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NCS000173_Modification request_20240620
NORTH CAROLINA PORT�� �_� June 11, 2024 Brianna Young Industrial Individual Permits Coordinator Stormwater Permitting Program Division of Energy, Mineral, and Land Resources 1612 Mail Service Center Raleigh,N.C. 27699-1612 Subject: North Carolina State Ports Authority Port of Morehead City, Permit No. NCS000173 Permit modification to add outfall SW200 Dear Ms. Young, The North Carolina State Ports Authority (NCSPA) is requesting a modification to add outfall SW 200 NPDES to the NCSPA current NPDES permit NCS000173, exp January 31, 2029. Please find enclosed the EPA form 2F and a site map of the facility with the location and drainage area of outfall SW200 noted. If any additional information is needed, please call me at(910) 746-6460. Sincerely, NORTH CAROLINA STATE PORT AUTHORITY "'Z�e--- C_ '�Jw Todd C. Walton Sr. Environmental Analyst Cc: environmental files North Carolina State Ports Authority - 2202 Burnett Bauleuard - PO Box 0002 • Wilmington,NC 28402 - www.ncpnrts.com EPA Identification Number NPDES Permit Number Facility Name OMB No.2040-0004 NGS oo0/73 [• Expires071311202G Form U.S Environmental Protection Agency 2F SAAW EP '� Application for NPDES Permit to Discharge Wastewater NPDES r/`i STORMWATER DISCHARGES ASSOCIATED WITH INDUSTRIAL.ACTIVITY SECTIONOUTFALL LOCATIONY 1.1 Provide information on each of the facilii 's outfalls in the table below Outfall Receiving Water Name Latitude Longitude Number Zo9i�j;- 0 U O J R 7 O SECTION 2. "IMPROVEMENTSY 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 ❑ No 4 SKIP to Section 3. 2_2 Briefly identify each applicable project in the table below. Final Compliance Brief Identification and Affected Outfalls Source(s)of Discharge Dates Description of Project (list eutrall numbers) Required Projected c a) E d 0 a E 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 Page 1 EPA Identification Number NPDES Permit Number Facility Name OMB No.2040-0004 Expires 07/3112026 SECTION 3.SITE 1 ' l a) 1-1 Have you attached a site drainage map containing all required information to this application?(See instructions for cn E 0 specific guidance.) N 'Ca � o Yes SECTION 4. •O i 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 facility) (within a mile radius of the facility) specify units specify units �j t l L no 3 .5 I*C"S �?-s /ICIAis specify units specify units specify units specify units specify units specify units specify units specify units specify uniis specify units 44.2 Provide a narrative description of the facility's significant material in the space below.(See instructions for content requirements.) Tfwgg, Af c nru v,,/.rrf+t s7ca,FJ ®v%s:/sr �i f�•'s � A•t¢�j, � W R2 f i7 d u1 F ��� f 7 0R EJ tt2�•!.�fa. Nt/��/�f' m ro C 2 d 4_3 Provide the location and a description of existing structural and non-structural control measures to reduce pollutants in stormwater runoff. See instructions forspecificguidance,) Stormwater Treatment Codes Outfall from Number Control Measures and Treatment Exhibit 2F-1 list 3cw fec, $P 3 ,041fA1 ;N tACf ,# 78® *,vva c riisv t4 _,is EPA Form 3510-2F Page 2 EPA Identification Number NPDES Permit Number Facility Name OMB No.2040-0004 Expires 07131/2026 SECTION •N STORMWATER 1 1 5-1 Provide the following certification.(See instructions to determine the appropriate person to sign the application.) I 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, I 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 Signature Date signed w Cn 552 Provide the testing information requested in the table below. 44) n Outfall Onsite Drainage Points a Number Description of Testing Method Used Date(s)of Testing Directly Observed Dudng Test 3 E `o in -- 0 z SECTION , SIGNIFICANT LEAKS •` 1 1 Describe any significant leaks or spills of toxic or hazardous pollutants in the last three years. 'a a /vDNL' J G f0 U W SECTION 7.DISCHARGE INFORMATIONI 7o See the instructions to determine the pollutants and parameters you are required to monitor and,in turn,the tables you must o com lets.Not all applicants need to complete each table. 