NCS000332_Email_20190520

Garcia, Lauren V
From: McDaniel, Jeffrey <[e-mail]>
Sent: Monday, May 20, 2019 4:27 PM
To: Garcia, Lauren V; Drennan, Kathryn
Subject: RE: [External] RE: [External]NCS000332 NPDES Stormwater Permit Renewal
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Thanks Lauren, we appreciate the additional info. Katie and I discussed and are aligned with your responses
Thanks again and have a great day.
Jeff
Jeff McDaniel
Site Leader
114Industrial Blvd
Morganton, NC 28655
Office: 828.219.3503
Mobile: [phone]
X HEXIN
www.hexion.com
From: Garcia, Lauren V <[e-mail]>
Sent: Monday, May 20, 2019 8:50 AM
To: Drennan, Kathryn <[e-mail]>; McDaniel, Jeffrey <[e-mail]>
Subject: RE: [External] RE: [External]NCS000332 NPDES Stormwater Permit Renewal
This message is from an EXTERNAL SENDER - be CAUTIOUS, particularly with links and attachments.
Hey Kathryn,
The results you have for your October -March monitoring event will end up being the last monitoring event for your old
permit. The good news is your new monitoring schedule (July -December) will overlap with the old April -September
period and you will actually have a little extra time to complete the monitoring event.
A bit of extra information (this is not as applicable to you because of your new permit going into effect at the end of
June), in the past the monitoring schedule has coincided with the date the permit is issued. I have had several facilities
ask to have their monitoring schedule edited to coincide with the schedule for facility inspections (page 5), so they can
do their inspections and monitoring at the same time. It is up to you if you would like your permit term to cover June -
November; December -May or to remain January -June; July -December. I picked the later as it gives you an extra month.

For your second question, the language in the permit means this:
If a facility is monitoring semi-annually, for example, and they decide to pull an extra sample during
that 6-month period (say maybe one parameter was over benchmark, they fixed something, and they
want to see how the discharge is now), they are required to report any extra sampling results on a
DMR to the State. BUT, that "extra" sample is not what they use for directing tier responses and
doesn't count toward the number of exceedances that might trigger another tier response. That first
sample is what they have to use. In this scenario, maybe their extra sample shows TSS came back
under benchmark, but they still have to count an exceedance for that monitoring period.
If they are already monitoring monthly, maybe they decide to pull additional samples several times in a
single month. Same thing applies. The first valid sample is the one they use to compare to
benchmarks (and determine if there's another step, like notify the RO because they hit their "any four
exceedances"), but they still have to send in DMRs for any subsequent weekly sampling. In other
words, they can't keep their "extra data" a secret; they have to report it. And, they can't pull extra
samples and just choose to report the one with values under benchmarks for that monitoring period.
I hope this helps, let me know if you have any other questions!
Lauren
From: Drennan, Kathryn <[e-mail]>
Sent: Tuesday, May 14, 2019 4:30 PM
To: Garcia, Lauren V <[e-mail]>; McDaniel, Jeffrey <[e-mail]>
Subject: [External] RE: [External]NCS000332 NPDES Stormwater Permit Renewal
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[e-mail]
Hi Lauren,
Please see attached for the updated analytical monitoring spreadsheet which includes data back to 2012.
In addition, we reviewed the draft permit and have the following clarifying questions:
• The new permit will be effective June 24, 2019. We are retesting for formaldehyde to meet the requirements for
October— March 2019 reporting period as per the current NPDES permit. Once this new permit is in effect, will
our next sample be required to meet the July — December 2019 reporting period?
• "The permittee must report the results from each sample token within the monitoring period (see Port lll, Section
E). However, for purposes of benchmark comparison and Tiered response actions, the permittee shall use the
analytical results from the first sample with valid results within the monitoring period." Could you please

elaborate on this requirement? Do we report all monthly sampling (if necessary) within one semiannual DMR as
opposed to submitting a separate report per sampling event?
Please let us know if the questions are unclear, or if you need additional information.
Thank you!
Katie
Katie Drennan
Associate Engineer
[e-mail]
TIRC
3 Walden Ridge Drive, Suite 250, Asheville, NC 28803
Iff T: [phone]
From: Garcia, Lauren V[mailto:[e-mail]]
Sent: Tuesday, May 07, 2019 8:51 AM
To: McDaniel, Jeffrey <[e-mail]>
Cc: Drennan, Kathryn <[e-mail]>
Subject: RE: [External] RE: [External]NCS000332 NPDES Stormwater Permit Renewal
Hi Jeff,
Thanks so much for sending me this information! Here is your updated permit draft. This will begin your 30-day
comment period where I will be able to address any comments or concerns you have with the permit. The permit has
been reformatted to be more concise and easier to read through. There have not been any changes made as far as
existing information goes, it will just look a little different. Changes are also outlined in the cover letter in the draft.
A quick question, do you happen to have any monitoring data from the beginning of the permit term (circa 2009-2014)?
Thanks for your help,
Lauren
From: McDaniel, Jeffrey <[e-mail]>
Sent: Monday, May 06, 2019 3:16 PM
To: Garcia, Lauren V <[e-mail]>
Cc: [e-mail]
Subject: RE: [External] RE: [External]NCS000332 NPDES Stormwater Permit Renewal
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[e-mail]
Hi Lauren,
Please see the response to your questions in red below and attached. Please let us know if you need any additional
information.
A spreadsheet summarizing all of the monitoring data that has been collected since the effective date of the
current permit; Please see the attached spreadsheet for this information. The last Discharge Monitoring
Report was submitted Wednesday, May 1, 2019.
A verification that the information in the renewal application is still is still complete and correct; and The
information from the last renewal application signed February 26, 2014 is correct; however, the Site

