NCG030103_Tier-Relief_RRO-Response

Energy, Mineral
and Land Resources
ENVIRONMENTAL QUALITY
December 19, 2017
Moen Incorporated
Attn: Ms. Zina Briner
Environmental Coordinator
2609 Cox Mill Road
Sanford, NC 27330
SUBJECT: NPDES Stormwater Permit: Request for Regulatory Relief
Moen Inc. -Sanford Plant
General Permit No: NCG030000; COC No: NCG030103
Lee County
Dear Ms. Briner:
ROY COOPER
Gove..or
MICHAEL S. REGAN
Secretary
TOBY VINSON
Interim Director
In response to your request for Regulatory Relief, NCDENR-Land Quality Section staff
conducted a site inspection on December 13, 2017. The primary goal of the inspection
was to evaluate the drainage to outfalls SDO1-SD04 and to ensure that there are no
illicit discharges at your facility. At the time of this inspection the facility was found to be
in compliance with permit NCG030103 with the exception of one possible illicit
discharge originating from the Chip Containment system loading area. The containment
and separation system located at the covered loading area is a potential source for
contamination to the stormwater system.
Monthly monitoring has been triggered by consistent exceedances of the zinc and
copper benchmarks since 2014 at your facility. Please keep in mind that benchmark
exceedances are NOT limit violations or violations of permit conditions; however, you
are obligated to follow the tiered response actions outlined in your permit. Moen
Incorporated has been following the tiered response actions and therefore is in
compliance with the permit.
Based on your materials inventory and certification that industrial activities at Moen
Incorporated does pose potential for release of copper and zinc into stormwater we are
requesting that further investigation of the containment and separation system at the
Chip Containment system loading area be undertaken. This will ensure that all
precautions are being taken to prevent the contamination of stormwater from copper
and zinc at this location. This office requests that the containment and separation
system design be reviewed and that field measurements be taken to ensure that the
system is functioning as designed and that additional measures cannot be taken to
Nothing Compares_
Slateol'North(ar'olina Eirviroamentai Quality I Energy. Miner al and Land Resources
512N.Salissbury Street I Inumail Servlce Center I Raleigh.North Carolina27h99-4612

improve the efficiency of the system before granting regulatory relief in the form of a
collapsed Tier 2 — Tier 3 response for SDO1. We do concur with the request for
regulatory relief for SDO2-SDO4. Upon receipt of this letter, Moen Inc. may resume the
permit specified semiannual analytical monitoring for the remainder of your current
permit for SDO2-SDO4 only. This decision only applies to the copper and zinc
benchmarks. A benchmark exceedance of any other parameter listed in your permit will
trigger tiered response actions as described in the general permit. Once a thorough
investigation of the containment and separating system has been completed and all
reasonable options to reduce the copper and zinc contamination in stormwater from this
area have been explored, regulatory relief for this outfall can be revisited.
You must notify this office in writing, within five business days, if you become aware of
any significant source of copper or zinc at your facility that has the potential to be
exposed to stormwater. The relief granted in this letter is contingent upon the current
industrial practices at Moen Inc. If industrial practices change and copper or zinc
become a significant stormwater exposure risk, then this office reserves the right to
withdraw this decision and reinstate the permit specified tiered response or other
actions that may be warranted by the new set of circumstances.
Please retain and append this letter to your Stormwater Pollution Prevention Plan
(SPPP) or permit. If you have any questions or comments concerning this letter, please
contact Thad valentine or me at [phone].
Enclosure
cc: Bethany Georgoulias, RCO
Sincerely,
William H. Denton, IV
Regional Engineer
RECEIVED
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Nothing Compares.
State or North Carolina IEnviironmen[al Quality IEnergy. 6liner<+I Hod Lund Resources
512N.SaiLsbury Strect h,12NUll S"Ou Center I Raleigh. North Carolina 27o9r+-1612
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