7 1 Is this a new source or new discharge? ❑ Yes 4 See instructions regarding submission of No-+ See instructions regarding submission of estimated data. actual data. E p Tables A,B,C,and D CU 7_2 Have you completed Table A for each outfall? ❑ Yes EPA Form 3510-2F Page 3 EPA Identification Number NPDES Permit Number Facility Name OMB No.2040-0004 Expires 0713112026 773 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. 774 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 7_5 Do you know or have reason to believe any pollutants in Exhibit 2F--2 are present in the discharge? ❑ Yes (R No 4 SKIP to Item 7.7. 7_6 Have you listed all pollutants in Exhibit 2F-2 that you know or have reason to believe are present in the discharge and provided quantitative data or an explanation for those pollutants in Table C? ❑ Yes 7.7 Do you qualify for a small business exemption under the criteria specified in the Instructions? ❑ Yes 4SKIP to Item 7.18. [T No 7_8 Do you know or have reason to believe any pollutants in Exhibit 2F-3 are present in the discharge? ❑ Yes No 4 SKIP to Item 7.10. 0 o7_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? c ❑ Yes M 7.10 Do you expect any of the pollutants in Exhibit 2F-3 to be discharged in concentrations of 10 ppb or greater? o ❑ Yes © No 3 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? ❑ Yes 7.12 Do you expect acrolein,acryionitrile,2,4-dinitrophenol, or 2-methyl-4,6-dinitrophenol to be discharged in concentrations of 100 ppb or greater? ❑ Yes .9 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 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 7.15 Do you know or have reason to believe any pollutants in Exhibit 2F-4 are present in the discharge? ❑ Yes F'] No 4 SKIP to Item 7.17. EPA Form 3510-2F Page 4 EPA Identification Number NPDES Permit Number Facility Name OMB No.2040-0004 Expires 07131 12026 7.16 Have you listed pollutants in Exhibit 217-4 that you know or believe to be present in the discharge and provided an explanation in Table C? ❑ Yes 7.17 Have you provided information for the storm event(s)sampled in Table D? C c ❑ Yes 0 CU o Used or Manufactured Toxics 7.18 Is any pollutant listed on Exhibits 2F-2 through 2F-4 a substance or a component of a substance used or o manufactured as an intermediate or final product or byproduct? ❑ Yes ❑ No-+ SKIP to Section 8. En s 7.19 List the pollutants below,including TCDD if applicable.Attach additional sheets,if necessary. 'R 1. 4. 7, 2. 5. 8. 1 6. 9. SECTION 8.BIOLOGICAL TOXICITY TESTING DATA(40 CFR 122.21(G)(1 1)) 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 ❑ Yes ❑ No 4 SKIP to Section 9. rn I CD 88.2 Identify the tests and their purposes below. Test(s) Purpose of Test(s) Submitted to NPDES Date Submitted X Permitting Authority? `- ❑ Yes ❑ No U_ 0' 0 ❑ Yes ❑ No o _ an ❑ Yes ❑ No SECTI•N 9.CONTRACT • - • l 9_1 Were any of the analyses reported in Section 7(in Tables A through C)performed by a contract laboratory or consulting firm? ❑ Yes ❑ No 4 SKIP to Section 10. 92 Provide information for each contract laboratory or consulting firm below. 0 Laboratory Number 1 Laboratory Number 2 Laboratory Number 3 E o Name of laboratory/firm a N Laboratory address a Y U (O 0 Phone number U Pollutant(s)analyzed EPA Form 3510-2F Page 5 EPA Identification Number NPDES Permit Number Facility Name OMB No.2040-0004 Expires 07/3112026 SECTION { CHECKLIST AND CERTIFICATION STATEMENT(40 1 • 10.1 In Column 1 below,mark the sections of Form 2F that you have completed and are submitting with your application. For each section, specify in Column 2 any attachments that you are enclosing to alert the permitting authority. Note that not all applicants are required to complete all sections or provide attachments. Column 1 Column 2 Section 1 ❑ wl attachments(e.g,,responses for additional outfalls) ❑ Section 2 ❑ wl attachments ® Section 3 wl site drainage map C�b Section 4 ❑ wl attachments ❑ Section 5 ❑ wl attachments © Section 6 ❑ wl attachments l❑ Section 7 ❑ Table A ❑ wl small business exemption request a ❑ Table B ❑ wl analytical results as an attachment Cn R ❑ Table C ❑ Table D U El Section 8 ❑ wl attachments U R ❑ Section 9 ❑ wl attachments(e.g.,responses for additional contact laboratories or firms) Section 10 a, i 10•2 Provide the following certification.