NCS000253 Draft Permit Cover Letter Signed

Energy, Mineral
and Lewd Resources
rwviPoNMEMrAL QUALITT
ROY COOPER
MICHAEL S. REGAN
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WILLIAM E. (TOBY) VINSON, JR.
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April 2, 2018
Mr. Thomas (Bud) Ward
Southeastern Foundries Corporation
2706 Oakland Avenue
Greensboro, NC 27403
Subject: Draft NPDES Stormwater Permit
Permit No. NCS000253
Southeastern Foundries Corporation
Guilford County
Dear Mr. Ward:
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.
Monitoring requirements in the draft permit have remained unchanged from the previous
permit issued in 2008. Monitoring is required for Total Suspended Solids (TSS), Total
Recoverable Copper (Cu), Total Recoverable Zinc (Zn), Total Nitrogen (TN), Total
Phosporous (TP) and pH. However, it appears that your facility has been monitoring for
parameters required as part of your original permit issued in 2000. The 2008 permit
dropped Lead and added TN and TP monitoring. Please make a note of this in your
process and assure that you are focused on the correct parameters.
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
State of Nonh Carolina I Environmental Quality I Energy, Mineral and land Resources
1612 Mail Service Center 1 512 North Salisbury Street I Raleigh. NC 27699-1612
919 707 9200 T

NCS000253 Draft Permit
Page 2
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 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 maybe emailed to meat bradley.bennett(cpncdenr.gov or
mailed to my attention at NC DEMLR, Stormwater Permitting Program, 1612 Mail Service Center,
Raleigh, NC 27699-1612. With this notification the Division will solicit comment on this draft by
publishing a notice in a local newspaper. Following the 30 day public comment period, the
Division will review comments and take appropriate action prior to issuance of the final permit.
If you have any questions, please email me or call me at [phone].
Sincerely,
U;=
Bradley Bennett
Stormwater Permitting Program
Attachment: Draft Permit NCS000253
cc: Matt Gantt, DEMLR Winston-Salem Regional Office — via email
Stormwater Permitting Program Files