WQ0034775_Final Permit_20101130

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North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Mr. Ronald Bazinet, Site Leader
Momentive Specialty Chemicals, Inc.
333 Neils Eddy Road
Riegelwood, North Carolina 28456
Dear Mr. Bazinet:
Division of Water Cualit-
Coleen H. Sullins
Director
November 30, 2010
Dee Freeman
Secretary
Subject: Permit No. WQ0034775
Momentive Specialty
Chemicals, Inc. formerly
Hexion Specialty
Chemicals.Inc.
Closed -Loop Recycle System
Columbus County
In accordance with your permit application received April 8, 2010, and subsequent additional
information received August 27, 2010 and October 18, 2010, we are forwarding herewith Permit No.
WQ0034775, dated November 30, 2010, to Momentive Specialty Chemicals, Inc. (formerly Hexion
Chemicals, Inc.) for the operation of the subject wastewater treatment and closed -loop recycle facilities.
This permit shall be effective from the date of issuance until December 31, 2016, and shall be
subject to the conditions and limitations as specified therein. Please pay particular attention to the
monitoring requirements listed in Attachment C. Failure to establish an adequate system for collectinc,
and maintaining the required operational information shall result in future compliance problems.
If any parts, requirements or limitations contained in this permit are unacceptable, the Permittee
has the right to request an adjudicatory hearing upon written request within 30 days following receipt of
this permit. This request shall be in the form of a written petition, conforming to Chapter 150B of the
North Carolina General Statutes, and filed with the Office of Administrative Hearings at 6714 Mail
Service Center, Raleigh, NC 27699-6714. Unless such demands are made. this permit shall be final and
binding.
AwIJIFEP PP 7ECTION SECTV.
16Mf' Se,:ic. Ce r. Re,,.igh..Ah 2 H -1636
Loaf:, 2729 C-r. I Boulevard. P.aieicfi {.: Carolina 275041
919-733-3221 , PnX ': 919-7 ; 5-Wa� K` 2, 919- 15-A4� , CUs ::^.7;Er lifnice: 1-8-'-�23-s 74 '
! ,t: rn: www.ncwaterguality.org
Oil .
N oi-Ji Cai-ol inf.,

Mr. Bazinet
November 30, 2010
Page 2 of 2
One set of approved plans and specifications is being forwarded to you. If you need additional
information concerning this matter, please contact Alice M. Wessner at [phone] or
[e-mail].
Sincerely,
�'r Coleen H, Sullins
cc: Columbus County Health Department
Wilmington Regional Office, Aquifer Protection Section
Daniel C. Shields. P.E., MACTEC Engineering and Consulting, Inc., 5710 Oleander Drive, Suite
110, Wilmington, NC 29403
Technical Assistance and Certification Unit
Permit File WQ0034775
Notebook File WQ0034775

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
CLOSED-LOOP'RECYCLE SYSTEM PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes ofNorth Carolina as
amended, and other applicable Laws, Rules and Regulations
PERMISSION IS HEREBY GRANTED TO
Momentive Specialty Chemicall s, Inc.
Columbus County
FOR THE
operation of a 129,600 gallon per day (GPD) wastewater treatment and closed -loop recycle facility
consisting of: a 130'x100' lined pond, two 1200 gallon per minute (GPM) pumps for Cooling Tower #3,
one 1200 GPM pump for Cooling Tower 45 and one 1200 GPM pump for Cooling Tower #6,
approximately 800 feet of 3-in.ch PVC pipe, and all associated piping, valves, controls, and
appurtenances, to serve Momentive Specialty Chemicals, Inc. (formerly Hexion Specialty Chemicals,
Inc.), with no discharge of wastes to surface waters, pursuant to the application received April 8, 2010,
and subsequent additional information received by the Division of Water Quality on August 27, 2010, and
in conformity with the project plans, specifications, and other supporting data subsequently filed and
approved by the Department of Environment and Natural Resources and considered a part of this permit.
This permit shall be effective from the date of issuance until December 31, 2016 and shall be subject to
the following specified conditions and limitations:
I. SCHEDULES
The Wilmington Regional Office, telephone number [phone], shall be notified at least 48
hours in advance (excluding weekends and holidays) of operation of the installed facilities such that
an in -place inspection can be made. During this inspection the permittee will be required to
demonstrate that the pond is operating with a 2 1/2foot minimum freeboard. Notification to the
Aquifer Protection Section's regional supervisor shall be made from 8:00 a.m. until 5:00 p.in. on
Monday through Friday, excluding State Holidays.
2. The Wilmington Regional Office, telephone number [phone], shall approve monitoring wells
MW-1 and MW-2 prior to installation, and the monitoring wells shall be installed prior to beginning
waste disposal operations. The regional office shall be notified at least 48 hours prior to the
construction of any monitoring well and such notification to the Aquifer Protection Section's regional
supervisor shall be made from 8:00 a.m. until 5:00 p.m. on Monday through Friday, excluding State
Holidays. The monitoring wells shall be constructed such that the water level in the well is never
above or below the screened (open) portion of the well at any time during the year, and in accordance
with 15A NCAC 02C .0108. The general location and name for each monitoring well is marked on
Figure 1.
WQ0034775 Version 1.0 Shell Version 100804 Page I of 6

