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NCS000292_Fact sheet binder_20240403
DEQ / DEMLR FACT SHEET FOR NPDES INDUSTRIAL INDIVIDUAL STORMWATER PERMIT DEVELOPMENT Basic Information for Permit Issuance and Renewals: Permit Writer/Date Brianna Young 3/25/2024 Permit Number NCS000292 Owner/Facility Name Resinall Corporation/Resinall Corporation 2821 (325211)/Plastics materials, synthetic resins, SIC(NAICS)Code/Category and nonvulcanizable elastomers (Plastics material and resin manufacturing) Basin Name/Sub-basin number Chowan/03-01-02 Receiving Stream/HUC UT to Kirb 's Creek/030102040907 Stream Classification/Stream Segment C;NSW/25-4-4 Is the stream impaired on 303 d list]? No Any TMDLs? No Any threatened and/or endangered species? See Section 2 below Any compliance concerns? See Section 2 below Any permit mods since lastpermit? See Section 1 below New expiration date 4/30/2029 Comments on Draft Permit? See Section 6 below Section 1. Facility Activities and Process: Resinall Corporation is a manufacturing plant for rosin esters, hydrocarbon resins, and rosin ester/hydrocarbon resins. These resins are produced from the thermal polymerization of hydrocarbon streams derived from the production of ethylene and tall oil or gum rosin esterified with various hydroxyl-containing substances at times, these substances are reacted or blended together to form hybrid products. Processing of resins include the mixing of raw materials in indirectly heated turbine-agitated reaction kettles. Bulk materials are loaded and unloaded at Northern and Southern Tank Farm Rail Car sidings and Truck Stations #1 and#2. All non-bulk materials are loaded and unloaded at B-82 Warehouse. Significant materials at Resinall Corp Severn Facility include C No. 2 Diesel Fuel, Gasoline, Zecosol (Co-Product Fuel), Hydrocarbon intermediates, Hydrocarbon feedstocks (NP-86 Recovered Styrene,N-145 Resin Oil, Resin Oil 80 and Dicyclopentadiene), various process oils, glycerine, mineral spirits and tall oil. The EPCRA Section 313 reportable chemicals found in the hydrocarbon feedstocks are Benzene, Cumene, Dicyclopentadiene, Ethylbenzene,Naphthalene, Styrene, Toluene, and Xylene. All significant chemicals referenced above are stored in tanks with secondary containment. Per the permit renewal application, the process wastewater spray pond was removed in early 2020 and the process wastewater is now handled in an enclosed tank system, reducing fugitive emissions as well as eliminating any potential to contaminate stormwater from an open-air concrete pond. Per information provided 11/10/2023,boiler blowdown is mixed with stormwater prior to stormwater discharge (per a 2011 inspection report: boiler blowdown was pH treated prior to being comingled with stormwater and discharged at 001. Per information provided 11/10/2023, the permittee states that the only way process wastewater may contaminate stormwater(outfalls SW001 and SW002)would be due to a potential catastrophic failure of the enclosed tank and carbon filtration system. Page 1 of 8 Outfall SW001: Drainage area consists of parking areas, a water supply pond, tank farms, unloading pad, buildings, cooling towers and a cooling pond, a warehouse, non-hazardous wase drum storage area, recycle are (where scrap metal and scrap tin are stored), boneyard, gum rosin storage area, and reject and hold material area. Per information provided 11/10/2023, SW001 discharges through SW002. Outfall SW002: Drainage area consists of parking areas, a water supply pond, tank farms, unloading pad, buildings, cooling towers and a cooling pond, a warehouse, non-hazardous wase drum storage area, recycle are (where scrap metal and scrap tin are stored), boneyard, gum rosin storage area, and reject and hold material area. Per information provided 11/10/2023, SW001 discharges through SW002. 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." Section 2. Monitoring Information and Compliance History: • June 2018 to June 2023,benchmarks exceeded for: o SW001: TSS Ix o SW002: TSS Ix Threatened/Endangered Species: The Tidewater Mucket(Leptodea ochracea; NC status: T) is in the nearby vicinity of the facility. Additional species of concern in the vicinity of the facility include Coppery Emerald(Somatochlora georgiana; NC status: SR) and Chowanoke Crayfish (Faxonius virginiensis;NC status: SC). Section 3. Proposed Monitoring for Stormwater Discharges: The Division considered potential pollutants from past and present industrial activities and data was submitted for June 2018 to June 2023. Quantitative sampling included pH, TSS, and COD. Parameters Page 2 of 8 are based on potential pollutants in the drainage area, sampling results, and in some cases, dependent upon future activities. Below is a table of the proposed monitoring for each outfall at the Resinall Corporation site. Outfalls SWO01 and 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 COD BASIS: Discharge potential indicator Quarterly monitoring Ammonia Nitrogen BASIS: Potential pollutant from drainage area in the event of a major spill or catastrophic failure of enclosed process wastewater tanks system Quarterly monitoring Benzene BASIS: Potential pollutant from drainage area Quarterly monitoring Ethylbenzene BASIS: Potential pollutant from drainage area Quarterly monitoring Naphthalene BASIS: Potential pollutant from drainage area Quarterly monitoring Toluene BASIS: Potential pollutant from drainage area Quarterly monitoring Styrene BASIS: Potential pollutant from drainage area in the event of a major spill or catastrophic failure of enclosed process wastewater tanks system Quarterly monitoring Total Xylenes BASIS: Potential pollutant from drainage area in the event of a major spill or catastrophic failure of enclosed process wastewater tanks system Page 3 of 8 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 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: Page 4 of 8 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 COD 120 mg/L BPJ; Generally found at levels 4x BOD5 in domestic wastewaters Ammonia Nitrogen 5 Based on the mussels-present/trout absent acute criteria table Summer .6 mg/L in the 2013 EPA criteria document Ammonia Nitrogen Based on the mussels-present/trout absent acute criteria table Winter 15 mg/L in the 2013 EPA criteria document Benzene 6,700 m /L 1/2 FAV Naphthalene 1 m /L 1/2 LOEL Toluene 55 µg/L From NC 02B Std. (I I µg/1), based on April 1986 DWQ Internal Report: Styrene 1.5 m /L - X lenes Total 6.7 m /L 1/2 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: • 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 Page 5 of 8 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 added • Monitoring increased from semi-annually to quarterly for all parameters (qualitative and quantitative) • "No discharge" clarifications made • Feasibility study and online SWPPP requirements removed per updated stormwater program requirements • eDMR requirement added • Boilerplate language moved into body of the permit; boilerplate no longer attached • Outfall-specific monitoring been implemented to reflect industrial activity and potential pollutants specific to each discharge area • Monitoring has been added for benzene, ethylbenzene, naphthalene, toluene, styrene, xylene, and ammonia nitrogen based on information provided with the permit renewal application o Ammonium hydroxide is present onsite, therefore ammonia nitrogen monitoring added • Benchmarks updated for parameters per guidance from DWR Standards group on stormwater benchmarks Section 5. Changes from draft to final: • Quarterly monitoring removed for ammonia nitrogen benzene, ethylbenzene, naphthalene, toluene, styrene, and xylene and existing footnote 4 (requiring monitoring in the event of a spill or catastrophic failure) expanded to include all these parameters o Based on comments received from permittee during public notice Page 6 of 8 Section 6. Discussions with the Facility and Regional Office: • Initial contact with facility: 10/31/2023 • Initial contact with Regional Office: 10/31/2023 • Draft sent to CO peer review: N/A • Draft sent to Regional Office: 2/7/2024 • Final permit sent for supervisor signature: 3/27/2024 Section 7. Comments received on draft permit: • Resinall representatives (via phone 3/11/2024): o Solvent management plan: What is that?How do we report? ■ DEMLR response: The plan should be kept as a part of your SWPPP. It should be documented if you use solvents onsite. o Non-polar O&G: Do we have to do monitor for that?What does it include? The transformer onsite is owned by the power company. ■ DEMLR response: Monitoring and reporting is required if you use more than 55 gallons per month. This includes oiled used for vehicle maintenance as well as equipment maintenance (including transformers) onsite. Since the transformer onsite is owned and maintained by the power company and does not have the possibility to impact outfalls, this does not need to be considered in the O&G usage. o Monthly oil usage: Do we have to report? How? ■ DEMLR response: This is a required monitoring parameter, therefore you must report it under the NCOIL code in eDMR. o Monitoring for benzene, ethylbenzene, naphthalene, toluene, styrene, xylene, and ammonia nitrogen. ■ They will submit written comments requesting removal of these. • Bill Lewis (Resinall Corp; via email 3/12/2024): o Remove from Table 1: Ammonia Nitrogen, Benzene, Ethylbenzene,Naphthalene, Toluene, Styrene and Total Xylenes. As stated in our Stormwater Permit Renewal Application all the referenced