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NCS000173_Fact sheet binder_20240710
DEQ / DEMLR FACT SHEET FOR NPDES INDUSTRIAL INDIVIDUAL STORMWATER PERMIT DEVELOPMENT Basic Information for Permit Issuance and Renewals: Permit Writer/Date Brianna Young 6/24/2024 Permit Number NCS000173 Owner/Facility Name NC State Ports Authority/Port of Morehead City 4491 /Shipping port SIC(NAICS)Code/Category Per 8/28/2023 email from permittee, code is 4463, however,this is not a valid SIC or NAICS code Basin Name/Sub-basin number White Oak/03-05-03 Receiving Stream/HUC Newport River Restricted Area(Morehead City Harbor)/030203010704(south side) and 030203010406(north side) Stream Classification/Stream Segment SC/21-31 Is the stream impaired on 303 d list]? No Any TMDLs? No Any threatened and/or endangered species? Yes; See Section 2 below Any compliance concerns? See Section 2 below Any permit mods since lastpermit? Yes see Section 1 below New expiration date 1/31/2029 Comments on Draft Permit? See Section 6 below Section 1. Facility Activities and Process: The Port of Morehead City handles the import/export of bulk and breakbulk materials, including rubber, logs, fertilizer, grains, cement, and aggregate. Per the June 2021 permit renewal application, logs are no longer stored, chipped, debarked, or exported, there are no open piles of bulk material stored outside, and if any material is outside or returns in the future, the piles are required to be fully covered except to load the material into trucks. The Port Authority requested modification of their existing permit to add Outfall SW200 to their permit. SW200 was previously covered under Nutrien's stormwater permit(NCS000520). Due to recent changes and additions to the drainage area that will be operated by the Port Authority, the outfall is transferring permits. Sampling Location SW201: Outfall 200 Drainage area consists of part of a phosphate/fertilizer storage building, a dumpster, and piles of scrap wood, stone base, and metal debris. Sampling Location SW301: Outfall 300 Drainage area consists of parking,paved areas, and the NC Marine building. Sampling Location SW402: Outfall 400 Drainage area consists of a warehouse and breakbulk storage. Page 1 of 6 Sampling Location SW506A1: Outfalls 400, 500, 600, 700, 1100, 1200, 1300 Drainage areas consist of an oil/water separator, loading docks, warehouses, bulk storage, crane maintenance, hopper washings, breakbulk storage, paved storage area, the dock, and dock area. Sampling Location SW506B1: Outfalls 400, 500, 600, 700, 1100, 1200, 1300 Drainage areas consist of a 750-gallon diesel AST, outside equipment maintenance and repair, loading docks, warehouses, bulk storage, crane maintenance, hopper washings, breakbulk storage,paved storage area, the dock, and dock area. Sampling Location SW510: Outfalls 1400, 1500, 2700, 2800, 2900, 5500 Drainage areas consist of dock area and pipeline/ship connection pit. Sampling Location SW803: Outfall 800 Drainage area consists of the dock, warehouse storage, dumpsters, ship loader conveyer, two (2) 10,000 gallon diesel ASTs, 1,500 gallon gasoline fuel tank, 500 gallon used oil AST, and equipment maintenance garage. Sampling Location SW907: Outfall 900 Drainage area consists of the woodchip storage area, 550 gallon diesel AST, railcar load out area, asphalt storage tanks, and container and drum storage area. Additional Outfalls: Outfall SW 100: Drainage area consists of the Nutrien area and enclosed storage. This is covered under a separate NPDES permit. Section 2. Proposed Monitoring for Stormwater Discharges: Parameters 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 Port of Morehead City site. Page 2 of 6 Outfall SW201 Quarterly monitoring Total Suspended Solids BASIS: Potential pollutant from drainage area and BMP effectiveness (TSS) indicator. Quarterly monitoring H BASIS: Pollutant indicator and important to interpreting toxicity potential p of metals. Quarterly monitoring Total Rainfall BASIS: Discharge potential indicator Quarterly monitoring Non-Polar Oil &Grease BASIS: Standard monitoring parameter; Potential pollutant from lubricants; Method 1664 SGT-HEM targets petroleum-based O&G Quarterly monitoring Monthly Oil Usage BASIS: Standard monitoring parameter; Potential pollutant from drainage area Quarterly monitoring BOD BASIS: Discharge potential indicator Quarterly monitoring COD BASIS: Discharge potential indicator Quarterly monitoring Total Aluminum BASIS: Potential pollutant from drainage area Quarterly monitoring Total Copper BASIS: Potential pollutant from drainage area Quarterly monitoring Total Zinc BASIS: Potential pollutant from drainage area Quarterly monitoring Tidal conditions BASIS: Outfalls have the potential to be tidally impacted Page 3 of 6 Outfalls SW301, SW402, SW510, and SW907 Quarterly monitoring Total Suspended Solids BASIS: Potential pollutant from drainage area and BMP effectiveness (TSS) indicator. Quarterly monitoring pH BASIS: Pollutant indicator Quarterly monitoring Total Rainfall BASIS: Discharge potential indicator Quarterly monitoring Non-Polar Oil &Grease BASIS: Potential pollutant from lubricants; Method 1664 SGT-HEM targets petroleum-based O&G Quarterly monitoring Monthly Oil Usage BASIS: Potential pollutant from drainage area Quarterly monitoring BOD BASIS: Discharge potential indicator Quarterly monitoring COD BASIS: Discharge potential indicator Tidal Conditions Quarterly monitoring (Describe) BASIS: Outfalls affected by tidal conditions Page 4 of 6 Outfalls SW506A1, SW506111, and SW803 Quarterly monitoring Total Suspended Solids BASIS: Potential pollutant from drainage area and BMP effectiveness (TSS) indicator. Quarterly monitoring pH BASIS: Pollutant indicator Quarterly monitoring Total Rainfall BASIS: Discharge potential indicator Quarterly monitoring Non-Polar Oil &Grease BASIS: Potential pollutant