NCS000258_COMPLIANCE_20101029

STORMWATER-DIVISI6N CODING -SHEET
PERMIT NO.
NC,������
DOC TYPE
❑FINAL PERMIT
❑ MONITORING INFO
❑ APPLICATION
'COMPLIANCE
❑ OTHER
DOC DATE
❑� o i 61 a a I
YYYYMMDD

NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Glycotech Inc.
Mr. Alan Stout
2271 Andrew Jackson Highway
Leland, NC 28451
Dear Mr. Stout,
Division of Water Quality
Coleen H. Sullins
Director
October 29, 2010
Subject: NPDES Compliance Evaluation
Glycotech, Inc.
Certificate of Coverage NCS000258
Dee Freeman
Secretary
A compliance evaluation inspection was conducted at the Glycotech, Inc. facility in Brunswick County on October
28, 2010. Thank you for your assistance during the inspection process. The laboratory tour was educational. I
appreciate any opportunity to learn about the industries in our region. Attached is a copy of the compliance
inspection report. The site is in significant compliance with the requirements of the NPDES Permit NCS000258.
While two deficiencies were found, it is apparent that the implementation of your stormwater pollution prevention
plan has been very affective. The good housekeeping efforts that are being exercised to maintain a clean
manufacturing facility are evident. Please continue the excellent stewardship.
Should you have any questions concerning this correspondence or the comments in the inspection report, please
do not hesitate to contact me at 910-796-7343.
Sincerely,
Gr�aL G�Q�a .
Linda Willis
Division of Water Quality
Surface Water Protection Section
Enclosure
CC: DWQ WIRO NCS000258 Brunswick w/att
DWQ CO w/att
Wilmington Regional Office
127 Cardinal Drive Extension Wilmington, NC 28405
Phone: [phone] FAX: [phone]
Internet: www.ncwateraualitv_ora
One
Nor hCarolina
Naturally
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50% Recycled/ 10% Post Consumer Paper
Customer Service 1-877-623-6748

0
Compliance Inspection Report
Permit: NCS000258 Effective: 07t01106 Expiration: 06/30/11 Owner: Glycotech Inc
SOC: Effective: Expiration: Facility: Glycotech, Inc.
County: Brunswick 2271 Andrew Jackson Hwy N
Region: Wilmington
Leland NC 28451
Contact Person: Alan C Stout Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Certification: Phone:
Inspection Date: 10/28/2010 Entry Time: 02:00 PM Exit Time: 03:30 PM
Primary Inspector: Linda Willis Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ■ Compliant ❑ Not Compliant
Question Areas:
© Storm Water
(See attachment summary)
Page: 1

Permit: NCS000258 Owner - Facility: Glycotech Inc
Inspection Date: 10/28/2010 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
While two deficiencies were found with the SWP3, the facility is in significant compliance with the requirements specified
by the NPDES permit. The plan is being implemented. House keeping at this site is excellent. The receiving waters were
inspected downstream at the rail road crossing. There were no signs of pollutants (foam, sheen, turbidity, etc.) directly
downstream of their stormwater discharges. The Division appreciates the good stewardship and all the efforts that have
gone into maintaining a clean manufacturing facility.
Page: 2

I"
Permit: NCS000258 owner - Facility: Glycotech Inc
Inspection Date: 10/28/2010 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?
■
❑
❑
❑
# 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: The plan is very well organized and very thorough. The plan needs to
show documentation (yearly) that the SWP3 has been reviewed and amended (in need
be).
Qualitative Monitoring
Yes
No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
■
❑
❑
❑
Comment:
Analytical Monitoring
Yes
No
NA
NE
Has the facility conducted its Analytical monitoring?
■
❑
Cl
❑
# 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?
❑
■
❑
❑
Page: 3

Permit: NCS000258 Owner - Facility: Glycotech Inc
Inspection Date: 10/28/2010 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Comment: The facility had records for 2008, 2009 were not present. This facility
monitors outfalls more frequently (monthly) than that required by the permit. The
outfalls were clean with no evidence of any non stormwater discharges.
Page: 4

