to this wastewater outfall). Outfalls
SW002, SW003, and SWO04 discharge into different locations of the same ditch; however,per an email
from December 2022, the Raleigh Regional Office inspector felt combining these outfalls into one
sample point is not appropriate as the ditch will receive water from offsite, potentially dealing with
BOD, COD and nitrogen issues from outside contamination, fertilizers, and decaying leaf litters. As
such, Outfalls SW002, SW003, and SWO04 will remain as separate outfall points.
Per the 2005 staff report, a special condition remained that effectively imposed a"limit" on
formaldehyde and phenol in stormwater discharges: if formaldehyde and phenol levels in the SWDB
exceed 1.0 and 2.0 mg/L, respectively, spray irrigation was required (i.e., no stormwater discharge from
outfall 002 allowed) (per an October 13, 1999 Memo to RRO).
Per the 2015 and 2020 permit renewal applications, the permittee requested clarification on the
formaldehyde concentration that triggers spray irrigation from the stormwater detention basin as Table 3
of the current permit has a benchmark of 0.49 ppm while Table 4 states a land application benchmark of
1.0 ppm. The application states the facility land applies any stormwater in the detention basin with a
concentration greater than 0.49 ppm. The permittee requests:
• Removal of the spray irrigation benchmark from Table 4 and make it a requirement that any
stormwater with formaldehyde concentration greater than 0.49 ppm be land applied in the spray
field. Modification of footnote#4 in Table 1 to reflect this change as well.
o DEQ response: The threshold for spray irrigation has been updated to match the
stormwater benchmarks.
Page 1 of 8

• Clarify that Tier I and Tier II requirements are only triggered in the event of a discharge of
stormwater with a formaldehyde concentration greater than 0.49 ppm.
o DEQ response: Tier Response relates to exceedance of stormwater benchmarks. Please
follow the permit requirements outlined in Part D of the permit.
Outfall SWO02:
Discharge area includes overflow for the stormwater detention basin(discharge from the basin is
controlled by a locked valve), runoff from the east and southeast sides of the formaldehyde plant, and
runoff from the central and west portion of the facility. Stormwater from the detention basin not meeting
water quality requirements is sent to the permitted land application/spray system via a stormwater
collection sump. Potential pollutants include: O&G, BOD, COD, TSS, nitrogen, phosphorus,
formaldehyde,phenol, and cresol.
Outfall SWO03:
Drainage area includes oil filled electrical transformers and the area east of the spray dry operation.
Potential pollutants include: O&G, BOD, COD, nitrogen, and phosphorus.
Outfall SWO04:
Discharge area includes runoff from the area east of the resin loading and raw material unloading area, a
roadway, parking lot, and office building. Potential pollutants include: O&G and TSS.
Additional Outfalls:
Outfall SW001: Discharge area includes a drainage ditch that collects most of the stormwater onsite,
boiler and cooling tower blowdown, the Spray Dry Operation parking area, the concrete area east of the
raw material warehouse, and a grassy area. SW001 is permitted under NCG500065. Potential pollutants
include: O&G, BOD, COD, nitrogen, and phosphorus.
Why Industrial Sites with Stormwater are Subject to a Permit: Federal NPDES regulations define
stormwater discharge associated with industrial activity in 40 CFR §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."
Page 2 of 8

Section 2. Monitoring Information and Compliance History:
• Spring 2011 to March 2022,benchmarks exceeded for:
o SW001: TP 5x, pH max exceeded 1x, Formaldehyde 3x
o SW002: TSS 1x, BOD 2x, COD 2x, TN 2x, TSS Ix, Formaldehyde 2x
o SW003: pH min not reached 1x, Formaldehyde 3x
o SW004: Formaldehyde 3x
• Per the inspection report from 9/20/2012, SW001 was in Tier I status for pH
• Per the inspection report from 9/20/2012, SW002 was in Tier I status for TSS
Threatened/Endangered Species:
There are no threatened/endangered species in the area of discharge. The Coppery Emerald
(Somatochlora georgiana; NC status: SR) is in the vicinity of discharge.
Section 3. Proposed Monitoring for Stormwater Discharges:
The Division considered potential pollutants from past and present industrial activities and data was
submitted for Spring 2011 to March 2022. Quantitative sampling included pH, TSS, O&G, BOD, COD,
Nitrate/Nitrite, TKN, Total Nitrogen, Total Phosphorus, formaldehyde, p-cresol, o-cresol, m-cresol, and
phenol.
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 Conway Resins Plant site.
Page 3 of 8

Outfall SWO02
Quarterly monitoring
Total Suspended Solids BASIS: Potential pollutant from drainage area and BMP effectiveness
(TSS) indicator.
Quarterly monitoring
pH BASIS: Pollutant indicator
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 from drainage area
Quarterly monitoring
BOD BASIS: Discharge potential indicator
Quarterly monitoring
COD BASIS: Discharge potential indicator
Quarterly monitoring
Total Nitrogen BASIS: Discharge potential indicator
Quarterly monitoring
Total Phosphorus BASIS: Discharge potential indicator
Quarterly monitoring
Total Cresol BASIS: Potential pollutant from drainage area
Quarterly monitoring
Phenol BASIS: Potential pollutant from drainage area. Spray irrigation required if
concentration in the stormwater detention basin exceed benchmarks.
Quarterly monitoring
Formaldehyde BASIS: Potential pollutant from drainage area. Spray irrigation required if
concentration in the stormwater detention basin exceed benchmarks.
Page 4 of 8

Outfalls SWO03 and SWO04
Quarterly monitoring
Total Suspended Solids BASIS: Potential pollutant from drainage area and BMP effectiveness
(TSS) indicator.
Quarterly monitoring
pH BASIS: Pollutant indicator
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 from drainage area
Quarterly monitoring
BOD BASIS: Discharge potential indicator
Quarterly monitoring
COD BASIS: Discharge potential indicator
Quarterly monitoring
Total Nitrogen BASIS: Discharge potential indicator
Quarterly monitoring
Total Phosphorus BASIS: Discharge potential indicator
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).
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
Page 5 of 8

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 example, one or more metals or
other parameters may serve as an adequate tracer for the presence of ash pollution during disturbance or
ash removal in specific drainage areas at this site. 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
Total Suspended 100 mg/L National Urban Runoff Program(NURP) Study, 1983
Solids TSS
H 6 s.u. —9 s.u. NC Water Quality Standard(Range)
Non-Polar Oil & Review of other state's daily maximum benchmark
Grease 15 mg/L concentration for this more targeted O&G;NC WQS that
EPA Method 1664 does not allow oil sheen in waters
SGT-HEM
BOD 30 mg/L BPJ; Based on Secondary Treatment Regulation(40 CFR
133.03
COD 120 mg/L BPJ; Generally found at levels 4x BOD5 in domestic
wastewaters
Total Nitrogen 30 mg/L TKN +Nitrate+Nitrite Benchmarks (Expressed in mg/L of
N
Total Phosphorus 2 mg/L BPJ; Based on wastewater permit limits for NSW waters
Total Cresol 4.0 mg/L I/,FAV
Formaldehyde 0.5 mg/L I/,FAV
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 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:
Page 6 of 8

• 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:
• Regulatory citations have been added
• Monitoring increased from semi-annually to quarterly for all parameters (qualitative and
quantitative)
• "No discharge" clarifications made
• eDMR requirement added
• Feasibility study removed as this is no longer a Stormwater Program requirement
• Boilerplate language moved into body of the permit; boilerplate no longer attached
• Outfall specific monitoring has been implemented
• Benchmarks updated for parameters per guidance from DWR Standards group on stormwater
benchmarks
• Owner entity updated per information previously submitted to DEMLR
• TSS and monthly oil usage monitoring added for all outfalls per current permitting strategy
• Outfall SW001 removed from the permit as it is covered under an NCG500000 wastewater COC
• Outfall SWO02 separated from other outfalls as there are separate monitoring requirements
• Spray irrigation threshold for formaldehyde has been updated to match stormwater benchmark
per comments received from the permittee
Page 7 of 8

Section 5. Changes from draft to final:
• None
Section 6. Discussions with the Facility and Regional Office:
• Initial contact with facility: 7/29/2022
• Initial contact with Regional Office: 7/29/2022
• Draft sent to CO peer review: N/A
• Draft sent to Regional Office: l l/l/2023
• Final permit sent for supervisor signature: N/A
Section 7. Comments received on draft permit:
• None
Page 8 of 8