The Wilmington Regional Office, telephone number [phone], shall approve monitoring wells
MW-1 and MW-2 prior to installation, and the monitoring wells shall be installed within 90 days of
permit issuance. The regional office shall be notified at least 48 hours prior to the construction of any
monitoring well, and such notification to the Aquifer Protection Section's regional supervisor shall be
made from 8:00 a.m. until 5:00 p.m. on Monday through Friday, excluding State Holidays. The
monitoring wells shall be constructed such that the water level in the monitoring well is never above
or below the screened (open) portion of the well at any time during the year, and in accordance with
15A NCAC 02C .0108. The general location and name for each monitoring well is marked on Figure
1.
4, Within 60 days of completion of the monitoring wells, the Permittee shall submit two original copies
of a site map with a scale no greater than 1-inch equals 100 feet, however, special provisions may be
granted upon prior approval for large properties. At a minimum, the map shall include the following
information:
a. The location and identity of each monitoring well.
b. The location of major components of the waste disposal system.
c. The location of property boundaries within 500 feet of the disposal areas.
d. The latitude and longitude of the established horizontal control monument.
e. The elevation of the top of the well casing (i.e., measuring point) relative to a common datum.
f. The depth of water below the measuring point at the time the measuring point is established.
g. The location of compliance and review boundaries.
h. The date the map is prepared and/or revised.
Control monuments shall be installed in such a manner and made of such materials that the
monument will not be destroyed due to activities taking place on the property. The map and any
supporting documentation shall be sent to the Division of Water Quality, Aquifer Protection Section,
1636 Mail Service Center, Raleigh, NC 27699-1636.
A gauge to monitor waste levels in the lined pond shall be installed within 60 days of permit
issuance/prior to operation. Caution shall be taken not to damage the integrity of the liner (if present)
when installing the gauge.
6. Sludge accumulated in the lined pond shall be removed within six (6) months of the permit
issuance date.
No later than six months prior to the expiration of this permit, the Permittee shall request renewal of
this permit on official Division forms. Upon receipt of the request, the Division will review the
adequacy of the facilities described therein, and if warranted, will renew the permit for such period of
time and under such conditions and limitations as it may deem appropriate, Please note Rule 15A
NCAC 02T .0105(d) requires an updated site map to be submitted with the permit renewal
application.
II. PERFORMANCE STANDARDS
The subject non -discharge facilities shall be effectively maintained and operated at all times so there
is no discharge to the surface waters, nor any contravention of groundwater or surface water
standards. In the event that the facilities fail to perform satisfactorily, including the creation of
nuisance conditions due to improper operation and maintenance, the Permittee shall take immediate
corrective actions including Division required actions, such as the construction of additional or
replacement wastewater treatment or recycle facilities.
2. This permit shall not relieve the Permittee of their responsibility for damages to groundwater or
surface water resulting froze the operation of this facility.
WQ0034775 Version 1.0 Shell Version 100804 Page 2 of 6

