NCS000253_Staff Report_2008

NCS000253
TEA
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
STAFF REVIEW AND EVALUATION
NPDES Stormwater Permit
Facility Name: Southeastern Foundries Corporation
NPDES Permit Number: NCS000253
Facility Location: Greensboro, NC (Guilford County)
Type of Activity: Non- Ferrous Foundry
SIC Code: 336
0
Receiving Streams: North Buffalo Creek
River Basin: Cape Fear River Basin, Sub -basin 03-06-02
Stream Classification: C; NSW
Proposed Permit Requirements: See attached draft permit.
Monitoring Data: See Table 1
Facility Location: See Figure 1�
Response Requested by (Date): June 9, 2008 ? ''
Central Office Staff Contact: Robert Patterson, [phone], ext. 360
Special Issues:
Issue
Rating Scale: 1 eas to 10 and
Comp] ance history
8
Benchmark exceedance
8
Location (TMDL, T&E
species, etc)
10
Other Challenges:
1
Difficult Rating:
27/40
Special Issues Explanation:
• Multiple TMDLs
Description of Onsite Activities:
• Non-ferrous foundry (brass, bronze, aluminum)
Documents Reviewed:
NPDES Stormwater Permit Application Materials
• Stormwater Permit File
1999 and 2007Central Files
• Cape Fear River Basinwide Plan
• Final 2006 303(d) List
• Draft 2008 303(d) List
EPA Sector -Specific Permit, 2006 draft
Page 1 of 8
RECEIVED
R.C. Dept of ENR
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NCS000253
• Natural Heritage Program's Federal Threatened and Endangered Species Database
• Check 40 CFR Subchapter N, Stormwater Effluent Guidelines
History:
• Date Permit first issued: November 7, 1994
• Date Permit re -issued: April 14, 2000
• Date: Permittee submitted renewal application: May 6, 2005
• Routine compliance inspection by WSRO: November 1, 2006 (not compliant)
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NCS000253
Central'Office Review Summary:
1. Owner's Other Permits:
• None
2. General Observations:
• This facility has two stormwater outfalls; one at the northeast comer and the other about halfway
between the northwest and southwest comers of the property. It consists of a non-ferrous foundry and
warehouse buildings. There appears to be some outside storage of metal, crates, drums, and two fuel oil
ASTs.
3. Impairment: The final 2006 303(d) lists this stream segment as impaired for aquatic life due to impaired
biological integrity; and for recreation due to fecal coliform. The draft 2008 lists it as impaired due to biological
integrity and biological criteria exceeded. There is a TMDL in place for this watershed for fecal coliform and
one for cyanide. The sources of fecal in the TMDL were identified as exfiltrating sewers, ss overflows, pets and
illicit discharges; none of which relate to this facility. There is also a TMDL for Jordan Lake that requires
reductions of Total Nitrogen and Total Phosphorous. This TMDL states that the local governments will
implement and achieve this reduction for new and existing stormwater discharges.
4. Threatened and Endangered: None.
5. Location: 2706 Oakland Ave., Greensboro, NC 27403
6. Industrial Changes Since Previous Permit: None.
7. Analytical Monitoring Notes: Performed only once during permit term. Additional monitoring was performed in
2006 and 2007 after the permit expired. Total flow was only calculated for the site as a whole (34.5 mg for a
1.27" rain), instead of for each outfall as required in the permit. Discharge was over the current benchmark for
zinc and copper in all samples.
8. Qualitative Monitoring Notes: Performed as required. No items of concern.
Page 4 of 8

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NCS000253
Revised Permit Recommendations: Analytical Monitoring:
1. Remove non -contact cooling water monitoring since this is now discharged into the sanitary sewer system.
Remove lead from monitoring due to low sample results, and since lead is not used. Keep all other parameters.
Add total nitrogen and total phosphorous due to Jordan TMDL and NSW classification.
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
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.
Page 6 of 8

NCS000253
Discussions with permittee: Bud Ward, 336-299-7211, April 18, 2008
1. Q: Type of foundry? SIC?
a. ANSWER: non-ferrous (brass, bronze, aluminum)
2. Q: Non -contact cooling water monitoring?
a. ANSWER: goes to sanitary sewer system now, so DWQ will remove this from the permit.
3, AO GY/+/ P45� - (ASS
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Page 7 of 8

NCS000253
Recommendations: Based on the documents reviewed, the application information submitted on May 6, 2005
sufficient to issue an Individual Stormw..a/tefr�Permit.
Prepared by (Signature)Date _E % uJo
Stormwater Permitting Unit Supervisor / eL s Date S / 2 0
radley Bennett
Concurrence by Regional Office Date Z�va
Water Quality Supervisor Date
Regional Office Staff Comments
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