North Carolina Department of Environment and Natural Resources
Division of Water Quality
.1%
Michael F. Easley, Governor
November 21, 2008
CERTIFIED MAIL #: 7007 0220 0000 8216 6988
RETURN RECEIPT REQUESTED
Lawrence J. Rosen
C.T. Specialties Properties, Inc.
3419 Smallman Street
Pittsburgh, PA 15201
Dear Mr. Rosen:
William G. Ross, Jr., Secretary
Coleen H. Sullins, Director
Subject: NPDES Compliance Inspection Report
C.T. Specialties Properties, Inc.
NPDES Permit No. NCS000258
Brunswick County
Jean Conway and myself conducted an inspection of the C.T. Specialties Properties, Inc. facility
located at 2271 Andrew Jackson Highway, NE in Leland, North Carolina on October 17, 2008.. This
inspection was conducted to verify that the facility is operating in compliance with the conditions and
limitations specified in NPDES Permit No. NCS000258. We met with your plant manager, Mr. Jimmy
McLawhorn and Mr. Gary Wooten. Mr. McLawhorn had indicated that the facility will be sold in the
near future. 1t is our understanding that a transfer of ownership for the stormwater permit NCS000258 is
forth corning. The findings and comments noted during this inspection are provided in the enclosed
copy of the inspection report.
There were no significant issues or findings noted during this inspection and therefore, a response to this
inspection report is not required. If you have any questions concerning this report, you may contact
me at the letterhead contact information or via email at [e-mail]
Sincerely,
Linda Willis
Environmental Engineer I
Enclosige
Cc. 'Wilmington Regional Office -- NCS000258 (Brunswick Cnty)
'Central Files, Stormwater Permitting Unit attn: Bradley Bennett
Jimmy McLawhorn, P.O. Box 1956, Leland NC 28451
Wilmington Regional Office
127 Cardinal Drive Extension Wilmington, NC 28405
Phone: [phone] / FAX: [phone]
Internet: www.ncwaterauaiity.org
Nne
orthCarolina
naturally
An Equal Opportunity/Affirmative Action Employer
50% Recycled/ 10% Post Consumer Paper
Customer Service 1-877-623-6748

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A

Compliance Inspection Report
Permit: NCS000258 Effective: 07/01/06 Expiration: 06/30/11 Owner: C T Specialty Properties LLC
SOC: Effective: Expiration: Facility: C. T. Specialty Properties
County: Brunswick 2271 Andrew Jackson Hwy N
Region: Wilmington
Leland NC 28451
Contact Person: Jimmy McLawhorn Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Certification: Phone:
Inspection Date: 11110/2008 Entry Time: 10:00 AM Exit Time: 12:30 PM
L
Primary Inspector: Linda Willis , _ 1 _ N}_ Prone: 910-79&7396
Secondary Inspector(s):
Jean Conwa Phone:
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ■ Compliant ❑ Not Compliant
Question Areas:
M Storm Water
(See attachment summary)
Page: 1

Permit: NCS000258 Owner - Facility: C T Speciatty Properties LLC
Inspection Date: 11/10/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
The.site appeared clean with good housekeeping. All outfalls were observed, no evidence of illicit discharges. The
SWP3 plan was complete with each component required by the NCS permit. The representative outfall status will have to
be re-evaluated when the permit is transferred'to the new permittee. The processes/manufacturing will not be the same
__ _as_the_existing.permittee._A new_SWP3_pian will be required of.ihe new permittee: The monitoring requirements for the
two outfalls on site will need to be monitored by the permittee. The Stormwater Permitting Unit should specify this'in the
permit cover letter. -The new permittee will need to contact WiRO if the existing wastewater treatment (pretreatment)
facility will be utilized to treat. wastewater from the manufacturing process.
Page: 2

Y Permit: NCS000258 Owner - Facility: C T Specialty Properties LLC
Inspection Date: 11/1012008 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?
■
❑ Cl ❑
# Does the Plan include a General Location (USGS) map?
■
❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices"? W
�■
Q-❑ -❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■
❑ ❑ ❑
# Does the Plan include a fist 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?
0.000
# 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?
0
❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
■
❑ ❑ ❑
Comment:
Qualitative Monitoring
Yes
No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually?
■
❑ ❑ ❑
Comment:
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? 0000
# 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:
Page: 3

