NCS000254_COMPLIANCE_20121010

T-- STORMWATER-DIVISION-CODING-SHEET---
PERMIT NO.
NCB
DOC TYPE
❑ FINAL PERMIT
❑ MONITORING INFO
❑ APPLICATION
9 COMPLIANCE
❑ OTHER
DOC DATE
❑ I �-_�_0 I o
YYYYM M DD

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P.E. Dee Freeman
Governor Director Secretary
October 10, 2012
Mr. Ronald Walls
Georgia-Pacific Chemicals, LLC
PO Box 368
Conway, NC 27820
SUBJECT: Compliance Evaluation Inspection
Georgia-Pacific Chemicals, Inc.
Permit Numbers — NCS000251 and NCG500348
County - N. Hampton
Dear Mr. Walls:
On September 20, 2012, Autumn Romanski, of the Division of Water Quality (DWQ), Raleigh Regional Office,
performed an Individual Stormwater NCS000251 compliance evaluation inspection and a wastewater
NCG500000 compliance evaluation inspection of the Georgia-Pacific Chemicals, LLC site in Conway. The
assistance and cooperation of Mr. Timothy Riddick, Site Environmental Coordinator was very helpful and
appreciated. Inspection findings are listed below.
Industry and Bite Des&lption
Georgia-Pacific Chemicals is a resin manufacturing plant that uses ferric molybdate catalyst to convert methanol
to formaldehyde. Stormwater associated with industrial activities (SIC Code 2821-Synthetic Resins) is
regulated, therefore, DWQ has issued Stormwater Individual Permit NCS000251 which became effective
February 1, 2011 and expires January 31, 2016. Also, wastewater, specifically, cooling water blowdown,
generated at facility is regulated by General Permit NCG500000. DWQ has therefore issued Wastewater
General Permit NCG500348 which became effective August 1, 2012 and expires July 31, 2015,
Inspection Summary
The facility was in compliance with the permit requirements the day of the inspection,
The following items were discussed:
1. The current sampling location for the NCG500000 cooling water blowdown discharge (at stormwater outfali
001) is commingling with stormwater flow. It is recommended that the NCG50000 sampling be conducted
closer to the NPDES Cooling Water Discharge Line prior to commingling with the sites stormwater. The
new language in the NCG50000 permit that became effective August 1, 2012 is as follows: "All non -contact
cooling water sample locations shall provide representative samples of the discharge and require sampling

NCS000251 and NG050065
• `
Page 2
prior to discharge commingling with any other water or substances, such as stormwater or surface water to
enable characterization of a pollutant of concern."
2. The low flow conditions at Stormwater Outfall 003 were discussed during the inspection. Sampling is
required due to direct stormwater conveyance and the location (drains the electrical oil containing
transformer paved surface). It was observed that the majority of the stormwater flow by this location drains
to outfall 002, thereby leaving very little flow exiting the 003 outfall. If there is not enough flow for a
representative sample, the facility should record (No Plow). The permittee could also investigate eliminating
the "direct" discharge by re-routing the stormflow or treating the flow with a level spreader (information on
level spreaders in the DWQ Stormwater BMP Manual was forwarded to the permittee). A review of outfall
003 data revealed that no benchmarks have been exceeded at this outfall, indicating it could be a good
candidate for conversion to sheet flow.
Please review the Compliance Inspection Report enclosed for further details of this inspection.
It is our goal to insure the quality of the surface waters of this State.
If you or your staff has any questions, do not hesitate to contact me at 919-791-4200.
Sincerely,
Autumn Romanski
Enclosures
cc: Mr. Timothy Riddick
Site Environmental Coordinator
Georgia-Pacific Chemicals, LLC
Conway, NC 27820
Central files
RRO Files -Wastewater and Individual Stormwater
3400 Barrett Drive One
RaVgh, North Carolina 27609 NorthCarohna
Phone, 919-791-4200 Fax; 919-788.7159 ;Vatumlly

