NCS000088_COMPLIANCE_20080515

--STORMINATER"DIVISION-CODfNG-SHEET
PERMIT NO.
MCC-, DOoD
DOC TYPE
❑FINAL PERMIT
❑ MONITORING INFO
❑ APPLICATION
� COMPLIANCE
❑ OTHER
DOC DATE
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YYYYMMDD

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May 15, 2008
Mrs. Cathy Thomas-Grazioli
HEXION
1411 Industrial Drive
Fayetteville, NC 28301
Michael F. Easley, Governor
William G. Ross Jr,, Secretary
North Carolina Department of Environment and Natural Resources
Subject: COMPLIANCE EVALUATION INSPECTION
HEXION
NPDES Stormwater Permit-NCS000088
Cumberland County
Dear Mrs. Thomas-Grazioli:
Coleen H. Sullins, Director
Division Of Water Quality
On May 9, 2008, I, Trent Allen from the Fayetteville Regional Office of the Division of Water
Quality, conducted a site inspection at the HEXION facility located at 1411 Industrial Drive,
Cumberland County, North Carolina. A copy of the Compliance Inspection Report is attached for your
review. Lynn Rives and Michelle Serrian were also present during the inspection and their time and
assistance is greatly appreciated. Stormwater from this facility drains to the Cape Fear River, a Class C
water located in the Cape Fear River Basin. The site visit and file review revealed that the subject
facility is covered by NPDES Stormwater Permit-NCS000088.
Accordingly, the following observations were noted during the Division of Water Quality
inspection:
1) Stormwater Pollution Prevention Plan (SPPP)
A Stormwater Pollution Prevention Plan (SPPP) has been developed, recorded, and properly
implemented.
es ■ No ❑
2) Qualitative Monitoring
Qualitative monitoring has been conducted and recorded in accordance with permit requirements.
es ■ No ❑
3) Analytical Monitoring
Analytical monitoring has been conducted and recorded in accordance with permit requirements.
Yes ■ No ❑
Noe Carolina
�tura!!y
North Carolina Division of Water Quality 225 Green Street, Suite 714 Fayetteville, NC 28301-5043 Phone [phone] Customer Service
Internet: www.ncwaterquality.Qre Fax [phone]
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Page 2
May 15, 2008
Mrs. Thomas- Grazioh
Other Observations:
Please refer to the attached Compliance Inspection Report for additional observations and comments.
Please be advised that violations of the NPDES Permit are subject to a civil penalty
assessment of up to $25,000 per day for each violation. If you or your staff has any questions,
comments, or needs assistance with understanding any aspect of your permit, please do not hesitate to
contact me at [phone].
Sincerely,
Trent Allen
Environmental Engineer
Attachment
cc: FRO -Surface Water Protection
NPS-Assistance & Compliance Oversight Unit

Compliance Inspection Report
Permit: NCS000088 Effective: 11/12/99 Expiration: 11/30/04 Owner: Borden Chemical Incorporated
SOC: Effective: Expiration: Facility: Borden Chemical incorporated
County: Cumberland 1411 Indusrtrial Dr
Region: Fayetteville
Fayetteville NC 28301
Contact Person: Michelle Serrian Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
On -site representative
Related Permits:
Cathy Thomas-Grazioli
Certification:
Inspection Date: 05/09/2008 Entry Time: 09:00 AM Exit Time: 10:30 AM
Primary Inspector: Trent Allen�L�
Secondary Inspector(s):
Danny Strickland
Belinda S Henson
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ■ Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Phone:
Phone:
Phone: [phone]
Phone:
Phone: [phone] Ext.726
Inspection Type: Compliance Evaluation
Page: 1

Permit: NCS000088 Owner - Facility: Borden Chemical Incorporated
Inspection Date: 05/09/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
This facility is now called HEXION, and not Borden Chemical Incorporated. The change of name was sent in with the
permit renewal package.The new permit has not been sent to HEXION yet, and they are following the old permit until the
new one arrives. All analytical and qualitative monitoring has been conducted. Qualitative monitoring is conducted after
every rainfall event before the water is released from the property,
HEXION is trying to reuse/recycle water back through the plant to reduce the amount of total water used by the plant.
Page: 2

