NCS000049 Staff Report 2008

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NCS000049
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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 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
Cognis Corporation
NCS000049
Charlotte, NC (Mecklenburg County)
CHEMICAL MANUFACTURING
2869 A 11
See Figure 1 RECEIv
Catawba River Basin, Sub -basin 03-08-34
C SSP 2 4 2003
See attached draft permit.
See Table 1 FiC,- DEW M`1.4':` .
See Figure 1 D%'Yb_ SugcjGe Tater Pr1
October 22, 2008 L�
Brian Lowther, [phone]
Issue
Rating Scale: 1(e as . to 10 hard
Compliance history
5
Benchmark exceedance
3
Location (TMDL, T&E
species, etc
5
Other Challenges:
• Finding Acetone
Benchmark
5
Difficult Rating:
18
Description of Onsite Activities:
Chemical Manufacture, store raw materials, Incoming & Outgoing trucks, and mixing chemicals a
Documents Reviewed:
• SPU File
• Central File
• 2004 Catawba Basinwide Plan
• 2008 draft 303(d) list
• National Heritage Program's T&E database
• EPA draft 2006 Sector -Specific permit, Sector C "Chemical and Allied Products"
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NCS000049
History:
• Date Permit first issued: 10/01/94
• Date Permit re -issued: 09/01/01
• Date: Inspection by Christopher Elmore of the Mecklenburg County Water Quality Program on March 11,
2005
• Date: Permittee submitted renewal application: 02/09/06
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NCS000049
Figure 1: Map of Facility
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Map Scale 1,24,000
Cognis Corporation
Lab Ude: 350 8' 9" N
Longitude: 80° 57' 43" W
County: M�Ienburg
Receiving Stream: Stede Creek
Stream CJass: C
Sub -basin: 03-08-39 (Catawba River Basin)
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Facility Location

NCS000049
Central Office Review Summary:
1. Owner's Other Permits: Owner has no other permits in BIMS.
2. General Observations:
• Based on the site visit 03/11/05 the site seems to be compliant with their permit. The facility is
engaged in producing a wide variety of chemicals for use in industry. The facility stores these products on-
site until they are transport to their purchaser. All production areas and most storage areas are covered to
exclude rainwater. All chemical storage areas have secondary containment.
3. Impairment: Steele Creek is not listed on the 303(d) and not in the Catawba Basinwide Plan.
4. Threatened and Endangered: No State or Federally endangeiecl ou tlueatened species within 2 miles of the site
based on the NC Natural Heritage Victual Workroom.
5. Location: Outfalls goes to a C Stream.
6. industrial Changes Since Previous Permit: The only change was the deactivation of the ethoxilation process in
May of 2005, for which ethylene oxide and phenol are no longer stored in bulk or used in the production at the
plant site.
7. Analytical Monitoring Notes: The analytical monitoring was done three times. A list of reasons was attached
for not being able to sample during March until May 2005. The central file shows no monitoring after the
application was filed. COD had one value over the current benchmark for outfall 3. COD and BOD were
maintained in the monitoring because only 3 samples were taken and more data is needed to withdraw the
monitoring. pH was below the range twice. Acetone was removed after talking to the permit contact. Acetone
is not used in any process onsite and current levels were very low.
Based on the EPA draft 2006 Sector -Specific permit, Sector C "Chemical and Allied Products", TSS should be
included for the SIC 2869.
8. _Qualitative Monitoring Notes: Nine different monitoring was done from 9/4/01 to 11/28/05. Most of the
responses were usual, none, and clear.
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NCS000049
Revised Permit Recommendations: Analytical Monitoring:
1. BOD -5, COD, and pH were maintained. Acetone was removed. TSS was added to the analytical monitoring
requirements based on FPA Sector C "Chemical and Allied Products" recommendations.
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. Exeeedances of benchmark values
require the permittee to increase monitoring, increase management actions, increase record keeping, and/or
install stomiwalet 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.
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NCS000049
Discussions with permittee: Bill Shaw, 704 945 8728, 9/10/08
Randy Rhoades has left new contact is Bill Shaw (Safety and Environmental Manager)
1. General description of industrial activities? Chemical Afanufacture, store raw materials, Incoming & Outgoing
trucks, and mixing chemicals as well as reactors.
2. Have there been any changes since filing the application? Shut down some processes areas.
3. What is your source of potential acetone pollution? Acetone is not in any of the processes and only in very
small quantities in the lab.
4. Do you have a waste water permit? Yes, they have pretreatment and a wastewater permit with Charlotte.
5 Ido you have vehicle maintenance onsite? Some fork lift maintenance.
6. What is you SIC code? NAICS 325998
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NCS000049
Recommendations: Based on the documents reviewed, the application information submitted on February 9, 2006
sufficient to issue an Individual Stormwater Permit.
Date 0, a I s
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Rtgiuunl Office Staff Cutn111elits
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