The Beaufort Gazette Durham I The Herald-Sun The Modesto Bee
The Belleville A'cws-Democrat Fort Worth Star-Telegram The Sim News-Myrtle Beach
Bellingham Herald Tlee Fresno Bee Raleigh views&Observer.
' Centre Daily Times The Island packet Rack Hill I Tire Herald
Mchy Sun Herald The Kansas City Star T1ceSrcaramento Bee
Idalw Statesman Lexington Herald-Leader San Luis Obispo Tribtute
Bradenton Herald The Telegraph-Macon Tacoma I The Mews Tribune
Tice Charlotte Olverter MercedSunStar Tri-City Herald
The State Miami Herald The Wichlta Eagle
Ledger-Enquirer El-Nuevo Herald The Olympian
AFFIDAVIT OF PUBLICATION
Aunt 9 Order Number Identlflcatlon Order PO I Amount Co{s Depth
39106 S72716 PrInt Legal Ad-IPLO1606SBO-IPL0160658 1 $481.68 1 48 L
Attentron: Joyce Sanford Clark STATE OF NORTH CAROLINA
NC DENR ENGERGY MINERAL&LAND RESOURCES COUNTY OF WAKE,COUNTY OF DURHAM
1612 MAIL SERVICE CENTER Before the undersigned,a Notary Public of Dallas
RALEIGH,NC 276991612 County,Texas,duly commissioned and authorized to
administer oaths,affirmations,etc.,personally
[e-mail] appeared Tara Pennington,who being duly sworn or
_ affirmed,according to law,cloth depose and say that he
"""""""'""""""-""'"-
NORTH CAROLINA ENV[RON----------------------------------------------------- or she is Accounts Receivable Specialist of the News&
;
MENTAL MANAGEMENT COM- Observer Publishing Company,a corporation organized
MISSION INTENT TO ISSUE
NPOES STORMWA7ER fBIS- and doing business under the laws of the State of North
CHARGE PERMITS Carolina,and publishing a newspaper known as The
The North Carolina Environmental News&Observer,Wake and State aforesaid,the said
Management Commission proposes '
to issue NPDES stormvater discharge newspaper in which such notice,paper,document,or
permit(s)to the persons)listed below. legal advertisement was published was,at the time of
Public comment or objection to the
draft permits Is invited.Written com- ; each and every such publication,a newspaper meeting
ments regarding the proposed permit all of the requirements and qualifications of Section I-
will
be accepted until 30 days attar the
publish data of this.notice and consid- 597 of the General Statutes of North Carolina and was a
publish '
ered in the final determination regard- qualified newspaper within the meaning of Section 1-597
ing permit issuance and permit provi- ,
sloes.The Director of the NC Division ; of the General Statutes of North Carolina,and that as
of Energy,Mineral,and Land Resourc-
es such he or she makes this affidavit;and is familiar with
shouuldld there
re be a significant degree of
}may hold if public hearing the books,files and business of said corporation and by
�
public interest.Please mail comments and/or information requests to DEMIA reference to the files of said publication the attached
at 1612 Mail Service Center,Raleigh, advertisement for NC DENR ENGERGY MINERAL&LAND
NC 27699-1612. RESOURCES was inserted in the aforesaid newspaper on
• Bakelite Chemicals, LLC [PO
Box 368, Conway, NC 27820) dates as follows:
has requested renewal of per ;
mft NCS000251 for the Conway ' 1 insertion(s)published on:
Resins Plant in Northampton
County.This facility discharg- a 02/21/24
es to an unnamed tributary to ;
Paddys Delight Creek (Dotittle '
Millpond)in the Chowan River 2 Basin.
Interested persons may visit DEMLR n � LSF
at W N. Salisbury street, Raleigh, c�{O
NC 27604 to review Information on +'`_`�l Water
Pro ra
file. Additional information on NP- h m ; f
DES permits and this notice may be �Y
found on our websits: httpsJ/deq. •--
nc.gov/about/divislons/energy-min- ; •'
eral-and-land-resoumes/stormwater/ '
stornwater-program/stormwater-pub-
lic-notices,or by contacting Brianna certifyor declare)under penalty o pequry t at t e
Young at brianna.young�deq.nc.gov 'or919-70T-364T. foregoing is true and correct.
;
tPLO160658 �
Feb 212024,
H
Notary Public in and for the state of Texas,residing in
Dallas County
='y"`
STEPHANIE HATCHER
- �
My hfIryFI � .
Extra charge for lost or dup[Iate affidavits.
Legal document please do notdestroyl

Young, Brianna A
From: Garcia, Lauren V
Sent: Tuesday, December 13, 2022 10:51 AM
To: Young, Brianna A
Cc: Riddick, Timothy A
Subject: NCS000251 Inspection Report
Attachments: NCS000251 Outfall Explanation jpg; NCS000251_Inspection Report_20221207.pdf; IMG_
9466.J PG; I MG_9459.J PG; I M G_9460.J PG; I M G_9461.J PG; I M G_9462.J PG; I M G_9463.J PG;
IMG_9464.JPG; IMG_9465.JPG
Hey Brianna,
Here is the inspection report for NCS000251. I have also included some photos from their documentation and the signed
permit just incase they are helpful during the renewal.
Thanks,
Lauren
Lauren Garcia
Environmental Senior Specialist
Division of Energy, Mineral, and Land Resources
Department of Environmental Quality
[phone]
lauren.garcia(q_�ncdenr.gov
1628 Mail Service Center, Raleigh, North Carolina 27699
3800 Barrett Drive, Raleigh, NC 27609
-ew.�D,E Q"--
DMvttmw.Li of Enr rwmrn dal Quality
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
1

Compliance Inspection Report
Permit:NCS000251 Effective: 02/01/11 Expiration: 01/31/16 Owner: Bakelite Chemicals LLC
SOC: Effective: Expiration: Facility: Conway Resins Plant
County: Northampton 200 Ampac Rd
Region: Raleigh
Conway NC 27820
Contact Person:Tim Riddick Title: Phone: [phone]
Directions to Facility:
System Classifications: SWNC,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 12/07/2022 Entry Time 01:55PM Exit Time: 03:30PM
Primary Inspector:Lauren Garcia Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 3

Permit: NCS000251 Owner-Facility:Bakelite Chemicals LLC
Inspection Date: 12/07/2022 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Inspection was in response to permit renewal. There have been no changes in industrial activity since the application was
submitted.
The facility has three main process, formaldehyde, resin manufacturing and spray dry. The resin manufacturing area drains
mainly to outfall 1 and slightly to outfall 4. The formaldehyde manufacturing area drains to outfall 2. The formaldehyde
manufacturing is operated continuously. The spray dry area drains to outfall three and partially to outfall 1. There is a dry
product warehouse within the drainage area to outfall 1. Onsite there are also spray fields and waste water lagoons, covered
under separate permits.
Outfall 1 currently has stormwater comingled with non contact cooler/boiler blowdown water. It is likely the current outfall 1
will be removed from the stormwater permit as this technically makes the comingled water wastewater. The stormwater only
discharges from the western side of the facility will need to be identified and sampled.
There are multiple holding areas onsite where stormwater is held and checked for formaldehyde before it is released to drain
through outfalls. The water is tested with "chemets". There is also a way for the water to be diverted to the onsite waste
water lagoons if the water tests positive for contaminants.
All storage tanks were observed to have secondary containment. Diesel tanks had propper secondary containment. All dry
products produced/used onsite are stored under cover in teh dry storage warehouse. Industrial processes for the spray dry
appear to take place within the building under cover. The industrial process for the resin and formaldehyde processes are
contained, but there are exposed pipes and storage tanks outside. All of the tanks and exposed areas have secondary
containment.
The facility appeared to be kept neatly. No issues with pollution prevention and good house keeping were observed. All
required documentation was present. The stormwater pollution prevention plan was thorough and addresses all permit
requirements. DMRs were provided.
Page 2 of 3

Permit: NCS000251 Owner-Facility:Bakelite Chemicals LLC
Inspection Date: 12/07/2022 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? ❑ ❑ ❑
#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? 0 ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented? 0 ❑ ❑ ❑
Comment:
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring? 0 ❑ ❑ ❑
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:
Page 3 of 3

Young, Brianna A
From: Garcia, Lauren V
Sent: Tuesday, December 13, 2022 10:44 AM
To: Young, Brianna A
Subject: RE: NCS000251 Outfall Discussion
Outfalls 2, 3,4 to remain, and then a 5 and 6 can be added where the two discharge points are shown that were flowing
to outfall 1 in the map I made.
bs - • • � w
wW
aat
h all
# # • • # ' 4-
ww
■ o R " • f
aehvd
# * i w
i * • * dottedareatocollecti
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Spray Dry Plant Rd DiF,Pll�nfl R
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If you think they can sample from the ditch for outfalls 2, 3 and 4, and condense them to one outfall,then by all means
go for it.They facility may be able to provide a justification to sample from there. I think they will start to have issues
with COD, BOD and nitrogen if they do that though.
From:Young, Brianna A<[e-mail]>
Sent:Tuesday, December 13, 2022 10:15 AM
To: Garcia, Lauren V<[e-mail]>
Subject: RE: NCS000251 Outfall Discussion
Thanks, Lauren. I did not see the red numbers before (hard to see the red on top of the green)—had to zoom in on the
image.The thought about combining the outfalls was that since they go to the same drainage ditch, rather than
sampling along 3 different points of the same ditch,they could just take 1 sample downstream of all 3 to get one
combined sample. If you don't feel that's appropriate, I'll keep them separate.
I'll go ahead and take 001 out of the permit since all the stormwater comingles with WW and flows out of the permitted
WW outfall.
Just to confirm, are you saying only outfall 4 and a new outfall 5 should be listed in the permit? Or would 2, 3,4, and a
new 5 be in the permit?

Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](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: Garcia, Lauren V<[e-mail]>
Sent:Tuesday, December 13, 2022 9:38 AM
To:Young, Brianna A<[e-mail]>
Subject: RE: NCS000251 Outfall Discussion
I don't think it would be appropriate for 002 and 003 to be combined,you can see in my map that they are two distinct
outfalls. 002 drains from the formaldehyde production, 003 drains the spray dry building. When they said it was hard to
collect a sample,they just meant there is not always a discharge large enough to collect a sample.There should be no
issue with them writing in "no discharge" during sampling events if there isn't one. I personally don't think they should
sample from the ditch in the woods.The ditch is a bit off into the woods and is not visible from the fenced in site. Outfall
4 does eventually discharge to the ditch above outfall 2 and 3.The ditch will receive water from offsite and they could
potentially deal with BOD, COD and nitrogen issues from outside contamination,fertilizers,and decaying leaf litters.
Yes,outfall 001 is covered under NCG500065 for discharges of non-contact cooling water, cooling tower blowdown,
condensate, exempt stormwater and cooling waters associated with hydroelectric operations, similar wastewaters, and
inflow from the cooling tower. I have a basic understanding of this kind of permit.
They also have a WQ0002012 permit.
If you look at the map I made, you can see there are two distinct stormwater only discharges that flow to their outfall 1,
one off of spray Dry Plant Rd and one behind the resin building.The easiest thing for them to do would be to just mark
those two points as stormwater outfalls 4 and 5 and be done with it.
From:Young, Brianna A<[e-mail]>
Sent: Monday, December 12, 2022 11:06 AM
To: Garcia, Lauren V<[e-mail]>
Subject: RE: NCS000251 Outfall Discussion
Hey Lauren,
Sorry for the late reply. If boiler and cooling blowdown is being mixed in,then that is a wastewater outfall.They will
need to move that out of the stormwater permit and into a wastewater permit. I understand previous permit writers
were notified and nothing happened, but we need to get that out of the stormwater permit because it really doesn't
2

belong. Per my notes, 001 is covered under an NCG500000 COC(wastewater permit), so we could potentially go ahead
and take it out of the stormwater permit since it's covered under NCG500000 anyway.
In my notes there are 4 outfalls, but there were questions about which ones should be in the permit or not. Did you
confirm if SWO02 and SWO03 can be combined into a single outfall? Does 004 use the same ditch as 002 and 003?
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)
[e-mail](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: Garcia, Lauren V<[e-mail]>
Sent:Thursday, December 8, 2022 12:23 PM
To: Riddick,Timothy A<[e-mail]>
Cc:Young, Brianna A<[e-mail]>
Subject: NCS000251 Outfall Discussion
Hey Brianna,
I made this little map to try to explain what is going on with the outfalls at the Conway Resins plant. I don't think that
there is an issue with outfall three, it is just that there is not always a discharge. Outfall 1 seems to be the bigger issue
because of the comingling with the non contact boiler and cooling blowdown.They have email documentation of the
previous writer of this permit being aware of the comingling, so it has been reported to the State before. I have tried to
show where the two stormwater discharges would be. Let me know what you think about that and I will work on the
inspection report. They have immaculate documentation btw.
Thanks,
Lauren
Lauren Garcia
Environmental Senior Specialist
Division of Energy, Mineral, and Land Resources
Department of Environmental Quality
[phone]
Iauren.garcia(@ncdenr.gov
3

1628 Mail Service Center, Raleigh, North Carolina 27699
3800 Barrett Drive, Raleigh, NC 27609
D,- E
oop,tine.,Li of Enr ro mrn dal qualft
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
4

13
The only with H thereto
[M1a[
�M1 bluebubbled areas are colleR on sites
wM1ere try - of y gM1 in 1 ,
and
t sbefore and release t the scrolls.
They
t that discharges tM1 t
hould be
y; is tch to to test
formaldehyde.
e. The smallest
estcollecta sample.They discharge
i I Se RE charter drain
test where
they are
to mute
ate li t monitor f ere ant
e
'T 7I nd
Garr tlena e spot isa drain wM1onsif them able tone with
during
again event
[M1ereiznt one
21 t cons an issuewitM1a tlunngarainevent
forpalRad pose for rontam ants
- mpacP n
r Georgia Pacific
Y 'xrc
Ip - C p ration
I . hytbuilding
.p ffiIllnon rbd boiler blow tl nrterts a' •1
f abourithistai no me.This gl" g was notedd i the t
previousperm, enewsal so I done k hat happe etl
mmtTM1ce w dotted line and the yellow straight 1 '✓H �
lin k[M1 rtor ter onlyd M1 dthat d t
ou[f II1 TM15 a Go in that thwill not b heavy
r e ougM1 tllsvM1erge from t itotted area to collect a sample. r t'
of Sir
Or
01 eyhSprayfo lam Rtl .- . Sprayscry Rant Rd
♦ P
Spray Fields
ngpst�y✓ 4 I goons,
Cutfall one is located right at the tree line at
the edge of the field here

13
The only with H thereto
[M1a[
�M1 bluebubbled areas are colleR on sites
wM1ere try - of y gM1 in 1 ,
and
t sbefore and release t the scrolls.
They
t that discharges tM1 t
hould be
y; is tch to to test
formaldehyde.
e. The smallest
estcollecta sample.They discharge
i I Se RE charter drain
test where
they are
to mute
ate li t monitor f ere ant
e
'T 7I nd
Garr tlena e spot isa drain wM1onsif them able tone with
during
again event
[M1ereiznt one
21 t cons an issuewitM1a tlunngarainevent
forpalRad pose for rontam ants
- mpacP n
r Georgia Pacific
Y 'xrc
Ip - C p ration
I . hytbuilding
.p ffiIllnon rbd boiler blow tl nrterts a' •1
f abourithistai no me.This gl" g was notedd i the t
previousperm, enewsal so I done k hat happe etl
mmtTM1ce w dotted line and the yellow straight 1 '✓H �
lin k[M1 rtor ter onlyd M1 dthat d t
ou[f II1 TM15 a Go in that thwill not b heavy
r e ougM1 tllsvM1erge from t itotted area to collect a sample. r t'
of Sir
Or
01 eyhSprayfo lam Rtl .- . Sprayscry Rant Rd
♦ P
Spray Fields
ngpst�y✓ 4 I goons,
Cutfall one is located right at the tree line at
the edge of the field here

Springs \
Discharges from f refighting or firefighting training
Waterline and fire hydrant flushin
g
g
Discharges of uncontaminated potable water
Water from footing drains
• Flows from riparian habitats and wetlands
i
• Air conditioning condensate without added chemicals
Non- stormwater discharges generated from the cooling tower, non- contact cooling tower,
condensate, boiler blow down and similar wastewater are diverted and conveyed to the permitted
discharge via SDO - 001 . This discharge is regulated under North Carolina DEQ Division of Water
Quality General Permit No . NCG500000 (Certificate of Coverage No . NCG500065 ) for discharges
of non-contact cooling water, cooling tower and boiler blowdown, condensate, exempt stormwater,
cooling waters associated with hydroelectric operations , and similar wastewaters , and receives
inflow from the cooling tower.
i
Permit No . NCS000251 requires the certification, annually , that the stormwater outfalls have been
evaluated for a presence of non- stormwater discharges . Worksheets #3 and 44 are provided to
facilitate this evaluation and certification . Completed copies of Worksheets 43 and 44 (if
appropriate) are located in the Environmental files .
44

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Outfall 001 is a drainage ditch that collects most of the stormwater on - site and ( some
permitted cooling water blowdowri,discharge ) . The outfall was clear and water was
discharging the day of the inspecOn . Outfall 002 is overflow for the stormwater
detention basin as applicable . Stormwater from the detention basin not meeting water
quality requirements is sent to the permitted land application /spray system . Outfall 002
was not discharging the day of the inspection . Outfall 003 is a low flow area of direct
stormwater discharge by the exterior (oil filled ) electrical transformers . Outfall 004 is
another low flow area that drains parking lot and office building - no industrial process .
Facility reported that all water collected in process area drains and truck wash area is
reused or hauled off- site and not discharged .
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M�e��7 No A105000251
a ".
A 1ito
-tjtj
n�c�nitorert mc>nito h8 shr ► Ill �cll �� ' � t �`r dischar�tes �hnll be Performed ns s�,cci ('ied in Table 1 . Ali
b \�ill result in � minimum- form1�c n� nnal� �i analytical ufrPrcnn, lin1 v� ctc• evem . "I he required
rhoj4)Cr7jt tit
it at ach
dhs4,, hargc uutlull ` � )p). � � ' wing con� u��ed over the term of
A repi•cscntIfive '
betNIVICIC11 this « () � torn � event th .. � t nicasures Etrc :� icr thiui �� � inchc � of rainfall , "The time
72 hours . A S ; n � �� c � ► t aii � d ihr ��-� vious sN , ini c � cnt measuring greater flust, (1 . 1 incfic � must he nt Icact
i[ rains hur stony befo " � � event mny leave a period of no precipitfition cif up to 10 hotirs . For example . if
producin � diselljr be
produciiiR nnY collrctahlc dischar�c , a sample may he collected if the next rain
' �� s within 10 hours .,Ta ble I-* — -A "Nuft" fecal r" OT114t0rill Ile uirements
D �Sch .
Char urge Measurement Frequencyl aceristics � & P It Sample.
Non -Polar Oil Units Tv e2 Localion3
& Grease / TPfj[EPA Method 1664 (SGT-HEM g/L semi-annual� Grab SDO
Biochemical oxygen Demand mg/I, semi -annual Grab SDO
Chemical Oxyge n
Demand m 2, semi -annual Ni trogen, Total Grab SDO
mg/L semi-annual Grab SDO
Phosphorous, Total
mg/L semi -annual Grab SDO
Cresol, Total
enol4 mg/L semi - annual G r ab SWDIBO
Fonaldem semi - annual hyde4 mg/L Grab SWD'BO
H Mg/L semi - annual Grab SWDBO
P standard semi - annual
Grab SDO
Total Rainfalls
i nches semi - annual Rain
Gauge
ootnotes :
1 Measurement Fre quency : Twice per year during a representative storm event .,
2 Grab amples shall be collected withi n the first 30 minutes o ischarge .
3
Sample Location : Samples shall be collected at all the stormwater discharge Outfalls (SDO) mg the stormwater deten tion bas i n o utfa S WD includ%4 Monitor in stOrmwater detention basin (SWDB ) prior to each storm event that could prompt discharge . The Chemetirics
test and gas Chromatograph analysis j* s recommended for detection o phenol and formaldehyde 16 . Spray irrigation is
req1tireal iftesl results exceed 2. 0 mg/L or P he�rol or 1 . 0 m g/L for form aldehyde. Spray Is treatment shall continue
until samples show concentrations i n the SWDB are below these thresholds .
5 For each sampled representative storm event the total precipitation must be recorded ., An on--site rain gauge or local rain
gauge reading must be recorded .
The e
i ee s a11 complete the minimum ten analytical samplings in accordance with the
schedule specified eowin Table 2 . A minimum of 60 days must separate Period 1 and
Part I I Page of 10

