NCS000057_Affidavit_20120229

Independent Tribune
Advertising Affidavit
North Carolina Community Newspapers
PO Box 968
Hickory, NC 28603
NC DENRIDWQ
BUDGET OFFICE
1617 MAIL SERVICE CENTER
RALEIGH, NC 27699
Account Number
3142720
Date
February 24, 2012
Date Category Description Ad Number Ad Size
02/24/2012 Legal Notices NC DIVISION OF WATER QUALITY INTENT TO ISSUE AST( 0002576994 1 x 31 L
NC DIVISION OF WATER QUALIFY INTENT TO ISSUE
A STORMWATER DISCHARGE PERMrr
Public comment or objection to the draft permit is
invited. Submit written comments to DWQ at the
address below. All comments received pprior to
March 29, 2012 will be considered in the Nnal de-
termination regarding permit issuance and permit
provisions.
Application: Chemical specialties, Inc., P.O. Box
1330, Harrisburg, NC 28075 has applied for an
NPDFS permit to discharge stormwater from an in-
dustrial facility at: 5910 Pharr Mill Rd., Harrisburg,
NC, Cabarrus County. The facility discharges to
the Rocky River.
Copies of the draft permit, No. NCS000057, are
available at: ht / ortal.ncdenr.o, web(wtLws
/su`current,no_lces , Additional permit docu-
men is are available for the reproduction cost at:
DWQ Stonnwater Permitting Unit
512 N. Salisbury Street (location, zip 27604)
1617 Mail Service Center (mail)
Raleigh, NC 27699-1617
DWQ Contact: Robert Patterson
(919)-807-6375
roberLpatterson@nc de nr.gov
PUBLISH: February 24, 2012
p@ROWR
FEB 2 9 2012
DENR-WATER QUALITY
WETLANDS AND STORMWATERBRANCH
Media General Operations, Inc.
Publisher of
Independent Tribune
Cabarrus County
Before the undersigned, a Notary Public of Catawba County, North
Carolina, duly commissioned, qualified, and authorized by law to
administer oaths, in said County and State: that he/she is authorized to
make this affidavit and sworn statement: that the notice or other legal
advertisement, a copy of which is attached hereto, was published in the
Independent Tribune on the following dates:
02/24/2012
and that the said newspaper in which such notice, or legal advertisement
was published. was a newspaper meeting all the requirements and
qualifications of Section 1-597 of the General Statutes of North Carolina.
Assistant Bookkeeper
Newspaper reference: 0002576994
Swom to and subscribed before me, this ��ay ofA�L__ 2012
„trlttlfl rlr
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Notary Pnbfic � �r
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My Commission expires: h*A,_sri//, -eel y , AU L3 0
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THIS IS NOT A BILL. PLEASE PAY FROM INVOICE. THAT KYff`fi
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April 4, 2012
Mr. Robert Patterson
Wetlands and Stormwater Branch
North Carolina Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Draft NPDES Stormwater Permit Response
Permit No. NCS000057
Chemical Specialties, Inc. (CSI)
Cabarrus County
Dear Mr. Patterson:
Thank you for your consideration in the changes you've made to Section E. There are a couple
other requests for changes in wording of the section.
SECTION E: MANDATORY BEST MANAGEMENT PRACTICES (BMPS)
Paragraph (1) As it currently reads:
1. The Permittee shall ensure entryways and loading/unloading areas near
manufacturing areas where copper exposure could occur are cleaned -up daily, and
that cleaning procedures are conspicuously posted within the affected work areas.
Any spills of material shall be immediately cleaned -up.
Paragraph (1) Changed to read:
1. The Permittee shall ensure entryways and loading/unloading areas near manufacturing
areas where copper exposure could occur are cleaned -up after use, and that cleaning
procedures are conspicuously posted within the affected work areas. Any spills of
material should be cleaned -up by the end of the work shift.; 0 2 s oowt a / F a R NY FALL # S E x ?(Z`T't A
??-%Oe 'ro -r►'1OL i *1�> or 1 r►✓t wuaK
Changes requested due to CSI not handling/moving copper on a daily basis. It is also believed s I IX''
that cleaning up the copper could be more effectively performed as an end of shift duty.
Paragraph (3) As it currently reads:
The Permittee shall implement BMPs to reduce copper and zinc exposure, including but not
limited to: storing empty drums/totes/bales indoors and clean-up from handling and
storing of the powdered, liquid, and scrap copper and zinc materials. For BMPs that have