C.T. SPECIALTY PROPERTIES, LLC
2271 Andrew Jackson Hwy, NE
PO Boa 1956
Leland.,. N:C..__28451
910-371-2234
July 6, 2006
Aisha Lau
North Carolina Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina
a' r
Re: NPDES Stormwater Permit NCS000258
C.T. Specialty Properties, LLC
Leland North Carolina; Brunswick County o
`r' Nnl
Dear Ms. Lau, �
As referenced in the telephone conversation initiated by Gary Wooten with you on June
28, 2006 and in response to our communication with Linda Willis, Surface Water
Protection Section on June 28, 2006; C.T. Specialty Properties, LLC is requesting that the
Division of Water Quality (NCDWQ) modify our NPDES Stormwater Permit
NCS000258 specifically in regard to lowering the pH Benchmark Values. This request
is made in accordance with regulation 15A NCAC 02B.0211-Fresh Surface Water
Quality Standards for Class C Waters (3(g)) which states "...except that swamp
waters may have a pH as low as 4.3 if it is the result of natural conditions...".
Linda Willis has visited our plant site and recommended a sampling plan to document the
surface waters pH. The sampling was implemented on May 27, 2006 as rain events
occurred. The data, which is attached, indicates low pH values in the waters of Alligator
Branch as well as low pH values in the rainwater collected in our rain gauge. We believe
the low pH in both cases is naturally occurring (due to swampy terrain and acidic rainfall)
and the data shows that it is not associated with collection and discharge of stormwater in
secondary containment structures at the plant site.
Furthermore, the stormwater discharged from the plant site will consistently be outside
the current specified Benchmark Values (as verified by the rain water analysis) unless we
implement a treatment to the rainwater to raise the pH before it is discharged to the
approved stormwater outfall, or modify the pH Benchmark Values in the current
Stormwater Permit.
Page 1 of 2

C.T. Specialty Properties is committed to complying with all water quality protection
requirements. Thank you in advance for your assistance with this matter. If you have any
-questions-regarding this permit -modification request, -please do not hesitate to contact me
at [phone].
--------------------------------
Sincerely,
C. . Specialty Properties
y whorn
Plant Manager
CC:
Kenneth Carlton, CEO, Nekekim Corporation (CT Specialty Properties, LLC owner)
Gary Wooten, Operations Support Leader, CT Specialty Properties, LLC
Linda Willis, Surface Water Protection Section -Wilmington Regional Office
Attachments:
Sampling Plan Narrative
Stormwater pH Monitoring Log
Facility Site Map
Sampling Points Site Map
Page 2 of 2

CT Specialty Properties, LLC
Starrnwater Mnn[tMna Lan- Alllaatnr Branch nH Proiila
Sample
Date
Approx
Sample
Time AM
Amount of
Rainfall
Inches
Rainguage
pH
Rain Event
Start
Rain Event
End
Approx
Duration
(Hours)
Upstream
pH
Final
Oontainment
Dike
pH
Outfall 002
pH
Down-
stream pH
Down -
Stream
Feeder
H
Notre
W19/20DB
7:30
0.31
5.3
18-Ma
18-May
3
**
6
5.3
*"
*"
**No Sam le
5/22/2008
7:00
0.52
5.5
21-Ma
21-May
2
`*
5.5
5.8
'"No Sample
5/29/2006
7:30
0.55
4.5
28-Ma
28-May
3
4.3
6
5.5
4.4
4.4
6/5/2006
6:30
1.13
4.7
3-Jun
3-Mar
6
4.4
5.3
5.3
4.5
4.4
6/B/200$
9:30
0.08
5.3
5- Ju
5-Jun
1
*3.9
5.5
5.3
4.3
1 4.4
*No flow
6 Q006
7:00
0.22
4.7
6-Ju
7-Jun
3
*3.9
5.3
5.4
4.3
4.3
*No Now
6/9/2006
7:30
0.2
4.7
8-Jun
9-Jun
4
4
5.5
5.5
4.4
'4
*No flow
6/13/2006
7:45
0.81
4.8
124un
13-Jun
6
4.2
6
5.8
4.6
`4
*No flow
6/14/2006
7:00
0.28
5
13Jun
14-Jun
3
4.2
5.5
5.7
4.7
*4.1
*No flow
6/15/2006
7:30
0.33
4.5
14-Jun
15-Jun
3
4.5
a
5.8
4.8
4.3'
6/2812006
8:00
0.13
4.5
24-Jun
25-Jun
2
4.3
5
4.8
4.4
*4.2
*No flow
6/27/20DB
6:30
0.65
4.5
26-Jun
27-,Jun
2.6
4.5
5.5
5.1
4.6
413
8/30/20DS
7:00
4.1
5.1
29-Jun
29-Jun
2
5.1
5
5.6
4.9
4.7
I
NOTES
k
Measured Typical PH range of Coollno Tower water is 8.0-9.0
Measured Typical PH range of Boiler Steam Condensate is 9.0-10.5
Measured Typical PH Range of County Water is 6.0-7.0
I
I
I