chemicals listed in the prior sentence have the potential to contaminate stormwater, but we have no reason to believe that any of the toxic pollutants are present in our stormwater discharge. A major spill or Catastrophic failure of our enclosed process wastewater tank system would be the only ways in which stormwater could be contaminated. ■ DEMLR response: Footnote 4 of the monitoring table states "Monitor in the event of major spill or catastrophic failure of process wastewater tanks system." The reference to quarterly monitoring will be removed for ammonia nitrogen, benzene, ethylbenzene, naphthalene, toluene, styrene, and xylene and the footnote refence expanded to include all these parameters. Monitoring for ammonia nitrogen shall remain on a quarterly basis as the facility stores ammonium hydroxide. o Remove Non-Polar Oil & Grease and Estimated Average Monthly Oil Usage from Table 1. Resinall Corp doesn't perform routine vehicle maintenance activities on our vehicles. Majority of maintenance activities are conducted by outside contractors. Resinall uses much less than 25 gallons of oil near stormwater drainage areas monthly. Non-Polar Oil and grease utilized in majority of our manufacturing facility are Page 7 of 8 in secondary containment areas that are not connected to stormwater drainage areas directly. In our current permit these parameters are only required to be monitored if use> 55 gallons for on-site vehicle maintenance. ■ DEMLR response: Monitoring and reporting for Non-polar O&G and Average Monthly Oil Usage are standard monitoring parameters in all stormwater permits and is meant for total oil used across the whole facility, not just in vehicle maintenance areas. This is an update to the previous permit and is standard across all individual industrial permits as they get renewed. If the indicated permit threshold of 55 gallons or greater is not met, then monitoring for Non-polar O&G is not required. o Please provide clarification on Page 12 of 38 as it pertains to the solvent management compliance certification. Will certification only be required on the eDMR and not in the Solvent Management Plan or will it be required in both? ■ DEMLR response: Please put the statement in both the comments section of the eDMR as well as tracking it in the solvent management plan. Page 8 of 8 01 Publisher's Certificate of Publication STATE OF NORTH CAROLINA PUBLIC NOTICE NORTH CAROLINA COUNTY OF HERTFORD ENVIRONMENTAL MANAGEMENT COMMISSION INTENT TO ISSUE Ashley Vansant, being duly sworn, on oath says NPDES STORMWATER he is and during all times herein stated has been DISCHARGE PERMITS Publisher of Roanoke-Chowan Publications, Inc. The North Carolina publisher and printer of the The Roanoke-Chowan Environmental Management News-Herald (the"Newspaper"), has full knowledge Commission proposes to issue of the facts herein stated as follows: NPDES stormwater discharge permit(s)to the person(s)listed below. Public comment or 1. The Newspaper printed the copy of the matter abjection to the draft permits attached hereto (the"Notice")was copied from the is invited. Written comments columns of the Newspaper and was printed and regarding the proposed permit published in the English language on the following will accepted until 30 days p 99 after the publish date of this days and dates: notice and considered in the final determination regarding 02/14/24 permit issuance and permit provisions. The Director of the NC Division of Energy,Mineral, 2. The sum charged by the Newspaper for said and Land Resources (DEMLR) publication is the actual lowest classified rate paid may hold a public hearing by commercial customer for an advertisement of should there be a significant deree similar size and frequency in the same newspaper Please ma commentsf ublicnterest and/or in which the Notice was published. information requests to DEMLR at 1612 Mail Service Center, 12. 3. There are no agreements between the News- Raleigh,NC 2 Corporation a er, publisher, manager or printer and the officer ' Resinall Corporation 77- PO P P 9 P Box 195, Sevem, NC 27877- or attorney charged with the duty of placing the at- 0195] has requested renewal tached legal advertising notice whereby any advan- of permit NCS000292 for the tage, gain or profit accrued to said officer or attorney Resinall Corporation facility in Northampton County. This facility discharges to an unnamed tributary to Kirbys Creek in the Chowan River Basin. Interested persons may visit DEMLR at 512 N. Salisbury street, Raleigh, NC 27604 to review information on file. Additional information on Z�4� NPDES permits and this notice may be found on our website: https://deq.nc.gov/about/ Ashley Vansant, Publisher divisions/energy-mineral-and- la n d-reso u rces/sto rmwate r/ Subscribed and sworn to before me this stormwater-program/ stormwater-publio-notices, or 14th Day of February,2024 by contacting Brianna Young at bnanna.young@deq.nc.gov or So 919-707-3647. { ~,'•4�� Roanoke-Chowan: Feb.14,2024 `'► '� a PUBLIC INCS000292 ;v� 4. Mary Jo Eskridge, Notary Public State of Alabama at Large My commission expires 03-02-2026 Account#300317 Ad# 1780428 NCDEQ/DIVISION OF ENERGY 1612 MAIL SERVICE CENTER RALEIGH NC 27699 Young, Brianna A From: Bill Lewis <blewis@resinall.com> Sent: Tuesday, March 12, 2024 4:30 PM To: Young, Brianna A Cc: Paul Pearce; Jerry Johnson Subject: RE: [External] RE: Draft NPDES stormwater permit NCS000292 Importance: High CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message button located on your Outlook menu bar on the Home tab. Dear Brianna, Per our recent conversation, I am including changes we would like to make to our DRAFT Permit. Resinall Corp would like to have the following parameters removed from Table 1 Page 15 of 38 of the DRAFT Permit: Ammonia Nitrogen, Benzene, Ethylbenzene, Naphthalene, Toluene, Styrene and Total Xylenes. As stated in our Stormwater Permit Renewal Application all the referenced chemicals listed in the prior sentence have the potential to contaminate stormwater, but we have no reason to believe that any of the toxic pollutants are present in our stormwater discharge. A major spill or Catastrophic failure of our enclosed process waste water tank system would be the only ways in which stormwater could be contaminated. We would also like to remove (1) Non-Polar Oil & Grease for drainage areas that use > 55 gallons/ per month on oil on average per EPA Method 1664 (SGT-HEM) and (2) Estimated Average Monthly Oil Usage at the Facility from Table 1 Page 15 of 38. Resinall Corp doesn't perform routine vehicle maintenance activities on our vehicles. Majority of maintenance activities are conducted by outside contractors. Resinall uses much less than 25 gallons of oil near stormwater drainage areas monthly. Non-Polar Oil and grease utilized in majority of our manufacturing facility are in secondary containment areas that are not connected to stormwater drainage areas directly. In our current permit these parameters are only required to be monitored if use > 55 gallons for on-site vehicle maintenance. Please provide clarification on Page 12 of 38 as it pertains to the solvent management compliance certification. Will certification only be required on the eDMR and not in the Solvent Management Plan or will it be required in both? I If you have any questions, please feel free to contact me. Thanks, Bill Lewis Environmental & Safety Specialist Resinall Corp, an Ergon Company 0 +1-252-585-1445 Ext: 144 M +1-757-653-7500 1_f OUalYly Rc5LM far]ndusi i. From:Young, Brianna A<Brianna.Young@deq.nc.gov> Sent: Friday, March 8, 2024 1:24 PM To: Bill Lewis<blewis@resinall.com> Cc: Paul Pearce<ppearce@resinall.com> Subject: [EXTERNAL]RE: [External] RE: Draft NPDES stormwater permit NCS000292 Bill, am available Monday anytime but am unavailable on Tuesday. Please call at your convenience on Monday. Thankyou, Brianna Young, MS (she/her) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young(a)deq.nc.gov(e-mail preferred) 919-707-3647(office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address:512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Bill Lewis<blewis@resinall.com> Sent: Friday, March 8, 2024 1:11 PM To:Young, Brianna A<Brianna.Young@deq.nc.gov> Cc: Paul Pearce<ppearce@resinall.com> Subject: [External] RE: Draft NPDES stormwater permit NCS000292 Importance: High 2 CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message button located on your Outlook menu bar on the Home tab. Dear Brianna, have some questions pertaining to the our new DRAFT Permit. Could you advise some available times you may have for Monday (03/11) or Tuesday (03/12) of next week to discuss our permit. look forward to hearing back from you. Thanks, Bill Lewis Environmental & Safety Specialist Resinall Corp, an Ergon Company 0 +1-252-585-1445 Ext: 144 M +1-757-653-7500 resin aft core From:Young, Brianna A<Brianna.Young@deg.nc.gov> Sent: Wednesday, February 7, 2024 8:51 AM To: Paul Pearce<ppearce@resinall.com> Cc: Bill Lewis<blewis@resinall.com> Subject: [EXTERNAL]Draft NPDES stormwater permit NCS000292 Good morning, Please find attached a copy of the draft NPDES stormwater permit for Resinall Corporation (NCS000292). A hard copy of this draft permit will be placed in the mail to Paul Pearce. Please provide any comments by March 14, 2024. Thank you, Brianna Young, MS(she/her) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) Brlanna.Young@deg.nc.gov(e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS 3 919-707-3647 (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. 