00
' NC: SQp0251
STA 'I'L OF-, NORTH CAROL1NA
T Or, ENVIR0IVM 4N 'I' AND NAJ'I " u
R
DIVISION U1 � W i ' I ' Elt QUAI_� TYA L a U RCES
I ' L; R M iT
TO D1SCIIAR �, L; s '1 'U RM �VA `I ' IIt UNDFo.R T -I ,
� A TIO
AL POLL UT'A h17 ' U15C' I-It1RG � Al ION 8V8Tr1.oM
Ift coil )
U11 c e � ,
st (an (jale(13 al (] I e1» avisio11s oFNo �•t Carali �ia Geriet*alSt<� tu tc 143 - 215 .
Iej � � e� tt ��ogl� prom �� f9tttecl a � 1d adopted by tl � e I� c� rth Caroti11aother lawllt131 ssr'�� i � , <� ruf tlae F�edei•al Wa to, * pol 111 tillo �� Control Ac
t , as amended ,
Ge � �•�i � -� Paci #ic �' 1 � ez�� icaIs
r'`S ) ere
y 10161 ze ( to Isc ilaron stortntivate�• #i�c�a ��
a #'� cility Ocictc (l at
coliNvay Rcsi � ts Plant
ZQQ �1 �� }�ti c .I� d
OIIWCIYI
or CojIllf
to r •�c;e� v�x ��; ��j� ters ctesi� �� t�c� �s
cuf �11jy tO a( . (lys � � ,� lCt•c �: k o (l) l � tt1 �
l �� ss B : NS �� sl����� � �� i �� t � � � C:ll � ti�<� t � .P� ie��r B��s ��
110111 �(?litl,�; 1' '�lllCtl �Si ti � IC� o (, IIl <'3CGt) ' � Ct .•�+� � nt�cl � tiv Is sit 01%c 0- -cc ti ve e
tl � C��arge
s s la
aii � t all
Z(01 1011 to 111tsLc 1 (ill �•
AL
fie(�
,Ion ` C'oleer � M � � ulli � � s bit�ec: t � i • �� .��..�....... �. .
D � v1S1011 0 , ' �V� t �; r C� tl � lity
B� the 01 ,11ty � I' I V ) ] *oil 111i1 �
� QI11111iSS1011

Pc iit No . NCS000251
1'a ble 4 .
D ischarge resholci Values re uirin ,� ) rav- Irro atm* on fr
I'lieno - .
rn thea-c te rishUl �s�» -a}, irr • -�i n its Benchmark
For"U7 . dehyde / 2 . 0
- --
» >bf/I,
I a ' • �ati�» >) n ���/I_ 1 -* 0
If: Th e S first valic] Tier One
a � s are above a benchmark value , or outside of the, benchmark range , for any
aidoalneter 1111P.. ail jall ;
Then : Ti, e pe� � rtee shall :
1 • Conduct
a stormwater manageme nt inspection of the facility within tw o weeks of receiving
Sampling res ults .
2 .0 Identi
fY and evaluate 39 possible causes of the benchmark value exceeii���denCe ,
Identify potential and select th e specific : source controls Improverrlents to reduce concentrations of theparameters� operational controls , sica of concern, or to bring concentrations
�'l �� in the bench ra nge .
44a Imple the s elected acti ons within two Months of the
5 • R each j n s tance of a Tier One response in the Stormw nspection .
the date and valu e of the ben chmark exceedence the inspectionater Pollution Prevention Pins echo , e selected actions, and the date the selec
date , the personnel Conducting the
ted actions were-40 imp lemented .
If: During the term of this Tier Two
permit, the first va11d ampling reSUtsrom two consecutive
areamonitorinbove the benchmark values, or outside of the benchmark r g eriic) ds
ange , for any specific parameter at a
S ecl �c dischar e oU 'lfall;
['hen : The permit-tee sha11 :
1 • Repeat all the required actions outlined a ov
2 . inediate ly institute In Tler One .
monthly monitoring Orall parameters at ve0taceeded t1ieenc hmark value for two conseCLt ' Where a S n plin ; resul �
71011toring shacoll ntinue anti ive samples . Monthly ( analytical anialitativ e
1 three consecutive sample results are )
« Ith � n tie benchmark range . below the ene mar� ralues oi
discharge occurs during the sam
p ing r1od , the permitt ee is requiret � « binit a 1 �
1irorin d ��g report indicating "No Flov� " to 11l IItIlI \
Comp ] y With reporting rec, Ll irement � .
. li� � t � � in a record of the Tier Two res
Is
e in ie Ift L � It I . li � } ' r �� � ' t Ilt loll

It
Pe it No . NCSOOO ") 51
hstriode � ate4 ijjjlcss 11u111iioring has be. instituted under a " Fier Two
dip
Ta ble 2.
........ .......... ...............Alon otorij, A40nitorin Schedule
Fea r 1 _ g � e�od � Sample Number Start End
.......... ............Period � — - - —1.11pCiar 1 — Period 2 Fcbruary 1 , 2011 Ji-ily 31 ., 2011
Fear 2 — pe . 2 _ August 1 , 20 1 1 January 31 . 2012
1 'eai• ? _IIII nllloI�d � 3 February 1 , 2012 July 31 , 2012
Yew 3 riod I 4 August 1 , 2012 January 31 , 2013
Ycar 3 _ 5 February 1 , 2013 July 31 , 2013
Year 4 _ eerio 1 6 August 1 , 2013 January 31 , 2014
Year 4 _ 7 February 1 , 2014 July 31 , 2014
Year S _ p�e�dod
2 g August 1 , 2014 January 31 , 2015
Ye w $ — Pe 9 February 1 , 2015 July 31 , 2015
otes , 10 August 1 , 2015 January 311, 2016
1 p amta.iia s MIq0IIInual monitoring during permit renewal process ,. If at the expiration of the Individual
the, the P ennittee has submiffed an application for renewal of coverage before the submittal deadline ,
pennittee W ill [)e considered for renewed coverage . The applicant must continue semi-annual
Monitoring Ohl the renewed Permit is issued .
2 If no dIscha-rge
"No F1oW�� occurs dursng the sampling per iod, the permittee must submit a monitoring report indicating
H'ithin 30 days of the end of the six-month sampling period.
The P erm�ttee shall report I e analyic al results from each sample «-ithin tnohonn
Permiftee sha11 co b .
values in Table 3 mp�e monitoring results to the benchmark values iil Table 3 . The benchmark
are not permit l iml ts but should be used as gu idelines for the permittee' s
StOI111111111111111111mwater Pollution Prevention Plan ( SPPP) xceedences of benchmark values require the
e to increase monitoring, increase management actions,, increase recordins :1111h.eeping, and/ or
tall rmv�,ater Best Management Practices (BMPs) in a tiered progr am . See below the
descriptions of lei-* One and Tier Two .
Table 3, Benchmark Valu es o r Allal tica
Discharge Characte ri sti cs Units Benchmark
Non -Polar Oil & Grease
M 1 �
Biochemical Oxygen Demand
m
Chemical Oxygen Demand M�/�,
Nitrogen, Total M �/�, � 0
Phosphorous , Total �
Ina/L
Cresol
mg/L 4
pIl
nic,
F01 C�e11yde (BMP � vall � ,� tion )
Illb
1'a rt I l Page 60 f 10

4% 1 1 11r ,4k1 . JONI j ( puiNts vtv -4pt 1141
I Al Itor� n
nlonito , - • � nn �. :� icr dlk-chargcg, Ouill be �crfurr"ed hlrted in 'r � hk 1 All
munitoriri r � u t i � y1 , 19 �� l rn nintum , � � f fell dtifing
a �Ic ITa� �n�� �nve �turrn event T � �kli �
K he
�+� I I rFwr( Ile Pc "Ilit at each nchill-ge i ► ull , � ll (ti1 )O ) . r " RA being r � ,nducted c►vei tF►e tern► Of
A it/i ►'r��• nt ;i � i � . �
hehvccti this � t � � � � 1i� rnt �• � � nf is a storm event thlrii measures �reatrr Ih ;in ( 1 . 1 inc hra Of rA � � fA11 The Ume
7-�- 110tirs . A S • �' `• � �• � � t � in �l � I � c previous stc► y n � event ineacuring gremer than U .. 1
� nCr At � � rni i� � �� r, Ave � � 111en o cl of no precipitation of u t � in � hchec �r,u�� he at Ie , �t
it t.� itt .ti but � tp��ti ��� li� rc P h � urs . Fit trample . it
produein a d � � � �� ar P ��dii � ing any collectable discharge , a sample may he co � iected � f the Wert rain
� b� ins within ] 0 hours ,.
Ta b le
A nal fical
o
n ] orin Reguire en
s j4D1Neharge
Char Measurement Frequency tiample Sa pie
stics Units
Non -Polar pil & Tv e2 1OCAV OT3
Grease / TPH
EPA Meti0d1664 mgAL semi - annual Grab SD ( )G(ST
Biochemical Ox
Ygen Demand mg/L semi - annual CrabC eMical Oxygen. De
mand semi -annual
Nitrogen, Total mg/L Grab Sp ��
mg/L semi - annual GrabPh0S OrOLS , Total Mg/L semi - annual ra stCresol , 0tal semi - annual
mg/ - Grab SWD "OPheno4l semi - annualm /LGra W DIB 0
Fo1rrrMM 4
semimg/L -annual Grab SWDBO
PH standard semi - annual
Grab SDO
Total Rainfall s
inches semi-annual Rain
Gauge
00tnotes ,
1 Measurement Frequency: Twice per year during are presentati ve storm event .
2 Grab samples shall be colle cted wi thin th e first 3 0 minute s o f di s charge .
3 Sample Location : Samples shall be collected at all the s-tormw ischarge outfalls SDO) including the stormwateir
detent ion basin outfall SWDBO) .
4 Monitor m stormwater detention basin SWD prior to each storm event that could prompt discharge . The CevaelLY11
test and as chromatograph analysis is recommended for detection of phenol and formaldehyde . Spray irrigation is
required1dP test results exceed 2. 0 Illg/L for phenol o� 1 . 0 �ng/L for formaldehyde. Spray irrigation treatme nt sh all Cor
until samples show concentrations in the SWDB are below these thresholds .
S For each sampled representative storm event the total precipitation must be recorded . An on-site rain gauge o-r local
gauge reading must be recorded .
IC C aiiijtte minimum ten analy tical samplings in accordance with the
sciec tie d below in Table 2 . A minimum of 60 days must separate Period 1 and
fart 11 Page 5 o
t 1 ( �

Young, Brianna A
From: Riddick, Timothy A <[e-mail]>
Sent: Monday, November 7, 2022 2:37 PM
To: Young, Brianna A
Subject: RE: [External] RE: Conway Resins Plant (NCS000251)
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Hi Brianna,
Yes,Outfall 004 does run into the same drainage feature as Outfall 002. Once they adjoin,they eventually meet with
Outfall 003 at a fork. I walked it down last week to refresh my memory as to what would be needed to consolidate the
sampling points and that point of convergence is quite deep into the woods. I think that may be why we did not
consolidate 002 and 003 before.
I still want to discuss with Lauren to get her point of view while she is here. Let me know if you have any other
questions.
Thanks,
Tim
Tim Riddick
Facility Environmental Manager
200 Ampac Rd
b Conway NC 27820 US
BAKELITE ,.+1252-585-3819
SYNTHETICS
:][e-mail]
0 Im
We are Bakelite —
• the next generation!
BAKELITE
This message,including attached files,is confidential and intended for the addressees.It may contain information that is proprietary,privileged or exempt for disclosure under applicable law.Any unauthorized use and dissemination of the
information or copying of this message is strictly prohibited.Any views,opinions or conclusions expressed in this message are those of the individual sender and do not necessarily reflect the view of the Bakelite Synthetics group of companies
("Bakelite Synthetics").If you received this message in error,please immediately advise the sender by reply email,delete all copies of this message and refrain from printing,copying,or disseminating this message or otherwise using the
information in it.Thank you.
Although Bakelite Synthetics routinely screens incoming and outgoing mail messages for viruses,addressees should scan this e-mail and any attachments for viruses themselves.Bakelite Synthetics does not guarantee in any way the absence of
viruses in this e-mail or any attachments and disclaims any liability in case of security problem that this message may cause to any system.
From:Young, Brianna A<[e-mail]>
Sent: Monday, November 7, 2022 1:58 PM
i

To: Riddick,Timothy A<[e-mail]>
Subject: RE: [External] RE: Conway Resins Plant (NCS000251)
CAUTION EXTERNAL EMAIL: Please be cautious when opening links or attachments in email
Good afternoon Tim,
After reviewing the information provided, I have one follow-up question. Looking at the map submitted with the 2020
permit application, it appears that outfall SW004 runs into the same drainage feature as outfalls SW002 and SW003. Is
this the case? If so, please discuss with Lauren Garcia during the inspection what the appropriate monitoring location is
when you discuss outfalls SW002 and SW003.
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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)
[e-mail](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.
2

From: Riddick,Timothy A<[e-mail]>
Sent: Friday, November 4, 2022 10:15 AM
To:Young, Brianna A<[e-mail]>
Subject: [External] RE: Conway Resins Plant (NCS000251)
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Good morning again Brianna,
Please find my replies below along with the attached documents in response to your request. I think that this will satisfy
your request but if not, please let me know at your convenience.
Thanks,
Tim
Tim Riddick
Facility Environmental Manager
200 Ampac Rd
b Conway NC 27820 US
BAKELITE [phone]
s.aT11T,Cs
[e-mail]
M0
We are Bakelite —
• the next generation!
..
BAKELITE
This message,including attached files,is confidential and intended for the addressees.It may contain information that is proprietary,privileged or exempt for disclosure under applicable law.Any unauthorized use and dissemination of the
information or copying of this message is strictly prohibited.Any views,opinions or conclusions expressed in this message are those of the individual sender and do not necessarily reflect the view of the Bakelite Synthetics group of companies
("Bakelite Synthetics").If you received this message in error,please immediately advise the sender by reply email,delete all copies of this message and refrain from printing,copying,or disseminating this message or otherwise using the
information in it.Thank you.
Although Bakelite Synthetics routinely screens incoming and outgoing moil messages for viruses,addressees should scan this e-mail and any attachments for viruses themselves.Bakelite Synthetics does not guarantee in any way the absence of
viruses in this—all or any attachments and disclaims any liability in case of security problem that this message may cause to any system.
From:Young, Brianna A<[e-mail]>
Sent: Friday,July 29, 2022 1:44 PM
To: Dalton, Robert E.<[e-mail]>
Cc: Riddick,Timothy A<timothy.riddick@ bake lite.com>
Subject: Conway Resins Plant (NCS000251)
CAUTION EXTERNAL EMAIL: Please be cautious when opening links or attachments in email
Good afternoon,
I am working on renewing the individual stormwater permit for the Conway Resins Plant (NCS000251). I need
additional information in order to 1) confirm that the information I have is correct and 2) make sure the permit
adequately serves the needs of the facility. Please provide the following:
3

• Description of industrial activities that take place in each drainage area;
See attached
• SIC or NAICS code;
We have two of each.
SIC Code: 2869 & 2821
NAICS Code(s): 325199 &325211
• An electronic spreadsheet summarizing all of the monitoring data that has been collected since the
effective date of the current permit;
See attached
• Verification that the information in the renewal application is still complete and correct; and
By this communication, I am verifying that the information in the renewal application is still complete
and correct to the best of my knowledge.
• An explanation of any operational changes since the renewal application was submitted.
No operational changes since the last renewal application was submitted on July 29, 2020 (see
administrative change request with this submittal)
Enter your stormwater permit number into the Stormwater Permit Summary Report and you will see a form that
includes the address of the facility, contact information for the permit, and the regulated stormwater outfall(s) for the
facility. Please review the facility information to make sure it is correct. Information can be updated using the links
provided below, where applicable:
• Facility/Company name or ownership: Name/Ownership Change Form
• Owner Affiliation (Legally responsible person; i.e., someone with the company who is designated to
represent the company per signatory requirements or another authorized representative): Permit Contact
Update Request Form
• Delegation of Signature Authority (DOSA): Permit Contact Update Request Form
• Billing contact: Permit Contact Update Request Form
• Permit contact: Permit Contact Update Request Form
• Facility contact: Permit Contact Update Request Form
• Facility address only: Email Bethanyy og ulias
• Stormwater outfall information: Email Bethany Georgoulias
• Visit the eDMR Six Steps website and complete Steps 1 and 2.
• Pay outstanding permit fees: Stormwater ePayment website
Once I have the above listed information, I can continue my review. You will receive a draft permit for a 30-day
comment period. During this time we will be able to address any comments or concerns you have. During the
same 30-day period, the draft will be sent to a Regional Office staff member for review as well as out to public
notice. Once all comments and concerns are addressed, you may be issued a final permit.
Please contact me if you have any questions.
Thank you,
Brianna Young, MS (she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Program
4

NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](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.
5

7/27/22,3:21 PM 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
Limited Liability Company
Legal Name
Bakelite Chemicals LLC
Prev Legal Name
Georgia-Pacific Chemicals LLC
Information
Sosld: 0898620
Status: Current-Active O
Date Formed: 2/15/2007
Citizenship: Foreign
State of Incorporation: DE
Annual Report Due Date: April 15th
Currentgnnual Report Status:
Registered Agent: United Agent Group Inc.
Addresses
Mailing Principal Office Reg Office
133 Peachtree St NE 133 Peachtree St NE 15720 Brixham Hill Avenue #300
Atlanta, GA 30303-5605 Atlanta, GA 30303-5605 Charlotte, NC 28277
Reg Mailing
15720 Brixham Hill Avenue #300
Charlotte, NC 28277
Company Officials
All LLCs are managed by their managers pursuant to N.C.G.S. 57D-3-20.
https://www.sosnc.gov/online_services/search/Business_Registration_ResuIts 1/2

7/27/22,3:21 PM North Carolina Secretary of State Search Results
Manager
Big Blue Holdings, Inc.
133 Peachtree St. NE
Atlanta GA 30303
https://www.sosnc.gov/online_services/search/Business_Registration_ResuIts 2/2

