WQ0034775_Final Permit_20150213

AMMMA
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
February 13, 2015
Ronald Bazinet , Site Leader
Hexion, Incorporated
333 Neils Eddy Road
Rieglewood, North Carolina 28456-9570
Dear Mr. Bazinet:
Donald R. van der Vaart
Secretary
Subject: Permit No. WQ0034775
Hexion, Incorporated
Closed -Loop Recycle System
Columbus County
In accordance with your permit name change request received January 22, 2015, we are
forwarding herewith Permit No. WQ0034775 dated February 13, 2015, to Hexion, Incorporated for the
continued operation of the subject wastewater treatment and closed -loop recycle facilities.
Please note the Pernaittee has been changed from Momentive Specialty Chemicals, Incorporated
to Hexion, Incorporated.
This permit shall be effective from date of issuance until December 31, 2016 shall void Permit
No. WQ0034775 issued November 30, 2010, and shall be subject to the conditions and limitations as
specified therein. Please pay particular attention to the monitoring requirements listed in Attachment C
for they may differ from the previous permit issuance. Failure to establish an adequate system for
collecting 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.
If you need additional information concerning this permit, please contact Alice M. Wessner at
[phone] or [e-mail].
Sincerely,
,Z.—ASJa Zimmerman, Acting Director
Division of Water Resources
cc: Columbus County Health Department Health Director Kimberly Smith
kim.l.smithCcD_columbusco.org (Electronic Copy)
Wilmington Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Central Files
Digital Permit Archive (Electronic Copy)
Non -discharge Permitting Unit
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Phone: 9IM07-64641 Internet: http:ltportaJ.ncdenr.orglweblwg
An Equal Opporlun,;y 1 Affirmative Action Employer - Made in part with recycled paper

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 of North Carolina as
amended, and other applicable Laws, Rules and Regulations
PERMISSION IS HEREBY GRANTED TO
Hexion, Incorporated
Columbus County
FOR THE
continued 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 43, one 1200 GPM
pump for Cooling Tower #5 and one 1200 GPM pump for Cooling Tower #6, approximately 800 feet of
3-inch PVC pipe, and all associated piping, valves, controls, and appurtenances, to serve aliceMomentive
Specialty Chemicals, Inc. (formerly Hexion Specialty Chemicals, Inc.), with no discharge of wastes to
surface waters, pursuant to the application received January 2, 2015, , 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 date of issuance until December 31, 2016, shall void Permit No.
WQ0034775 issued November 30, 2010 and shall be subject to the following specified conditions and
limitations:
I. SCHEDULES
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. [15A NCAC 02T .0105(d), 02T .0106, 02T .0109, and 02T .0115(c)]
IT. 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. [15A NCAC 02T .0108(b)(1)]
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2. This permit shall not relieve the Permittee of their responsibility for damages to groundwater or
surface water resulting from the operation of this facility. [ 15A NCAC 02B .0200, 02L .0100]
3. 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. [15A NCAC 02C .0108]
4. The facilities permitted herein shall be constructed according to the following setbacks:
a. The setbacks for storage and treatment units permitted under 15A NCAC 02T .1000 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
[15A NCAC 02T .1006(a)]
III. OPERATION AND MAINTENANCE REOUII2EMENTS
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, which at a minimum shall include operational functions, maintenance schedules,
safety measures and a spill response plan. [15A NCAC 02T .1007]
2. 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 back-up 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. [ 15A NCAC 02T A 117]
3. Public access to the wastewater treatment facilities and closed -loop recycle system shall be
prohibited. [15A NCAC 02T .1000(a)(1)]
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. [15A NCAC 02T .1008, 02T .1100]
5. Diversion or bypassing of untreated or partially treated wastewater from the treatment facilities is
prohibited. [15A NCAC 02T 15A NCAC 02T .0108(b)(1)]
6. Freeboard in the lined pond shall not be less than two and half feet at any time. [15A NCAC 02T
.1005(b)(6)]
7. A gauge to monitor waste levels in the lined pond shall be provided. This gauge shall have readily
visible permanent markings, at inch or tenth of a foot increments, 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. [15A NCAC
02T .0108(b)(1)]
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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. [15A NCAC
02T .0108(b)(1)]
IV. 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. [ 15A NCAC 02T .0108(c)]
2. A Division certified laboratory shall conduct all laboratory analyses for the required effluent,
groundwater or surface water parameters. [15A NCAC 02H .0800]
3. Freeboard (i.e., waste level to the lowest embankment elevation) in the lined pond shall be measured
to the nearest inch or tenth of a foot, and 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. [ 15A NCAC 02T .0108(c)]
4. A record shall be maintained of all residuals removed from this facility. This record 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. At a minimum, this record shall include:
a. Name of the residuals hauler;
b. Non -Discharge permit number authorizing the residuals disposal, or a letter from a municipality
agreeing to accept the residuals;
c. Date the residuals were hauled; and
d. Volume of residuals removed.