All wells constructed for purposes of groundwater monitoring shall be constructed in accordance with
15A NCAC 02C .0108 (Standards of Construction for Wells Other than Water Supply), and any other
jurisdictional laws and regulations pertaining to well construction.
4. The facilities permitted herein shall be constructed according to the following setbacks:
a. The setbacks for storage and treatment units permitted after September 1, 2006 shall be as follows
(all distances in feet):
i. Any habitable residence or place of public assembly under separate ownership: 100
ii. Any private or public water supply source: 100
iii. Surface waters: 50
iv. Any well with the exception of a Division approved groundwater monitoring well: 100
v. Any property line: 50
M. OPERATION AND MAINTENANCE REQUIREMENTS
1. The facilities shall be properly maintained and operated at all times. The facilities shall be effectively
maintained and operated as a non -discharge system to prevent the discharge of any wastewater
resulting from the operation of this facility. The Permittee shall maintain an Operation and
Maintenance Plan pursuant to 15A NCAC 02T .1007, which at a minimum shall include operational
functions, maintenance schedules, safety measures and a spill response plan.
Upon the Water Pollution Control System Operators Certification Commission's (WPCSOCC)
classification of the subject non -discharge facilities, in accordance with 15A NCAC 08G .0200 the
Permittee shall designate and employ a certified operator in responsible charge (ORC) and one or
more certified operator(s) as backup ORC(s). The ORC or their back-up shall visit the facilities in
accordance with 15A NCAC 08G .0200, and shall comply with all other conditions specified in the
previously cited rules.
3. Public access to the wastewater treatment facilities closed -loop recycle system shall be prohibited.
4. The residuals generated from the wastewater treatment facilities shall be disposed or utilized in
accordance with 15A NCAC 02T .1100. The Permittee shall maintain a residual management plan
pursuant to 15A NCAC 02T .1008.
Diversion or bypassing of untreated or partially treated wastewater from the treatment facilities is
prohibited.
6. Freeboard in the lined pond shall not be less than two and a half feet at any time.
7. A gauge to -monitor waste levels in the lined pond shall be provided. This gauge shall have readily
visible permanent markings indicating the following elevations: maximum liquid level at the top of
the temporary liquid storage volume; minimum liquid level at the bottom of the temporary liquid
storage volume; and the lowest point on top of the dam.
S. A protective vegetative cover shall be established and maintained on all earthen embankments (i.e.,
outside toe of embankment to maximum allowable temporary storage elevation on the inside of the
embankment), berms, pipe runs, erosion control areas, and surface water diversions. Trees, shrubs,
and other woody vegetation shall not be allowed to grow on the earthen dikes or embankments -
Earthen embankment areas shall be kept mowed or otherwise controlled and accessible.
WQ0034775 Version 1.0 Shell Version 100804 Page 3 of 6

IN'. MONITORING AND REPORTING REQUIREMENTS
1. Any Division required monitoring (including groundwater, plant tissue, soil and surface water
analyses) necessary to ensure groundwater and surface water protection shall be established, and an
acceptable sampling reporting schedule shall be followed.
2. Per 15A NCAC 02H .0800, a Division certified laboratory shall conduct all laboratory analyses for
the required effluent, groundwater or surface water parameters.
3. Freeboard (i.e., waste level to the lowest embankment elevation) in the lagoon shall be recorded
weekly. Weekly freeboard records shall be maintained at the facility for a period of no less than five
years, and shall be made available to the Division upon request.
4. Monitoring wells shall be sampled after construction and within 3 months prior to initiating non -
discharge disposal operations. Monitoring wells shall be sampled thereafter at the frequencies and for
the parameters specified in Attachment C. All mUping. well construction forms well abandonment
forms and monitoring data shall refer to the permit number and the well nomenclature as provided in
Attachment C and Figure 1.
5. For initial sampling of monitoring wells, the Permittee shall submit a Compliance Monitoring Form
(GW-59) and a Well Construction Record Form (GW-1) listing this permit number and the
appropriate monitoring well identification number. Initial Compliance Monitoring Forms (GW-59)
without copies of the Well Construction Record Forms (GW-1) are deemed incomplete, and may be
returned to the Permittee without being processed.
Two copies of the monitoring well sampling and analysis results shall be submitted on a Compliance
Monitoring Form (GW-59), along with attached copies of laboratory analyses, on or before the last
working day of the month following the sampling month. The Compliance Monitoring Form (GW-
59) shall include this permit number, the appropriate well identification number, and one GW'-59a
certification form shall be submitted with each set of sampling results. All information shall be
submitted to the following address:
Division of Water Quality
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
7. Noncompliance Notification:
The Permittee shall report by telephone to the Wilmington Regional Office, telephone number (910)
796-7215, as soon as possible, but in no case more than 24 hours, or on the next working day
following the occurrence or first knowledge of the occurrence of any of the following:
a. Any occurrence at the facility resulting in the treatment of significant amounts of wastes that is
abnormal in quantity or characteristic, including the known passage of a hazardous substance.
b. Any process unit failure (e.g., mechanical, electrical, etc.), due to known or unknown reasons,
rendering the facility incapable of adequate wastewater treatment.
c. Any facility failure resulting in a by-pass directly to receiving surface waters.
d. Any time self -monitoring indicates the facility has gone out of compliance with its permit
limitations.
Any emergency requiring immediate reporting (e.g., discharges to surface waters, imminent failure of
a storage structure, etc.) outside normal business hours shall be reported to the Division's Emergency
Response personnel at telephone number [phone], [phone], or [phone].
Persons reporting such occurrences by telephone shall also file a written report in letter form within
five days following first knowledge of the occurrence. This report shall outline the actions taken or
proposed to be taken to ensure the problem does not recur.
WQ0034775 Version 1.0 Shell Version 100804 Page 4 of 6