F�c STATEo
Y,pY e.'73 'O
ROY COOPER _=
Governor v C
MICHAEL S.REGAN
Secretary *4
QUAMV•°�*
BRIAN WRENN NORTH CAROLINA
Director Environmental Quality
July 30, 2020
Ronald E.Walls
Plant Manager/Regional Manufacturing Manager
Georgia-Pacific Chemicals
Conway Resin Plant
200 Ampac Rd
Conway, NC 27820 Subject: NPDES Permit Renewal Application
Permit Number NCS000251
Conway Resin Plant
Northampton County
Dear Mr.Walls:
The Division of Energy,Mineral,and Land Resources'Stormwater Permitting Program
acknowledges receipt of your renewal application for coverage under NPDES Permit Number
NCS000251 on July 27,2020. We appreciate your patience and are now making every effort to
review your permit renewal as expeditiously as possible.We are currently beginning our review of
your renewal application. Please continue to comply with all conditions and monitoring
requirements in your expired NPDES stormwater permit. As long as you have submitted a
complete renewal request package and maintain compliance with those permit conditions,
stormwater discharges from this facility are authorized by that permit until the Division issues a
renewal permit or notifies you of an alternative action.
No additional information is required at this time,but we may contact you in the future.
Please notify us if any significant changes have taken place at this facility since you submitted the
renewal package. If you have any questions about this matter,please contact me at 919-707-3648
or matt.gwinn0ncdenr.gov.
Sincerely,
/4mp���_ �
Matthew Gwinn
Stormwater Program
cc: Tim Riddick, Facility Environmental Manager
Raleigh Regional Office
DEMLR Stormwater Permitting Program Files
D EQIP North Carolina Department of Environmental Quality 1 Division of Energy,Mineral and Land Resources
512 North Salisbury Street 1 1612 Mail Service Center I Raleigh,North Carolina 27699-1612
NORTH CAROLINA -
oepanmemof enmmnm MI Quail� 919.707.9200

Gwinn, Matt
From: Gwinn, Matt
Sent: Thursday, July 30, 2020 11:04 AM
To: [e-mail]
Cc: Lucas, Annette
Subject: NCS000251 Conway Resin Plant Renewal
Attachments: Letter of Acknowledgement.docx
Good Morning,
My name is Matt Gwinn, and I am in charge of individual industrial stormwater permits at the NCDEQ central office. We
received the renewal application for your NPDES permit no. NCS000251. Attached is a copy of the letter being sent for
your file. If you have any questions please email or call me at 919-707-3648.
Thank you,
Matt Gwinn
Stormwater Program Environmental Technician 11
Division of Energy, Mineral and Land Resources
Department of Environmental Quality
i

Georgia-Pacific Chemicals LLC
Conway Resins Plant
P.O. Box 368
Conway,NC 27820
Phone: [phone]
Fax [phone]
July 27,2020
Certified Mail—7014 2120 0004 5521 0077
SW Individual Pen-nit Coverage Renewal RECEIVED
Stormwater Pennitting Program C[t✓J
1612 Mail Service Center AUG 0 4 2020
Raleigh,NC 27699-1612
DENR-LAND QUALITY
RE: NPDES Stormwater Pen-nit Coverage Renewal STORMWATER PERMITTING
Conway Resins Plant
NPDES Stormwater Permit No.: NCS000251
Northampton County
To Whom It May Concern,
Please find enclosed the completed NPDES stormwater permit renewal application for our Conway,NC facility
located in Northampton County. The permit application includes the following information in duplicate at your
request.
I. A current site map from the Stormwater Pollution Prevention Plan that includes the location of industrial
activities, drainage structures,drainage areas for each outfall,building locations and impervious surfaces.
2. A summary of Analytical Monitoring results during the term of the existing permit.
3. A summary of the Visual Monitoring Results during the term of the existing permit.
4. A summary of our facility's Best Management Practices.
5. There have been no significant changes in industrial activities at this facility during the existing term of this
permit.
6. Signed Certification of the development and implementation of the Stormwater Pollution Prevention Plan
at this facility.
REQUESTED PERMIT MODIFICATIONS
We are requesting a modification to the pen-nit to clarify the concentration of formaldehyde that triggers spray
irrigation from the stormwater detention basin(SWDB), In Section B,Table 3 (Benchmark Values for Analytical
Monitoring)of the permit,the benchmark concentration for formaldehyde is set at 0.49 ppm. However,Table 4
(Threshold Values requiring Spray Irrigation from the SWDB) in Section B establishes a land application
benchmark of 1.0 ppm. The gap between the Analytical Benchmark concentration(0.49 ppm)and the Spray
Irrigation Benchmark concentration(1.0 ppm)creates uncertainty as to how stormwater in the SWDB with a
concentration between 0.50 ppm and 0.99 ppm should be managed. The facility's standard operating procedure is to
land apply any stormwater in the SWDB with a concentration greater than 0.49 ppm. We are requesting the
following modifications and clarifications:
I) Remove the Spray Irrigation benclunark for formaldehyde from Table 4 and make it a requirement that any
stormwater with a fonnaldehyde concentration greater than 0.49 ppm be land applied in the spray field.
Modify footnote 94 of Table 1 to reflect this change as well.
2) Clarify that Tier 1 and Tier II requirements are only triggered in the event of a discharge of stormwater with
a fonnaldehyde concentration greater than 0.49 ppm.

Should you have any questions,please feel free to contact Tim Riddick at(252)585-3819.
Sincerely,
--F,-"- t"
Ronald E. Walls
Plant Manager I Regional Manufacturing Manager
2

Permit Coverage
® Renewal Ayolication Form
NCDENR National Pollutant Discharge Elimination System NP Permit Number
NCS60Q251
Stormwater Individual Permit
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 * Address to which permit correspondence will be mailed
Owner/ Organization Name: Georgia-Pacific Chemicals,Conway NC
Owner Contact: Mr.Ronald E.walls
Mailing Address: P.C.eor 368 Conway.NC,27820
Phone Number: 252-585-3840
Fax Number: 252-585-1754
E-mail address: [e-mail]
Facility Information
Facility Name: Conway Resin Plant
Facility Physical Address: 200Ampac Rd Conway.NC 27820
Facility Contact: Tim Riddick
Mailing Address: P.O.Box 366 Conway,NC 27820
Phone Number: 252-585-3814
Fax Number: 252-585-1754
E-mail address: [e-mail]
Permit Information
Permit Contact: Tim Riddi(:k
Mailing Address: P.O.8a 368 Go—y,NC 27820
Phone Number: 252-585-3619
Fax Number: 252585-1754
E-mail address: tadddic®gapac.c—
Discharge:Information
Receiving Stream: Paddy's Delirtht Creek(Doolittle Mill Pond
Stream Class: B:NSW
Basin: Chowar)River Basin
Sub-Basin: 03-01.02
Number of Outfalls: 4
FacilitvlActivity Changes Please describe below any changes to your facility or activities since issuance of your permit. Attached a
separate sheet if necessary.
There have been no changes to the facility or activities since inssuance of our permit.
CERTIFICATION
I certify that I am familiar with the information contained in the application and that to the best of my knowledge and belief
such information is true, complete and accyr qte.
Signature `I Date _ Zzz
Mr,Ronald E.Walls Plant Manager/Regional Manufacturing Manager
Print or type name of person signing above Title
SW Individual Permit Coverage Renewal
Please return this completed application form Stormwater Permitting Program
and requested supplemental information to: 1612 Mail Service Center
Raleigh, North Carolina 27699-1612

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
FkV 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.
/�F / 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.
�W 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.
9 6'1 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)

STORMWATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
North Carolina Division of Energy, Mineral, and Land Resources- Stormwater Permitting
Facility Name: Conway Resin Plant
Permit Number: NCS000251
Location Address: 200 Ampac Rd Conway,NO 27820
County:
Northampton
"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
"l 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
"l 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.
Signaturef:w== Date w1jaMr. Ronald E. Walls Plant Manager 1 Regional Manufacturing Manager
Print or type name of person signing above Title
SPPP Certification 10/12

Required Item #1
x,36A24551 Ta Ladd
D, Y -7720390 RECEIVING WATERS. CHEWAN RIVER BASIN .., LEGEND
Drolnane A—-US acres AppUeatlon RECEIVINQ =EAM, PATTY'S DELIGHT CREEK
G28.4X Inpervfbuc.—P-> Sys
sterl f A ) Wlvert
fran naiwFactvr,.g sA.. Y UOULITTLE MILL POND) � aP.n starn.at¢r Droch
} M N❑ IMPAIRED WATERS �—
Potent' D,coo,N -DM1 brW w N❑ TMDLs ■ �,�. Surface Dralna a Flow
Greast,D1TD,coo,N,P. } rb D
Arrbs
Dutf.L 001 h alsb
NPD S DutFall that our Quep¢f� _� Raof Dralrnpe ow Arrow
k '
R
canEtWn,baler blo.dam, Storn¢ater Drop Inlet
—thg teser btawd— S } }, } k '� A Lind o W Stvrn.bter
( ` A pp
caNray-t¢
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lrttse,80D,Cap,Al,P. F.t¢ntht Pbliutbni.-M bad ,a., SWPJ & SPCC SITE MAP
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Farnbldehdye,Phend,C-%*4 Fencellne Ibcntlan tpp—ln to

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Required Item #4
(Pagel of 3)
BEST MANAGEMENT PRACTICES
All material and process storage areas that pose a reasonable potential for
stormwater pollution at the Conway Resins facility have been placed inside
buildings or sheds. All bulk liquid storage tanks, loading/unloading areas, and
manufacturing areas are provided with secondary containment and/or are roofed to
minimize stormwater contact and to collect any stormwater that comes into
contact with manufacturing operations. All technical and economically feasible
means to eliminate and/or reduce exposure of materials and processes to
stormwater have been implemented.
Good Housekeeping Measures and Controls
Good housekeeping practices are designed to maintain a clean and orderly work
environment. At this facility, the following types of good housekeeping measures
are implemented in an effort to prevent pollutants from entering storm water
discharges.
Operation and Maintenance
• Floors and ground surfaces are kept dry and clean by using brooms,
shovels, vacuum cleaners, or cleaning machines.
• Garbage and waste materials are regularly picked up and properly disposed.
• All spillage is promptly removed.
• Equipment is routinely inspected to make sure it is maintained in working
order.
• The importance of spill cleanup procedures is communicated to employees
through routine meetings.
Materials Storage Practices
• Adequate aisle space is provided to facilitate material transfer and easy
access for inspections.
• Containers, drums, and bags of material are stored away from direct traffic
routes to prevent accidental spills.
• Containers are stacked according to manufacturers' instructions.
• Containers are stored on pallets to prevent corrosion.