•
•
Compliance Inspection Report
Permit: NCS000251 Effective: 02/01/11 Expiration: 01/31/16 Owner: Georgia-Pacific Chemicals LLC
SOC: Effective: Expiration: Facility: Conway Resins Plant
County: Northampton 200 Ampac Rd
Region: Raleigh
Conway NC 27820
Contact Person: Lise.iziaghs - .mo`w Title: Si+(l 6'nViR0hvrte 'f { Phone: [phone]
Directions to Facility: pUawcK CDOr� Ailit+atl
System Classiflcatlons:
Primary ORC: Certiflcatlon: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 09/20/2012 EntryTlme: 10:00 AM Exit Time: 12:00 PM
Primary Inspector: Autumn H Romanski fs Phone: [phone]
Secondary inspector(s):
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ■ Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Inspection Type: Compliance Evaluation
Page: 1

Permit: NCS000251 Owner - Facility: Georgia-Pacific Chemicals LLC
Inspection Date: 09/2012012 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
The permittee was compliant with the permit requirements the day of the inspection.
The facility keeps excellent records and had completed all of the permit monitoring requirements as evidenced by record
review results the day of the inspection. The annual DMR summary was reveiwed by DWQ stormwater permitting Unit
upon the permit renewal and showed that TN, TIP, BOD, and formaldehyde should continue to be monitored at this site.
Page: 2

Permit: NCS000251 Owner - Facility: Georgia-Pacific Chemicals LLC
Inspection Date: 09/20/2012 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 detailed 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?
# Does the Facility provide all necessary secondary containment?
# Does the Plan include a BMP summary?
Reason for Visit: Routine
# 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: The Environmental Coordinator was knowledgeable on the permit and the
records were well organized and complete.
The facility was in compliance with all of the SPPP requirements of the permit the day of
the inspection.
Qualitative Monitoring
Has the facility conducted its Qualitative Monitoring semi-annually?
Comment: Qualitative Monitoring records were complete as required.
Analytical Monitoring
Has the facility conducted its Analytical monitoring?
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
Yes
No NA NE
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Yes No NA . NE
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Yes No NA N£_
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Page: 3

Permit: NCS000251 Owner -Facility: Georgia-Pacific Chemicals LLC
inspection Date: 09120i2012 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Comment: Outfall 002 is monitored as a vehicle maintenance area.
The following results from 2011, required Tier I Response:
Outfall 002 had one elevated TSS result on 11/17/2011.
Outfall 001 had one elevated pH result on 3/30/2011.
The facility reported completing the Tier I response - housekeeping changes were made
and subsequent results returned below the benchmark values for TSS at outfall 002 and
pH at outfall 001. It was noted during the inspection that pH adjustment can be made to
the cooling water blowdown as needed -this should also provide protection against
elevated pH at outfall 001.
Permit and Outfalls Yes No NA NE
# 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? 0000
Comment: The site has four stormwater outfalis. Signs are being made to mark the
location of the outfalls.
Outfall 001 is a drainage ditch that collects most of the stormwater on -site and (some
permitted cooling water blowdown discharge). The outfall was clear and water was
discharging the day of the inspection. Outfall 002 is overflow for the stormwater
detention basin as applicable. Stormwater from the detention basin not meeting water
quality requirements is sent to the permitted land application/spray system. Outfall 002
was not discharging the day of the inspection. Outfall 003 is a low flow area of direct
stormwater discharge by the exterior (oil filled) electrical transformers. Outfall 004 is
another low flow area that drains parking lot and office building- no industrial process.
Facility reported that all water collected in process area drains and truck wash area is
reused or hauled off -site and not discharged.
Page: 4

NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Mr. Tim Riddick
Georgia Pacific Resins
P.O. Box 368
Conway, NC 27820
Dear Mr. Riddick:
Division of Water Quality
Celeen H. Sullins
Director
August 19, 2011
Subject: Compliance Evaluation Inspection on 8/18/2011
Stormwater Permit NCS000251
Georgia Pacific Resins
Conway, NC
Northampton County
Dee Freeman
Secretary
Thank you for your help during the DWQ inspection on 8/18/2011. The facility is in compliance with
the permit. Attached is the inspection checklist. You requested an electronic copy of the permit in
Word. This will be sent by email.
Stormwater documentation was well organized, available and essentially complete. One small
improvement is suggested, however. Information covering the question of significant spills in the last
three years (there had been none) was tucked into an inspection summary. It will be more in keeping
with the permit requirement to put this on a separate page in the Stormwater Pollution Prevention Plan.
to have it readily available during future inspections.
All analytical values were low, well below benchmark levels.
There is a revised observation form for recording Qualitative Monitoring data available on the DWQ
website, as well as a guidance document, if you are interested. The URL is:
http://portal.ncdenr.orp,/web/wg/ws/su/npdessw
There were a large number of wooden pallets in the facility, ready to be sent to a recycler. These may
be left exposed to rain as long as they have not been contaminated with chemicals. An added part of
employee training should be to separate any "dirty" ones that can potentially contaminate to keep them
under roof until they can be recycled or disposed.
If you have questions or comments, please contact a staff member at 919-791-4200.
Sincerely,
a.Y"
My A. Nisely
Environmental Chemist
Raleigh Regional Office
cc: RROISWP riles/ Central Files One hCaraHna
Amurally
North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone [phone] Customer Service
Internet: www.ncwaterquality.org 1628 Mail Service Center Raleigh, NC 27699.1628 FAX [phone].623-6748
An Equaf Opportunity/Affirmative Action Employer — 50% Recycled110% Post Consumer Paper

Permit: NCS000251
SOC:
County: Northampton
Region: Raleigh
Compliance Inspection Report
Effective: 02/01/11 Expiration: 01/31/16 Owner: Georgia-Pacific Chemicals LLC
Effective: Expiration: Facility: Conway Resins Plant
200 Ampac Rd
Contact Person: Liss�� s,, ILcctotcc i, Title. -
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 08/18/2011 Entry Time: 09:30 AM
Primary Inspector: Myrl Nisely
Secondary Inspector(s):
Reason for inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ■ Compliant ❑ Not Compliant
Question Areas:
N Storm Water
(See attachment summary)
Conway NC 27820
Phone: [phone]
Certification:
Exit Time: 1 i:10 AM
Phone:
Phone: [phone]
Inspection Type: Compliance Evaluation
Page: 1

Permit: NCS000251 Owner - Facility: Georgia-Pacific Chemicals LLC
Inspection Date: 08/1812011 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Comment: This is a strong program, well organized and fully implimented.
Page: 4

Permit: NCS000251 Owner - Facility: Georgia-Pacific Chemicals LLC
Inspection Date: 08/18/2011 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Yes No
NA NE
Does the site have a Stormwater Pollution Prevention Plan?
NOOO
# Does the Plan include a General Location (USGS) map?
■ ❑
❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
■ ❑
❑ ❑
# Does the Plan include a detailed 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?
■ ❑
❑ ❑
# 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: Documentation of Significant Spills will be more readily available if a
separate page for that purpose is inserted into the plan.
Qualitative Monitoring
Yes No
NA NE
Has the facility conducted its Qualitative Monitoring semi-annually?
■ ❑
❑ ❑
Comment: The new form with fewer subjective designations is available. S ee cover
letter for URL
Analytical Monitoring
Yes No
NA NE
Has the facility conducted its Analytical monitoring?
■ ❑
❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
■ ❑
❑ ❑
Comment:
Permit and Outfalls
Yes No
_NA NE
# 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?
■ ❑
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Page: 3

Mr. Ronald E. Wells
Georgia Pacific Chemicals, LLC
PO Box 368
Conway, NC 27820
Michael F. Easley, Governor
William G. Ross Sr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
Subject; Permit name or ownership change request
Permit NCS000251
Your request for a permit name change or ownership change received on is being
returned due to:
❑ Permit Name/Ownership Change Form is missing.
❑ Permit Name/Ownership Change Form is incomplete.
❑ Permit Name/Ownership Change Form signatures missing.
❑ Missing legal document of the transfer of ownership (such as a contract or a deed).
Is'Other
r mom
�w
• 1 I
Please return the information so we can continue processing your request. If you have any
additional questions, please contact Sarah Young at [phone] extension 502. Our mailing
.address is as follows: Wetlands and Stormwater Branch
1617 Mail Service
Raleigh, NC 27699-1617
DWQ Stormwater Permitting Unit
Cc:
DWQ Central Files
SPU
Npama`hCarolina
,wattura!!y
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet h2o.enr.state.no.us 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
An Equal OpportunitylAffirmative Action Employer— 50% Recycled110% Post Consumer Paper

