NCS000315 Staff Report - 2008

NCS000315
Ashland Distribution Co.
Vd A % -4E�'
Michael F. Easley, Governor
? Q�William
G. Ross Jr., Secretary
Type of Activity:
North Carolina Department of Environment and Natural Resources
SIC Code (if applicable):
Coleen H. Sullins Director
gi 74
Division of Water Quality
River Basin:
Catawba River Basin, Sub -basin 03-08-34
Stream Classification:
Class C
Proposed Permit Requirements:
STAFF REVIEW ANIS EVALUATION
Monitoring Data:
NPDES Stormwater Permit
Facility Name:
Ashland Distribution Co.
NPDES Permit Number:
NCS000315
Facility Location:
3930 Glenwood Dr, Charlotte, NC (Mecklenburg County) See Figure 1
Type of Activity:
CHEMICAL DISTRIBUTION
SIC Code (if applicable):
5169
Receiving Streams:
MSSS to Stewarts Creek
River Basin:
Catawba River Basin, Sub -basin 03-08-34
Stream Classification:
Class C
Proposed Permit Requirements:
See attached draft permit.
Monitoring Data:
See Table 1
Response Requested by (Date):
December 20, 2008
Central Office Staff Contact:
Return to Cory Larsen, [phone]
Special Issues:
Issue
Rating Scale: I(easy) to 10(hard)
Compliance history
2
Benchmark exceedance
1
Location (TMDL, T&E
species, etc)
7
Other Challenges:
• Renewal app
lacking info
8
Di culty Rating:
(18)/40
Special Issues Explanation:
• NA
Description of Onsite Activities:
• The facility blends, repackages and distributes organic solvents to customers. They also pickup and
temporarily store spent solvents (haz waste) collected from customers onsite. They are a large -quantity haz waste
generator.
Documents Reviewed:
• SPU & Central Files
• 2008 Draft 303(d) List
• Final NC TMDL List
• 2004 Catawba Basinwide Plan
• NC Natural Heritage Program for T&E species
History:
• Date Permit first issued: June 1, 1996
• Date Permit re -issued: January 1, 2002
• Date Permittee submitted renewal application: July 6, 2006
Page 1 of 6

I
NCS000315
NCS000315
Map Scale 1,,20,000
Ashland Inc.
Ashland Distribution Co.
Lab tude: 35c' 15' 2.08" N
Longitude: 800 53' 11.18" W
County: Mecklenburg
Receiving Stream: Stewats Creek,
Stream Class: C
Sub -basin: 03-08-04 (Cata,.vba River Basin)
Figure]: Map of Facility
Page 2 of 6
Facility Location

NCS000315
Central Office Review Summary:
1. Owner's Other Permits: (If applicable)
• NCGO90026 Paints, Varnishes & Lacquers (Greensboro facility)
• NCD061263315R2 RCRA permit (Charlotte facility)
2. General Observations:
Medium-sized facility with high percentage of impervious cover. Located in industrial and residential areas.
3. Impairment: Irwin Creek, which Stewart's Creek drains into, is an impaired water body listed on the 303(4) list for
turbidity and lead violations and is discussed in the Catawba Basinwide Plan for fecal coliform contamination and
elevated turbidity. Irwin Creek currently has Final TMDLs for fecal coliform & turbidity.
4. Threatened and Endangered: One species, the Carolina Heelsplitter has state and federal protection status E (Natural
Ilei itago Map).
5. Location: Facility is located in an industrialized area bordering residential areas in Charlotte. Stormwater from the
site discharges to the municipal storm sewer system that conveys stormwater to Stewart's Creek.
6. Industrial Changes Since Previous Permit: In addition to chemical distribution activities, the permittee recently added
a small shed to store haz waste onsite prior to disposal
7. Analytical Monitoring Notes: No analytical monitoring required per current permit.
8. Qualitative Monitoring Notes: Visual monitoring performed semi-annually since October 2001. Consistent light
brown to brown color in stormwater discharge at all outfalls. Monitoring also indicates some level of floatable and
suspended solids and reduced clarity. See Table 1 below.
Page 3 of 6

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NCS000315
Revised Permit Recommendations: Analytical Monitoring:
1. Adding parameters...
a. TSS — to monitor for solids and provide quantitative gauge of color/clarity of discharge noted on visual
monitoring summary. Turbidity TMDL in place downstream as well;
b. O&G — rationale is that facility has heavy truck traffic as a distribution plant and O&G associated with large
trucks may need to be monitored;
c. COP — this parameter should be a good indicator of general organic compounds picked up by stormwatcr as it
runs offsite.
d. Toluene — consistent onsite releases from 1998-2006. Parameter not measured by COD analysis.
e. Xylene — consistent onsite releases from 1998-2006. Parameter may not be measured by COD analysis.
2. pH added.
3. All analytical monitoring set to semi-annually.
4. Benchmarks for analytical monitoring and Tiered monitoring system added to this draft permit.
5. Analytical and qualitative monitoring required during representative storm events. Qualitative monitoring required
regardless of representative outfall status.
6. Flow reporting replaced by total rainfall parameter.
7 Vehicle maintenance monitoring revised to semi-annually
Other Proposed Changes to the Previous Permit:
1. See draft permit for frill details.
Discussions with permittee: Linda Denison, 614-790-4277, 10/17/2008, 10/27/08
1. Q: Is 5159 your correct SIC code?
a. ANSWER: 5169 is correct.
2. Q: Can you please provide a description of facility activities?
a. ANSWER: This facility is involved in chemical distribution of solvents which includes blending and
repackaging components for customers. No manufacturing occurs at this facility.
3. Q: What kinds of solvents are onsite?
a. ANSWER: The facility handles 100's of types of solvents. Some chemicals include but are not limited to
peroxides, acetone, hexane, toluene, MEK, naphthalene, ethers, etc.
4. Q: What chemicals are stored outdoors?
a. ANSWER: Most chemicals are stored under roof in warehouses. Chemicals stored outside such as in the
tank -farm have concrete bermed secondary containment sized to hold 110% of tank volume plus the water
volume of the 25 -year 24-hour storm. Everything outside has secondary containment per SPCC requirements.
5. Q: How many total outfalls are onsite?
a. ANSWER: The facility now has seven separate stormwater outfalls.
6. Q: How much vehicle maintenance is performed onsite?
a. ANSWER: Some maintenance is performed on a small fleet of trucks resulting in less than 55 gal/mo of new
motor oil usage.
7. Q: How does the facility receive/distribute chemical shipments?
a. ANSWER: Mainly by truck. Rail not used often anymore.
8. Q: How much haz waste is stored onsite?
a. ANSWER: A small shed is utilized for haz waste storage. The facility is a permitted as a large quantity HW
generator.
9. Q: Are there any sources of lead onsite or any lead additives in solvents handled there?
a. ANSWER: No lead product is handled in the process area. Any HW containing lead is not exposed.
Page 5 of 6

NCS000315
Recommendations: Based on the documents reviewed, the application information submitted on July 6, 2006
sufficient to issue an Individual Stormwater Permit.
Prepared by (Signature) Date_
Stormwater Permitting i Tnit Supervisor (s��� _ � NF1 r .. _�+' Pate
or Br e tt
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Concurrence by Regional Office Date -2'W46
♦ P / j� � Y
Water Quality Supervisor. -- Date
Regional Office Staff Comments
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Page 7 of 7