NCS000354_Staff Report_20081201

NCS000354
� 0 l 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:
Starpet, Inc.
NPDES Permit Number:
NCS000354
Facility Location:
801 Pineview Rd., Asheboro, NC (Randolph County)
Type of Activity:
Plastics Materials & Resins
SIC Code:
2821
Receiving Stream.
UTTif Back Creek, See Figure 1 —
River Basin:
Yadkin Pee -Dee River Basin, Sub -basin 03-07-09
Stream Classification:
WS -II; HQW
Proposed Permit Requirements:
See attached draft permit.
Monitoring Data:
See Table 1
Response Requested by (Date):
December 1, 2008
Central Office Staff Contact:
Return to Robert Patterson, [phone]
Special Issues:
Issue
Rating Scale: 1 eas to 10 hard
Compliance history
3
Benchmark exceedance
4
Location (TMDL, T&E
species, etc
1
Other Challenges:
1
Difficulty Rating:
9/40
Description of Onsite Activities:
• Manufacure plastics materials and resins.
Documents Reviewed:
• NPDES Stormwater Permit Application Materials
• National Heritage Program (NHP) Threatened and Endangered Species Database
• SPU File
• Central Files
• EPA Sector -Specific Permit, 2008
• 303(d) List, 2008 draft, 2006 final
• 2008 (draft) Yadkin Pee -Dee Basinwide Plan
History:
• Date Permit first issued: October 1, 1996
• Date Permit re -issued: December 14, 2001
• Permit Modification Name/Ownership Change: March 21, 2003
• Date permittee submitted renewal application: June 29, 2006
Page 1 of 5

NCS000354
NCS000354
Starpet, Inc.
Latitude: 350 46' 18" N
Longitude: 79" 49' 20" W
County: Randolph
Receiving Stream: UT of Back Creek
Stream Class: WS -II; HQW
Sub -basin: 03-07-09 (Yadkin Pee -Dee River Basin)
Page 2 of 5
rr.
Facility Location

NCS000354
Central Office Review Summary:
1. Owner's Other Permits:
• RCRA ID # NCR000004218
2. General Observations:
• Samples are taken at the outlet of the pond on the site.
3. Impairment: None.
4. Threatened and Endangered: None.
5. Industrial Changes Since Previous Permit: There is a new truck unloading area for isophthalic acid from tankers;
new rail car unload system for terephthalic acid and ethylene glycol. Increased quantity of the following onsite:
Therminol 66, Therminol VPI, ethylene glycol, terephthalic acid, isophthalic acid, polyethylene terephthalate.
New silos constructed for all of these except Therminol 66 and Therminol VPI. Smaller storage tanks
constructed in the CP2 building for Therminol 66 and Therminol VPI.
6. Analytical Monitoring Notes: No monitoring done the first year of the last permit term. Otherwise, monitoring
done as required. They continued monitoring as required after the permit expired. A total of nine events were
submitted. Most sample results are under the current benchmarks. One oil & grease sample had a value greater
than the benchmark; two samples that had high BOD; two high values for COD; three high for TSS. The last
two samples showed elevated Cobalt values. EPA's Multi -Sector General Permit for this SIC code only lists
Zinc to be monitored for.
7. Qualitative Monitoring Notes: No items of concern. Light brown color noted for majority of samples.
Revised Permit Recommendations: Analytical Monitoring:
1. Continue all parameters from the last permit term.
2. pH has been added to the analytical monitoring requirements.
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 stonnwater 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. The permittee is required to collect all of the analytical and qualitative monitoring samples during representative
storm events as defined in Part H Section B. Qualitative monitoring is required regardless of representative
outfall status.
6. The permittee is responsible for all monitoring until the 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.
Page 3 of 5

NCS000354
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 stonnwater
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.
Discussions with permittee: Michael Crabtree, 336-672-0101 x307, October 28, 2008
1. Q: Verify SIC code and industry?
a. ANSWER: manufacture PET polymer plastic in a chip form, sell it to be made into food containers.
2. Q: Any spills or anything that would explain the elevated values of cobalt and ethylene glycol?
a. ANSWER: No. Have doubled plant size and amount of steel pipes.
3. Q: Are unloading/loading areas covered?
a. ANSWER: they are covered.
4. Q: Does the entire site drain to the pond?
a. ANSWER: yes. Have added a second pond downstream before leaving site.
Page 4 of 5