[15ANCAC 02T. 0 10 8(b)(1)]
5. 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 mapping, well construction forms, well abandonment
forms and monitoring data shall refer to the permit number and the well nomenclature as provided in
Attachment C. [15A NCAC 02T .0105(m)]
6. 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 Resources
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
[15A NCAC 02T .0105(m)]
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7. Noncompliance Notification:
V.
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. Treatment of wastes 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. [15A NCAC 02T .0105(1), 02T
.0108(b)(1)]
1. The Permittee shall provide adequate inspection and maintenance to ensure proper operation of the
wastewater treatment and recycle facilities. [15A NCAC 02T .0108(b)]
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. [15A NCAC 02T .0108(b)]
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. [G.S. 143-21.5.3(a)(2)]
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. [G.S. 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. [15A NCAC 02T .0110]
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). [G.S. 143-21.5.1]
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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 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. [15A NCAC 02T .0105(c)(6)]
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. [15A NCAC
02T .0104]
The Permittee shall retain a set of Division approved plans and specifications for the life of the
facilities permitted herein. [15A NCAC 02T .0108(b)(1)]
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. [15A NCAC 02T
.01050)]
8. 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. [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). [ 15A
NCAC 02T .0120]
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 because for the Division to revoke this permit. [15A NCAC 02T
.0105(e)(3)]
Permit issued this the 13th day of February 2015
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
r ay Z' merman, Acting Director
Division of Water Resources
By Authority of the Environmental Management Commission
Permit Number WQ0034775
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ATTACHMENT C --- GROUNDWATER MONITORING AND LIMITATIONS
Monitoring wells: MW-1, MW-2
Permit Number: WQ0034775 Version: 1.1
GROUNDWATER CHARACTERISTICS
GROUNDWATER STANDARDS
MONITORING REQUIREMENTS
PCS Code
Parameter Description
Daily Maximum
Frequency Measurement
Sample Type
Footnotes
00680
Carbon, Tot Organic (TOC)
mg/L
3 x Year
Grab
1,6
00610
Nitrogen, Ammonia Total (as N)
1.5
mg/L
3 x Year
Grab
1
00620
Nitrogen, Nitrate Total (as N)
10
mg/L
3 x Year
Grab
1
00400
pH
6.5-8.5
su
3 x Year
Grab
1,2
00665
Phosphorus, Total (as P)
mg/L
3 x Year
Grab
1
70300
Solids, Total Dissolved - 180 °C
500
mg/L
3 x Year
Grab
1
00945
Sulfate, Total (as SO4)
250
mg/L
3 x Year
Grab
1
76995
Methanal (Formaldehyde) Whole Water
60.0
µg/L
3 x Year
Grab
I
GWVOC
Volatile Compounds (GC/MS)
Present: Yes/No
Annually
Grab
1, 4, 5
82546
Water Level, Distance from measuring point
feet
3 x Year
Calculated
I, 2, 3
I . 3 x Year monitoring shall be conducted in March, July & November; Annual monitoring shall be conducted every November.
2. The measurement of water levels shall be made prior 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 pH shall be made after 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 measuring point for each monitoring 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:
a. Standard Method 6230D, PQL at 0.5 µg/L or less
b. Standard Method 6210D, PQL at 0.5 ltg/L or less
c. EPA Method 8021, Low Concentration, PQL at 0.5 µg/L or less
d. EPA Method 9260, Low Concentration, PQL at 0.5 µg/L or less
e. Another method with prior approval by the Water Quality Permitting Section Chief
Any method used must meet the following qualifications:
a. A laboratory must be DWR certified to run any method used.
b. The method used must, at a minimum, include all the constituents listed in Table VIII of Standard Method 6230D.
c. The method used must provide a PQL of 0.5 µg/L or less that must be supported by laboratory proficiency studies as required by DWR. Any constituents detected above the MDL 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 supervisor, telephone number [phone],
must be contacted immediately for further instructions regarding any additional follow-up analyses required.
6. If TOC concentrations greater than 10 mg/L are detected in any downgradient monitoring well, additional sampling and analysis must be conducted to identify the individual constituents
comprising this TOC concentration. If the TOC concentration as measured in the background monitor well exceeds 10 mg/L, this concentration will be taken to represent the naturally occurring
TOC concentration. Any exceedances of this naturally occurring TOC concentration in the downgradient wells shall be subject to the additional sampling and analysis as described above.
7. Monitoring wells shall be reported consistent with the nomenclature and location information provided in this attachment.
WQ0034775 Version 1.1 Attachment C Page 1 of I