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. Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized state official. This message (including any attachments) may contain confidential, proprietary, privileged and/or private information. The information is intended to be for the use of the individual or entity designated above. If you are not the intended recipient of this message, please notify the sender immediately and delete the message and any attachments. Any disclosure, reproduction, distribution or other use of this message or any attachments by an individual or entity other than the intended recipient is prohibited. This message (including any attachments) may contain confidential, proprietary, privileged and/or private information. The information is intended to be for the use of the individual or entity designated above. If you are not the intended recipient of this message, please notify the sender immediately and delete the message and any attachments. Any disclosure, reproduction, distribution or other use of this message or any attachments by an individual or entity other than the intended recipient is prohibited. 4 Young, Brianna A From: Bill Lewis <blewis@resinall.com> Sent: Thursday, November 16, 2023 9:37 AM To: Young, Brianna A Cc: Paul Pearce; Jerry Johnson Subject: RE: [External] RE: Stormwater Permit NCS000292 for Resinall Corporation Importance: High CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message button located on your Outlook menu bar on the Home tab. Dear Ms. Young: The receiving Stream for both Outfall 001 and 002 is Kirbys Creek to the South. Kirbys Creek eventually discharges into the Meherrin River. No recognizable stormwater flows off our plant site to the North due to the slope of the terrain, the railroad tracks and the rail road overpass directly North of the facility prevents water from flowing toward the Meherrin River. The stormwater is forced to be diverted back toward the South through our storm drains which discharge into our plant ditch where Outfalls 001 and 002 are located. If any other information is needed, please let me know. Sincerely, Bill Lewis Environmental & Safety Specialist Resinall Corp, an Ergon Company 0 +1-252-585-1445 Ext: 144 M +1-757-653-7500 rsinall' core From:Young, Brianna A<Brianna.Young@deq.nc.gov> Sent:Thursday, November 16, 2023 9:02 AM To: Bill Lewis<blewis@resinall.com> Cc: Paul Pearce<ppearce@resinall.com>;Jerry Johnson <jerryjohnson@resinall.com> Subject: [EXTERNAL]RE: [External] RE: Stormwater Permit NCS000292 for Resinall Corporation 1 Good morning, Can you confirm the receiving stream for each outfall?The application states Kirbys Creek(which is to the south) but given the distance of the site to this waterbody, I would like to make sure the discharge does not discharge to another creek or river(such as the Meherrin River to the north which is significantly closer). Thank you, Brianna Young, MS(she/her) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@deg.nc.gov(e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS 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. 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. From:Young, Brianna A Sent:Wednesday, November 15, 2023 3:01 PM To: Bill Lewis<blewis@resinall.com> Cc: Paul Pearce<ppearce@resinall.com>;Jerry Johnson <jerryiohnson@resinall.com> Subject: RE: [External] RE: Stormwater Permit NCS000292 for Resinall Corporation Good afternoon Bill, Thank you for providing this information. I will reach out with any additional questions once I've had a chance to review everything. Thank you, Brianna Young, MS(she/her) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@deg.nc.gov(e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS 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. 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. 2 From: Bill Lewis<blewis@resinall.com> Sent: Friday, November 10, 2023 2:01 PM To:Young, Brianna A<Brianna.Young@deg.nc.gov> Cc: Paul Pearce<ppearce@resinall.com>;Jerry Johnson <ierryiohnson@resinall.com> Subject: [External] RE: Stormwater Permit NCS000292 for Resinall Corporation Importance: High CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message button located on your Outlook menu bar on the Home tab. Dear Ms. Young: Refer to emailed below for answers to your Stormwater Applications questions. If any other information is needed, please let me know. Sincerely, Bill Lewis Environmental & Safety Specialist Resinall Corp, an Ergon Company O +1-252-585-1445 Ext: 144 M +1-757-653-7500 fesinall' c rp From:Young, Brianna A<Brianna.Young@deg.nc.gov> Sent:Tuesday, October 31, 2023 3:26 PM To: Paul Pearce<ppearce@resinall.com> Cc: Bill Lewis<blewis@resinall.com> Subject: [EXTERNAL]Stormwater Permit NCS000292 for Resinall Corporation Good afternoon, I am working on renewing the individual stormwater permit for the Resinall Corporation (NCS000292). 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: • Table D of EPA Form 2F was not filled out; Per our conversation on Wednesday, I have attached updated Table B,Table C and Table D of EPA Form 2F for Outfalls 001 and 002. • Confirm whether treated boiler blowdown is mixed with stormwater prior to discharge; Yes, boiler blowdown is mixed with stormwater prior to discharge at outfalls. 3 • Description of industrial activity occurring and chemicals stored onsite; Refer to EPA Form 1 Section 8 and EPA Form 2F Section 4,4.2. • Confirmation on the number of outfalls, associated coordinates, and respective receiving stream(s); Refer to EPA Form 2F Section 1, 1.1. • Description of industrial activity in each drainage area; Industrial activities addressed in EPA Form 1 and EPA Form 2F affect both Outfall 001 and 002. Outfall 001 discharges go through Outfall 002. • An electronic spreadsheet summarizing all of the monitoring data that has been collected since the effective date of the current permit; Updated Analytical and Visual Monitoring Data Spreadsheets have been attached. • Verification that the information in the renewal application is still complete and correct; All information in the renewal application is complete and correct with the additional information included in this email. • An explanation of any operational changes since the renewal application was submitted; and There have been no operational changes since we submitted our original NPDES Stormwater Permit Renewal. • Confirmation of the entity that has ownership of the permit and site. Our internal database indicates Ergon Chemicals, LLC is the owner, however, this LLC is not registered with the North Carolina Secretary of State to do business in North Carolina. Resinall Corp SOS ID: 1782383 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 Bethany 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 ePUment 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) Industrial Individual Permits Coordinator Stormwater Permitting Program 4 NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@deg.nc.gov(e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS 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. 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. Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized state official. This message (including any attachments) may contain confidential, proprietary, privileged and/or private information. The information is intended to be for the use of the individual or entity designated above. If you are not the intended recipient of this message, please notify the sender immediately and delete the message and any attachments. Any disclosure, reproduction, distribution or other use of this message or any attachments by an individual or entity other than the intended recipient is prohibited. This message (including any attachments) may contain confidential, proprietary, privileged and/or private information. The information is intended to be for the use of the individual or entity designated above. If you are not the intended recipient of this message, please notify the sender immediately and delete the message and any attachments. Any disclosure, reproduction, distribution or other use of this message or any attachments by an individual or entity other than the intended recipient is prohibited. 5 Young, Brianna A From: Bill Lewis <blewis@resinall.com> Sent: Friday, November 10, 2023 2:01 PM To: Young, Brianna A Cc: Paul Pearce; Jerry Johnson Subject: [External] RE: Stormwater Permit NCS000292 for Resinall Corporation Attachments: Form 2F Tables B,C,D (Outfalls 001 &002) Revised.pdf; STRMRSLT2018-2023Summary.xlsx;Visual Monitoring (Stormwater) 2018-2023.xlsx Importance: High CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message button located on your Outlook menu bar on the Home tab. Dear Ms. Young: Refer to emailed below for answers to your Stormwater Applications questions. If any other information is needed, please let me know. Sincerely, Bill Lewis Environmental & Safety Specialist Resinall Corp, an Ergon Company 0 +1-252-585-1445 Ext: 144 M +1-757-653-7500 r sin ft core 1_t OUalkly RC5Lrs for Indusi i. From:Young, Brianna A<Brianna.Young@deq.nc.gov> Sent:Tuesday, October 31, 2023 3:26 PM To: Paul Pearce<ppearce@resinall.com> Cc: Bill Lewis<blewis@resinall.com> Subject: [EXTERNAL]Stormwater Permit NCS000292 for Resinall Corporation Good afternoon, I am working on renewing the individual stormwater permit for the Resinall Corporation (NCS000292). 