NCS000049 Review Document

Last update: 111512018
NC Division of Energy, Mineral and Land Resources
Review for Permit Renewal — NCS000049
IGM Resins USA Inc. - Charlotte, NC
• Facility Activities and Process — Website says they specialize in development, manufacturing and supply of products and
technical services to the global UV ink and coating industry. UV and EB (Electronic beam) energy cured coatings. DWM
RCRA inspection states IGM is a manufacturer of UV acrylate esters where bases are mixed with acrylic acid to produce
UV light sensitive resins. Resins are used in paint to produce a drying effect immediately after the paint is applied to any
surface that is expose to sun light. Most likely SIC 2821— Plastic Materials and Synthetic Resins. Currently 2869 in BIMS.
• Monitoring — The facility has been monitoring for TSS, COD, BOD and pH. Previous permit did have tier system.
o Data from 2009 — 2013 (in renewal app) shows five benchmark exceedances for TSS, two for COD, none for BOD
and 12 for pH. Data for 2014 -2018 submitted indicates fewer exceedances and a few high values that did not
exceed. pH values did not exceed during this time frame.
o All pH exceedances were for values below 6.
o No BOD exceedances, so propose to remove BOD from permit.
o Some question from review of files about the monitoring locations for at least one of the outfalls. In a 2009
inspection conducted by Charlotte -Mecklenburg Stormwater Services (CMSWS) several issues came up, including
the concern that the facility was monitoring what they called a swale. The swale goes through the property and
could be a channelized stream. The swale also collects discharge from another property. The MRO asked that
they create a new outfall (005) for a discharge going into the swale and stop sampling the swale (004) as it leaves
the property and flows into the creek since this was not an outfall point. This was verified in correspondence from
the central office with previous owners in June 2010 letter. In the previous permit renewal staff in the MRO had
outlined where outfalls should be monitored. It appears that with change of ownership, etc. the facility may still
be monitoring the swale?
o Parameters remaining in the permit —TSS, COD and pH.
o Tier structure adjusted to have the three levels as in current permits.
o Parameter codes added to permit.
Discussions with Facility— Need to check on the activities at the site. Are they different from the previous owner (Cognis
Corporation)? Is the SIC different? Are there potentially different parameters of concern that haven't been monitored
for? Check on the outfall points, are they still monitoring the Swale instead of the outfall (see discussion above). Name
change in DWM LF files indicates no changes in operation with owner change to IGM.
Conference call with Gerald Walker (IGM) and Kim Ackerman (consultant) — 8/29/18. Major items discussed:
o Changes in Process — No major changes, but reduction in process. They lost their largest customer so there is less
material on site and they have dropped to 5 days per week production.
o Questions on Monitoring Locations — Discussed the issues with monitoring of swale versus outfall point (see
discussion above under monitoring). Facility staff working with process now were not here in that timeframe and
seemed unaware of the previous issues. They confused the discussion with an outfall from an off site facility that
also goes to the swale. Forwarded the previous correspondence to Gerald and Kim in an email on 8/29 for their
review and response.
o Discussion of Spills and Drainage to WW Treatment — Inspection info outlined spill issues in previous years.
Discussed this and staff indicated there had been a wastewater leak that was repaired and materials cleaned up,
etc. Indicated that all of the tank farm area at the facility drains to wastewater treatment. Also said whole
production area goes to WW treatment. They indicated they do have a map showing the drainage area that flows
to WW. Could be helpful for regional staff during inspection.
o Permit Timeframe — Discussed with facility staff that in order to help with backlog and get renewals on better time
frames where equal numbers come up for renewal each year, we are short cycling some permits. Their permit will
run through 2021.
Sent a second email to Gerald and Kim on 9/10/18 to try and get accurate locations for outfalls to enter in BIMS.
Previous information submitted had the same lat/long for all four outfalls.
Surface Water Information - Facility drains to Steele Creek in the Catawba River Basin, 11-137-10 , a class C stream. 2016
Integrated Report does not list this stream segment as having any impairment issues.
NC National Heritage review — NHP report shows no aquatic resources within project area or within one mile. No areas
of concern for the discharge from this facility.
Regional Office Information - MRO — Draft to region and CMSWS on 09/19/2018 by email. Asked them to review the
issues of sampling instream. MRO visited the site on 10/18/18 and sent okay to issue 10/22/18. But there was no

Last update: 111512018
response to the issue of whether they were sampling in a stream segment. Email to MRO to ask about this on 11/5/18.
Talked with James—11/5/18 and he doesn't think they are monitoring instream. Thinks there are only four outfalls and
the MRO will be working with them in the future on ROS.
See image to the right . Faci
They still show it as an outfall point even though this was pointed out in a 2010 letter about a new outfall #005
check this on site visit.
May need to