NCS000312 2009 Draft Permit Letter

March 25, 2009
Mr. Craig Hogarth
Heritage Environmental Services, LLC
7901 West Morris Street
Indianapolis, Indiana 46231
Subject: Draft NPDES Stormwater Permit
Permit No. NC9000312
Heritage Environmental Services, LLC
Mecklenburg County
Dear Mr. Hogarth:
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. Analytical mariit-OTIng parameters have been added to this permit. They include COD, TSS, and pH.
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 1-� Tabic 2.
3. Benchmarks for analytical monit.oring 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, br outside of the benchmark range, for any parameter at any outfall then the
facility shall follow the Tier 7 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 Iisted 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. 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.
5. You are 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.)
Wetlands and Stomiwater Branch One
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 NQI'e7CcglOTl1a
Location: 512 N, Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: wwwmwaterquality,org i� r 6t%�f�ral
An Equal Opportunily 1 Affirmative Action Employer

Mr. Craig Hogarth
Heritage Environmental Services, LLC
Permit No. NCS000312
7. 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 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 changes:
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 outfaII. 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 Il 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.
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 me at [phone].
cc: Mooresville Regional Office, Dee Browder
Stormwater Permitting Unit
Attachments
2
Sincerely,
Robert D. Patterson, PE
Environmental Engineer
Stormwater Permitting Unit