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: 1 • Table D of EPA Form 2F was not filled out; Per our conversation on Wednesday, I have attached updated Table B,Table C and Table D of EPA Form 2F for Outfalls 001 and 002. • Confirm whether treated boiler blowdown is mixed with stormwater prior to discharge; Yes, boiler blowdown is mixed with stormwater prior to discharge at outfalls. • Description of industrial activity occurring and chemicals stored onsite; Refer to EPA Form 1 Section 8 and EPA Form 2F Section 4,4.2. • Confirmation on the number of outfalls, associated coordinates, and respective receiving stream(s); Refer to EPA Form 2F Section 1, 1.1. • Description of industrial activity in each drainage area; Industrial activities addressed in EPA Form 1 and EPA Form 2F affect both Outfall 001 and 002. Outfall 001 discharges go through Outfall 002. • An electronic spreadsheet summarizing all of the monitoring data that has been collected since the effective date of the current permit; Updated Analytical and Visual Monitoring Data Spreadsheets have been attached. • Verification that the information in the renewal application is still complete and correct; All information in the renewal application is complete and correct with the additional information included in this email. • An explanation of any operational changes since the renewal application was submitted; and There have been no operational changes since we submitted our original NPDES Stormwater Permit Renewal. • Confirmation of the entity that has ownership of the permit and site. Our internal database indicates Ergon Chemicals, LLC is the owner, however, this LLC is not registered with the North Carolina Secretary of State to do business in North Carolina. Resinall Corp SOS ID: 1782383 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 Bethany Georgoulias • Stormwater outfall information: Email Bethany Geor og ulias • 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. 2 Thank you, Brianna Young, MS(she/her) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@deg.nc.gov(e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS 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. 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. Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized state official. This message (including any attachments) may contain confidential, proprietary, privileged and/or private information. The information is intended to be for the use of the individual or entity designated above. If you are not the intended recipient of this message, please notify the sender immediately and delete the message and any attachments. 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CU _ / k �a rcc % r- -0 � � � ■ e2 cu M % > 0 k 2 § mot E \ § 2 § L ) & 02 . 7 � 0 > / $ .0 cm ® k ' § f 0 j ■ / ® z E ° J ` $ 4) f0 a � LLI bD - _ cr \ = 0) ) � E C 2w $ AD \ k e f g 2 § {_ � - \ k / ( � E � E } § k 7 j ƒ § 8 © E % § ' G k 7 2 ƒ § = 2 I� CD m > , \ — q 3: $ 0 co %� $ k £ { ® = 2 i k ( E 2 G ) _ E ® 2 \ � ? \ ® k } / 0 q � � � s ) § • � � ® � / § * ƒ ) \ ' \ ( / \ U 7 � / k} - 7 2 ƒ J \ _ \ 2 \ k § STORMWATER SAMPLING ANALSIS RESULTS Date: 11/9/2023 Stormwater 2018 2019 2020 2021 2022 2023 Benchmark Values Stormwater for Analytical Average 6/20/2018 10/26/2018 6/18/2019 11/12/2019 6/11/2020 12/16/2020 6/2/2021 12/8/2021 6/12/2022 11/30/2022 6/7/2023 Outfall# Discharge Characteristics Monitoring m /I m /I m /I m /I m /I m /I m /I m /I m /I m /I m /I m /I 001 Chemical Oxygen Demand(COD) 120 26.35 28.90 < 100.00 34.00 < 10.00 24.00 < 10.00 23.00 12.00 18.00 20.00 < 10.00 Total Suspended Solids(TSS) 100 19.30 146.00 4.30 12.20 7.30 13.70 5.80 2.60 7.30 4.20 6.40 < 2.50 pH(standard units) 6-9 7.38 7.12 7.44 7.04 7.46 7.45 7.22 7.46 7.62 7.67 7.40 7.36 Total Flow(MG) 0.02 0.09 0.02 0.03 0.01 0.02 0.01 0.02 0.01 0.010 0.007 0.002 Total Rainfall(Inches) 0.81 0.60 1.30 1.25 0.75 1.50 0.75 1.00 0.10 1.10 0.50 0.10 002 Chemical Oxygen Demand(COD) 120 26.45 30.90 < 100.00 < 10.00 16.00 < 10.00 < 10.00 17.00 25.00 29.00 28.00 15.00 Total Suspended Solids(TSS) 100 34.62 148.00 4.90 37.00 5.60 82.00 8.00 8.80 8.10 54.10 20.20 4.10 pH 6-9 7.18 7.16 7.26 6.78 7.28 7.25 6.58 7.52 7.16 7.29 7.21 7.51 Total Flow(MG) 0.08 0.13 0.08 0.06 0.04 0.21 0.09 0.11 0.01 0.14 0.019 0.003 Total Rainfall(Inches) 0.81 0.60 1.30 1.25 0.75 1.50 0.75 1.00 0.10 1.10 0.50 0.10 Visual Monitoring Results for Stormwater Permit No. NCS000292 November 1,2023 Date Outfall# Color Odor Clarity Floating Solids Suspended Solids Foam Oil Sheen Erosion/ (1-5) (1-5) (1-5) Deposition 1(clear) 1(no solids) 1(no solids) 5(surface covered w/floating 5(very cloudy) solids) 5(extremely muddy) 6/7/2023 001 no visible tint no distinct odor 1 1 1 No No No 002 no visible tint no distinct odor 1 2 1 No No No 11/30/2022 001 no visible tint no distinct odor 1 1 1 No No No 002 light brown tint no distinct odor 2 2 2 No No No 6/12/2022 001 no visible tint no distinct odor 1 2 1 No No No 002 light brown tint no distinct odor 2 2 2 No No No 12/8/2021 001 no visible tint no distinct odor 1 1 1 No No No 002 no visible tint no distinct odor 1 1 1 No No No 6/2/2021 001 no visible tint no distinct odor 1 1 1 No No No 002 no visible tint no distinct odor 1 1 1 No No No 12/16/2020 001 no visible tint no distinct odor 1 1 1 No No No 002 no visible tint no distinct odor 1 2 1 No No No 6/11/2020 001 no visible tint no distinct odor 2 2 2 No No No 002 light brown tint no distinct odor 3 3 3 No No No 11/12/2019 001 no visible tint no distinct odor 1 1 1 No No No 002 no visible tint no distinct odor 1 1 1 No No No 6/18/2019 001 no visible tint no distinct odor 1 2 1 No No No 002 no visible tint no distinct odor 1 2 1 No No No 10/26/2018 001 no visible tint no distinct odor 1 2 1 No No No 002 no visible tint no distinct odor 1 2 1 No No No 6/20/2018 001 brown medium tint no distinct odor 3 2 3 No No No 002 brown medium tint no distinct odor 4 2 4 No No No 10/31/23,9:44 AM North Carolina Secretary of State Search Results • File an Annual Report/Amend an Annual Report • Upload a PDF Filing • Order a Document Online - Add Entity to My Email Notification List • View Filings • Print a Pre-Populated Annual Report form • Print an Amended a Annual Report form Business Corporation Legal Name Resinall Corp Information Sosld: 1782383 Status: Current-Active O Date Formed: 12/17/2018 Citizenship: Foreign State of Incorporation: MS Fiscal Month: June Annual Report Due Date: October 15th Currentgnnual Report Status: Registered Agent: CT Corporation System Addresses https://www.sosnc.gov/onIine_services/search/Business_Registration_ResuIts 1/2 10/31/23,9:44 AM North Carolina Secretary of State Search Results Reg Office Reg Mailing Principal Office 160 Mine Lake Ct Ste 200 160 Mine Lake Ct Ste 200 2829 Lakeland Drive Raleigh, NC 27615 Raleigh, NC 27615 Flowood, MS 39232 Mailing PO Box 1639 Jackson, MS 39215 Off icers Executive Director President Treasurer Vice President Craig Busbea Kenneth Cooley Kenneth E Hodges Jerry Johnson 2829 Lakeland Drive 2829 Lakeland Drive 2829 Lakeland Drive 2829 Lakeland Drive Flowood MS 39232 Flowood MS 39232 Flowood MS 39232 Flowood MS 39232 Assistant Secretary Vice President Executive Director Secretary Lance Mazerov Kris Patrick Lance Puckett Kathryn W. Stone 2829 Lakeland Drive 2829 Lakeland Drive 2829 Lakeland Drive 2829 Lakeland Drive Flowood MS 39232 Flowood MS 39232 Flowood MS 39232 Flowood MS 39232 Chief Financial Officer Alan Wall 2829 Lakeland Drive Flowood MS 39232 Stock https://www.sosnc.gov/online_services/search/Business_Registration_ResuIts 2/2 Young, Brianna A From: Young, Brianna A Sent: Wednesday, November 2, 2022 9:56 AM To: Bill Lewis Cc: Paul Pearce Subject: RE: [External] NPDES Stormwater Permit Coverage Renewal (Permit Number NCS000292) Good morning, The Division of Energy, Mineral, and Land Resources (DEMLR) Stormwater Permitting Program acknowledges receipt of your renewal application for coverage under NPDES Permit Number NCS000292. Please continue to comply with all conditions and monitoring requirements in your current 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. Please note that due to the current backlog and staff shortages, review of this permit renewal is not scheduled until 2024,however this schedule is subject to change. Please let me know if you have any questions in the interim. Thank you, Brianna Young, MS(she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov(e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public during this challenging time. From:Young, Brianna A Sent:Thursday, October 27, 2022 3:59 PM To: 'Bill Lewis' <blewis@resinall.com> Cc: Paul Pearce<ppearce@resinall.com> Subject: RE: [External] NPDES Stormwater Permit Coverage Renewal (Permit Number NCS000292) Bill, Thank you for providing the electronic version.An official acknowledgement will be sent when the hardcopy is received in our office. i Thank you, Brianna Young, MS(she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov(e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public during this challenging time. From: Bill Lewis<blewis@resinall.com> Sent:Thursday, October 27, 2022 3:27 PM To:Young, Brianna A<Brianna.YounR@ncdenr.Rov> Cc: Paul Pearce<ppearce@resinall.com> Subject: [External] NPDES Stormwater Permit Coverage Renewal (Permit Number NCS000292) Importance: High CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to Report Spam. Dear Ms. Young: Attached is the required electronic copy of Resinall's Stormwater Permit Renewal Application. The original application is being sent today by US Mail Certified Return Receipt to your attention. If you have any questions, please feel free to contact me at (252) 585-1445 or by e-mail at blewiskresinall.com. Sincerely, Bill Lewis Environmental & Safety Specialist Resinall Corp P.O. BOX 195 2 Severn, NC 27877 blewisgresinall.com (252) 585-1445 This message (including any attachments) may contain confidential, proprietary, privileged and/or private information. The information is intended to be for the use of the individual or entity designated above. If you are not the intended recipient of this message, please notify the sender immediately and delete the message and any attachments. Any disclosure, reproduction, distribution or other use of this message or any attachments by an individual or entity other than the intended recipient is prohibited. 