(See instructions to determine the appropriate person to sign the application.) Certification Statement l 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 Signature Date signed �11712-o 2,1 EPA Form 3510-2F Page 6 Alutrien- Feeding the Future CERTIFIED MAIL June 7, 2024 Attn: Brianna Young Division of Energy, Mineral and Land Resources Stormwater Permitting Program 1612 Mail Service Center Raleigh,NC 27699-1612 Subject: NPDES Permit No.NCS000520 PCS Phosphate Company,Inc. Morehead City Port Terminal Permit Renewal Dear Ms. Young, In response to above referenced draft permit, issued on April 30, 2024 for the PCS Morehead City Port Terminal Facility, please see the comments referenced in the attached copy of the draft permit(w/highlights): 1. Outfall Labeling: ■ Page 15 The permit states:"Table 1. Summary of Quarterly Baseline Sampling Requirements for Stormwater Discharges for Outfalls SW001 and SW002." ■ Page 16 The outfalls are labeled"Outfall SW 100 and Outfall SW200." The outfalls should be labeled Outfall SW100 and Outfall SW200,as detailed in the previous permits. 2. Benchmarks for pH Monitoring Page 15 -The Benchmark for pH is currently listed as 6.8 s.u.—8.5 s.u. In the footnotes there is a statement"instead of 6 SU." Should the footnote also read 6.8 SU.? 3. After discussion and agreement with the North Carolina Port Authority(NCPA),NCPA intends to submit a permit modification to add the referenced outfall to their facility permit within 90 days of this letter being submitted. Outfall SW200 should be removed from this permit and incorporated in the NCPA stormwater permit. 1530 NC Hwy 306 South,Aurora,NC USA 27806 nutrien.com 1 Effective January 1,2018,PCS Phosphate Company,Inc.is an indirect subsidiary of Nutrien Ltd.PCS Phosphate Company,Inc. remains the legal operating entity and permittee. �lutrien- Feeding the Future- Thank you for allowing us to provide comments on this draft. If you have additional questions or I can provide any additional clarification, please do not hesitate to contact me at(252)402-6044. Sincerely, James handler Stroud J Supervisor, Environmental Affairs and Technical Services Nutrien—Aurora PC: File ec: Brian Lambe,DEMLR Doug Vogt,NCPA K.A. Alnandy B.R. Curtis D.D. Winstead 1530 NC Ftwy 306 South,Aurora,NC USA 27806 nutrien.cOm t Effective January 1,2019,PC5 Phosphate Company,Inc.is an Indirect subsidiary of Nutrien Ltd.PCS Phosphate Company,Inc. remains the legal operating entity and permittee. Draft Permit Pages 15 & 16 NCS000520 -O�z�A�s SGJ,lGY� DNA S1n124� - Permit NCS000520 Table 1. Summary of Quarterly Baseline Sampling Requirements for Stormwater Discharges for OutfWb SW00117and SWO02 Parameter Code for Parameter Frequency' Benchmark Reporting C0530 Total Suspended Solids(TSS) Quarterly 100 mg/L 00400 pIf,2 Quarterly 6.8 s.u.—8.5 s.u. 46529 Total Rainfall of Sampled Event Quarterly - (inches) Non-Polar Oil&Grease for drainage 00552 areas that use>55 gallons/month of Quarterly 15 mg/L oil on average per EPA Method 1664 (SGT-HEM) Estimated Average Monthly Oil NCOIL Usage at the Facility(gallons) Quarterly - 00094 Conductivity Quarterly - C0310 Biochemical Oxygen Demand Quarterly - (BODs) 00340 Chemical Oxygen Demand(COD) Quarterly - C0600 Total Nitrogen Quarterly - C0665 Total Phosphorus Quarterly - C0610 Ammonia Nitrogen Quarterly - 01105 Total Aluminum Quarterly 240 µg/L 01042 Total Copper Quarterly 6 µg/L 01092 Total Zinc Quarterly 95 µg/L - Tidal conditions s Quarterly - Footnotes: 1. Measurement frequency:Quarterly during a measurable storm event.If the facility is monitoring monthly due to Tier Two or Tier Three response actions,the facility shall continue a monthly monitoring and reporting schedule in Tier Two or Tier Three status until relief is granted. 