I l r nae
1 DRAINAGE AREA 2 EOUaATION BASIN
CLARIFIER % 1,
ItkdRtt
iGROUNDWATER 1� pPR�xRAPSE
4 OITC-1 REMEDIATION
A
:LOG:
I PRE-TREATMENT
TANKS
i TR c s D 4— Z DRAINAGE AREA I
. � ,O,OOD GAL. FUEL
TANK OIL STORAGE Peapax /
Gas Tank
CULVERT �i. �� o
a
flaaox,wu�sM
a ,' ./
OUTFALL #002 � � . A - �\ � storepe Building /
T 11 B�nc� , ` a Stprrnvaea Fnd {l� Pump Have k
~ � T `�• Bker3ip 1�Ce4itq Tower r7' I
Race Ll�ia
t SwimnirgPod , a� v� / LEGEND
� Istamwelat . , r
-JS HWY. 74/76 F Fanci �� 1 =SECONDARY CONTAINMENT
1 D,000 gel.:kdk i J ,(
Storage Tanks
g
k ♦! �L// OTHER, IMPERVIOUS SURFACE
Truck Leading iT Hydrogen
0 / - Liq,adNOopm =LOW pi+iECiIDN
Dock 2 Gm Storage Tank
♦� ♦� f f — — — DITCH OR SWALE
1 Hydrogen
Tube S ORWATER DISCHARGE
Sim —Shed Tracers OUTFALL
""umuft. D+2A0:AGr_ AREAS
aurdDus
Peaca iSnide HWaibeRm RAILROAD TRACKS
I shmae Shed 4 Satd �
1 Pnnei Gsse BASE MAP WAS PROVIDED BY C.T. SPECIALTIES CORP.
4 DRAWING IS INTENDED FOR GENERAL LOCATION
I 1 Tned` INFORMATION ONLY. DRAWING SCALE IS APPROXIMATE.
1 cored Gravel PwUry Ga0e
Lit Stetimtc erg Area O B..,.k Co. POTw V.-ALL R001
Gravel pecats
+ f Ravel Access
Nct« Oufd tt001 Wes takai gut
dserv�ee,999 ad Ditch Toward Hood Creek k 0 40 60 120
PavadAoaass ` / muwt m to used as rnrad n the
-? Road _ SWP3Plan Aloft drampoa Altlgaor Branch Conlivance
r I
Pevargrt Ends &WAM 0 Oudai 0 OD2.
1
r odd Dirl Rood APPROXIMATE GRAPHIC SCALE
j PROACT eegA. v.pr cLtsnprrt-s F=Af;
! TRC Triangle, Inc.wT G•Mcs ITN SITE DRAINAGE PLAN
! 7/2001 C.T Specialty Properties, L.LC
RALEIGH. N.02
.
` wILAIINGTCN. N.C. REVISE€} 511 /06 by Gary Wooten to comply with new Stormwater Permit effective swol).
i CHARLOTTE. N.C.

o'Hood Creek
Sample Point A located
1.4 mile off LIS7+76 at
Avert on Harrelson Rd.
Clearcut Area makes up the
drainage for the feeder branch
Sample PointU. (ekt culvert)
Road
Locked Gate
North
Site Map for CT Specialty Properties
Stormwater Sampling Points to: determine
Alligator Branch pH Characteristics and
evaluate impact of Stormwater Discharges
from CTSP Plant Site on Stream pH
Drawing Not To Scale... Distances are
estimated GaryWooten
6/8106
Aliigator Branch Rom approi 0.4 mile from
WWI 002 to sampling point ai culvert on
Harrelson Road.
US 7+76 Highway
Railroad Track
Power Transmission Line
Paved Driveway into
CT Speciaftl Properties
Alligator Branch
f
CT Specialty
PropertiesPlant
Site
Locked
Gahrs -
Outfall 002
.Sprayfield
Upstream sampkg
Posit C at culvert under
road to Spf44ield