3 _ An Ergono Company • fesina corp P.O. Box1639 _o Quality Resins for Industry Jackson, MS 39215-1639 USA 601-933-3000 resinall.com October 27, 2022 DEMLR Stormwater Program 1612 MSC Raleigh,NC 27699-1612 _ Attn.: Ms. Brianna Young,NPDES Industrial Individual Permit Lead `� F� - brianna.young(a�ncdenr. w V NOV o 12022 Reference: NPDES Stormwater Permit Coverage Renewal Resinall Corp l)EtdR-LAND QUALITY STC Permit NumberNCS000292 (14'ATE PER Iv11TTiPVC Northampton County Dear Ms. Young: Resinall Corp requests the renewal of North Carolina NPDES Stonnwater Permit Number NCS000292 for Resinall Corp, 302 N. Water Street, Severn,NC 27877. The EPA Applications Form 1 and Form 2F,the SPPP Certification Form and Supplemental Information Form have been included with this permit renewal. An electronic copy all the forms and supporting documents will be emailed to brianna.youngkricdenngov. Item 5 of the Supplemental Information Form: 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 changes in the raw materials used at the facility. A significant change was made to the process wastewater systein at the Resinall Severn facilio,in early 2020. The process wastewater spray pond was removed, and the process wastewater is now handled in an enclosed tank system therefore reducing fugitive emissions as well as eliminating any potential to contaminate stormwater from an open-air concrete pond If you have any questions concerning this renewal, please contact me at (252) 585-1445 or by e-mail at blewis(a-)resinall.com. Sincerely, RESINALL CORP e'er& 4&wz� Bill Lewis Environmental& Safety Specialist cc: Ken Cooley, COO, Resinall Corp Jerry Johnson, V.P.of Operations, Resinall Corp Paul Pearce, Plant Manager, Resinall Corp Austin Moody, Regulatory Manager, Resinall Corp Jake Neihaus, Environmental Manager(Ergon Chemicals, LLC) EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19 110018688981 NCS000292 Resinall Corporation OMB No.2040-0004 Form U.S.Environmental Protection Agency t :GiEPA Application for NPDES Permit to Discharge Wastewater NPDES GENERAL INFORMATION SECTION • •D •0 1.1 Applicants Not Required to Submit Form 1 Is the facility a new or existing publicly owned Is the facility a new or existing treatment works 1.1.1 treatment works? 1.1.2 treating domestic sewage? If yes,STOP.Do NOT complete No If yes,STOP,Do NOT 0 No Form 1.Complete Form 2A. complete Form 1.Complete Form 2S. 1.2 Applicants Required to Submit Form 1 1.2.1 Is the facility a concentrated animal feeding 1.2.2 Is the facility an existing manufacturing, operation or a concentrated aquatic animal commercial,mining,or silvicultural facility that Is d production facility? currently discharging process wastewater? oYes 4 Complete Form 1 Q No Yes 4 Complete Form ❑✓ No z and Form 2B. 1 and Form 2C. �. 1.2.3 Is the facility a new manufacturing,commercial, 1.2.4 Is the facility a new or existing manufacturing, mining,or silvicultural facility that has not yet commercial,mining,or silvicultural facility that 5 commenced to discharge? discharges only nonprocess wastewater? Cr ❑ Yes 4 Complete Form 1 No Yes 4 Complete Form No oe.. and Form 2D. 1 and Form 2E. 1.2.5 Is the facility a new or existing facility whose discharge is composed entirely of stormwater a associated with industrial activity or whose discharge is composed of both stormwater and :. non-stormwater? ❑✓ Yes 4 Complete Form 1 No and Form 2F unless exempted by 40 CFR 122.26(b)(14)(x)or b 15. SECTION 2.NAME, MAILING ADDRESS,AND LOCATiON (40 CFR 122.21(f)(2)) - 2.1 Facl! Name Resinall Corporation 0 2.2 EPA Identification Number 110018688981 2.3 Facility Contact d: Name(first and last) Title Phone number Bill Lewis Environmental&Safety Specialist (252)585-1445 a Email address blewis@resinall.com 2.4 Facility Mailing Address cc Street or P.O.box z P.0.Box 195 City or town State ZIP code Severn North Carolina 27877 EPA Form 3510-1(revised 3-19) Page 1 EPA Identification Number NPDES Permit Number Facility Name Form Approved 03105/19 110018688981 NCS000292 Resinall Corporation OMB No.204U004 2.5 Facility Location I Street,route number,or other specific identifier Q 0 302 N.Water Street oy U C 0 County name County code(if known) 2 0 Northampton E _j City or town State ZIP code z Severn North Carolina 27877 SECTION !t 1 3.1 SIC Code(s) Description(optional) 2821 Plastics Materials,Synthetic Resins,and Nonvulcanizable Elastomers a� 0 U U z 3.2 NAICS Code(s) Description(optional) C c f° 325211 Plastics Material and Resin Manufacturing U 4.1 Name of Operator Paul Pearce 0 4.2 Is the name you listed in Item 4.1 also the owner? co € ❑ Yes 21 No 4.3 Operator Status b ❑ Public—federal ❑ Public—state ❑ Other public(specify) o ❑ Private ❑ Other(specify) r.4 Phone Number of 0 erator (252)585-1445 4,5 Operator Address Street or P.O. Box P.O.Box 195 City or town State ZIP code 0 0 Severn North Carolina 27877 � U Q Email address of operator O ppearce@resinall.com SECTION1 v c 5.1 Is the facility located on Indian Land? ❑Yes ❑✓ No ti EPA Form 3510.1(revised 3-19) Page 2 EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19 110018688981 NCS000292 Resinall Corporation OMB No.2040-0004 SECTIONR• 6.1 Existing Environmental Permits(check all that apply and print or type the corresponding permit number for each) v m NPDES(discharges to surface ❑ RCRA(hazardous wastes) ❑ UIC(underground injection of water) fluids) • NCG500289 NCD109025932 wCL ❑ PSD(air emissions) ❑ Nonattainment program(CAA) ❑✓ NESHAPs(CAA) c' NC Air Permit 03304R32 X ❑ Ocean dumping(MPRSA) ❑ Dredge or fill(CWA Section 404) ❑ Other(specify) w SECTION1 7.1 Have you attached a topographic map containing all required information to this application?(See instructions for CL specific requirements.) ❑ Yes ❑ No ❑ CAFO—Not Applicable(See requirements in Form 2B.) SECTIONOF 8.1 Describe the nature of your business. Resinall Corporation is a manufacturing plant for rosin esters,hydrocarbon resins and rosin ester/hydrocarbon in resins.These resins are produced from the thermal polymerization of hydrocarbon streams derived from the cproduction of ethylene and tall oil or gum rosin esterified with various hydroxyl-containing substances at times, .� these substances are reacted or blended together to form hybrid products.Processing of resins include the mixing of Co raw materials in indirectly heated turbine-agitated reation kettles. 0 io z SECTION •• 1 9.1 Does your facility use cooling water? v ❑✓ Yes ❑ No-* SKIP to Item 10.1. � L R 9.2 Identify the source of coaling water.(Note that facilities that use a cooling water intake structure as described at w 40 CFR 125,Subparts I and J may have additional application requirements at 40 CFR 122.21(r).Consult with your o Y NPDES permitting authority to determine what specific information needs to be submitted and when.) U :4 The cooling water originates from a ground water well on site.All non-contact cooling water,cooling tower and c boiler blowdown,condensate and exempt stormwater are covered by NPDES Permit#NCG500289. SECTION1 VARIANCE REQUESTS 10.1 Do you intend to request or renew one or more of the variances authorized at 40 CFR 122.21(m)?(Check all that y apply.Consult with your NPDES permitting authority to determine what information needs to be submitted and when.) ❑ Fundamentally different factors(CWA [] Water quality related effluent limitations(CWA Section Section 301(n)) 302(b)(2)) ❑ Non-conventional pollutants(CWA [! Thermal discharges(CWA Section 316(a)) Section 301(c)and(g)) ❑✓ Not applicable EPA Form 3510-1(revised 3.19) Page 3 EPA Identification Number NPDES Permit Number Facility Name Form Approved 03105/19 110018688981 NC5000292 Resinall Corporation OMB No.2040-0004 SECTIONs r 11.1 In Column 1 below,mark the sections of Form 1 that you have completed and are submitting with your application. For each section,specify in Column 2 any attachments that you are enclosing to alert the permitting authority. Note that not all applicants are required to provide attachments. Column 1 Column 2 Section 1:Activities Requiring an NPDES Permit ❑ wl attachments 0 Section 2: Name,Mailing Address,and Location ❑ wl attachments ❑� Section 3:SIC Codes ❑ wl attachments ❑✓ Section 4: Operator Information ❑ wl attachments ❑✓ Section 5: Indian Land ❑ wl attachments Section 6:Existing Environmental Permits ❑ wl attachments E wl topographic R ❑✓ Section 7:Map ❑ map ❑ wl additional attachments 05 o Section 8:Nature of Business El wl attachments ,2 R ❑� Section 9:Cooling Water Intake Structures ❑ wl attachments ❑✓ Section 10:Variance Requests ❑ wl attachments �] Section 11:Checklist and Certification Statement ❑ wl attachments x v 11.2 Certification Statement s U I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system,or those persons directly responsible for gathering the information,the information submitted is,to the best of my knowledge and belief, true,accurate,and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. Name(print or type first and last name) Official title Paul Pearce Plant Manager Signature Date signed ��� Yam- 10/27/2022 EPA Form 3510-1(revised 3-19) Page 4 EPA Identification Number NPDES Permit Number Facility Name Form Approved 03105/19 110018688981 NC5000292 Resinall Corporation OMB No.2040-0004 Form U.S Environmental Protection Agency 21F .