HomeMy WebLinkAboutNCS000115 Draft Permit Cover LetterEnergy, Mineral
and Land Resources
ENVIRONMENTAL QUALITY
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
WILLIAM E. (TOBY) VINSON, JR.
Interim Director
February 21, 2018
Mr. Randy Green
Novozymes North America
77 Perry Chapel Church Road
Franklinton, NC 27525
Subject: Draft NPDES Stormwater Permit
Permit No. NCS000115
Novozymes North America
Franklin County
Dear Mr. Green:
Enclosed with this letter is a copy of the draft stormwater permit for your facility. Please review
the draft carefully to ensure thorough understanding of the conditions and requirements it
contains.
The draft permit contains the following significant changes from the facility's current permit:
1. You are required to collect analytical and qualitative monitoring samples during
"measurable storm events" as defined in Part II, Section B. This term is different from the
"representative storm event" in earlier permits.
2. Requirements for the Stormwater Pollution Plan (SPPP) have been updated in Part II,
Section A.
3. Monitoring requirements in the draft permit have changed slightly. Monitoring is
required for BOD, COD, TSS and pH. After review of monitoring data from the past 10
years the results for TKN, NO2/NO3 and TP have remained well below benchmark levels.
The draft permit proposes to remove these parameters. Comments from our regional
staff or other information may result in maintaining these if it is apparent that your
activities in some way have the potential to release these pollutants. Stormwater
benchmarks remain in the permit as before. Keep in mind that benchmarks are not permit
limits, but rather guidelines for implementing the Stormwater Pollution Prevention Plan
(SPPP). A benchmark exceedance is not a permit violation; however, the permittee must
respond to exceedances. The draft permit has modified the tiered response process for
State of North Carolina I Environmental Quality I Energy, Mineral and Land Resources
1612 Mail Service Center 1512 North Salisbury Street I Raleigh, NC 276 99-16 12
919 707 9200 T
NCS000115 Draft Permit
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benchmark exceedances consistent with other permits in our program. Please become
familiar with the tiered process as proper response under the tiers may be enforceable
items under your permit. Response to the tiered process may include review of onsite
conditions, installation of BMPs or requirements for more frequent monitoring.
4. Vehicle maintenance (Tables 4 & 5) monitoring parameters have been revised. Non -Polar
Oil & Grease [EPA Method 1664 (SGT -HEM)] replaces Oil & Grease/TPH. The benchmark
for Non -polar Oil & Grease using this method is 15 mg/L. This requirement appears in all
individual stormwater permits; however, it only applies to facilities that perform onsite
vehicle maintenance activities. If the facility begins vehicle maintenance during the permit
cycle, the requirements shall apply. Also, pH monitoring is no longer required for
discharges only associated with vehicle maintenance activities.
5. Language has been added under Part II Section D to address potential responses to
qualitative monitoring issues.
6. A new section on Special Conditions has been added in Part II, Section E to comply with
federal regulations requiring electronic submittal of discharge monitoring reports. Our
electronic submittal process is not available for use at this time, but we will continue to
provide feedback on when this process will be available.
7. Civil and administrative penalty amounts have been updated to reflect current federal
law in Part III, Section A, 2(b) and (g).
Please review the draft permit and submit any comments to me no later than 30 days following
your receipt of the draft. Comments may be emailed to meat bradley.bennett@ncdenr.gov or
mailed to my attention at NC DEMLR, Stormwater Permitting Program, 1612 Mail Service Center,
Raleigh, NC 27699-1612.
If you have any questions, please email me or call me at (919) 807-6392.
Sincerely,
Bradley Bennett
Stormwater Permitting Program
Attachment: Draft Permit NCS000115
cc: Bill Denton, DEMLR Raleigh Regional Office — via email
Stormwater Permitting Program Files