from lubricants; Method 1664 SGT-HEM targets petroleum-based O&G Quarterly monitoring Monthly Oil Usage BASIS: Potential pollutant from drainage area Quarterly monitoring BOD BASIS: Discharge potential indicator Quarterly monitoring COD BASIS: Discharge potential indicator Quarterly monitoring Total Phosphorus BASIS: Potential pollutant from drainage area Tidal Conditions Quarterly monitoring (Describe) BASIS: Outfalls affected by tidal conditions Stormwater Benchmarks and Tiered Response: Rather than limits,North Carolina NPDES Stormwater permits contain benchmark concentrations. Stormwater benchmarks are numerical action levels for stormwater monitoring. Benchmarks are not effluent limits, and benchmark exceedances are not permit violations. Benchmarks provide facilities a tool for assessing the significance of pollutants in stormwater discharges and the effectiveness of best management practices (BMPs). Benchmark concentrations are intended as guidelines for the facility's development and implementation of the Stormwater Pollution Prevention Plan (SWPPP). Benchmark exceedances require the permittee to increase monitoring, increase management actions, increase record keeping, and/or install stormwater BMPs in a tiered program. The permit establishes a tiered approach to specify actions the permittee must take in response to analytical results above benchmark concentrations. The tiered structure of the permit provides the permittee and DEMLR wide flexibility to address issues that may arise with one or more parameters and/or outfalls. Metals benchmarks are calculated to mimic acute water quality standards and with the guidance of DWR. NC DWR follows established federal procedures for calculating acute standards when developing the benchmarks. Just like the acute standards, metals benchmarks normally reflect one half of the Page 5 of 6 calculated Final Acute Value (the "1/2 FAV"). In most cases, translation into total recoverable values is based on an assumed hardness of 25 mg/L and a total suspended solids (TSS) concentration of 10 mg/L. Acute standards protect aquatic life from negative impacts of short-term exposure to higher levels of chemicals where the discharge enters a waterbody. The Stormwater Permitting Program applies this approach because of the ephemeral nature of rainfall events. The Division may evaluate results to determine if a smaller suite of parameters for some outfalls is adequate to characterize potential pollution or BMP effectiveness. For example, one or more metals or other parameters may serve as an adequate tracer for the presence of ash pollution during disturbance or ash removal in specific drainage areas at this site. For parameters that do not have a stormwater benchmark, the Division may develop a benchmark value if appropriate toxicity data become available or if rising trends in concentrations suggest a persistent source. A summary of the benchmarks in the draft permit, and their basis, is below: Parameter Benchmark Basis Total Suspended 100 mg/L National Urban Runoff Program(NURP) Study, 1983 Solids TSS PH 6.8 s.u. —8.5 NC Water Quality Standard(Range) s.u. 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 Aluminum Total 240 /L '/2 FAV Copper Total 6 /L Acute Aquatic Criterion, '/2 FAV Zinc Total 95 /L Acute Aquatic Criterion, '/2 FAV Section 3. Changes from previous permit to modification: • Monitoring for SW200 added per modification request Page 6 of 6 Young, Brianna A From: Todd Walton Sent: Monday,June 24, 2024 1:52 PM To: Young, Brianna A; Clark, Brian E Subject: RE: Port of Morehead City (NCS000173) Brianna, have circled the sampling location in yellow. Please note that the green pipeline was abandoned and plugged 13+yrs ago at the 2 red lines. 5 ; Todd C. Walton NORTH CAROLINA PORTS Senior Environmental Analyst 910-746-6460 Direct 800-336-2405 Toll Free ncpOrtS.com Email to and from this address is public record and may be disclosed to authorized third parties. From:Young, Brianna A<Brianna.Young@deq.nc.gov> Sent: Monday,June 24, 2024 1:38 PM To: Clark, Brian E <brian.clark@ncports.com> Cc:Todd Walton <todd.walton@ncports.com> Subject: Port of Morehead City (NCS000173) Good afternoon, The Division of Energy, Mineral, and Land Resources (DEMLR) Stormwater Permitting Program acknowledges receipt of your modification application for NPDES Permit Number NCS000173. Please continue to comply with all conditions and monitoring requirements in your current NPDES stormwater permit. I do have one question regarding the application. Please identify the sampling location that will be used for Outfall 200 (as was done for all the other outfalls). There appear to be multiple outfalls in the drainage area for Outfall 200. Please let me know if you have any questions in the interim. 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@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. 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. 2 Young, Brianna A From: Young, Brianna A Sent: Monday,June 24, 2024 1:38 PM To: Clark, Brian E Cc: Todd Walton Subject: Port of Morehead City(NCS000173) Good afternoon, The Division of Energy, Mineral, and Land Resources (DEMLR) Stormwater Permitting Program acknowledges receipt of your modification application for NPDES Permit Number NCS000173. Please continue to comply with all conditions and monitoring requirements in your current NPDES stormwater permit. I do have one question regarding the application. Please identify the sampling location that will be used for Outfall 200 (as was done for all the other outfalls). There appear to be multiple outfalls in the drainage area for Outfall 200. Please let me know if you have any questions in the interim. 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) 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. 1 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