leader who signed the report is no longer at the facility. The contact information has been updated using
the links you provided below. Please let us know if you would like the facility to submit an updated
Renewal Application Form.
An explanation of any operational changes since the renewal application was submitted. There have not
been any significant operational changes in industrial activities at the facility. The facility added secondary
containment around non -hazardous waste totes on the east side of the main building in 2016. In addition,
a gravel truck tanker parking lot was added to the east side of the property in 2017.
Thanks and have a great day.
J eff
Jeff McDaniel
Site Leader
114Industrial Blvd
Morganton, NC 28655
Office: 828.219.3503
Mobile: [phone]
HEXIT
www.hexion.com
From: Garcia, Lauren V <[e-mail]>
Sent: Tuesday, April 30, 2019 1:31 PM
To: McDaniel, Jeffrey <[e-mail]>
Cc: [e-mail]
Subject: RE: [External] RE: [External]NCS000332 NPDES Stormwater Permit Renewal
This message is from an EXTERNAL SENDER - be CAUTIOUS, particularly with links and attachments.
Hi Jeff,
I just received your voicemail. I did get exactly what I needed from your e-mail. I left several messages last week just
hoping someone would call me back. That must be what the new message was from.
I'm sorry you have had network challenges and I hope things are able to be fixed for you soon. If Katie is able to access
that information in my first email for you, that would be great. If not, you may end up with your draft permit for review
before I have it. If I need to adjust the permit based on the monitoring information, I will send you an updated copy. The
Hexion draft permit is scheduled to be published for public notice on May 8, 2019, so things are moving along well.
Thanks,
Lauren
From: McDaniel, Jeffrey <[e-mail]>
Sent: Thursday, April 25, 2019 2:50 PM
To: Garcia, Lauren V <[e-mail]>

Cc: [e-mail]
Subject: [External] RE: [External]NCS000332 NPDES Stormwater Permit Renewal
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[e-mail]
Hi Lauren,
I did receive your voicemail as well, thanks for contacting me. Randy Beets told me he also received a voicemail, so you
have (2) good contacts now, he mentioned you had a couple obsolete contacts. We have had some turnover over the
past 4 years so you may have some inaccurate information. I have also copied Katie Drennan on this email, she is
consulting with us right now as we are filling the environmental position on a permanent basis.
We've had some network challenges over the past month as we have a total blackout for approximately 3 weeks and are
in the process now of coming back online fully. I attempted to access the links below and also tried copy/paste in my
browser but can't get them to go through. My guess is that it is on our end as things aren't back to normal yet. My
contact info is below, if you can email me any other information that is needed I can email that back.
Thanks very much.
Katie, are you able to access this information on our behalf? We do have our server files back as of yesterday so we can
research records on our end if needed.
Please advise.
Thanks.
Jeff McDaniel
Site Leader
114Industrial Blvd
Morganton, NC 28655
Office: 828.219.3503
Mobile: [phone]
X HEXI`
www. hexion.com
From: Garcia, Lauren V <[e-mail]>
Sent: Thursday, April 25, 2019 9:50 AM
To: McDaniel, Jeffrey <[e-mail]>
Subject: [External]NCS000332 NPDES Stormwater Permit Renewal
This message is from an EXTERNAL SENDER - be CAUTIOUS, particularly with links and attachments.
Good morning Jeffrey,
I left you a voicemail explaining that I am working on renewing your facility's individual stormwater permit (Permit No.
NCS000332). There is some information I am required to ask you for to (1.) confirm that the information I have is correct
and (2.) make sure the permit adequality serves the needs of the facility.

What I need from you:
• A spreadsheet summarizing all of the monitoring data that has been collected since the effective date of the
current permit;
• A verification that the information in the renewal application is still is still complete and correct; and
• An explanation of any operational changes since the renewal application was submitted.
The following link will take you to an online search box where you will be able to enter your permit number and review
the facilities information to make sure it is correct:
https://reports.ncdenr.org/BOE/Open Document/1703191515/CrystalReports/viewrpt.cwr?id=25212&apsuser=BIMS U
&apspassword=blOMs cr%28ddnri59%29&apsauthtype=secEnterprise&cmd=EXPORT&EXPORT FMT=U2FPDF%3AO.
Information can be updated using the links provided below, where applicable:
Owner Update: https://edocs.deg.nc.gov/Forms/SW-Name-Change
Owner Affiliation (i.e., someone with the company who is designated to represent the company per signatory
requirements in the permit (e.g., CEO) or another authorized representative): https://edocs.deg.nc.gov/Forms/SW-
Owner-Affiliation
Company of Facility Name: https://edocs.deg.nc.gov/Forms/SW-Name-Change
What happens next:
• Once I have the above listed information, I will verify the "draft" permit information is correct;
You will receive the draft for a 30-day comment period. During this time we will be able to address any
comments or concerns you have about your permit draft.
During the same 30-day period, the draft will be sent to an Asheville Regional Office staff member for review
and the permit draft will be sent for Public Notice.
• Once all comments and concerns are addressed, you will be issued the final permit.
Feel free to contact me with any questions as well.
Thanks,
Lauren
Lauren Garcia
Environmental Specialist II
Stormwater Program
Division of Energy, Mineral, and Land Resources
North Carolina Department of Environmental Quality
919-707-3648 (0)
[e-mail]
DEMLR Stormwater Program
512 N. Salisbury Street
1612 Mail Service Center
Raleigh, NC 27699-1612
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