&EPA Application for NPDES Permit to Discharge Wastewater NPDES STORMWATER DISCHARGES ASSOCIATED WITH INDUSTRIAL ACTIVITY SECTIONOUTFALL LOCATION •0 1.1 Provide information on each of the facll' s outfalls in the table below Outfall Receiving Water Name Latitude Longitude Number 001 Kirbys Creek 36 31 8.875" N 77` 11' 12.96" W c 0 R' 002 Kirbys Creek 36' 31 2.481" N 77° 11' 17.68" W 0 J o r n o • N 0 o I u o I n o I N o I N p I N O I N SECTION IMPROVEMENTS •1 O I 2.1 Are you presently required by any federal,state,or local authority to meet an implementation schedule for constructing, upgrading,or operating wastewater treatment equipment or practices or any other environmental programs that could affect the discharges described in this application? ❑ Yes ❑,r No 4 SKIP to Section 3. 2.2 Briefly identify each applicable project in the table below. Brief Identification and Affected Outfalls Finai,Comp[iance Dates Sources)of Discharge bescription.of Project (listoutfallnumbets Required rtp octed d. E d 0 L a 2.3 Have you attached sheets describing any additional water pollution control programs(or other environmental projects that may affect your discharges)that you now have underway or planned?(Optional Item) ❑ Yes ❑ No EPA Form 3510-2F(Revised 3-19) Page 1 EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19 110018688981 NCS000292 Resinall Corporation OMB No.2040-0004 SECTION1• 1 3.1 Have you attached a site drainage map containing all required information to this application?(See instructions for specific guidance.) ® Yes ❑ No SECTIONPOLLUTANT SOURCES .0 4.1 Provide information on the facility's pollutant sources in the table below. Outfall Impervious Surface Area Total Surface Area Drained Number (within a mile radius of the faalfly) (wihin a mile radius of the facility) specify units specify units 001 5.50 acres 20 acres specify units specify units 002 9•75 acres 25 acres specify units specify units specify units specify units specify units specify units specify units specify units 4.2 Provide a narrative description of the facility's significant material in the space below.(See instructions for content requirements.) There were no significant materials that in three years prior to the submittal of this application have been treated, stored or disposed of in a manner to allow exposure to stormwater.Bulk materials are loaded and unloaded at oNorthern and Southern Tank Farm Rail Car sidings and Truck Stations#1(Refer to Site Map).All non-bulk co materials are loaded and unloaded at B-82 Warehouse.Significant materials at Resinall Corp Severn Facility include No.2 Diesel Fuel,Gasoline,Zecosol(Co-Product Fuel),Hydrocarbon intermediates,Hydrocarbon feedstocks(NP-86 Recovered Styrene,N-145 Resin Oil,Resin Oil 80 and Dicyclopentadiene),various process oils,glycerine,mineral spirits a and tall oil.The EPCRA Section 313 reportable chemicals found in our hydrocarbon feedstocks are Benzene,Cumene, Dicyclopentadiene,Ethylbenzene,Naphthalene,Styrene,Toluene and Xylene.All significant chemicals referenced above arp stored in tanks with secondary containmL-nt. 4.3 Provide the location and a description of existing structural and non-structural control measures to reduce pollutants in stormwater runoff. See instructions for specificguidance.) Stormwater Treatment Codes Cutfall from Number Control Measures and Treatment Exhibit 2F-1 list 001 See attached Supplemental Information Form Best Management Practices Attachment 002 See attached Supplemental Information Form Best Management Practices Attachment EPA Form 3510-2F(Revised 3-19) Page 2 EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19 110018588981 NC5000292 Resinall Corporation OMB No.2040-0004 SECTIONO• 1 I 51 l certify under penalty of law that the outfall(s) covered by this application have been tested or evaluated for the presence of non-stormwater discharges. Moreover, ! certify that the outfalls identified as having non-stormwater discharges are described in either an accompanying NPDES Form 2C. 2D. or 2E application. Name(print or type first and last name) Official title Paul Pearce Plant Manager Sig ture � date signed - -r— 10/27/2022 N CD 5.2 Provide the testing information requested in the table below. Onsite Drainage Points N OutfaA Description of Testing Method Used Date(s)of Testing Directly Observed Number During Test m �v 001 Discharges covered by NPDES Permit #f NCG500289 Yes 0 N (pH and temperature are measured daily) 0 Z 002 Discharges covered by NPDES Permit ##NCG500289 Yes (pH and temperature are measured daily) SECTIONOR I 1 6.1 Describe any significant leaks or spills of toxic or hazardous pollutants in the last three years. 'a There have been no significant leaks or spills of toxic or hazardous pollutants in the last 3 years. `o a� ro J C N U a SECTION 7.DISCHARGE INFORMATIONI See the instructions to determine the pollutants and parameters you are required to monitor and,in turn,the tables you must o corn late. Not all applicants need to complete each table. 1° 7.1 is this a new source or new discharge? El estimated 4 See instructions regarding submission of El No 4 See instructions regarding submission of estimated data. actual data. Tables A,B,C,and D h7.2 Have you completed Table A for each outfall? n 0 Yes ❑ No EPA Form 3510-2F(Rev#sed 3-19) Page 3 EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19 110018688981 NCS000292 Resinall Corporation OMB No.2040-0004 7.3 Is the facility subject to an effluent limitation guideline(ELG)or effluent limitations in an NPDES permit for its process wastewater? ❑� Yes ❑ No 4 SKIP to Item 7.5. 7.4 Have you completed Table B by providing quantitative data for those pollutants that are(1)limited either directly or indirectly in an ELG and/or(2)subject to effluent limitations in an NPDES permit for the facility's process wastewater? © Yes ❑ No 7.5 Do you know or have reason to believe any pollutants in Exhibit 2F-2 are present in the discharge? ❑ Yes ❑✓ No>SKIP to Item 7.7. 7.6 Have you listed all pollutants in Exhibit 217-2 that you know or have reason to believe are present in the discharge and provided quantitative data or an explanation for those pollutants in Table C? ❑ Yes ❑✓ No 7.7 Do you qualify for a small business exemption under the criteria specified in the Instructions? .:' ❑ Yes 4SKIP to Item 7.18, ❑✓ No 7.8 Do you know or have reason to believe any pollutants in Exhibit 217-3 are present in the discharge? ❑ Yes ❑✓ No-> SKIP to Item 7.10. 7.9 Have you listed all pollutants in Exhibit 2F-3 that you know or have reason to believe are present in the discharge in Table C? ❑� Yes ❑ No 7.10 Do you expect any of the pollutants in Exhibit 2F-3 to be discharged in concentrations of 10 ppb or greater? i Ir� ❑ Yes ❑✓ No 4 SKIP to Item 7.12. .; ., 7.11 Have you provided quantitative data in Table C for those pollutants in Exhibit 2F-3 that you expect to be discharged in concentrations of 10 ppb or greater? �c,, ❑ Yes ❑ No 7.12 Do you expect acrolein,acrylonitrile,2,4-dinitrophenol,or 2-methyl4,6-dinitrophenol to be discharged in concentrations of 100 ppb or greater? ❑ Yes ❑ No 4 SKIP to Item 7.14. ! 7.13 Have you provided quantitative data in Table C for the pollutants identified in Item 7.12 that you expect to be discharged in concentrations of 100 ppb or greater? ❑ Yes ❑ No 7.14 Have you provided quantitative data or an explanation in Table C for pollutants you expect to be present in the discharge at concentrations less than 10 ppb(or less than 100 ppb for the pollutants identified in Item 7.12)? ❑ Yes ❑� No 7.15 Do you know or have reason to believe any pollutants in Exhibit 2F-4 are present in the discharge? ❑ Yes Q No 4 SKIP to Item 7.17. 7.16 Have you listed pollutants in Exhibit 2F-4 that you know or believe to be present in the discharge and provided an explanation in Table C? ❑ Yes No 7.17 Have you provided information for the storm event(s)sampled in Table D? ❑ Yes ❑✓ No EPA Form 3510-2F(Revised 3-19) Page 4 EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19 110018688981 NCS000292 Resinail Corporation OMB No.2040-0004 Used or Manufactured Toxics 7.18 Is any pollutant listed on Exhibits 2F-2 through 21F-4 a substance or a component of a substance used or o manufactured as an intermediate or final product or byproduct? � ❑ Yes ❑ No 4 SKIP to Section 8. c 0 7.19 List the pollutants below,including TCDD if applicable. 0 1•Benzene 4.Naphthalene 7 ar 2 S. $Ethyl Benzene Styrene G 3 Toluene fi.xylene 9' SECTION • •GICAL TOXICITY TESTING 1• I 8.1 Do you have any knowledge or reason to believe that any biological test for acute or chronic toxicity has been made on any of your discharges or on a receiving water in relation to your discharge within the last three years? 0 c ❑ Yes ElNo 4 SKIP to Section 9. 10/27/2022 12 8.2 Identify the tests and their purposes below. Test(s) Purpose of Test(s) Submitted to NPDES Date Submitted •K Permitting Authority? _ 0 ~ ❑ Yes ❑ No ❑ Yes ❑ No 0 m ❑ Yes ❑ No SECT(ON 9.CONTRACT •- • 9.1 Were any of the analyses reported in Section 7(on Tables A through C)performed by a contract laboratory or consulting firm? ❑ Yes ❑ No 4 SKIP to Section 10. 