NCS000354
Recommendations: Based on the documents reviewed, the application information submitted on June 29, 2006
sufficient to issue an Individual StormmwatJerr Permit.
Prepared by (Signature) /7L (/ . { � Date
Stormwater Permitting Unit Supervisor 4,.2 &49-1 Date le"Z2 i
for Bradley Bennett
Concurrence by Regional Office Date
RO Water Quality Supervisor Date
Regional Office Staff' Comments (please return this with comments and original signatures)
91.
Page 5 of 5
OT'
f
�i
► n
Page 5 of 5

O
November 14, 2008
Mr. Michael D. Crabtree
StarPet, Inc.
801 Pineview Road
Asheboro, NC 27203
Subject: NPDES Stormwater Permit Inspection
StarPet, Inc.
Permit No. NCS000354
Randolph County
Dear Mr. Crabtree:
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
On November 13, 2008, Mike Mickey of this office met with you to perform a NPDES
Stormwater Permit Inspection at the StarPet facility in Asheboro. The inspection found
StarPet to be compliant with the stormwater permit. This inspection evaluated the five (5)
areas as designated on the attached inspection form. Observations from, each area are
addressed below:
1. Permit
StarPet holds NPDES Stormwater Permit No. NCS000354 for the discharge of stormwater
from the facility. The permit expired on December 31, 2006 and StarPet requested renewal
June 29, 2006. This inspection was conducted in response to your renewal request.
Comments from this office have been sent to our Central Office recommending that the
permit renewed. Hopefully, they can accomplish that in the near future.
2. Records/Reports
Part II, Section A of the permit requires the development of a Stormwater Pollution
Prevention Plan (SPPP). A copy of StarPet's SPPP was reviewed during the inspection.
The plan, dated March 2006, appeared to be thorough and complete. Please note that Item
7 of Part A requires the plan be reviewed and updated on an annual basis.
3. Facility Site Review
The facility recently completed an expansion that includes new truck and railcar unloading
areas. A tour of the property found the site to be clean and well managed.
4. Effluent/Receiving Waters
Stormwater from the site is discharged from a single outfall after being routed through two
sediment basins. The stormwater eventually reaches an unnamed tributary to Back Creek,
Class "WS -ll, HWQ" Waters in the Yadkin -Pee Dee River Basin.
N���1,,Cazo ina
✓vatuaro
North Carolina Division of Water Quality 585 Waughtown Street Winston Salem, NC 27107 Phone [phone] Customer Service
Internet .ncwatemuality.orc FAX [phone]
An Equal Opportunity/Allirmative Action Employer- 50% Recycled/70% Post Consumer Paper

Mr. Michael Crabtree
Page #2
November 14, 2008
5. Monitoring Program
Part II, Section B of the permit requires the collection of annual analytical samples of the
stormwater discharge during a representative storm event. A review of the facility files found
that StarPet is performing this sampling as required. Please note that the results should be
submitted to the Division no later than 30 days from the date that you receive the sampling
results from your laboratory.
Part Il, Section C of the permit requires that qualitative (visual) monitoring be performed and
documented semi-annually. StarPet is also performing this monitoring as required. Please
note that the qualitative records do not need to be submitted to the Division, however, they
must be kept on file at the facility for a period of five years.
Analytical monitoring for on-site vehicle maintenance listed in Section D of the permit is not
required since StarPet does not use more that 55 gallons of new motor oil per month when
averaged over the calendar year.
Your efforts to comply with the stormwater permit are appreciated. If you have any
questions concerning this letter, please contact Mike Mickey or me at [phone].
Sincerely,
Steve W. Tedder
Water Quality Regional Supervisor
cc: NPS Assistance and Compliance Oversight Unit
Central Files — SWP
WSRO

