NCG180000_Final Factsheet_20240529

DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF ENERGY, MINERAL,AND LAND RESOURCES
FACT SHEET
GENERAL PERMIT NCG180000
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
PERMIT TO DISCHARGE STORMWATER
Permit No. NCG180000 Date: June 1, 2024
1. TYPES OF DISCHARGES COVERED
a. Industrial Activities Covered by this General Permit
Coverage under this general permit is applicable to All owners or operators of
stormwater point source discharges associated with establishments primarily engaged
in the manufacture of Furniture and Fixtures [ Standard Industrial Classification SIC)
Major Group 25] and Wood Kitchen Cabinets [Standard Industrial Classification (SIC)
2434];
Coverage is also applicable to point source discharges from like industrial activities
deemed by the Division of Energy, Mineral, and Land Resources (DEMLR) to be similar
to these operations in the process, or the discharges, or the exposure of raw materials,
intermediate products, by-products, products, or waste products.
b. Types of Operations Covered
Major Group 25: Furniture and Fixtures
This major group includes establishments engaged in manufacturing household, office,
public building, and restaurant furniture, and office and store fixtures. Establishments
primarily engaged in the production of millwork are classified in Industry 2431; those
manufacturing wood kitchen cabinets are classified in Industry 2434; those
manufacturing cut stone and concrete furniture are classified in Major Group 32; those
manufacturing laboratory and hospital furniture, except hospital beds, are classified in
Major Group 39; and those engaged in woodworking to individual order or in the
nature of reconditioning and report are classified in nonmanufacturing industries.
2434 Wood Kitchen Cabinets
Establishments primarily engaged in manufacturing wood kitchen cabinets and wood
bathroom vanities, generally for permanent installation. Establishments primarily
engaged in manufacturing free-standing cabinets and vanities are classified in Major
Group 25. Establishments primarily engaged in building custom cabinets for individuals
are classified in Retail Trade, Industry 5712.
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NCG180000 Fact Sheet-NC DEQ June 1,2024
c. Characteristics of Discharged Stormwater
Except for facilities where vehicle maintenance triggered analytical monitoring
requirements,the draft renewal permit maintains the requirement for analytical and
qualitative monitoring of all stormwater discharges associated with industrial activity.
The draft renewal permit also maintains that Non-Polar Oil &Grease be monitored at
stormwater discharges from on-site vehicle and equipment maintenance activities (VMA)
in which more than 55 Gallons of motor oil and/or hydraulic oil is used per month. This
parameter continues to be useful as the standard stormwater pollution indicator for
VMA from this industrial sector.
d. GeographicArea(s) Covered by this General Permit
Discharges covered by this general permit are located at any place within the political
boundary of the State of North Carolina. Discharges located on the Cherokee Indian
Tribal Reservation are subject to permitting by the U.S. Environmental Protection
Agency and are not covered by this general permit.
e. Receiving Waters
Receiving waters include all surface waters of North Carolina or municipal separate
storm sewer systems conveying stormwater to surface waters.
2. MONITORING REQUIREMENTS
This permit specifies monitoring and reporting requirements for both quantitative and
qualitative assessment of the stormwater discharges and operational inspections of the
entire facility. Pollutant parameters and sampling frequency are based on the industrial
activity performed at subject facilities, and on the potential for contamination of the
stormwater runoff from those facilities. Qualitative parameters are consistent with other
general permits in the NPDES stormwater program.
The draft renewal permit maintains specific monitoring requirements for the following
parameters for stormwater discharges from vehicle and equipment maintenance
areas: Total Rainfall, Non-polar Oil and Grease ("Non-polar O&G") [by EPA Method
1664 (SGT-HEM)], and Total Suspended Solids (TSS), based on the amount of average oil
usage (more than 55 gallons of new motor oil and/or hydraulic oil per month when
averaged over the calendar year). The rationale for retaining these parameters in the
renewal permit is their utility as stormwater pollution indicators for such maintenance
areas.