V. INSPECTIONS
1. The Permittee shall provide adequate inspection and maintenance to ensure proper operation of the
wastewater treatment and recycle facilities.
2. The Permittee or their designee shall inspect the wastewater treatment and recycle facilities to prevent
malfunctions, facility deterioration and operator errors resulting in discharges, which may cause the
release of wastes to the environment, a threat to human health or a public nuisance. The Permittee
shall maintain an inspection log that includes, at a minimum, the date and time of inspection,
observations made, and any maintenance, repairs, or corrective actions taken. The Permittee shall
maintain this inspection log for a period of five years from the date of the inspection, and this log
shall be made available to the Division upon request.
3. Any duly authorized Division representative may, upon presentation of credentials, enter and inspect
any property, premises or place on or related to the wastewater treatment and recycle facilities
permitted herein at any reasonable time for the purpose of determining compliance with this permit;
may inspect or copy any records required to be maintained under the terms and conditions of this
permit, and may collect groundwater, surface water or leachate samples.
VI. GENERAL CONDITIONS
1. Failure to comply with the conditions and limitations contained herein may subject the Permittee to
an enforcement action by the Division in accordance with North Carolina General Statutes 143-
215.6A to 143-215.6C.
2. This permit shall become voidable if the permitted facilities are not constructed in accordance with
the conditions of this permit, the Division approved plans and specifications, and other supporting
documentation.
3. This permit is effective only with respect to the nature and volume of wastes described in the permit
application, Division approved plans and specifications, and other supporting documentation. No
variances to applicable rules governing the construction or operation of the permitted facilities are
granted, unless specifically requested and approved in this permit pursuant to 15A NCAC 02T
.0105(n).
4. The issuance of this permit does not exempt the Permittee from complying with any and all statutes,
rules, regulations, or ordinances, which may be imposed by other jurisdictional government agencies
(e.g., local, state, and federal). Of particular concern to the Division are applicable river buffer rules
in 15A NCAC 02B .0200; erosion and sedimentation control requirements in 15A NCAC Chapter 4
and under the Division's General Permit NCG010000; any requirements pertaining to wetlands under
15A NCAC 02B .0200 and 02H .0500; and documentation of compliance with Article 21 Part 6 of
Chapter 143 of the General Statutes.
5. In the event the permitted facilities change ownership or the Permittee changes their name, a formal
permit modification request shall be submitted to the Division. This request shall be made on official
Division forms, and shall include appropriate property ownership documentation and other supporting
documentation as necessary. The Permittee of record shall remain fully responsible for maintaining
and operating the facilities permitted herein until a permit is issued to the new owner.
6. The Permittee shall retain a set of Division approved plans and specifications for the life of the
facilities permitted herein.
7. The Permittee shall maintain this permit until all permitted facilities herein are properly closed or
permitted under another permit issued by the appropriate permitting authority pursuant to 15A NCAC
02T .01050).
WQ0034775 Version 1.0 Shell Version 100804 Page 5 of 6