I
Page 1 of 4
CT Specialty Properties
SAMPLING PLAN NARRATIVE
Submitted to Aisha Lau on 7/6/06
(Gary Wooten's project notes, edited 6/30/06)
BACKGROUND INFORMATION
2/15/06.... Draft Stormwater Permit issued
"Significant changes," mentioned in cover letter.
4/22/06... Started collection of rain gauge data
Evaluating relationship of acidic rainwater & permit changes.
V27/06 ... Conducted Spring Stormwater Sampling Outfall 002.
Out#all 002 Spring Report mailed to DWQ-Raleigh Tuesday 5-23-06.
Qualitative Monitoring points all OK
(New Permit is effective July 1 2006; Analytical Monitoring was elective, not
required) Analysis: pH was 5.8. New pH benchmark range is 6.0-9.0.
Analysis: COD was 88. New COD benchmark is 120mg/L max.
5/13/06...Phone call with Linda Willis
Discussed Spring Sampling results and low pH of rainwater
Linda suggested upstream/downstream sampling
5/19/06...Follow-up call with Linda Willis
**Linda called Gary back to discuss status of upstream and downstream feeder
sampling she had suggested. Gary informed her that the rain events had not been
sufficient to obtain flow in Alligator Branch, but that a 6-point sampling plan had
been formulated and potential sampling sites identified.
**Linda stated she would be visiting the plant site in late summer and that unless
we had specific new issues to discuss, we should follow thru with our sampling
plan to document that our stormwater discharges are not affecting the water
quality in Alligator Branch. She will be looking at our data during the next site
visit. Evaluation of the data may require further sampling and possibly revision of
SWP3 Management Plan.
5/27/06 ... First rain event in (-point sampling program
Implemented sampling program, recording data on spreadsheet
6/16/06... Final draft of Stormwater Permit issued, to be effective 7/1/06
6/26/06 ... Discussed 6 point Sampling Data and permit revision with Linda Willis
6/28/06 ... Contacted Aisha Lau, planned submitting permit revision request.
6/30/06 ... Permit Revision Request Package submitted to Aisha Lau
(End of background Information-G Wooten)

