NCS000386_Staff Report_20080930

Facility Name:
NPDES Permit Number:
Facility Location:
Type of Activity:
SIC Code:
Receiving Streams:
River Basin:
Stream Classification:
Proposed Permit Requirements
Monitoring Data:
Facility Location:
Response Requested by (Date):
Central Office Staff Contact:
Special Issues:
Michael P. 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 ANI) EVALUA ION
NPDES Stormwater Permit
Rohm and Haas Chemicals, LLC
NCS00©386
Charlotte, NC (Mecklenburg County)
CHEMICAL MANUFACTURING
2821
See Figure 1
Catawba River Basin, Sub -basin 03-08-34
C
See attached draft permit.
See Table 1
See Figuie 1
9/30/08
Brian Lowther, [phone]
Issue
Rating Scale: 1 eas to 10 and
Compliance history
2
Benchmark exceedance
5
Location (TMDL, T&E
species, etc
5
Other Challenges:
• Contacting
Permittee
6
18140
DifficuI Rating:
Special Issues Explanation:
• Benchmark exceedence: BOD -5 at both outfalls. Zinc once at Outfall 1.
Description of Onsite Activities:
+ Chemical Plant, a list of stored chemical was provided.
Documents Reviewed:
• SPU File
0 2004 Catawba Basinwide Plan
• 2008 draft 303(d) list
a EPA draft 2006 Sector -Specific permit, Sector C "Chemical and Allied Products"
Pagel of 8

NCS000386
History:
• Date Permit first issued: September 1, 2001
• Date Permit re -issued: December 2, 2005
• Date: Permittee submitted renewal application: February 28, 2006
• Date permit request transfer to individual permit: November 23. 2005 for change of name from Rohm and
Haas Company to Rohm and Haas Chemicals, LLC
Page 2 of 8

NCS000386
Figure 1: Map of Facility
NCS000386
!d
NIP Scale 1.24,000
Rohm and Hass Chemicals, LLC
Latitude: 350 15'44" N
Longitude: -800 45'43" W
County: Nledclenburg
Receiving Stream: UT to Brier Creek
Stream Class: C
Sub -basin: 03-08-34 (Catawba River 5asin)
Page 3 of 8
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Facility Location
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NCS000386
Central Office Review Summary:
1. Owner's Other Permits: (If applicable)
NCG090005 Inactive: Paints, Varnishes, Lacquers Stormwater Discharge, Rohm and Haas Chemicals LLC
2. General Observations: Chemical plant that produces architectural and functional coatings.
3. Impairment: Not 303(d) listed. Not addressed in the 2004 Basinwide Plan.
4. Threatened and Endangered: On the National Heritage map no species were federally regulated.
S. Location: The outfalls drain to a C stream.
6. Industrial Changes Since Previous Permit: Only change since the last permit application is the addition of methyl
methacrylate in bulk storage. "It is stored in a tank in the same dike as other bulk hazardous materials. And does
not pose any additional issues requiring changes in stormwater management."
7. Ana!34ical Monitoring Notes: The permittee sampled, BOD -5, cBOD, Lead, and Zinc. Four sampling dates
were given from 11/4/2004 to 8/9/2005. Two outfalIs were collected. A letter in the file dated February 18,
2004 stated that due to a lab error the BOD sample was analyzed as carbonaceous BQD instead of BOD -5. The
sample from the maim stormwater collection area (`pipe 001') which collects the stormwater from the Plant's
processing area was not affected. Monitoring was required quarterly on the four year.
8. Qualitative Monitoring Notes: The qualitative monitoring was from 11/26/01 to 10/6/05. Stormwater was
contaminated on 5/21103 because of an overflow of a rail car loading spill pan. All contaminated stormwater
was contained and treated. None left the site. Outfall 001 had some slightly muddy water on occasion. Outfall
2 was all OIC.
Page 4 of 8

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NCS000386
Revised Permit Recommendations: Analytical Monitoring:
L Zinc and BOD -5 sampling has been maintained. Sector C recommends monitoring for Zn and TSS. TSS has
been added to the permit.
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 H
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. 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 I 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.
Other Proposed Changes to the Previous Permit:
I. 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 riot c ontairi tion-stormwater discharges. Additional information is provided in Part H Section
A.
2. Additional requirements for the Stormwater Management PIan have been specified in Part R Section A. More
details regarding secondary containment are provided.
3. Additional requirements for the Stormwater Pollution Prevention Plan have been specified in Part lZ 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 H 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.
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NCS000386
Discussions with permittee: Timothy Ryan, 704-596-3021, 8/15108
Left message on 08/11/08
1. Have there been any changes since the application was submitted? Some new chemicals were added in storage.
List of olltlinicals was providcd.
2. The analytical monitoring shows higher BOD -5 for both outfalls on the first sampling date. Were any changes done
after this monitoring? No changes after the monitoring. The permittee noted the lab had given some comments
about the samples.
3. What chemicals are stored outside? Will receive a list of chemical in the mail.
4. Jho you have a waste water permit? Waste water permit through CMUD.
5. Vehicle Maintenance? No
6. What is your SIC code? 2821
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NCS000386
Recommendations: Based on the documents reviewed, the application information submitted on February 24, 2006
sufficient to issue an Individual Stormwater Permit.
Piepared by (Signature) x---::(�'` �'—'"� Date
Stormwater Permitting Unit Supet visoi mss- Civ Date
for Bradley Bennett
Concurrence by Regional Office Date
Water Quality Supervisor
Regional Office Staff Comments
Page: 8 of 8
Date

NCS000386
Recommendations: Based on the documents reviewed, the application information submitted on February 24, 2006
sufficient to issue an Individual Stormwater Permit.
Prepared by {Signature} ^� �• Date o8 1' »
Sturinwater Permitting Unit Supervisor Date
FAV Rra Ala- 'R.— nf+
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