NCS000057_Draft permit cover letter_20120203

NCDE�IR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Mr. Mark Dwyer
Chemical Specialties, Inc.
P.O. Box 1330
Harrisburg, NC 28075
Dear Mr. Dwyer:
Division of Water Quality
Charles Wakild, P.E.
Director
February 3, 2012
Subject: Draft NPDES Stormwater Permit
Permit No. NCS000057
Chemical Specialties, Inc. (CSI)
Cabarrus County
Dee Freeman
Secretary
Enclosed with this letter is a copy of the draft stormwater permit for your facility. Please review the draft very
carefully to ensure thorough understanding of the conditions and requirements it contains.
The draft permit contains the following significant changes from this facility's current permit:
Analytical monitoring changes:
1. The analytical monitoring parameters have been reduced in this permit to include TSS, COD, Copper, Zinc, and
pH. Sampling for Arsenic and Lead have been removed.
2. All analytical monitoring remains at semi-annually during a qualifying storm event However, the qualifying
storm event has been revised from a representative storm event to a measurable storm event as defined in
Part II Section B. The permittee must also document the total precipitation for each event If no discharge
occurs during the sampling period, the permittee must submit a monitoring report indicating "No Flow"
within 30 days of the end of the six-month sampling period. Additionally, samples must be taken a minimum
of 60 days apart, as specified in Table 2.
3. Failure to monitor semi-annually per permit terms immediately institutes monthly monitoring for all
stormwater parameters for six months, as specified in below Table 2.
4. Benchmarks for analytical monitoring remain in this draft permit Exceedances of benchmark values require
the permittee to increase monitoring, increase management actions, increase record keeping, and/or install
stormwater Best Management Practices (BMPs) in a tiered program. If the sampling results are above a
benchmark value, or outside of the benchmark range, for any parameter at any outfall then the facility shall
follow the Tier One guidelines which require a facility inspection within two weeks and implementation of a
mitigation plan within two months. If during the term of this permit, the sampling results are above the
benchmark values, or outside of the benchmark range, for any specific parameter at a specific discharge
outfall two times in a row (consecutive), then the facility shall follow the Tier Two guidelines which require a
repetition of the steps listed for Tier One and also immediately institute monthly monitoring for all
parameters at every outfall where a sampling result exceeded the benchmark value for two consecutive
samples. During the term of this permit, if the valid sampling results required for the permit monitoring
periods exceed the benchmark value, or are outside the benchmark range, for any specific parameter at any
specific outfall on four occasions, the permittee shall follow the Tier Three guidelines which require the
permittee to notify the DWQ Regional Office Supervisor in writing within 30 days of receipt of the fourth
analytical results.
Wetlands and Stormwater Branch One
1617 Mail Service Center, Ralegh, North Carolina 27699-1617 NorthCarolina
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Natmrally
Intemet: www.ncwaterqua[4.org
An Equal Opportunity 1 Affirmative Action Employer

Mr. Mark Dwyer
CSI
Permit No. NCS000057
S. As discussed previously, Copper and Zinc are not subject to triggering the increased monitoring requirements
of Tier Two and Three. In lieu of this, mandatory best management practices (BMPs) are included as
specified in Part 11, Section E.
6. You are required to collect all of the analytical and qualitative monitoring samples during measurable storm
events as defined in Part II Section B. Qualitative monitoring is required regardless of representative outfall
status.
7. A section on qualitative monitoring response has been added in Part II, Section C, which is similar to the Tier
Three for analytical monitoring, for repeatedly failing to respond effectively to correct problems identified by
qualitative monitoring, or if the discharge causes or contributes to a water quality standard violation.
8. You are responsible for all monitoring until the renewal permit is issued. See Footnote 1 of Tables 2, 4, and 5.
9. The event duration requirement has been removed per DWQ revised strategy. (The total rainfall parameter is
in this permit, however.)
10. Vehicle maintenance monitoring remains semi-annually in order to coincide with analytical and qualitative
monitoring. Monitoring for TPH has replaced Oil & Grease. This requirement appears in all Individual
Stormwater permits, however it only applies to facilities that do vehicle maintenance. If the facility begins
vehicle maintenance during the permitted timeframe then the requirements shall apply.
Other permit changes:
1. Additional guidance is provided about the Site Plan requirements. The site map must now identify if the
receiving stream is impaired and if it has a TMDL established. It must also describe potential pollutants in
each outfall. The map requirements are stated more explicitly. And, the site plan must contain a list of
significant spills that have occurred in the past three years and also must certify that the outfalls have been
inspected to ensure that they do not contain non-stormwater discharges. Additional information is provided
in Part Il Section A.
2. Additional requirements for the Stormwater Management Plan have been specified in Part 11 Section A. More
details regarding secondary containment are provided.
3. Additional requirements for the Stormwater Pollution Prevention Plan have been specified in Part 11 Section
A. The plan must also be updated annually to include a list of significant spills and to certify that the outfalls
do not contain non-stormwater discharges.
4. Information regarding the No Exposure Exclusion has been added to this draft permit If industrial materials
and activities are not exposed to precipitation or runoff as described in 40 CFR §122.26(g), the facility may
qualify for a No Exposure Exclusion from NPDES stormwater discharge permit requirements. Additional
information is provided in Part I Section A.
5. In addition to submitting two signed copies of DMRs to Central Files, a separate signed Annual Summary DMR
copy must be submitted to the local DWQ Regional Office by March 1 of each year.
Please submit any comments to me no later than thirty (30) days following your receipt of the draft Comments
should be sent to the address listed at the bottom of this page. If no adverse comments are received from the
public or from you, this permit will likely be issued in about two months.
If you have any questions or comments concerning this draft permit, contact me at [phone] or
[e-mail].
Sincerely,
Robert D. Patterson, PE
Environmental Engineer
Stormwater Permitting Unit
cc: Mooresville Regional Office, Michael Parker
Stormwater Permitting Unit
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