V�
Page 2 of 4
5123/06...SIX POINT STORMWATER pH SAMPLING PLAN
. _ A. Stormwater Monitoring Log
Our path forward is to record rain events: date, time, duration, and amount of rainfall.
For each event we will analyze and record the pH of reengage water,.upstream flow. pH,
Outfall 002 pH, and downstream feeder pH. Data will be collected in attached
spreadsheet and stored in CTSP common e-Molder as well as in the Stormwater Discharge
Logbook, and kept current in preparation for the late summer visit by DWQ.
B. Sampling Points
Following are the six -sampling points and a brief description of each:
1. Sample Point A:"Downstream- culvert where Harrelson road crosses Alligator
Branch (Picture is Attached)
* * The downstream portion of Alligator Branch is a series of thickly vegetated low-lying
bay -like areas with a poorly defined 'run' that lies on property on the north side of
US74/76 owned by Bobby Harrelson, (Landmark Corporation) and a second portion
owned by Raeford Trask. The property is currently in use as a hunting lease controlled by
Bobby Harrelson, and the access road is gated and locked. Gary is trying to obtain
permission to access the property. It is desirable to collect pH samples from Alligator
Branch at the road culvert where it flows under Harrelson road as it flows toward
junction with Hood Creek.
2. Sample Point B: Feeder stream -north side of Alligator Branch, culvert where right
hand fork in Harrelson mad crosses drainage before it flows into Alligator Branch. (this
drainage is isolated from our discharges and will serve as a comparison point to show if
acidity is common to the area or originating from CTSP stormwater discharges.
**This is the first, and possibly only accessible point to collect a sample from a feeder
flow downstream of Outfall 002 and where pH cannot be affected by Outfall 002. Based
on information from Jimmy Hollis, a previous leaser of the property, the only discernable
flow thru this section of Alligator Branch during the drier spring months is immediately
after a rain event. Currently (as of 5/23/06) there are small standing puddles of water and
areas of muddy ground affording no opportunity to obtain a representative sample.
3.Sample Point C: Upstream- Same ditch (Alligator Branch) where Outfall 002 is
located.
**The upstream sampling point will be on CTSP property at the culvert where Alligator
Branch crosses the road leading to the CTSP sprayfield. This is located upstream of
outfall 002 and is representative of the flow before any Stormwater discharged from
CTSP secondary containment devices or run off from Drainage Areas 1 or 2 (shown on
SWP3 Site Drainage Plan) enters Alligator Branch. This area is the "headwaters" section
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of Alligator Branch resulting from another bay -like area draining the area immediately
south of the CTSP sprayfield (which is not currently in use, out of service approximately
9 months to date. The most recent use of the sprayfield was with the National Starch
groundwater remediation activities, but that remediated water is now sent to Brunswick
County POTW instead of the sprayfield.)
4.Outfall 002: (Shown on SWP3 Site Drainage Plan)
**Site of pH sampling, which does not meet Benchmark Limits in Stormwater Permit.
5. Rain gauge (Located South side of Warehouse shown on SWP3 Site Drainage Plan)
** Measure pH and volume of rainwater to help determine if low pH of collected
stormwater is the product of a naturally occurring event(s) or as a result of
conditions at the plant site which lower pH of Stormwater while it is being
collected in CTSP secondary containment structures.
6. Final Containment Sumps (Shown on SWP3 Site Drainage Plan)
**Stormwater is collected in various containment structures and routed here for final
inspection before discharge. (pH checks are performed here per our SWP3 Best
Management Practices.)
(End of 5/23/06 Sampling Plan-G Wooten)
REQUEST FOR REVISION OF PERMIT -Summary of events (thru 7/6/06)
6/26/06... Phone call with Linda Willis
Gary called Linda Willis on Monday 6/26/06 @ 15;00 and left message on her voice mail
stating that we had received the final version of our new Permit and that sampling results.
to date indicate that we will not be able to meet the pH benchmarks of 6.0-9.0 as
specified in the new Permit, and we feel it is inappropriate to accept the Permit as written
because the benchmark pH range is not achievable. We have a 30-day window (until July
16) to petition Raleigh for any items we find unacceptable in the Permit.
Linda returned Gary's call on Monday 6/26/06, but Gary had left site.
6/28/06...Phone call with Linda Willis
Linda and Gary spoke again Wednesday, 6/28/06 and pH sampling was discussed. Linda
was informed that we desired to petition Raleigh to request a permit revision, given that
the data we have obtained to date suggests the low pH is not influenced by the plant
operation, but instead is a result of naturally occurring conditions (i.e. rainfall pH and
swamp water). She suggested we could request a Permit revision based on an exemption
for pH as low as 4.3 for swamp waters, if the low pH is from natural conditions.
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(6/28/06 con't)
The upstream, feeder stream, and rain gauge sample data we have collected show this to
be true. Pictures and SWP3 narrative document the swamp conditions.
Linda also suggested that we call Aisha Lau in the Raleigh office to discuss an exact path
forward, but suggested we E-mail the spreadsheet and sampling diagram to Aisha as well
as a formal letter. Linda sent Aisha an. e-mail outlining our situation, and provided Gary
with an explanation of Regulation 15A NCAC 02B.0211 "Fresh Surface Water
Quality Standards for Class C Waters (3(G))" that apply to our situation.
6/28/06... Phone Call with Aisha.Lau
Gary called Aisha Lau [phone] ext 578 at 09:30 Wednesday, 6/28/06 and left
brief message on voicemail requesting a return call.
Aisha returned Gary's call same day and stated she had received Linda's e-mail outlining
our pH problems and Linda's suggestion for the path forward. Aisha requested we e-mail
our data to her, as well as prepare a formal request on Company Letterhead being sure to
reference our Permit number. Gary asked about discharging stormwater in the interim
period, since the new permit is effective July 1, and Aisha stated that Linda had provided
e-mail documentation and recommended the permit modifications be made, based on an
exemption for swamp waters. Aisha estimated the total time required to evaluate and
process the requested permit modification will take one to two months.
6/29/06:
Collected full set of samples from Wednesday's rain event.
6/30/06
Collected full set of samples from Thursday's rain event.
Entered final data in spreadsheet.
7/6/06
Send e-mail and certified US Mail to Aisha mid -day 7/6/06.
Jimmy McLawhorn as Facility Contact Person, signed Request Letter.
(End of Request for Revision of Permit, 7/6/06-G Wooten)
(End of Samolina Plan Narrative)
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