NCS000334_Draft 2009 Permit Cover Letter_20090115

Q�QF W A �FAQG Beverly Eaves Perdue, Governor
.T, Dee Freeman, Secretary
North Carolina Department of Environment and Natural Resources
O _ C Coleen H. Sullins, Director
Division of Water Quality
January 15, 2009
Mr. Timothy Gaffney
JCI Jones Chemicals
1.00 Surmy Sol Blvd.
Caledonia, NX 1.4423
Subject: Draft NPDES Stormwater Permit
Permit No. NCS000334
JCI Jones Chemicals Inc.
Mecklenburg County
Dear Mr. Gaffney:
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 this facility's current permit:
Analvtical monitoring changes:
1. Analytical monitoring parameters have been added to this permit including total suspended solids,
nitrate+nitrite, phosphorus, oil & grease, and chlorine.
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 11 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 benclunark 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 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.) One
nKhCarolina
Naturally
North Carolina Division of Water Quality 1617 Mail Service Center Raleigli, NC 27699-1617 Phone [phone] Customer Service
Internet: h2o.enr,state.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
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Mr. 'Timothy Gaffney
JCl Jones Chemicals Inc.
Permit No. NCS000334
S. 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
hi 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 11
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-storfnwater discharges.
4. The facility must now implement a semi -at Lnual Facility Inspection Prograni 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 (3 0) days following your receipt of the draft.
Comtments should be sent to my attention at the address listed at the bottom of page 1. If no adverse
comments are received from the public or from you, this permit will likely be issued in approximately two
months.
If you have any questions or comments concerning this draft permit, please contact me at [phone] or
cory.lai:[e-mail]
cc: Mooresville Regional Office, Samar Bou-Ghazale
SPU Files
Encl
2
Sincerely,
Cory L r
Environmental Engineer
Stormwater Permitting Unit.