Required Item #4
(Page 2 of 3)
Material Inventory Procedures
• An up-to-date inventory of all hazardous and non-hazardous materials kept
at the facility is maintained.
• All containers are labeled showing the name of the materials.
• Storage areas where hazardous materials are stored have been specially
designed to contain spills.
Employee Participation
• Information on good housekeeping practices are distributed during
employee training sessions.
• Good housekeeping measures are discussed at routine employee meetings.
• Good housekeeping tips and reminders are noted around the plant.
Preventive Maintenance
The facility's preventive maintenance program includes:
• Timely inspections and maintenance of storm water management devices.
• Regular inspection and testing of facility equipment and systems to uncover
conditions that could cause breakdowns or failures resulting in discharges
of pollutants to surface waters.
• Proper maintenance of facility equipment and systems.
• The facility has an active preventive maintenance program under the
guidance of the maintenance supervisor.
Equipment Repair or Replacement
• Defective equipment found during inspections and testing shall be promptly
repaired or replaced.
Records on Preventive Maintenance
• The facility has a records system that indicates when inspections are to be
conducted. Inspection and testing records are maintained at maintenance
planner's office.

Required Item #4
(Page 3 of 3)
Visual Inspections
• Visual inspections are conducted on a routine basis. The inspections shall
be performed periodically and after storm events. The following areas are
inspected:
1. areas around all equipment
2. areas where spills and leaks have occurred in the past
3. material storage areas (tank farms and drum storage)
4. outdoor material processing areas
5. material handling areas (loading, unloading, and transfer)
6. waste generation, storage, treatment, and disposal areas

Required Item # 5
This requirement does not apply for our facility as there have been no significant
changes in industrial activities of this facility during the existing term of the
current permit.

�'lm5
y
Georgia-Pacific Chemicals LLC
Conway Resins Plant
P.O. Box 368
Conway,NC 27820
Phone: [phone]
Fax [phone]
SC,&NNRDl
July 30,2015
JUL 3 0 2020
Certified Mail—7011 0110 0000 3033 1182
SW Individual Permit Coverage Renewal ��
Stormwater Permitting Program c�(f V��®
1612 Mail Service Center
Raleigh,NC 27699-1612 AUG 0 5 2015
RE: NPDES Stormwater Permit Coverage Renewal STO ENR-LAND QUALITY
Conway sins Plantrmwater Permit No.:NCS000251 R1 WATER PCRMI
NPDES Stormwater TTING
Northampton County
To Whom It May Concern,
Please find enclosed the completed NPDES stormwater permit renewal application for our Conway,NC facility
located in Northampton County. The permit application includes the following information in duplicate at your
request.
1. A current site map from the Stormwater Pollution Prevention Plan that includes the location of industrial
activities,drainage structures,drainage areas for each outfall,building locations and impervious surfaces.
2. A summary of Analytical Monitoring results during the term of the existing permit.
3. A summary of the Visual Monitoring Results during the term of the existing permit.
4. A summary of our facility's Best Management Practices.
5. There have been no significant changes in industrial activities at this facility during the existing term of this
permit.
6. Signed Certification of the development and implementation of the Stormwater Pollution Prevention Plan
at this facility.
REQUESTED PERMIT MODIFICATIONS
We are requesting a modification to the permit in order to clarify the concentration of formaldehyde that triggers
spray irrigation from the stormwater detention basin(SWDB). In Section B,Table 3 (Benchmark Values for
Analytical Monitoring)of the permit,the benchmark concentration for formaldehyde is set at 0.49 ppm. However,
Table 4(Threshold Values requiring Spray Irrigation from the SWDB)in Section B establishes a land application
benchmark of 1.0 ppm. The gap between the Analytical Benchmark concentration(0.49 ppm)and the Spray
Irrigation Benchmark concentration(1.0 ppm)creates uncertainty as to how stormwater in the SWDB with a
concentration between 0.50 ppm and 0.99 ppm should be managed. The facility's standard operating procedure is to
land apply any stormwater in the SWDB with a concentration greater than 0.49 ppm. We are requesting the
following modifications and clarifications:
1) Remove the Spray Irrigation benchmark for formaldehyde from Table 4 and make it a requirement that any
stormwater with a formaldehyde concentration greater than 0.49 ppm be land applied in the spray field.
Modify footnote#4 of Table I to reflect this change as well.
2) Clarify that Tier I and Tier II requirements are only triggered in the event of a discharge of stormwater with
a formaldehyde concentration greater than 0.49 ppm.

Should you have any questions,please feel free to contact Tim Riddick at(252)585-3819.
Sincerely, '
Ronald E. Walls
Regional Manufacturing Manager
2

Permit Coverage
©GA Renewal Aoolication Form
WDENR National Pollutant Discharge Elimination System NPDES Permit Number
Stormwater Individual Permit NCS 000251
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 * Address to which permit correspondence wi//be mailed
Owner/Organization Name: Georgia-Pacific Chemicals LLC
Owner Contact: Mr. Ronald E. Walls
Mailing Address: P.O. Box 368
Phone Number: (252) -585-1232
Fax Number: (252) -585-1754
E-mail address: [e-mail]
Facility Information
Facility Name: Conway Resins Plant
Facility Physical Address: 200_Ampac Road
Conway, NC 27820
Facility Contact: Tim Riddick
Mailing Address: P.O. Box 368
Conway, NC 27820
Phone Number: (252) -585-3819
Fax Number: (252) -585-1754
E-mail address: [e-mail]
Permit Information
Permit Contact: Tim Riddick
Mailing Address: P.O. Box 368
Conway, NC 27820
Phone Number: (252) -585-3819
Fax Number: (252) -585-1754
E-mail address: [e-mail]
Discharge Information
Receiving Stream: Paddy's Delight Creek (Doolittle Mill Pond)
Stream Class: B;NSW
Basin: Chowan River Basin
Sub-Basin: 03-01-02
Number of Outfalls: 4
Facility/Activity Changes Please describe below any changes to your facility or activities since issuance of your permit. Attached a
separate sheet if necessary.
No changes to the facility or activities since issuance of our permit.
CERTIFICATION
I certify that I am familiar with the information contained in the application and that to the best of my knowledge and belief
such information is true,complete an curate.
Signature Date 7/ 3 /f
Ronald E. Walls Regional Manufacturing Manager
Print or type name of person signing above Title
Please return this completed application form SW Individual Permit Coverage Renewal
and requested supplemental information to: 1612 Mail l S Permitting Program
612 M Service Center
Raleigh, North Carolina 27699-1612

f
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,
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.
/per 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)

STORMWATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
1.
North Carolina Division of Energy, Mineral, and Land Resources-Storm water Permitting
Facility Name: Conway Resins Plant
Permit Number: NCS000251
Location Address: 200 Ampac Road
Conway, NC 27820
County: Northampton
"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.
7
Signature OL Date
Ronald E. Walls Regional Manufacturing Manager
Print or type name of person signing above Title
SPPP Certification 10/13