h W
Georgia-Pacific Resins, Inc.
December 6, 2006
VIA CERTIFIED MAIL No. 7005 0390 0002 2649 3390
Ms. Sarah M. Young
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1636
RE: Name Change/Ownership Change Form
Permit No. NCG500065
Perniit No. NCS000251
Dear Ms. Young:
NCS000z5l
a wholly owned subsidiary of
Georgia-Pacific Corporation
P.O. Box 368
Conway, NC 27820
Phone [phone]
Fax [phone]
As requested please find enclosed the completed ownership change form for the Georgia-
Pacific Resins, Inc; Conway, NC facility. This facility will became Georgia-Pacific Chemicals
LLC, effective on January 1, 2007. The legal documentation of the ownership change will be
submitted under separate cover once obtained. Any permits associated with the facility should
be under this new entity from that date forward. If you have any questions or comments
regarding this matter, please contact Lisa Hughes at [phone].
Sincerely,
,i2,
Vv
Ronald E. Walls
Plant Manager an
U�v
o
cc: Mr..lim Eckenrode — GA029
Mr. Cliff Bowling — VA019 Q

Michael F. Easley, Goventor
William G. Ross Jr., Secretary
North Carolina Department orEnvironntent and Natural Resources
Alan W. Klimek, P.E., Director
NVISiDll of WatcrQnality
SURFACE WATER PROTECTION SECTION
PERMIT NAME/OWNERSHIP CHANGE FORM
I. Please enter the permit number for which the change is requested.
NI'DES Number (ol) Certificate of Coverage
N C S 0 0 0 2 5 l I N I C I G 1 5 10 1 0 0 6 5
11. Permit status priff to status change.
a.
Permit issued to (company name)
Georgia-Pacific Resins, Inc
b.
Person legally responsible for permit:
Ronald E. Walls
First / MI I Last
Plant Manager
Tine
P.O. Box 308
Pcrmit Holder Mailing Address
ConwayNC
27820
City State
'lip
[phone]
[phone]
Phone
Fax
c.
Facility name (discharge)
Georgia-Pacific Resins, Inc.
d.
Facility address:
200 Ampac Road
Address
Conway NC
27820
City State
'Lip
e.
Facility contact person:
Lisa W. Hughes
252 585-1232
First I M I Last
Phone
III Please
provide the following for the requested change (revised permit).
a.
Request for change is a result of:
® Change in ownership of the facility
❑ Name change of the facility or owner
If'other, pletrse explain:
b.
Pcrnvt Issued to (company name)::
Geor ia-Pacific Chemicals LLC
C.
Person legally responsible for permit:
Ronald E. Walls
First / MI / Last
d. Facility name (discharge):
e. Facility address:
f. Facility contact person:
Plant Manager
Title
P.O. Box 368
Permit Ilolder Mailing Address
ConwayNC 27820
[phone] [e-mail]
Phone & nail Address
a -Pacific Chemicals LLC
200 Am ac Road
Address
Conway NC 27820
Lisa W. Hughes
First I Ml I Last
[phone] [e-mail]_
Phone H_mail Address
Revised 7/2005

PERMIT NAM E/OW NERSH II' CI IANGE FORM
Page 2 of 2
IV. Permit Contact information:. (if different from the person legally responsible for the permit)
V
Person contact: Lisa W. Hughes
First 1 MI / Last
Spray DrX Plant Superintendent/Environmental Coordinator
Tide
P,0. Box 368
,Mailing Address
Conway NC 27820
252 585-1232 lwhu ghes 'a ac.com
Phone E-itutiI Address
Will the permitted facility continue to conduct the same industrial activities conducted prior to the
ownership or name change?
® Yes
❑ No (please explain)
Vt. Required Items: THIS APPLICATION WILL BE RETURNED UNPROCESSED IF ITEMS ARE
INCOMPLETE OR MISSING.
® The completed application is required for both name change and/or ownership change requests.
❑ Legal documentation of the transfer of ownership (such as relevant pages of a contract deed, or a bill of
sale) is required for an ownership change request. Articles of incorporation are not sufficient for an
ownership change.
The certification below must be completed and signed by 6ntk the permit holder prior to the change, and the new
applicant in the cast' of on ownership change request. For a name change request, the signed Applicant's
Certification is snffneient.
PERMITTEE CERTIFICATION_(Permit holder prior to ownership change):
I, Ronald E. Walls, attest that this application for name/ownership change has been reviewed and is accurate and
complete to the best of my knowledge. I understand that if all required parts of this application are not completed
and that if all required supporting information and attachments are not included, this application package will be
re w,�e as i complete
�/,,ll t z- t t O G
Signature Bate
APPLICANT CERTIFICATION:
1, Ronald E. Walls, attest that this application for name/ownership change has been reviewed and is accurate and
complete to the best of my knowledge. I understand that if all required parts of this application are not completed
and that if all required supporting information and attachments are not included, this application package will be
ret s t mplete.
�x
[ fZftr
Signature Date
PLEASE SEND THE COMPLETE APPLICATION PACKAGE TO:
DIVISION OF WATER QUALITY
Surface Water Protection Section
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Revised 7/2005

