NCS000209_Staff Report_20081114

NCS000209
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Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleco H. Sullins Director
Division of Water Quality
STAFF REVIEW AND EVALUATION
NPDES Stormwater Permit
Facility Name:
Haynes International — Haynes Wire Co.
NPDES Permit Number:
NCS000209
Facility Location:
158 N Egerton Rd, Mountain Home, NC (Henderson County)
Type of Activity:
Metal wire manufacturing
SIC Code:
3315 (�
CI E
8/40
Receiving Streams:
I
UT to Mud Creek, See Figure 1 . �, , v
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River Basin:
French Broad River Basin, Sub -basin 04-03-02 NOV 14 2003
Stream Classification:
C
Proposed Permit Requirements:
See attached draft permit.
rATER G�UALITY SECTION
F' REGIONAL
LAS�IHL_VILLF REGIONAL OFFICE
Data:
See Table 1
Response Requested by (Date):
December 12, 2008
Central Office Staff Contact:
Return to: Robert Patterson, [phone]
Special Issues:
Issue
Rating Scale: 1 eas to 10 and
Compliance history
1
Benchmark exceedance
1
Location (TMDL, T&E
species, etc
5
Other Challenges:
1
Difficulty Rating:
8/40
Description of Onsite Activities: m^ m C"n
• Manufacturing of stainless steel alloy and nickel alloy wire. Some storage of metal outside.
Documents Reviewed:
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• NPDES Stormwater Permit Application Materials
• National Heritage Program (NHP) Threatened and Endangered Species Database m
• SPU File, Central Files, NCG 030000 & NCG200000
• EPA Multi -Sector Permit, 2008 O
• 303(d) List, 2008 draft, 2006 final
• 2005 French Broad Basinwide Plan
History:
• Date Permit first issued: August 31, 1994
• Date Permit re -issued: April 5, 2002
• Date Permit Modified for Name/Ownership change: June 19, 2006
• Date permittee submitted renewal application: November 21, 2006
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NCS000209
Figure 1: Map of Facility
Haynes Wire Co.
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NCS000209
Haynes International
Haynes Wire Co.
Latitude: 35" 22. 25" N
Longitude: 82" 29'09' W
County: Henderson
Receiving Stream: LIT to Mud Creek
Stream Class: C
Sub -basin: 04-03-02 (French Broad River Basin)
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Facility Location

IICS000209
Central Office Review Summary:
1. General Observations:
• The site plan states that the roof drains are non-regulated and not monitored; this does not seem
correct. The roof drains appear to receive roof runoff from process areas, so they should be subject to the
permit and monitored.
2. Impairment: The 303(d) list state Mud Creek is impaired for biological integrity. The basinwide plan states that
the stream is impacted by toxicity (pesticides & urban toxicants), habitat degradation, storm flow scour from
urban areas, nutrient overloading, and widespread stream degradation. There are numerous water quality
initiatives in the watershed.
3. Threatened and Endangered: None. ✓
4. Industrial Changes Since Previous Permit: Continuing to shift from stainless steel alloys to nickel alloys.
Reduced inventory stored outside by approx. 40%. Reduced pounds produced by approx. 30%.
5. Analytical Monitoring Notes: None required, none submitted.
6. Qualitative Monitoring Notes: One event was mentioned, noted slight yellow color. It was stated that they
performed all the required monitoring, but no records were submitted. Records were submitted for monitoring
in 2007 and 2008. Multiple mentions of slight yellow color.
Revised Permit Recommendations:
1. Add pH, Nickel, and TSS to the analytical monitoring requirements. This is partly because it discharges to an
impaired stream; and partly because of potential contaminates and wire exposure.
2. All analytical monitoring has been set to semi-annually during a representative storm event as defined in Part II
Section B. The permittee must also document the total precipitation for each event. If no discharge occurs
during the sampling period, the permittee must submit a monitoring report indicating "No Flow" within 30 days
of the end of the six-month sampling period. Additionally, samples must be taken a minimum of 60 days apart,
as specified in Table 2.