2. If pH values outside this range are recorded in sampled stormwater discharges,but ambient precipitation pH levels are lower,then the lower threshold of this benchmark range is the pH of the precipitation (within instrument accuracy)instead of 6 s.u:.Readings from an on-site or local rain gauge(or local precipitation data)must be documented to demonstrate background concentrations were below the benchmark pH range. 3. For each sampled measurable storm event,the total precipitation must be recorded.An on-site rain gauge is required.Where isolated sites are unmanned for extended periods of time,a local rain gauge reading may be substitute for an on-site reading. Page 15 of 37 Permit NCS000520 4. The permittee shall document tidal influences at that time of the sample to record whether samples were taken at high or low tide conditions(or a more average condition in between). • Outfall-SW100, Drainage area consists of phosphate storage buildings and conveyor belts. • Qutfall SW200r Drainage area consists of a phosphate storage building,a dumpster,and piles of scrap wood, stone base,and metal debris. Should the permittee identify or create any new stormwater outfalls,remove any stormwater outfalls identified in this permit,or alter any drainage areas that change the potential pollutants in runoff discharged through corresponding outfalls,the permittee will submit a request to NC DEMLR to modify this permit.For any newly discovered pipes or outfalls,the permittee must evaluate the structure and provide a report of the status and planned actions to NC DEQ within 14 days.The permittee must either (1)request modification of this permit and modify the SWPPP accordingly,or(2)eliminate potential discharges by removal,plugging,or combination of both. D-3. Methodology for Collecting Samples [40 CFR 122.416); 15A NCAC 02H.0143(a)(22)J (a) Outfall monitoring efforts shall begin with the first measurable storm event that occurs during the facility's normal operating hours and begins at least 72 hours after the previous measurable storm event. (b) Grab samples shall be collected within the first 30 minutes of discharge. If physical separation between outfalls prevents collecting samples from all outfalls within the first 30 minutes of discharge, then the permittee may continue collecting samples until all outfalls that are discharging have been sampled. (c) Outfalls that are not discharging during or after the first measurable storm event shall be sampled during the next measurable storm event,until a sample has been collected from every outfall. (d) If,during an entire monitoring period,there is no discharge from an outfall during any measurable storm event that occurs during the facility's normal operating hours and begins at least 72 hours after the previous measurable storm event,then the permittee shall report"No Discharge"in the DMR and shall record"No Discharge"in the SWPPP.In this case,the DMR shall be submitted within 30 days after the end of the monitoring period.Lack of a discharge from an outfall for the monitoring period shall not constitute failure to monitor as long as this condition is met. (e) Sampling is not required to be performed outside of the facility's normal operating hours or during adverse weather conditions. (f) Samples collected shall be characteristic of the volume and nature of the permitted discharge. (g) If the sampled storm event coincides with a known non-stormwater discharge that is deemed permitted under 15A NCAC 02H .0106,then this shall be noted on the stormwater discharge monitoring report. D4. Locations for Collecting Samples [40 CFR 122.416); 15A NCAC 02H.0143(a)(22)J Samples shall be collected at all stormwater discharge outfalls(SDOs)that discharge stormwater associated with industrial activity.If the Division has issued a representative outfall status(ROS) approval letter,then the permittee shall collect samples from all SDOs in accordance with the ROS approval letter. Page 16 of 37