The renewal permit maintains benchmark concentrations for stormwater discharges from
industrial site activities to provide facilities with a tool with which to assess the
effectiveness of best management practices (BMPs). These benchmark concentrations are
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NCG180000 Fact Sheet-NC DEQ June 1,2024
not effluent limits but provide guidelines for the facility's Stormwater Pollution Prevention
Plan (SWPPP). Exceedances of benchmark values require the permittee to increase
monitoring, increase management actions, increase record keeping, and/or install
stormwater BMPs in a tiered program. Four (4) benchmark exceedances within the 5-year
permit cycle trigger notification to the Regional Office and prompts Tier Three status. This
renewal adds language to the Action Plan required as part of Tier Three status.
Total Rainfall (inches) will continue to be monitored. The total rainfall amount for each
sampling event shall be recorded in inches. Total rainfall shall be determined from an on-
site rain gauge or a regional rain gauge located within one (1) mile of the facility.
If required by a change in state or federal law, Per-and polyfluoroalkyl substances (PFAS) will
be added as a potential required monitoring parameter if deemed by the Director on a case-by-
case basis.
Monitoring frequency has increased from two to four times a year. Seasonal and weather
changes may impact the facility and its discharge. More frequent monitoring will better
represent the discharge throughout the entire year. Samples shall be collected four
separate monitoring periods per year. A minimum of thirty (30) days must separate
sampling events:
January 1 —March 31
April 1 —June 30
July 1 — September 30.
October 1 —December 31
Some parts of the Stormwater Pollution Prevention Plan (SPPP) have been expanded or
modified. Please refer to the proposed draft General Permit NCG180000 for those
requirements.
3. REPORTING REQUIREMENTS
a. Deadlines for Submitting Discharge Monitoring Reports
If the facility's vehicle maintenance triggers analytical monitoring requirements,
discharge Monitoring Reports (DMRs) shall be submitted in accordance with following
table. For COCs issued between March 1-31, June 1-30, September 1-30 or Dec 1-31,
sampling shall not commence until the next sampling period following initial issuance
of the COC.
b. Submittal Process before eDMR
Prior to eDMR, samples analyzed in accordance with the terms of General Permit shall
be reported as follows:
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NCG180000 Fact Sheet-NC DEQ June 1,2024
Sample results shall be recorded on Discharge Monitoring Report (DMR) forms that are
available on Division's website: https:[/deq.nc.gov/about/divisions/energy-mineral-land-
resources/npdes-industrial-stormwater.
DMRs shall be signed and certified by a person meeting the Signatory requirements.
Original, signed DMR forms shall be scanned and uploaded to the electronic DMR submittal
form,which can be found by typing"deq.nc.gov/SW-Industrial" into a browser window and
hitting"enter."Original signed DMR Forms shall be mailed or otherwise delivered to the
appropriate Regional Office, which is indicated at: https:[/deq.nc.gov/contact/regional-
offices .
c. Submittal Process after eDMR
If the facility's vehicle maintenance triggers analytical monitoring requirements,
permittees shall register for eDMR within 30 days of the Certificate of Coverage issuance
date and shall begin reporting discharge monitoring data. Information about eDMR can
be found by typing"https:,[/deq.nc.govldeq.nc.govlsw-edmr" into a browser window
and hitting"enter"
d. Qualitative Monitoring Reports
The permittee shall record the required qualitative monitoring observations on the
SDO Qualitative Monitoring Report form provided by the Division and shall retain the
completed forms on site. Qualitative monitoring results shall not be submitted to
the Division, except upon the Division's specific requirement to do so. Qualitative
Monitoring Report forms are available the Division's website
(https://deq.nc.gov/about/divisions/energy-mineral-land-resources/npdes-
stormwater-gns).
As before, the renewal permit specifies qualitative (visual) monitoring of each stormwater
outfall for the purpose of evaluating the effectiveness of the Stormwater Pollution
Prevention Plan (SPPP) and assessing new sources of stormwater pollution. Qualitative
monitoring parameters include color, odor, clarity, floating and suspended solids, foam, oil
sheen, and other obvious indicators of stormwater pollution. Qualitative monitoring
should be performed during any analytic sampling event.