already been implemented, the Permittee shall ensure those practices are maintained as
long as they effectively reduce copper and zinc exposure.
Paragraph (3) Changed to read. -
The Permittee shall implement BMPs to reduce copper and zinc exposure, including but not
limited to: storing empty drums/totes/bales under cover, and requiring clean-up
resulting from handling and storing of the powdered, liquid, and scrap copper and zinc
materials. For BMPs that have already been implemented, the Permittee shall ensure those
practices are maintained as long as they effectively reduce copper and zinc exposure.
There is a temporary staging area in front of the copper production tanks/reactors where copper
bales are kept under cover for a limited time; but area is not enclosed on four sides. The second
changes are proposed simply to make the text read easier.
Thank you again for working with us on this renewal. I'll wait for your comments.
Sincerely,
Mark Dwyer
Safety, Health and Environmental Manager
Chemical Specialties, Inc.

March 13, 2012
Mr. Robert Patterson
Wetlands and Stormwater Branch
North Carolina Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
ME nz
CSI MAR 1 b 2012 lG%
CHEMICAL SPECIALTIES. INC.
KEi(gtJGSANGSTOR'MWATS BRaNCN
Subject: Draft NPDES Stormwater Permit Response
Permit No. NCS000057
Chemical Specialties, Inc. (CSI)
Cabarrus County
Dear Mr. Patterson:
Thank you for your time and efforts in assisting CSI with our stormwater permit application. The
following are Chemical Specialties' comments and requests for changes in the draft permit:
SECTION E: MANDATORY BEST MANAGEMENT PRACTICES (BMPS)
Paragraph 1 causes CSI the most concern in the draft permit. This item is very labor intensive and
stormwater improvements are doubtful. Please remove paragraph (1) based on the following
analysis:
Copper is transferred in chopped (scrap) bales, on pallets from the #4 Warehouse to the ACQ
reactor building (with overhead storage) via forklift. The forklifts travel a distance of
approximately 400 feet (Attached Map A) on a macadam surface.
CSi contends that sweeping the area daily would not er`rectiveily ciean or renrove copper scrap
or fines from the surface of the macadam drive. The surface of the macadam drive traps
particles within the aggregate. CSI would prefer to direct stormwater BMPS to other practices
that may be more practical and yield better results. The employee task group can evaluate
other possible means of decreasing our copper exposure through material handling
procedures and other operating procedures. An example of other operating procedures that
may be more practical is the relocation of the ACQ-Cl production process to building 300. The
operation is being relocated away from our main drive at the top of the #4 warehouse
driveway. One of the benefits of this relocation will be reduced surface area of current copper
scrap exposure.
-/MM1't T I2N/ j 4C,#j>4," s14944fte
rod 1 4 51ro-rz G6y--,q ✓'410
PO Box 1330 •5910 Pharr Mill Road • Harrisburg, NC 28075 • 704-455-5181- Pj.4M -r 0 RJFA-*Ck
Main Fax [phone] • Purchasing and Transportation Fax [phone]c-fD4 M
Lab Fax [phone] • Accounting and PoleCare Fax [phone] S .RIa"1 e t-,/
Engineering Fax [phone] fc3 /cif crs. oVJII�.K
.T'r'" y