9.2 Provide information for each contract laboratory or consulting firm below. Laboratory Number 1 Laboratory Number 2 Laboratory Number 3 Name of laboratory/firm Summit Environmental Technologies,Inc. eo 0 w Laboratory address •2 3310 Win Street cc Z% Cuyahoga Falls,Ohio 44223 eo c Q Phone number v (330)253-8211 Pollutant(s)analyzed Total Suspended Solids(TSS), Chemical Oxygen Demand (COD), Benzene,Ethyl Benzene, Napthalene,Toluene EPA Form 3510-2F(Revised 3-19) Page 5 EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19 110018688981 NCS000292 Resinall Corporation OMB No.2040-0004 SECTION1 CHECKLIST AND CERTIFICATION1 and • 10.1 In Column 1 below,mark the sections of Form 2F that you have completed and are submitting with your application.For each section,specify in Column 2 any attachments that you are enclosing to alert the permitting authority.Note that not all applicants are required to com lete all sections or provide attachments. Column 1 Column 2 0 Section 1 ❑ w/attachments(e.g.,responses for additional outfalls) ❑ Section 2 ❑ w/attachments 0 Section 3 ❑ w/site drainage map ✓❑ Section 4 ❑ w/attachments ✓❑ Section 5 ❑ w/attachments « ❑ Section 6 ❑ w/attachments ✓❑ Section 7 ❑� Table A ❑ w/small business exemption request co `" ❑✓ Table B ❑ w/analytical results as an attachment _ O Ss 0 Table C ❑ Table D ❑ Section 8 ❑ w/attachments _ ❑� Section 9 ❑ w/attachments(e.g.,responses for additional contact laboratories or firms) 0 Section 10 0 10.2 Certification Statement 1 certify under penalty of taw that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel property gather and evaluate the information submitted.Based on my inquiry of the person or persons who manage the system or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate,and complete.I am aware that there are significant penalties for submitting false information,including the possibility of fine and imprisonment for knowing violations. Name(print or type first and last name) Official title Paul Pearce Plant Manager Signature Date signed 10/27/2022 EPA Form 3510-2F(Revised 3-19) Page 6 EPA Identification Number NPDES Permit Number Facility Name Outfall Number Form Approved 0310 M 110018688981 NCS000292 Resinall Corporation 001 OMB No.2040-0004 TABLE A,CONVENTIONAL AND NON CONVENTIONAL PARAMETERS(40 CFR 122.26(c)(1)(i)(E)(3)), You must provide the results of at least one anal sis for every pollutant in this table.Complete one table for each outfall.See instructions for additional details and requirements. Maximum Daily Discharge Average Daily Discharge Source of (specify units) (specify units) Number of Storm Information Pollutant or Parameter Grab Sample Taken Flow-Weighted Grab Sample Taken Flow-Weighted Events Sampled (new sourcelRew During First During First dischargers only;use 30 Minutes Composite 30 Minutes Composite codes in instructions) 1, Oil and grease N/A N/A 2. Biochemical oxygen demand(BOD5) N/A N/A 3. Chemical oxygen demand(COD) 100 mg/I 28.88 mg/I 9 4. Total suspended solids(TSS) 146 mg/I 22.6 mg/1 9 5. Total phosphorus N/A 6. Total Kjeldahl nitrogen(TKN) N/A 7. Total nitrogen(as N) N/A PH(minimum) 8. PH(maximum) 7.67 7.39 9 ' Sampling shall be conducted according to sufficiently sensitive test procedures(i.e.,methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or required under 40 CFR chapter I,subchapter N or 0.See instructions and 40 CFR 122.21(e)(3). EPA Form 3510.2F(Revised 3-19) Page 7 EPA Identification Number NPDES Permit Number Facility Name Outfall Number Form Approved 03105119 110018689981 N C5000292 Resin all Corporation 002 OMB No.2040-0004 TABLE A. • • 1 NON CONVENTIONALF You must provide the results of at least one anal sis for every pollutant in this table.Complete one table far each outfall.See instructions for additional details and requirements. Maximum Daily Discharge Average Daily Discharge Source of (specify units) (specify units) Number of Storm Information Pollutant or Parameter Grab Sample Taken Flow-Weighted Grab Sample Taken Flow-Weighted Events Sampled (new source/new During First During First dischargers only;use Composite Composite codes in instructions 30 Minutes 3fl Minutes ) 1. Oil and grease N/A N/A 2. Biochemical oxygen demand(BODs) N/A N/A 3. Chemical oxygen demand(COD) 100 mg/1 27.54 mg/l 9 4. Total suspended solids(TSS) 148 mg/1 39.61 mg/1 9 5. Total phosphorus N/A 6, Total Kjeldahl nitrogen(TKN) N/A L LpH nitrogen(as N) NIAinimum) aximum) 7.5z 467.14 9 ' Sampling shall be conducted according to sufficiently sensitive test procedures(i.e., methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or required under 40 CFR chapter i,subchapter N or 0.See instructions and 40 CFR 122.21(e)(3). EPA Form 3510-21'(Revised 3-19) Page 7 EPA Identification Number NPDES Permit Number Facility Name Outfall Number FormApproved 03r05/19 110018688981 NCS000292 Resinall Corporation 001 OMB No.2040-0004 TABLE •IN CONVENTIONAL AN1 NON CONVENTIONAL '• • 41 CFR 122.26(c)(1)(i)(E)(4)and 41 c List each pollutant that is limited in an effluent limitation guideline(ELG)that the facility is subject to or any pollutant listed in the facility's NPDES permit for its process wastewater(if the facility is operating under an existing NPDES permit).Complete one table for each outfall.See the instructions for additional details and requirements. Maximum Daily Discharge Average,Dafly.Discharge Source of s ' units s , units Number of Storm Information Pollutant and CAS Number(if available) Grab Sample.Taken Grab Sample Taken (new source/new During First FIComp Bitted During First Flow-Weighted site Events Sampled dischargers only;use 30 Minutes Composite 30 Minutes Composite codes in instructions) Benzene(CAS#:71-43-2) <5.0 micro-grams/I <5.0 micro-grams/I 0 2-A Ethyl Benzene(CAS#:100-41-4) <5.0 micro-grams/I <5.0 micro-grams/I 0 2-A Naphthalene(CAS#:91-20-3) 7.8 micro-grams/I 7.8 micro-grams/I 0 2-A Toluene(CAS#:108-88-3) <5.0 micro-grams/I <5.0 micro-grams/I 0 2-A Sampling shall be conducted according to sufficiently sensitive test procedures(i.e.,methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or required under 40 CFR chapter I,subchapter N or 0.See instructions and 40 CFR 122.21(e)(3). EPA Form 3510-2F(Revised 3-19) Page 9 EPA IdenUcation Number NPDES Permit Number Facility Name Outfall Number Form Approved 0305119 110018688981 NCS000292 Resinall Corporation 002 OMB No.2040-0004 TABLE B.CERTAIN CONVENTIONAL AND NON CONVENTIONAL POLLUTANTS(40 CFR 122.26(c)(1)(i)(E)(4)and 40 CFR 122.21(g)(7)(vi)(A))1 List each pollutant that is limited in an effluent limitation guideline(ELG)that the facility is subject to or any pollutant listed in the facility's NPDES permit for its process wastewater(if the facility is operating under an existing NPDES permit).Complete one table for each outfall.See the instructions for additional details and requirements. Maximum Daily Discharge Average Daily Discharge Source of s ea units) (sp units Number of Storm Information Pollutant and CAS Number(if available) Grab Sample Taken Grab Sample Taken (new sourcelnew During First FlComposit ed During First Flow-Weighted site Events Sampled dischargers only;use 30 Minutes Composite 30 Minutes Composite codes in instructions) Benzene(CAS#:71-43-2) <5.0 micro-grams/I <5.0 micro-grams/I 0 2-A Ethyl Benzene(CAS#:100-41-4) <5.0 micro-grams/I <5.0 micro-grams/I 0 2-A Naphthalene(CAS#:91-20-3) 7.8 micro-grams/I 7.8 micro-grams/1 0 2-A Toluene(CAS#:108-88-3) <5.0 micro-grams/I <5.0 micro-grams/I 0 2-A Sampling shall be conducted according to sufficiently sensitive test procedures(i.e.,methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or required under 40 CFR chapter I,subchapter N or 0.See instructions and 40 CFR 122.21(e)(3). EPA Forth 3510-21'(Revised 3-19) Page 9 EPA Identification Number NPDES Permit Number Facility Name Outfall Number Form Approved 03105119 110018688981 NCS000292 Resinali Corporat+on 001 OMB No.2040-0004 TABLE C.TOXIC POLLUTANTS,CERTAIN HAZARDOUS SUBSTANCES,AND ASBESTOS(40 CFR 122.26(c)(1)(i)(E)(4)and 40 CFR 122.21(g)(7)(vi)(8)and(vil))' List each pollutant shown in Exhibits 2F-2,2F-3,and 2F-4 that you know or have reason to believe is present.Complete one table for each outfall, See the instructions for additional details and requirements. Maximum Daily Discharge Average Daily Discharge Source of s eci units (sped units Number of Storm Information Pollutant and CAS Number(if available) Grab Sample Taken Grab Sample Taken (new sourcetnew During First fto Composite ed During First Flow-Weighted Events Sampled dischargers only;use 30 Minutes Composite 30 Minutes Composite codes in instructions) Ammonium Hydroxide(CAS#:1336-21-6) Benzene(CAS#:71-43-2) Ethyl Benzene(CAS#:100-41-4) Naphthalene(CA5#:91-20-3) Styrene(CAS#:100-42-S) Toluene(CAS#:108-88-3) Xylene(CAS#:1330.20-7) Sulfuric Acid(CAS#:7664-93-9) All chemicals listed above have the potential to contaminate stormwater,but we have no reason to believe that any of the above toxic pollutants are present in our stormwater discharge. Sampling shall be conducted according to sufficiently sensitive test procedures(i.e.,methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or required under 40 CFR chapter I,subchapter N or 0.See instructions and 40 CFR 122,21(e)(3). EPA Form 3510-21'(Revised 3-19) Page 11 EPA Identification Number NPDES Permit Number Facility Name OutW Number Form Approved 03M5119 ' 110018689991 NCSOOO292 Resinall Corporation 002 OMB No.2040-0004 