The draft permit maintains specific direction to the permittee about how to respond to
qualitative monitoring. If qualitative monitoring indicates that existing stormwater BMPs
are ineffective, or that significant stormwater contamination is present, the permittee must
investigate potential causes, evaluate the feasibility of corrective actions, and implement
those corrective actions within 60 days. A written record of the permittee's investigation,
evaluation, and response actions must be kept in the SPPP. The Qualitative Monitoring
Response establishes actions for when a permittee repeatedly fails to respond effectively
to correct problems, or if the discharge causes or contributes to a water quality standard
violation.
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NCG180000 Fact Sheet-NC DEQ June 1,2024
e. Analytical Monitoring
The draft renewal permit proposes specific monitoring requirements for the following
parameters for all stormwater discharges associated with industrial activity: Total
Rainfall and Average Monthly Oil Usage.
Permittees shall monitor for Non-polar Oil and Grease ("Non-polar 0&G") [by EPA
Method 1664 (SGT-HEM) if the facility uses more than 55 gallons of new motor oil and/or
hydraulic oil per month when averaged over the calendar year. The rationale for
maintaining this parameter in the renewal permit is its utility as stormwater pollution
indicators for vehicle maintenance areas.
The renewal permit maintains benchmark concentrations for stormwater discharges from
industrial site activities to provide facilities with a tool with which to assess the
effectiveness of best management practices (BMPs). These benchmark concentrations are
not effluent limits but provide guidelines for the facility's Stormwater Pollution Prevention
Plan (SWPPP). Exceedances of benchmark values require the permittee to increase
monitoring, increase management actions, increase record keeping, and/or install
stormwater BMPs in a tiered program. Four (4) benchmark exceedances trigger
notification to the Regional Office and may prompt additional requirements (Tier Three).
The Environmental Protection Agency (EPA) 2021 Multi Sector General Permit (MSGP)
incorporates recommendations from a National Academies of Sciences, Engineering, and
Medicine (NAS) National Research Council (NRC) study. Some of these recommendations
have been included in this draft permit. Specifically, Total Suspended Solids (TSS) is
recommended as a basic indicator of Stormwater Control Measure (SCM) effectiveness.
4. COMPLIANCE SCHEDULE
The compliance schedule in Part I, Section 1 still advises that the permittee comply with
Limitations and Controls specified for stormwater discharges in accordance with the
following schedule:
Existing Facilities already operating but applying for permit coverage for the
first time: The Stormwater Pollution Prevention Plan shall be developed and
implemented within 12 months of the effective date of the Certificate of Coverage
and updated thereafter on an annual basis. Secondary containment, as specified in
Part B-7 of this general permit, shall be accomplished within 12 months of the
effective date of the issuance of the Certificate of Coverage.
New Facilities applying for coverage for the first time: The Stormwater
Pollution Prevention Plan shall be developed and implemented prior to the
beginning of discharges from the operation of the industrial activity and be updated
thereafter on an annual basis. Secondary containment, as specified in Part B of this
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NCG180000 Fact Sheet-NC DEQ June 1,2024
general permit shall be accomplished prior to the beginning of discharges from the
operation of the industrial activity.
Existing facilities previously permitted and applying for renewal under this
General Permit: All requirements, conditions, limitations, and controls contained
in this permit (except new SPPP elements in this permit renewal) shall become
effective immediately upon issuance of the Certificate of Coverage. New elements
of the Stormwater Pollution Prevention Plan for this permit renewal shall be
developed and implemented within 6 months of the effective date of this general
permit and updated thereafter on an annual basis. Secondary containment, as
specified in Part B of this general permit shall be accomplished prior to the
beginning of discharges from the operation of the industrial activity
S. SPECIAL CONDITIONS WHICH WILL HAVE A SIGNIFICANT IMPACT ON THE
DISCHARGE
This draft general permit does not propose any special conditions that will have a
significant impact on the discharge. However, the proposed draft does add Special
Conditions in Part F.that address electronic reporting requirements mandated by the
federal NPDES Electronic Reporting Rule. The permittee must report discharge
monitoring data electronically using the Electronic Discharge Monitoring Report
(eDMR) internet application. Permittees must register within 30 days of permit
issuance.