Michael F. Fosley. Governor
a oaoF w a 7-F9QG
r'
Ms. Lisa Hughes
Georgia Pacific Resins
P.O. Box 368
Conway, NC 27820
Dear Ms. Hughes:
William G. Ross, Jr.. 5ecretar}
North Carolina Departnicnt of Environment imd Natural Resources
Alan W. 1tilintc{:, I'.I:., I)ileUlilr
Division ol' Water QU:Ilith
December 8, 2005
Subject: Compliance Evaluation Inspection on 12/5/2005 & Staff Report
Stormwater Permit NCS000251
Georgia Pacific Resins
Conway, NC
Northampton County
Your participation with Mr. Myrl Nisely and Mr. Ron Boone throughout this inspection was much
appreciated. The facility is in compliance with the permit. This visit was made for the added purpose of
reviewing facility operations in order to write a staff report in support of the permit renewal. The following
descriptions are meant to provide detail to the permit writer. If you detect any inaccuracies, please contact
me.
There are four point discharges through which stormwater can leave the site, but only three are covered by
this permit. This is explained further below. The flow begins at the corner of the parking, lot at outfall 004.
then travels around the perimeter of the facility past the Storm Water Detention Basin (SWDB) where
outfall 002 can join, then passes (receives) outfall 003. The ditch turns cast into the woods briefly, then
back to the southwest again to eventually empty into a flat swampy area south of the plant. The water in
due course travels southwest to a blue line UT to Doolittle Millpond. (see attached topo maps) Close
scrutiny of the topo maps looked as though the combination of outfalls 004-002-003 might flow southeast
to the blue line UT to Panther Swamp. Apparently the ditch does not intersect that blue line, but rather
makes its way to the southwest as described above.
Permit NCG500065 also has outfall 001 for certain wastewaters that joins the same blue line UT as the
other outfalls. This system of ditches for 001 picks up stormwater as well. See the CEI report by Ron
Boone for a description of this outfall. Latitude/Longitude data for all four release points are as Follows,
and could be added to BIMS.
Outfall
Latitude, Deg -Min -Sec
Longitude, Deg -Min -Sec
001
36-25-28.4
77-13-31.1
002
36-25-43.1
77-13-20.6
003
36-25-40.3
77-13-20.2
004
36-25-47.0
77-13-24.4
�ni7hC�u'u1in;�
�11rrlrrtrr!!f
North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone [phone] Customer Service
Internet: h2o.enr.state.nc.us 1628 Mail Service Center Raleigh, NC 27699.1628 FAX [phone].621-6744
An Equal OpportunitylAffirmative Action Employer— 50% Recycled110% Post Consumer Paper