TABLE C.TOXIC POLLUTANTS,CERTAIN HAZARDOUS SUBSTANCES,AND ASBESTOS(40 CFR 122.26(c)(1)(i)(E)(4)and 40 CFR 122.21(g)(7)(vi)(B)and(vii))' List each pollutant shown in Exhibits 2F-2,2F-3,and 2F-4 that you know or have reason to believe is present Complete one table for each outfall.See the instructions for additional details and requirements. Maximum Daily Discharge Average Daily Discharge Source of s units units Number of Storm information Pollutant and CAS Number(If available) Grab Sample Taken Grab Sample Taken (new source/new During First FlComp sit ed During First Flow-Weighted o site Events Sampled dischargers only,use 30 Minutes Composite 30 Minutes Composite codes in instructions) Ammonium Hydroxide(CAS#:1336-21-6) Benzene(CAS#:71-43-2) Ethyl Benzene(CAS#:100-41-4) Naphthalene(CAS#:91-20-3) Styrene(CAS#:100-42-5) Toluene(CAS#:108-88-3) Xylene(CAS#:1330-20-7) Sulfuric Acid(CAS#:7664-93-9) All chemicals listed above have the potential to contaminate stormwater,but we have no reason to believe that any of the above toxic pollutants are present in our stormwater discharge. Sampling shall be conducted according to sufficiently sensitive test procedures(i.e.,methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or required under 40 CFR chapter I,subchapter N or 0.See instructions and 40 CFR 122.21(e)(3). EPA Form 3510-2F(Revised 3-19) Page 11 EPA Identificabon Number NPDES Permit Number Facility name Outfall Number Form Approved 03M5119 110018688981 NCS0OO292 Resinall Corporation 002 OMB No.2040-0004 STORMTABLE D. a- r Provide data for the storm event(s)that resulted in the maximum daily discharges for the flow-weighted composite sample. Number of Hours Between Total Rainfall During Maximum Flow Rate Date of Storm Event Duration of Storm Event Stone Event Beginning of Storm Measured and During Rain Event Total Flow from Rain Event (in hours) (in inches) (in gpm or specify units}End of Previous Measurable Rain (in gallons or specify units) Event Provide a description of the method of flow measurement or estimate. EPA Form 3510.21'(Revised 3-19) Page 13 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. 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. VZ6. 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 SAMPLING ANALSIS RESULTS Date: 10/6/2022 Stormwater 2018 2019 2020 2021 2022 Benchmark Values Stormwater for Analytical Average 6/2012018 10126/2018 611812019 1111212019 6111/2020 1211612020 6/212021 121812021 611212022 Outfall# Discharge Characteristics Monitoring (ma/Il (maul (mall) Imelil (mail) (ma/Il m !I m /I (maul (maAf 001 Chemical Oxygen Demand(COD) 120 28.88 28.90 < 100.00 34.00 < 10.00 24.00 < 10.00 23.00 12.00 18.00 Total Suspended Solids(TSS) 100 22.60 146.00 4.30 12.20 7.30 13.70 5.80 2.60 7.30 4.20 pH(standard units) 6.9 7.39 7.12 7.44 7.04 7.46 7.45 7.22 7.46 7.62 7.67 Total Row(MG) 0.02 0.09 0.02 0.03 0.01 0.02 0.01 0.02 0.01 0.010 Total Rainfall(Inches) 0.93 0.60 1.30 1.25 0.75 1.50 0.75 1.00 0.10 1.10 002 Chemical Oxygen Demand(COD) 120 27.54 30.90 < 100.00 < 10.00 16.00 < 10.00 < 10.00 17.00 25.00 29.00 Total Suspended Solids(TSS) 100 39.61 148.00 4.90 37.00 5.60 82.00 8.00 8.80 8.10 54.10 PH 6-9 7.14 7.16 7.26 6.78 7.28 7.25 6.58 7.52 7.16 7.29 Total Flow(MG) 0.10 0.13 0.08 0.06 0.04 0.21 0.09 0.11 0.01 0.14 Total Rainfall(Inches) 0.93 0.60 1.30 1.25 0.75 1.50 0.75 1.00 0.10 1.10 Visual Monitoring Results for Stormwater Permit No. NCS000292 October 6,2022 Date Outfall# Color Odor Clarity Floating Solids Suspended Solids Foam Oil Sheen Erosion 1 (1-5) (1-5) (1-5) Deposition 1(deer) 1(no sorida) 1(no adid.) 5(sudeco coverod vd floaBjg 5(vory cloudy) solids) 5(.xt—.I'n uddy) 6/12/2022 001 no visible tint no distinct odor 1 2 1 No No No 002 light brown tint no distinct odor 2 2 2 No No No 12/8/2021 001 no visible tint no distinct odor 1 1 1 No No No 002 no visible tint no distinct odor 1 1 1 No No No 6/2/2021 001 no visible tint no distinct odor 1 1 1 No No No 002 no visible tint no distinct odor 1 1 1 No No No 12/16/2020 001 no visible tint no distinct odor 1 1 1 No No No 002 no visible tint no distinct odor 1 2 1 No No No 6111/2020 001 no visible tint no distinct odor 2 2 2 No No No 002 light brown tint no distinct odor 3 3 3 No No No 11/12/2019 001 no visible tint no distinct odor 1 1 1 No No No 002 no visible tint no distinct odor 1 1 1 No No No 6118/2019 001 no visible tint no distinct odor 1 2 1 No No No 002 no visible tint no distinct odor 1 2 1 No No No 10/26/2018 001 no visible tint no distinct odor 1 2 1 No No No 002 no visible tint no distinct odor 1 2 1 No No No 6/20/2018 001 brown medium tint no distinct odor 3 2 3 No No No 002 brown medium tint no distinct odor 4 2 4 No No No Best Management Practices Stormwater Permit No. NCS000292 The Stormwater Pollution Prevention Best Management Practices (BMP's)utilized at Resinall Corp in Severn,NC are discussed below. (1.)Grass has been maintained along open drainage ditches to help minimize erosion and sedimentation. Periodic inspections of the ditches are made to help detect and eliminate any sedimentation or erosion problems found. (2.) Resinall's Preventative Maintenance System identifies equipment inspection time intervals. A good preventative maintenance system decreases the potential to contaminate stormwater runoff. Daily visual inspections, conducted by shift supervisors will reveal deficiencies, if any, in our preventative maintenance system. If deficiencies are found, improvements can be made immediately. (3.) Good Housekeeping is another best management practice. Employees are trained to maintain a clean work environment. (4.) Resinall's Contingency and Spill Prevention, Control, and Countermeasure Plan(SPCC)contains the spill prevention and response procedures employees need to know, when responding to an emergency that could potentially contaminate stormwater. Employees are trained annually on our SPCC plan. (5.)Training on our Stormwater Pollution Prevention Plan is conducted annually along with our SPCC Plan. (6.)Visual site inspections are conducted on a routine basis by supervisors and management. (7.) Record keeping is another important best management practice. Records are kept for fueling, vehicle maintenance, loading and unloading, liquid storage, inventory levels, and waste management inspections whether they are daily,monthly,or quarterly. (8.)New Donaldson Torit Dust collectors have been installed at Flaker Belt 1 and Flaker Belt 4 to significantly reduce the amount of dust released in the areas. These flaker belt areas are inspected periodically to assure that the pollution control devices are working properly. (9.) Inspections of rework and nonhazardous waste storage areas are performed routinely to assure areas are kept clean and free debris. (10.) Process Wastewater Spray Pond was removed in early 2020, which has reduced the potential for process wastewater to contaminated stormwater as well as reduce potential air emissions from the process wastewater spraying. (11.) Inspections of Southern and Northern Tank farm railcar loading and unloading areas are performed routinely to assure that no spilled material is present that could possibly contaminate stormwater. Improvements were made in 2003 to the material transfer system used for loading and unloading rail cars to eliminate fugitive air emissions. (12.) Inspections of all tank truck loading and unloading areas are performed routinely. (13.)Vehicle fueling stations are inspected daily to assure the area is kept clean and free of spilled material. (14.)When new construction is being conducted, daily inspections are performed in this area to assure there is no construction erosion. Contractors are trained prior to construction work to minimize the chance of construction erosion. �d' ��°°, Via° °°•"° a d° c �/�it c° e",�." a •` r" d' ��` ir I d Cy tpp P°P �. �� �cP rP.P a°9 ° h -iF le X._ t+°Xd' etPed' "d' r°d 6P 19 North Carolina Division of Energy, Mineral, and Land Resources—Stormwater Program Facility Name: Resinancorporation Permit Number: NCS000292 Location Address: 302 N.water street,P.O.Box 195 Sevem,North Carolina 27877 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 accordin 4o permit si nato . requirements) and return this Certification.. g ( g p g ry eq j cation: DO NOT SEND,STORMWATER/POLLUTION PREVENTION PLAN WITH THIS CERTIFICATION:= Signature a 7 "`�� D to October 27,2022 Paul Pearce Plant Manager Print or type name of person signing above Title SPPP Certification 10/13 21+M U S DEPMTMEW OF THE WTERIOR TTke N.1--1 Mey 7.5-A ME TOPO 1 QUA4R�N�u E �r.r.rr u.s-nwslw�c.E sw,vE, t OnOEmsnd Tupo 71+F»UIE Tcsa »so c, m ay a EE a a "• »w, sE 41 A A w y L ' n , 1 1 m . - sa s. e nr-» 1/ M ..mom P, R: m a m a m a a� n•w "' n,w.aerwss+.,susnr os..n xaEe,:7.mo � ...— u..�..���,.�•.��...........ram. .�..�".... .aw.rw+u.� � ].s-Y9RrtE 7O►O t.fK mll p 6 , r ,! 1 ,'�je, 1. .q r-,�T} a" M.•.,r. InJ t VI ,l'' h- _t.�{ �y•.�A r..- 4 'y i 41tZ M - 47. 1. 1� i'• �rti_r ��'. i '�'•� m jai , t �• '•+�' �.l q-�". t y fig[ S• V *• Y.E. S:'!�,z. 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F„ ..a m aTi ,.•..n.. ., a .,,� .,. ,.. •. ^,u .....e.., a a.>., x,...... ,�.. .. v,..,...... ... ,,., .. . .. ......... .. ..an, x, ,...n. ..",:,max . RESINALL - SEVERN T PL4N 302 N❑RTH WATER STRE 1 E SEVERN, NC 27877 I i i / Done Yard \ RECYCLE AREA \ l V e� \.. v2 /� _�-• � sue. - _.._. o ._ t .. / eu t U41— array. t / i NW Corner B- 41 N 36* 31,165' sa, DWG ND, >EVERN ATER STREET SCALE, None DATE 10-2022 '_7 8 7 7 DRAWN' B, Bridgers APPROVED