Required Item #1
$.Iri.pa R.en-1.75 nmea aft A Nlffll 001 la f,x.vw
ocr. h ervlwn.-P.W fpan 1 W=OWa11 tlwS
n.na..YurWB me. '�,PG.teeanft4W lB Pal.twta-m onN � a W.n W ., ) LEGEND
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Co.C®.N. To Land Appllcntlon __ I$en stxn..e«wcF
System
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.f p/aM.pe Fl.f Rmw
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Gt.fe.Role.[Op.n N.P.
F—WeltlYe.PM ,Gea.L f_,_l.c.tbn W epproµgte
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Required Item#2
Stonilwater Discharge Outfall(SDO)
Monitoring Reoort
Ouffall 001
Year Year2 Year3 Years Tears
Spring Fall Spring Fall Fall S ring Fall Spring Fall Fall Spinp Fall
Total Flow MG 0.013 0.010 0.056 O.053 0.013 0.073 0.040 0.015 0.022 0.030
Oil and Grease moll <5 <5 <5 <5 <5 e5 <5 <5 <5 Q
GODS on 5 5 5 2 4 5 4 2 10 6
COO mgg 55 55 38 u 17 36 50 44 54 65.62
Nitntel Nitrite men 1.W 0.3 1.17 2.2 0.4 1.5 1.5 1.2 0.8 0.47
MN -10 1.2 1.5 1.3 2.6 owe 1.6 1.9 0.9 1.9 1.8
Total Ninma moll 2.5 1.8 2.5 4.8 12 3.1 3.4 2.1 2.7 2.2
Total Phoamova MA 2.78 0.98 au 0.52 am am 126 am 5.54 0.28
IMM 111 10.0 8.1 7.4 7.1 7.9 6.52 7.4 7.04 7.90 7.31
Formaldehyde moll 0.48 0.61 0.50 OM We 0.99 0.02 0.010 0.037 0.049
NPDES Fiow®Wrcr MGO 00857 0.0375 0.0140 0.0140 0.0140 0.1171 11
Water Temoenturt •C 6.9 15.6 15.6 20.0 14.1 ].]
Ouffall 002
YeerI Yaar2 Year Yaar4 Yaar5
Spring Fall Spring Fall Fall S dog Fall spring FaU Fall Spring Fall
Total Flow MG am 0.047 0167 0236 am 0.345 0.188 0071 0.102 M.O.W5
0.141
Oil and Grease, on <5 <5 <5 <5 <5 <5 c5 <5 8 <5
B005 mon 6 10 9 5 4 4 4 5 44
NhnnlNitrite n� am <0.1 am <0.1 0.6 0.5 0.4 U.4 DA0.13
MN mgg 1.8 22 2.3 OS 5.3 1.7 1.1 22 0.71&1
COO moll 62 71 40 58 Q 25 27 38 QO15.3
Total Nihooen mg_II 2.4 22 32 0.5 5.90 22 1.5 2.6 1.115.3
Toni Phesptays 11Um 023 0.39 127 a04 027 021 0.17 0.13 0.41020
Z S.0 7.8 7.8 S.n 7.57 8.7 7.0 am Be 7.38.05
pC l � <5 <5 4 elo <0.01 Q.a098 <0.005 <0.005
0. noml can c$ <5 Q <10 Q.01 W.0099 Q.005 <aaws
mzmsol go t5 Q <4 <10 eD.01 Q.00B9 Q.005 Q.DOS
PMnol US99 6 <5 <10 <10 Q.01 e0.0099 <0.005 0.027 Q.005
FormameM1vde mglf 0.48 0.81 1 am I am Na 0.99 002 1 0.050 O.8% 0.317
TSS MBA 18 110 a 7.4 8.5 26 4 1 6.2 1.7 1 14.5
Water Tem nnrt •C 8.9 122 18.7 221 131 1 7.8
Outfall 003
Yaar1 Year2 Year Ymr4 T a,S
Spring Fall Spring Fan Fall B Mg Fall Spdra Fall Fell Spring Fall
Total Flew MG 0.007 0.01M5 0.030 0.027 0.007 amo aul g
0.012 0.018
Oil and Grease "In <5 e5 <5 <5 11 <5 eS e5 <5
BODS mqn 4 6 8 4 Q 2 Q 2 4
COD moan Sr 55 57 36 <10 <10 20 24 26.43
W"te l Nitrite B am 1.02 0.70 0.8 1.3 Q.1 2.0 0.6 0.31
WN -0 12 0.9 4.3 3.0 0.8 0.9 0.8 0.7 0.5
Tani Nino en al 2.0 1.9 5.0 3.6 21 0.9 28 1.5 0.8
Tool Phes hews n 0.31 0.12 0.14 036 <02 0.07 0.12 D14 am
EnH Su 7.1 8.4 7.49 7.07 7.5 8.4 7.3 7.3 5.58
-0 0.48 0.61 0.50 am Na am 0.02 0.044 0.034
Wanr Tem stun •C 9.4 122 16.1 23.9 13.3 7.5
Ouffall 004
Yw1 Yur2 Yaar3 Year4 YurS
Spring Fall Spring FO Fall Spring Fall Spring Fall Fall Spring Fall
Tent Flaw MG 0.010 0.007 0.042 1 aD37 0.010 awat awe 0.011 aGlG am
Dlland Goan mill <5 <5 <5 <5 6 Q <5 Q eS Q
SODS Mell 4 e Q 3 2 Q 4 3 3 4
COD mgn 55 m <10 21 <10 <10 41 m Qa 21.82
Nhnte l Nitrin m n 0.43 0.24 aw 0.1 al 0.1 G.4 02 02 Q.1
MN man 1.0 1.4 0.6 0.4 1.1 0.4 0.9 0.7 0.4 1.0
Total N' man 2.2 1.8 1.1 0.6 12 OS 1.3 0.9 0.6 1
Tool Ph mg9 ON 0.12 DOB 0.03 am aw 0.0 0.10 am 0.11
o Stu 72 7.8 7M 7.02 7.3 SM 6.59 6.96 7.16 6.94
Fonnaldenvtle nn 0.48 0.61 am OM we am 0.02 0.044 0.043 0.046
Water Tem ntun •C 8.3 122 15.6 24.4 10.6 7.9
'Prim to the Year2 Fall sampling.the facility did not utilize a 40 CFR 136 method for formaldehyde anlaysis based on a misunderstanding ofrhe permit requirements. This discrepancy was corrected prior to the next
sampling period.

Required Item#3
Outfall Visual Qualitative Monitoring
Ouffall 001
Year Yea,2 Year Year Year5
Spring Fall Spring Fall Spring Fall Spring Fall spd.g Fall
Color ❑ght Brown None None None None Nona Nan. ❑ghtGmen Light Brown
Odor Non More 1N.r.
one None Non None None None None
CIadN 3 e 1 1 2 1 e 1 1 2 2
Floaling Solids 1 2 3 2 1 1 1 1 6
Suspended Solids 2 2 2 1 2 1 1 1 5
Settled Solids 3 1 1 5 5
Foam No No No No No No No No No
OII Sheen No No No No No No No No No
Olner OEvlous Shams of SW Pollution None Nona None None None None None None
Outfall 002
Yaar1 Year2 Year Year4 YeerS
Spring Fall Spring Fall Spring Fall Spring Fall Spring Fall
Cole, Light Brawn Ught Brown None LigMBmwnMN
None Light Gray None None
Odor Non None None None None None None None
Chaff 2e 2 1 21 5 1 2
Floatino Solids 2 2 1 1 1 1 1 5
Suspended Solid. 2 2 1 21 1 1 5
Settled Solids 3 1 2 1 6
Foam No No No No No No No No
Oil Sheen No No No No No No No No
Other Obvious Signs of SW Pollution None None None None None None None None
Oullall 003
Years Year2 Yuri Year Year
Spring Fall Spring Fall Spring Fall Spring Fall Spring Fall
Color No Color/Clear None None ❑gid Blue N... None None CbM Grey Light Brown
Odor None None None None None None None None None
Olari 2 1 1 1 1 1 1 2 6
Floatino Solids 2 1 1 1 2 1 1 1 3
Sus ended Solids 2 1 1 2 1 1 1 2 5
Settled Solids 3 1 3 3 5
Foam No No No No No No No No No
Oil Sheen No No No No No No No No No
Other obvious si ns of SW Pollution None None None None None None None None None
Oullzll 004
Years Year2 Year Year4 Year5
Spring Fall Spring Fell Spring Fall Spring Fall Spring Fall
Color ClearBmsvn Medium Brown Medium Brown Medium Brown Light Brown None B./tight None Clear
Odd, None None None None None None None None None
Varty 3 4 3 2 2 1 4 1 1
Fldnln Solids 2 2 2 2 2 1 2 1 2
S. 3 2 2 2 2 1 4 1 2
Seined Solids 4 1 1 3
Foam No No No No No No No No No
Oil Sheen No No No No No No No No No
Other Obvlouz Si ns of 3W Pollution None None None None None None None None None
Clarity-1 is ciearan 110Is very dourly
Floating Solids-1 Is no solids and 10 Is the sulfate covered with floating solids
Suspended Solids-1 is no solids and 101s extremely muddy
Settled Sollds-1 is no solids and t01s a Ihlck layer pf solids in the container bodom
1

Required Item # 4
BEST MANAGEMENT PRACTICES
All material and process storage areas that pose a reasonable potential for
stormwater pollution at the Conway Resins facility have been placed inside
buildings or sheds. All bulk liquid storage tanks, loading/unloading areas, and
manufacturing areas are provided with secondary containment and/or are roofed to
minimize stormwater contact and to collect any stormwater that comes into
contact with manufacturing operations. All technical and economically feasible
means to eliminate and/or reduce exposure of materials and processes to
stormwater have been implemented.
Good Housekeeping Measures and Controls
Good housekeeping practices are designed to maintain a clean and orderly work
environment. At this facility,the following types of good housekeeping measures
are implemented in an effort to prevent pollutants from entering storm water
discharges.
Operation and Maintenance
• Floors and ground surfaces are kept dry and clean by using brooms,
shovels,vacuum cleaners, or cleaning machines.
• Garbage and waste materials are regularly picked up and properly disposed.
• All spillage is promptly removed.
• Equipment is routinely inspected to make sure it is maintained in working
order.
• The importance of spill cleanup procedures are communicated to
employees through routine meetings.
Materials Storage Practices
• Adequate aisle space is provided to facilitate material transfer and easy
access for inspections.
• Containers, drums, and bags of material are stored away from direct traffic
routes to prevent accidental spills.
• Containers are stacked according to manufacturers' instructions.
• Containers are stored on pallets to prevent corrosion.

Required Item # 4
Material Inventory Procedures
• An up-to-date inventory of all hazardous and non-hazardous materials kept
at the facility is maintained.
• All containers are labeled showing the name of the materials.
• Storage areas where hazardous materials are stored have been specially
designed to contain spills.
Emplovee Participation
• Information on good housekeeping practices are distributed during
employee training sessions.
• Good housekeeping measures are discussed at routine employee meetings.
• Good housekeeping tips and reminders are noted around the plant.
Preventive Maintenance
The facility's preventive maintenance program includes:
• Timely inspections and maintenance of storm water management devices.
• Regular inspection and testing of facility equipment and systems to uncover
conditions that could cause breakdowns or failures resulting in discharges
of pollutants to surface waters.
• Proper maintenance of facility equipment and systems.
• The facility has an active preventive maintenance program under the
guidance of the maintenance supervisor.
Equipment Repair or Replacement
• Defective equipment found during inspections and testing shall be promptly
repaired or replaced.
Records on Preventive Maintenance
• The facility has a records system that indicates when inspections are to be
conducted. Inspection and testing records are maintained at maintenance
planner's office.

Required Item ## 4
Visual Inspections
• Visual inspections are conducted on a routine basis. The inspections shall
be performed periodically and after storm events. The following areas are
inspected:
1. areas around all equipment
2. areas where spills and leaks have occurred in the past
3. material storage areas (tank farms and drum storage)
4. outdoor material processing areas
5. material handling areas (loading, unloading, and transfer)
6. waste generation, storage, treatment, and disposal areas

Reguired Item # 5
This requirement does not apply for our facility as there have been no significant
changes in industrial activities at this facility during the existing term of the
current permit.