l�
CSI
CHEMICAL SPECIALTIES, INC.
nlGAevCurS
2. In regards to zinc, the plant does not have any regular exterior zinc handling or storage
activities. So the zinc is not likely related to any sort of housekeeping shortcoming. Further,,,.,,
testing as proposed may serve to further identify sources of zinc exposure.
— 2A/ 41-4Yr Ittwh" ttoor, Fv� v lu,tpavG//
/N Ait o.¢ 41,yG.
a CSI would also like to have a simple edit to:
Paragraph (3)
"...improving preventative maintenance for any dust collectors;"
CSI does not have any dust collectors; and thereby would like to have this removed from the text.
Sincerely,
Mark Dwyer
Safety, Health and Environmental Manager
Chemical Specialties Incorporated
CC: Jonna Stein, CSI, Steve Novak, CSI
attachment
PO Box 1330 • 5910 Pharr Mill Road • Harrisburg, NC 28075. 704-455-5181
Main Fax [phone] • Purchasing and Transportation Fax [phone]
Lab Fax [phone] • Accounting and PoleCare Fax [phone]
Engineering Fax [phone]

Patterson, Robert
From: Derek Slocum [[e-mail]]
Sent: Thursday, March 01, 2012 10:33 AM
To: Patterson, Robert
Subject: Chemical Specialties, Inc. - NPDES SW Permit -Town of Harrisburg Storm Water Comments
Robert,
I received this notice through Cabarrus County. Harrisburg does have a Storm Water Ordinance aligned with the Ph II
program. I am the acting storm water administrator.
Just a comment to include:
• The Town just wants to ensure that Chemical Specialties, Inc. understands that this industrial permit does not
exempt them from any new development (i.e. parking lot, building expansion, etc.) that they may pursue in the
future. Any type of new develop would be reviewed per the Town's Storm Water Ordinance.
Thank you.
Derek Slocum
Town Engineer
Town of Harrisburg
(704)455--4758
[phone]-Fox
[e-mail]

Patterson, Robert
From:
Patterson, Robert
Sent:
Thursday, March 01, 2012 6:33 AM
To:
'Dwyer, Mark'
Cc:
Stein, Jonna
Subject:
FW: Draft Review
Mark,
I just saw in my box that for some reason the public notice to the paper didn't get printed until February 24, 2012. (not
sure what happened there) So, the comment period is open anyways until March 29, 2012 for the public and you.
Thanks.
Robert
From: Patterson, Robert
Sent: Thursday, March 01, 2012 6:27 AM
To: 'Dwyer, Mark'
Cc: Stein, Jonna
Subject: RE: Draft Review
Mark,
That would be fine. Please take this email for your record of granting your request to extend time for your comments to
March 23, 2012. This won't extend the public comment period, but would be extension for Chemical Specialties to
comment. Please let me know if you have any questions.
Thanks
Robert D. Patterson, PE
Environmental Engineer
NCDENR I DWQ I Stonnwater Perinitting
1617 Mail SenTice Center, Raleigh, NC 27699-1617 Mail 1 512 N. Salisbury St, Raleigh, NC 27604 1 911, Floor Loci--Atic ,) tip l arcels
[phone] Y)horw 1 [phone] Fax I Robert. Pattersoumcdenr.gov Kinail I http://portal.ncdenr.org/web/wa/ws/su Website
pA Before printing this email. pleww consider your budget and the environment.
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties unless the content is
exempt by statute or other regulation.
From: Dwyer, Mark f mailto:[e-mail]]
Sent: Wednesday, February 29, 2012 4:36 PM
To: Patterson, Robert
Cc: Stein, Jonna
Subject: Draft Review
Good afternoon Robert. Earlier today, I unearthed the Stormwater Permit Draft you mailed me. My apologies, I just
took over this position and am learning the environmental reporting nuances. I have reviewed the draft and created a
list of some feedback. On your letter you asked for a response from my received date (which probably was the 8th or 9th
of this month). Could we extend our draft comment submission date to March 23rd?
Jonna Stein, whom you've spoken with, was the past SHE Manager and is the current Operations Manager. She is
reviewing your draft; and has much experience with the process. I would like to get together with her and ensure we
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capture all of our thoughts on our response. I appreciate your consideration. I was loaded up with reporting
requirements for the annual EPA items and was doing them for my first time.
Mark Dwyer
Safety, Health and Environmental Manager
Chemical Specialties, Inc.
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