6. BASIS FOR CONTROLS AND LIMITATIONS
a. Stormwater Discharges
The conditions of this general permit have been designed using best professional
judgment to achieve water quality protection through compliance with the
technology-based standards of the Clean Water Act (Best Available Technology
[BAT] and Best Conventional Pollutant Control Technology [BCT]). Where the
Director determines that a water quality violation is occurring and water quality-
based controls or effluent limitations are required to protect the receiving waters,
coverage under the general permit shall be terminated and an individual permit will
be required. Based on a consideration of the appropriate factors for BAT and BCT
requirements, and a consideration of the factors discussed below in this fact sheet
for controlling pollutants in stormwater discharges associated with the activities as
described in Item 1 (Types of Discharge Covered), this permit retains a set of
requirements for developing and implementing stormwater pollution prevention
plans, and specific requirements for monitoring and reporting on stormwater
discharges.
The permit conditions reflect the Environmental Protection Agency's (EPA) and
North Carolina's pollution prevention approach to stormwater permitting. The
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NCG180000 Fact Sheet-NC DEQ June 1,2024
quality of the stormwater discharge associated with an industrial activity will
depend on the availability of pollutant sources. This renewal permit still reflects the
Division's position that implementation of Best Management Practices (BMPs) and
traditional stormwater management practices which control the source of
pollutants meets the definition of BAT and BCT. The permit conditions are not
numeric effluent limitations, but rather are designed to be flexible requirements for
developing and implementing site specific plans to minimize and control pollutants
in the stormwater discharges associated with the industrial activity.
Title 40 Code of Federal Regulations (CFR) Part 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 of the renewal permit
are retained under the authority of both of these regulatory provisions. The
pollution prevention requirements (BMP requirements) in this permit operate as
limitations on effluent discharges that reflect the application of BAT/BCT. The basis
is that the BMPs identified require the use of source control technologies which, in
the context of these general permits, are the best available of the technologies
economically achievable (or the equivalent BCT finding).
All facilities covered by this general permit must prepare, retain, implement, and (at
a minimum of annually) update a Stormwater Pollution Prevention Plan (SPPP).
The term "pollution prevention" distinguishes this source reduction approach from
traditional pollution control measures that typically rely on end-of-pipe treatment
to remove pollutants in the discharges. The plan requirements are based primarily
on traditional stormwater management, pollution prevention and BMP concepts,
providing a flexible basis for developing site-specific measures to minimize and
control the amounts of pollutants that would otherwise contaminate the
stormwater runoff.
The pollution prevention approach adopted in the SPPP in this renewal permit still
focuses on two major objectives: 1) to identify sources of pollution potentially
affecting the quality of stormwater discharges associated with industrial activity
from the facility; and 2) to describe and ensure that practices are implemented to
minimize and control pollutants in stormwater discharges associated with
industrial activity from the facility and to ensure compliance with the terms and
conditions of the permit.
The Division believes that it is not appropriate at this time to require a single set of
effluent limitations or a single design or operational standard for all facilities which
discharge stormwater associated with industrial activity. This permit instead
establishes a framework for the development and implementation of a site-specific
SPPP. This framework provides the necessary flexibility to address the variable risk
for pollutants in stormwater discharges associated with the industrial activities that
are addressed by this permit,while ensuring procedures to prevent stormwater
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NCG180000 Fact Sheet-NC DEQ June 1,2024
pollution at a given facility are appropriate given the processes employed,
engineering aspects, functions, costs of controls, location, and age of facility (as
discussed in 40 CFR 125.3). This approach allows flexibility to establish controls
which can appropriately address different sources of pollutants at different
facilities.
There has been no significant change to this rationale since the previous General
Permit NCG180000.
Stormwater Benchmarks
The "Non-polar O&G" [by EPA Method 1664 (SGT-HEM)] benchmark of 15.0 mg/1 is
consistent with other States' benchmarks and/or limits for total petroleum hydrocarbons
(TPH) and reflects a value normally only associated with significant oil contamination.
