Sept 2009 Draft Letter on Revision

ALYI-WYTA
�ia
NCDENR
North Carolina Department «fEnvironment nndNatnral
Division of Water Quality
Beverly Eaves Perdue COe8n..8UUiD8
(jOVe0O[ Director
DRAFT
September I'2OO9
Ms. Linda Denison
Ashland Inc.
P0Box 22I9
Columbus, Ohio 432I6
Resources
Dee Freeman
Secretary
Subject: Revised NPDE5StonnwaterPermit
Permit No. NCS0003I5
Ashland Distribution
Mecklenburg County
Dear Ms. Denison:
Following our site visit to the Ashland Distribution facility on August 26, 2009, the Stormwater
Permitting Unit (SPU) has revised the requirements ofthe appealed NPOE5 permit as attached based
on site observations and discussions with Ashland personnel. The revised permit contains the
foUnvvmg proposed changes:
l. The number ofstorrnvvater outfalls covered under the permit has been reduced to one (I)
outfall associated with industrial activity. Approximately seven (7) outfalls were observed at
the facility, however, the drainage area feeding Outfall 001 captures the hazardous waste
portion of the site and presents the largest exposure potential.
2. Analytical and qualitative monitoring requirements apply only to Outfall 001 which drains the
area around the hazardous waste storage area. |tissuggested that Ashland continue visual
monitoring of all stormwater discharge outfalls as part of the stormwater pollution prevention
plan in place atthe facility.
The revised permit contains no other changes from the appealed permit except that Table 2 dates
have been updated to reflect 8 new effective permit date. Monitoring parameters, frequency and
duration remain the same.
VVefeel that the revised permit limits the cost, time, and energy burden placed onAshland tothe
nnaxirnunn extent practicable vvhi|8 still protecting water quality at the site, Additionally, the revised
permit is equitable tothose already in place across the State including approximately 2,500 general
permits and nearly I00 individual permits. Each of these permits contains components similar to
those in Ashland's permit (e.g. analytical monitoring requirements, semi-annual schedule,
benchmarks, tiered system, etc).
We appreciate the opportunity to visit the site and commend Ashland on maintaining a well -kept
facility. If you have any questions or comments concerning permit revisions, please contact Cory
Larsen at(9I9)807-h355orKen Pickle at(9I9)887'5376.
Sincerely,
Bradley Bennett
SPU Supervisor
Wetlands and Storinwater Branch
1m7Mail Service Center, Raleigh, North Carolina umo9-1n17
Location: 51uw.Salisbury St. Raleigh, North Carolina u76o ^ `
oithCarolina
Phone: e1n-8o -6300\FAx:91e-807'0494\Custnmo,S*mkm: 1-877-623-6748 ^/
|mnmm��n��nm�mmuo|i��� � ' --' ''' '--'�y
An Eooal 0000r1uni*\ Affirmative Action Emmmm,

Ms. Linda Denison
Ashland Inc.
Permit No. NCB0003I5
yu 2
�e
cc: McGuire@boodsLLP' Benne[. Hudson
Department ofjustice, John A. Payne
Mooresville Regional Office, Dee Browder
5tornnmxaterPenmitting Unit
Central Files
Attachments
2