Georgia Pacific Resins CE11Stat'1' Rept 12/5/2005 NCS000251 Page 2 of"—' 4
In the permit file for GP there a mixture of two names used for the receiving stream — Doolittle Millpond
and Paddy's Delight Creek. It might be helpful in the future to refer to just one name, probably Paddy's
Delight Creek because it is the water of the State that flows through the pond. In other words, the pond is
simply a "wide place in the creek". Paddy's Delight Creek to the dam that creates Doolittle Millpond is
classified B; NSW. Therefore, the UT serving the GP site is properly classified the same. However, just as
soon as the water leaves the Millpond dam, the classification changes to C; NSW. Please refer to the topo
maps.
Stormwater BMPs for Each Outfall
004
The parking lot that drains into 004 is used as a short term holding zone for trucks loaded with finished
resin products. No raw material trucks stop there. There is no connecting of hoses, ptunping or other
industrial activity on the lot. The trucks have already been washed elsewhere alter loading, so the only
potential contamination might be from material tracked on the tires. Catastrophic tallure of a tank truck is
theoretically possible, but is considered so unlikely that no special BMP has been installed to contain such
a release. A more likely source of contamination would be the oil drippings from automobile and truck
engines parked there. Parking lots are typically exempted from stonmwater pcnnits, and that is proposed as
the correct assessment in this case. Unless a release is known to have occurred, in which case sampling at
004 would be needed until cleanup is completed and tests drop to levels required for outfall 002, only
visual inspections will be needed for this outfall.
002
Outfall 002 is sometimes used to release stormwater after analyses show acceptable water purity (sampled
before it mixes in the ditch with 004 flow). The permit requires analysis of the contents of the concrete -
lined basin for phenol and formaldehyde by a Chemetrics test and GC. Records show that meticulous care
is taken, not only for those two .Pollutants of Concern (POCs), but also for oil sheen and any other
contaminant that might impact the SWDB water duality. Frequent and repeated analyses are done as
actions are taken to handle contaminants. The disposal options for the contents of the SWDB are
interesting.
As stated, if shown to be clear and clean, the water can be released as stormwater via 002, (but there is a
more preferable use, explained below). However, if the SWBD contains POCs, the water is transferred by
sump pump and a hose to a grate connected to a 12' x 12' pit (See site map). The SWDB is pumped dry.
The pit then serves as a distribution center from which three options exist: 1) pump into the manufacturing
process 2) send to the nondischarge spray system or 3) return to the SWDB. The contaminated water can
be pumped into a process tank known as the "MC System" for use in place of fresh water in the
manufacturing process. This is the preferred use, to cut fresh water costs, even when clean enough to
release via 002. If that system cannot take the water, it is pumped to the lagoon serving the non -discharge
spray system and is land applied according to that permit. Philosophically, the company prefers to
minimize the volume of water sent to the spray system.
The 12 x 12 pit also receives stormwater runoff via the grate from areas of paved roadway. When the level
in the pit reaches the elevation of the grate, water begins to puddle above the grate. This signals personnel
to analyze the pit and transfer some of the water to either the MC System, the Spray System, or to the
SWDB. This flexibility, always preceded by analyses, provides adequate control of the volumes of
stormwater encountered. Valves on the pit discharge lines are interlocked with the SWDB release valve so
that nothing can be pumped to the SWDB if the valve to 002 is open.

Georgia Pacific Resins CEI/Staff ReptS/2005 NCS000251 Page 3 of 3
tPhenol and formaldehyde can enter the SWDB from the loading area small quantities of product that
are carried by trick tires onto the roadway after they leave the roofed loading area. Levels are seldom high
enough in the SWDB to preclude discharge to 002, but even when clean enough to release, the preference
is for the MC System as explained above. Larger volumes of product escaping from disconnected hoses
and other loading activities are captured when the trucks are washed. Once loaded, the trucks are washed
off to a separate, steeply sloped collection point from where the wash water is pumped to the MC System.
Just west of the SWDB is secondary containment for Kerosene, Gasoline and Oil storage. A leaky pump
for diesel fuel in that area had been removed in recent days because an almost constant oil sheen was being
observed in the SWDB. At the time of this visit, the SWDB was being pumped to plastic carboys for
disposal to clean up this problem. Any releases into the SWDB from these secondary containments would
be easily identified, and appropriate disposal would be undertaken as in this example.
003
Runoff exits from a grassy area with minimal industrial activity at this discharge point. Semi-annual
sampling will suffice.
This facility performs field pH measurements, so an application form was provided to you to be submitted
to the Laboratory Certification Unit for obtaining field certification. There is no ORC requirement for this
permit since the SWDB is not a treatment process in the usual sense for NPDES permits.
Attached is the standard stormwater inspection checklist used by RRO for your reference.
If you have questions or comments, please contact me at 919-791-4255.
Sincerely,
M
01K
Myrl A. Nisely
Environmental Chemist
Raleigh Regional Office
Attachments
Stormwater Inspection Checklist
Topo maps and aerial photos (only to Permitting Unit)
cc: Bethany Georgoulias, Stormwater Permitting Unit
Central Files