Specifying the EPA Method 1664 with the silica gel treatment step (SGT-HEM) in the permit
ensures a cost effective way to estimate TPH (as opposed to gas chromatographic analysis).
The standard total suspended solids (TSS) benchmark of 100 mg/1 is based on the
median concentration derived from the National Urban Runoff Program (NURP) study in
1983 and serves as a benchmark in most other industrial stormwater permits with TSS
monitoring. The lower TSS benchmark for ORW, HQW, trout, and primary nursery area
(PNA) waters of 50 mg/1 reflects half that standard value and was set to flag potential
problems in discharges to waters with much lower water quality standards for TSS
concentrations (20 mg/1 for HQW and ORW; 10 mg/1 for trout and PNA waters).
7. REQUESTED VARIANCES OR ALTERNATIVES TO REQUIRED STANDARDS
There are no requested variances or alternatives to required standards. Facilities
requesting variances to required standards will not be covered under this General Permit
but will instead be required to seek coverage under an individual permit.
8. THE ADMINISTRATIVE RECORD
The public notice, containing the NCG16 draft renewal permit and fact sheet are available
at the NC Stormwater Program's Public Notice web site:
https:[/deq.nc.gov/about/divisions/energy-mineral-and-land-
resources/stormwater/stormwater-program/stormwater-public.
In addition,the historical record on the NCG16 permit is available at the Stormwater
Program Laserfiche Repository,which can be found at:
https:[/edocs.deq.nc.gov/WaterResources1Browse.aspx?id=280110&dbid=0&repo=Water
Resources.
9. STATE CONTACT
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NCG180000 Fact Sheet-NC DEQ June 1,2024
Additional information about the draft permit may be obtained at the above address
between the hours of 8:00 AM and 5:00 PM Monday through Friday by contacting:
Brittany Cook at [phone].
10. SCHEDULE OF PERMIT ISSUANCE
Draft Permit Public Notice - Statewide Notice to publish April 15, 2024;
Draft available online by April 15, 2024;
Comment Period Ended May 15, 2024
Permit Scheduled to Issue - No later than May 31, 2024;
Effective June 1, 2024
11. PROCEDURE FOR THE FORMULATION OF FINAL DETERMINATIONS
a. Comment Period
The Division of Energy, Mineral, and Land Resources proposes to issue an NPDES
General Permit for the above described stormwater discharges subject to the outlined
effluent limitations, management practices, and special conditions. These
determinations are open to comment from the public.
Interested persons are invited to submit written comments on the permit applications
or on the Division of Energy, Mineral, and Land Resources' proposed determinations to
the following address:
Stormwater Program
Division of Energy, Mineral, and Land Resources
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
Attn: Brittany Cook
All comments received within thirty (30) days following the date of public notice are
considered in the formulation of final determinations.
b. Public Meeting
The Director of the Division of Energy, Mineral, and Land Resources may hold a public
meeting if there is a significant degree of public interest in a proposed permit or group
of permits. Public notice of such a meeting will be circulated in newspapers in the
geographical area of the discharge and to those on the Division of Energy, Mineral, and
Land Resources' mailing list at least thirty (30) days prior to the meeting.
c. Appeal Hearing
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NCG180000 Fact Sheet-NC DEQ June 1,2024
An applicant whose permit is denied, or is granted subject to conditions he deems
unacceptable, shall have the right to a hearing before the Commission upon making
written demand to the Office of Administrative Hearing (OAH) within 30 days following
issuance or denial of the permit.
d. Issuance of a Permit When no Hearing is Held
If no public meeting or appeal hearing is held, after review of the comments received,
and if the Division of Energy, Mineral, and Land Resources determinations are
substantially unchanged, the permit will be issued and become effective on the first day
of the month following the issuance date. This will be the final action of the Division of
Energy, Mineral, and Land Resources.
If a public meeting or appeal hearing is not held, but there have been substantial
changes, public notice of the Division of Energy, Mineral, and Land Resources revised
determinations will be made. Following a 30-day comment period, the permit will be
issued and will become effective on the first day of the month following the issuance
date. This will be the final action of the Division of Energy, Mineral, and Land Resources
unless a public meeting or appeal hearing is granted.
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