EPA Form 3560-3 (Rev 9-94)
Form Approved
OMB No.2040-0057
Approval Expires
United States Environmental Protection Aeencv. Washineton. D.C.. 20460 8-31-98
Section A: National Data System Coding
Transaction Code NPDES No. Yr/Mo/Day Inspection Type Inspector FacilityType
N 5 NCS000354 08-11-13 C S 2
Facility Evaluation Rating BI QA ..........Reserved...........
I N N
Section B: Facility Data
Name and Location of Facility Inspected:
Entry Time:
Permit Effective
0930 hrs.
Date: Dec 14, 2001
Starpet, Inc.
801 Pineview Road
Asheboro, NC 27203
Exit Time:
Permit Expiration
1055 hrs.
Date: Dec 31, 2006
Name(s) of On-Site Representative(s): Title(s): Phone No(s):
Mike Crabtree HR Manager [phone], ext. #307
Name, Address of Responsible Official:
Title: HR Manager
Mr. Michael D. Crabtree
Starpet, Inc.
Phone No. [phone]
Contacted? Yes
801 Pineview Road
Asheboro, NC 27203
Section C: Areas Evaluated During Inspection (check only those areas evaluated)
Yes Permit NA Flow Measurement NA Operations/Maintenance NA Sewer Overflow
Yes Records/Reports Yes Self-Monitoring Program NA Sludge Handling/Disposal NA Pollution Prevention
Yes Facility Site Review NA Compliance Schedules NA Pretreatment
Yes Effluent/Receiving Waters NA Laboratory Yes Stormwater
Section D: Summary of Findings/Comments
See cover letter and attached inspection form for specific comments.
Name(s) and Signature(s) of Inspectors:
Agency/Office/Telephone:
Date:
_{t
Vag,
DWQ / WSRO / [phone]
i, vy+O'l
Signature o eviewer:
Agency/Office:
Date:
�
DWQ / WSRO / [phone]
11-17
EPA Form 3560-3 (Rev 9-94)

Permit: NCS000354 Owner- Facility: Starpet Inc
Inspection Date: 11/13/2008 Inspection Type: Stormwater Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Yes
No
NA NE
Does the site have a Stormwater Pollution Prevention Plan?
■
n
❑
❑
# Does the Plan include a General Location (USGS) map?
■
n
n
❑
# Does the Plan include a "Narrative Description of Practices"?
■
❑
❑
❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■
n
F1
n
# Does the Plan include a list of significant spills occurring during the past 3 years?
■
n
❑
❑
# Has the facility evaluated feasible alternatives to current practices?
■
n
n
n
# Does the facility provide all necessary secondary containment?
■
❑
❑
❑
# Does the Plan include a BMP summary?
■
❑
Cl
❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■
n
n
n
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
■
n
❑
n
# Does the facility provide and document Employee Training?
■
❑
fl
n
# Does the Plan include a list of Responsible Party(s)?
■
Q
❑
Cl
# Is the Plan reviewed and updated annually?
■
❑
Q
0
# Does the Plan include a Stormwater Facility Inspection Program?
■
❑
❑
❑
Has the Stormwater Pollution Prevention Plan been implemented?
■
❑
❑
❑
Comment: A review of the Stormwater Pollution Prevention Plan prepared for Starpet
found the plan to be thorough and complete. The plan was dated March 2006. Part II
Section A (7) of the permit requires that the plan be reviewed and updated on an annual
basis.
(Note: The Starpet permit expired on 12-31-06. A request for renewal was submitted to
the Division on 6-29-06.)
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ■ Cl ❑ ❑
Comment: The on-site file review showed that the semi-annual qualitative (visual)
monitoring had been conducted per Part II Section C of the permit. The monitoring was
continued after permit expiration.
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? ■ ❑ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ D ■ ❑
Comment: The file review also revealed that the annual analytical monitoring had
been conducted per Part II Section B of the Permit . This monitoring was also continued
after permit expiration.
Permit and Outfalls Yes No NA NE
Page: 3

Permit: NCS000354
Inspection Date: 11/13/2008
Owner - Facility: Starpet Inc
Inspection Type: Stonnwater
# Is a copy of the Permit and the Certificate of Coverage available at the site?
# Were all outfalls observed during the inspection?
# If the facility has representative outfall status, is it properly documented by the Division?
At Has the facility evaluated all illicit (non stormwater) discharges?
Reason for Visit: Routine
Comment: Stormwater from the Starpet site is discharged through a single outfall into
an unnamed tributary to Back Creek, Class "WS -II, HQW" waters of the State. The
stormwater is routed through two large sediment basins and piped under railroad tracks
where it is discharged at the property line.
0000
0000
0000
■❑❑❑
Page:4