NCS000253_Draft Permit Letter_2008

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Michael F. Easley, Governor
QG State of North Carolina
rWilliam G. Ross, Jr., Secretary
] Department of Environment and Natural Resources
Coleen H Sullins, Director
Division of Water Oualit
May 28, 2008
Mr. Bud Ward
Southeastern Foundries Corp
2706 Oakland Avenue
Greensboro, North Carolina 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
very carefully to ensure thorough understanding of the conditions and requirements it contains.
The draft permit contains the following significant changes from this facility's current permit:
Analytical monitoring changes,
1.. Lead has been removed from the analytical monitoring requirements.
2. Total nitrogen and total phosphorous have been added to the analytical monitoring requirements
due to the Jordan Lake Total Maximum Daily Load (TMDL) approved by EPA in 2007 and the
discharge receiving water being classified as a Nutrient Sensitive Water (NSW).
3. 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.
4. 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.
5. You are 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.
6. You are responsible for all monitoring untilthe renewal permit is issued. See Footnote 1 of
Tables 1, 4, and 5.
7. The flow reporting requirement has been removed per DWQ revised strategy. (The total rainfall
parameter is in this permit, however.)
8. Vehicle maintenance monitoring has been revised to semi-annually in order to coincide with
analytical and qualitative monitoring. This requirement appears in all Individual Stormwater
1617 Mail Service Center y Yeo r [phone]
Raleigh, North Carolina 27699-1617 FAX [phone]
On the Internet at http://h2o.enr.state.nc.us/

Mr. Bud Ward
Southeastern Foundries Corporation
Permit No. NCS000253
permits, however it only applies to facilities that do vehicle maintenance. If the facility begins
vehicle maintenance during the permitted timeframe then the requirements shall apply.
Other permit chanees:
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 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 II 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.
Please submit any comments to me no later than thirty (30) days following your receipt of the draft.
Comments should be sent to the address listed at the bottom of this page. If no adverse comments are
received from the public or from you, this permit will likely be issued in about two months.
If you have any questions or comments concerning this draft permit, contact Robert Patterson at (919)
733-5083 x 360 or [e-mail]
Sincerely,
Robert D. Patterson, P.E.
Environmental Engineer
Stormwater Permitting Unit
cc: Winston-Salem Regional Office, Corey Basinger
Stormwater Permitting Unit
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