S. This permit is subject to revocation or unilateral modification upon 60 days notice from the Division
Director, in whole or part for the requirements listed in 15A NCAC 02T .0110.
9. Unless the Division Director grants a variance, expansion of the permitted facilities contained herein
shall not be granted if the Permittee exemplifies any of the criteria in 15A NCAC 02T .0120(b).
10. The Permittee shall pay the annual fee within 30 days after being billed by the Division. Failure to
pay the annual fee accordingly shall be cause for the Division to revoke this permit pursuant to 15A
NCAC 02T .0105(e)(3).
Permit issued this the 30`h day of November 2010
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
i
Zw Veen ullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0034775
WQ0034775 Version 1,0 Shell Version 100804 Page 6 of 6

ATTACHMENT C — GROUNDWXrER MONITORING AND LIMITATIONS
Monitoring wells: 11 V-1 and MAV 2
Permit Number: WQ0034775 Version: 1.0
GROUNDWATER CHARACTERISTICS
GROUNDWATER STANDARDS
MONITORING REQUIREMENTS
Parameter Description - Parameter Code
Daily Maximum
frequency Measurement
Sample Type
Footnotes
Water level, distance from Measuring point - 82546
feet
3 x year
Calculated
1,2
pl l - 00400
6.5 - 8.5
SAL
3 x year
Grab
I
Solids, fotal Dissolved- 180 Deg.0 - 70300
500
ingil
3 x year
Grab
Sulfate, Total (as SO4) - 00945
250
Mg/t
3 x year
Grab
Nitrogen, Ammonia Total (as N) - 00610
1500
}ig/I
3 x year
Grab
Nitrogen, Nitrate Total (as N) - 00620
10
mg/I
3 x year
Grab
Volatile Compounds, (GC/MS) - 78732
ing/1
Annually
Grab
3,4
Carbon, Tot Organic JOC) - 00680
nlg/I
3 x year
Grab
6
Methanal (Formaldehyde) wliole Water - 76995
Got}
11g/I
3 x year
Grab
I. 3 x Year monitoring shall be conducted in March, July 8c November; annual monitoring shall be conducted every November.
2. The measurement of water levels shall be made pricer to purging the wells. The depth to water in each well shall be measured from the surveyed point on the top of the casing. The measurement
of pli shall be made all:er purging and prior to sampling for the remaining parameters.
3. The measuring points (top of well casing) of all monitoring wells shall be surveyed to provide the relative elevation of the pleasuring point for each ionitoring well. The measuring points (top
of casing) of all monitoring wells shall be surveyed relative to a common datum.
4. Volatile Organic Compounds (VOC) - In November only, analyze by one of the following methods:
U. Standard Method 6230D, PQL at 0.5 Iig/L or less
b. Standard Method 6210D, PQL at 0.5 pg/L or less
e. EPA Method 802 I, Low Concentration, PQL at 0.5 µg/L or less
d. EPA Method 8260, Low Concentration, PQL at 0.5 )ig/L or less
e. Another method with prior approval by the Aquifer Protection Section Chief
Any method used must meet the following qualifications:
a. A laboratory must be t)1TvQ eertitied to ran any method used.
b. The method used must, at a mininliim, include all the constituents listed in Table VI11 of Standard Method 6230D.
c. The method used must provide a PQL of 0,5 µg!L or less that must be supported by laborato y proficiency studies as required by the DWQ Laboratory CertiFication Unit. Any constituents
detected above (lie NIDL but below the PQL of 0.5 µg/L must be qualified (estimated) and reported.
5. If any volatile organic compounds (VOC) are detected as a result of monitoring as provided in Attachment C, then the Wilmington Regional Office Aquifer Proteetioll Supervisor, telephone
number [phone], must be contacted immediately for further instructions regarding any additional tbllow-nip analyses required.
6. Monitoring wells shall he reported consistent with (lie nomenclature and location infonnation provided in Figure I and this attachment_
WQ0034775 Version 1.0 Attachment C Page I of I

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