3. Benchmarks for analytical monitoring have been added to this draft permit. Exceedances of benchmark values
require the permittee to increase monitoring, increase management actions, increase record keeping, and/or
install stormwater Best Management Practices (BMPs) in a tiered program. If the sampling results are above a
benchmark value, or outside of the benchmark range, for any parameter at any outfall then the facility shall
follow the Tier 1 guidelines which require a facility inspection within two weeks and implementation of a
mitigation plan within two months. If during the term of this permit, the sampling results are above the
benchmark values, or outside of the benchmark range, for any specific parameter at a specific discharge outfall
two times in a row (consecutive), then the facility shall follow the Tier 2 guidelines which require a repetition of
the steps listed for Tier 1 and also immediately institute monthly monitoring for all parameters at every outfall
where a sampling result exceeded the benchmark value for two consecutive samples.
4. The permittee is required to collect all of the analytical and qualitative monitoring samples during representative
storm events as defined in Part II Section B. Qualitative monitoring is required regardless of representative
outfall status.
5. The permittee is responsible for all monitoring until the renewal permit is issued. See Footnote 1 of Tables 1, 4,
and 5.
6. The flow reporting requirement has been removed per DWQ revised strategy. (The total rainfall parameter is in
this permit, however.)
7. Vehicle maintenance monitoring has been revised to semi-annually in order to coincide with analytical and
qualitative monitoring.
Other Proposed Changes to the Previous Permit:
1. Additional guidance is provided about the Site Plan requirements. The site map must now identify if the
receiving stream is impaired and if it has a TMDL established. It must also describe potential pollutants in each
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NCS000209
outfall. The map requirements are stated more explicitly. And, the site plan must contain a list of significant
spills that have occurred in the past three years and also must certify that the outfalls have been inspected to
ensure that they do not contain non-stormwater discharges. Additional information is provided in Part II Section
A.
2. Additional requirements for the Stormwater Management Plan have been specified in Part II Section A. More
details regarding secondary containment are provided.
3. Additional requirements for the Stormwater Pollution Prevention Plan have been specified in Part II Section A.
The plan must also be updated annually to include a list of significant spills and to certify that the outfalls do not
contain non-stormwater discharges.
4. The facility must now implement a semi-annual Facility Inspection Program of the site's stormwater
management controls as specified in Part 11 Section A.
5. Information regarding the No Exposure Exclusion has been added to this draft permit. If industrial materials and
activities are not exposed to precipitation or runoff as described in 40 CFR § 122.26(g), the facility may qualify
for a No Exposure Exclusion from NPDES stormwater discharge permit requirements. Additional information
is provided in Part I Section A.
Discussions with permittee: Angela Marsico, 828-393-1258, November 4 & 5, 2008
1. Q: SIC code and industry?
a. ANSWER: 3315
2. Q: Actual monitoring results instead of the summary provided?
a. ANSWER: emailing inspection results and site map
3. Q: Roof drains on plan are labeled "non-regulated outfall no exposure"?
a. ANSWER: Sounds like they do perform visual inspections of the roof drain outfalls.
4. Q: Are the ditches on the property? If so, why are they not monitored SDOs?
a. ANSWER: Border property.
5. Q: What is stored outside exposed to sw?
a. ANSWER: rod coils (rolls of wire) and wood pallets
6. Q: Do you use any kind of a coating (oil/grease) on the wire stored outside?
a. ANSWER: no coatings on the wire rolls
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NCS000209
Recommendations: Based on the documents reviewed, the application information submitted on November 21,
2006 sufficient to issue an Individual Stormwater Permit.
Prepared by (Signa
Stormwater Permit
Concurrence by Re
RO Water Quality
Regional Office Staff Comments
Date t % e -u
Date i 1 i Z 20ob
Date
Date 2 z C S
Analytical monitoring was not required before, but has been added to the draft permit. If the ARO feels after a site visit
that the site is has minimal exposure and the addition of analytical monitoring is not warranted, then we can continue
visual monitoring only.
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