NCS000315 2009 Permitee Comments

ASHLANEX
Environmental, Health and Safety
February 25, 2009
CERTIFIED MAIL — Return Receipt Requested
Mr. Cory Larsen
Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Comments on Draft Renewal Permit
Ashland Distribution
3930 Glenwood Drive
Charlotte, NC
Permit #NCS000315
Dear Mr. Larsen:
Ashland Inc.
P. O. Box 2219
Columbus, OH 43216
TO: 614 790-33.33, Fax: [phone]
www.ashland.com
Ashland Inc. (Ashland) would like to thank you for the opportunity to comment on the draft
NDPES Stormwater Permit issued by your office. Overall, the permit is what we anticipated;
however there are a few specific items we are requesting to modify.
Part II, Section A, Paragraph 5.
This section requires that annual training be documented by the signature of each
employee trained. Ashland uses on-line training to meet many of our regulatory training
requirements. Each employee must log in to the system with their unique ID number and
password. At the end of the training class, the employee must pass a test on the subject.
Completion of the training and test scores are maintained electronically. A sign in sheet
is used and employee signatures are collected only when group training is performed.
Ashland would like to propose the following language for the final sentence of paragraph
five "Facility personnel (or team) responsible for implementing the training shall be
identified, and their annual training shall be documented by the signature of each
employee trained or recorded in Ashland's electronic training system."
2. Part II, Section B — Analytical Monitoring Requirements
Ashland requests that this section be removed completely, or at least limit the outfalls to
which it applies. Only outfall 001 is associated with an activity that requires a storm
water permit under 40 CFR 122.26. Outfall 001 collects stormwater from the area near
the hazardous waste storage building. All hazardous waste is stored on a raised, bermed

concrete pad covered with a canopy. The hazardous waste containers are not directly
exposed to storm water.
The remaining outfalls are associated with chemical distribution, SIC code 5169, which is
not subject to permitting requirements under US EPA or NC DENR regulations.
Ashland requests that the first paragraph in Section B state that only outfall 001 must
have analytical monitoring conducted.
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Thank you again for the opportunity to comment on the draft permit. If you have any questions,
or need additional information, please contact me at 614-790-4277 or via e-mail at
[e-mail].
Sincerely, q/
Linda J. Denison, CHMM
Environmental Engineer
Cc: Mike Trull — Charlotte Facility Manager
File: AD/ Permits / Charlotte /Water
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