Permit: NCS000088 Owner - Facility: Borden Chemical Incorporated
Inspection Date: 05/09/2008 Inspection Type: Compliance Evaluation
Stormwater Pollution Prevention Plan
Does the site have a Stormwater Pollution Prevention Plan?
# Does the Plan include a General Location (USGS) map?
# Does the Plan include a "Narrative Description of Practices"?
# Does the Plan include a detaiied site map including outfall locations and drainage areas?
# Does the Plan include a list of significant spills occurring during the past 3 years?
# Has the facility evaluated feasible alternatives to current practices?
r
# Does the facility provide all necessary secondary containment?
# Does the Plan include a BMP summary?
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
# Does the facility provide and document Employee Training?
# Does the Plan include a list of Responsible Party(s)?
# Is the Plan reviewed and updated annually?
# Does the Plan include a Stormwater Facility Inspection Program?
Has the Stormwater Pollution Prevention Plan been implemented?
Comment: Spill kits have been placed at every station in the plant.
Qualitative Monitoring
Has the facility conducted its Qualitative Monitoring semi-annually?
Comment:
Analytical Monitoring
Has the facility conducted its Analytical monitoring?
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
Comment: Following old permit and sampling every 4th year.
Permit and Outfalls
# Is a copy of the Permit and the Certificate of Coverage available at the site?
# Were all outfalls observed during the inspection?
# If the facility has representative outfall status, is it properly documented by the Division?
# Has the facility evaluated all illicit (non stormwater) discharges?
Comment:
Reason for Visit: Routine
Yes No NA NE
■ ❑ ❑ ❑
Yes No NA NE
■ ❑ ❑ ❑
❑❑■❑
Yes No NA NE
Page: 3

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Bruce Johnson
SIT%1"dustrial. Pr
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8/15/00

NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
August 14, 2000
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Bruce A. Johnson
Plant Manager
Borden Chemical, Inc.
1411 Industrial Drive
Fayetteville, NC 28301
DIVISION OF WATER QUALITY
FAYETTEVILLE REGIONAL OFFICE
SUBJECT: NOTICE OF VIOLATION
Failure to properly implement NPDES Stormwater Permit Condition
Borden Chemical Inc.
NPDES Permit No. NCS000088
Cumberland County
Dear Mr. Johnson:
The purpose of this letter is to convey a Notice of Violation for release of 1750 gallons of
50% Sodium Hydroxide to the Cape Fear River (during the period from 7:00 P.M., July 22, to
8:00 P.M., July 23, 2000) and for failure to implement Part II, Section A, 2., (b) of your NPDES
permit:
Secondary Containment Schedule. A schedule to provide secondary containment for
bulk storage of liquid materials, storage of Section 313 of Title III of the Superfund
Amendments and Reauthorization Act (SARA) water priority chemicals, or storage of
hazardous substances to prevent leaks and spills from contaminating stormwater runoff.
If the secondary containment devices are connected directly to stormwater conveyance
systems, the connection shall be controlled by manually activated valves or other similar
devices [which shall be secured with a locking mechanism] and any stormwater that
accumulates in the containment area shall be at a minimum visually observed for color,
foam, outfall staining, visible sheens and dry weather flow, prior to release of the
accumulated stormwater.' Accumulated stormwater shall be released if found to be
uncontam'nated by the material`stured within the containment area.
On July 24, 2000, at 4:45 P.M., this office was notified of a release of 1750 gallons of
contaminated stormwater that contained 50% sodium hydroxide to the waters of the state. After
investigation, conducted on July 25, the opinion of this office is that Borden Chemical should have
performed more extensive screening measures prior to release of the secondary containment
stormwater to the surface waters. Borden Chemical would have thus avoided the spill discharge
into the Cape Fear River that occurred.
On August 4, Scott Dubree (Borden Chemical Plant Engineer) personally delivered to
this office the recently revised Stormwater PollutionPrevention-Plan-(revised 8-2-00). Borden
Chemical Inc. should always insure that no release of substances injurious to the environment
occurs. Please review your plan before releasing any liquids or substances from your secondary
containment areas.
225 GREEN STREET, Sl11TE 714 / SYSTEL 9LD• FAYETTEVILLE, NORTH CAROLINA 28301-5043
PHONE 910-48G-1541 FAX [phone]
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Please be advised that failure to adhere to NPDES permit conditions in the future will
result in this office making recommendations to the Director of Water Quality for enforcement
actions.
If you have questions or comments related to this notice, please do not hesitate to contact
Dale Lopez of my staff at [phone].
S' e
,J l
Paul awls
Water Quality Regional Supervisor
Idl
cc: Ricky Revels, FRO-DWQ
Bradley Bennett, Stormwater and General Permits Unit
Roberta Runge, EPA
Shannon Langley, NPDES Compliance Unit