NCS000088_Fact sheet binder_20230726

DEQ / DEMLR
FACT SHEET FOR NPDES INDUSTRIAL INDIVIDUAL
STORMWATER PERMIT DEVELOPMENT
Basic Information for Permit Issuance and Renewals:
Permit Writer/Date Brianna Young 7/21/2023
Permit Number NCS000088
Owner/Facility Name Hexion,Inc./Hexion, Inc.
2821 /Plastic Material and Resin Manufacturing
SIC(NAICS)Code/Category 2869/Industrial Organic Chemicals,Not Elsewhere
Classified
2891 /Adhesives and sealants
Basin Name/Sub-basin number Cape Fear/03-06-15
Receiving Stream/HUC Cape Fear River/030300040707
Stream Classification/Stream Segment C/ 18- 26
Is the stream impaired on 303 d list]? No
Any TMDLs? No
Any threatened and/or endangered species? See Section 2 below
Any compliance concerns? See Section 2 below
Any permit mods since lastpermit? See Section 1 below
New expiration date 8/31/2028
Comments on Draft Permit? See Section 6 below
Section 1. Facility Activities and Process:
Hexion, Inc. is an inorganic chemical manufacturer that produces formaldehyde, wax emulsions, urea-
formaldehyde concentrate, urea-formaldehyde resins, methanol/formaldehyde blend(methaform), and
phenol-formaldehyde resins/adhesives. The facility previously produced hexamine (manufacturing
facility has not been used for several years).
Per the previous permit fact sheet, materials are brought by rail and truck and stored in tanks on site, and
the majority of the industrial area drains to the pretreatment WWTP. TRI has releases of phenol,
methanol, formaldehyde, mercury, ammonia, and triethylamine listed.
Per information provided 9/22/2022, additional raw materials that have the potential to come into
contact with stormwater include:
Acetic Acid, Glacial GN 8-Low Chloride Sodium Hydroxide
Alpha Olefin Wax A Guar Gum Sodium Sulfate Anhydrous
Ammonia Aqua Magnesium Chloride HS-100 solution
Borax Melamine Corn Starch
Boric Acid Methanol Stearic Acid, Liquid
Crude Glycerine Methocel Sulfonated Naphthalene
Molasses Phenol Sulfuric Acid
Diethylene Glycol Potassium Carbonate Defoamer
Dry Material Additive Potassium Hydroxide Triethanolamine
FC-414 Antifoam Rhodoline Urea
Foam-A-Tac 611 Slack Wax Water-Based Silicone Emulsion
Formic Acid Sodium Bicarbonate Wheat Flour
Formaldehyde Sodium Carbonate-Anhydrous Wil-Fil
Page 1 of 8

Per the 2015 permit renewal application, old formaldehyde storage tanks have been replaced with new
ones along with new secondary containment. There has been increased automation in the facility, and
secondary containment has been expanded for the methanol tanks and tank farm. Per information
received 9/22/2022, the production of hexamine has been stopped therefore aqua ammonia is no longer
received at the facility.
Outfall SW001:
Drainage area consists of an employee parking lots, tanker truck parking area, covered bulk urea
unloading area, formaldehyde truck loading area, methanol unloading and storage, main warehouse
loading dock, wastewater treatment system, and tank farm.
Outfall SW002:
Drainage area consists of a raw material,phenol-formaldehyde, aqueous ammonia, ready to use resin
tank farms, and cooling towers (blowdown and cooling tower water go to the WWTP).
Outfall SW003:
Drainage area consists of a covered flammable liquid drum storage area, graveled tank truck parking
area, and the edge of the phenol-formaldehyde and ready to use resin processes.
Why Industrial Sites with Stormwater are Subject to a Permit: Federal NPDES regulations define
stormwater discharge associated with industrial activity in 40 CFR §122.26 (b)(14) as: "the discharge
from any conveyance that is used for collecting and conveying storm water and that is directly related to
manufacturing,processing or raw materials storage areas at an industrial plant. The term does not
include discharges from facilities or activities excluded from the NPDES program under this part 122.
For the categories of industries identified in this section, the term includes, but is not limited to, storm
water [sic] discharges from industrial plant yards; immediate access roads and rail lines used or traveled
by carriers of raw materials, manufactured products, waste material, or byproducts used or created by
the facility; material handling sites; refuse sites; sites used for the application or disposal of process
waste waters (as defined at part 401 of this chapter); sites used for the storage and maintenance of
material handling equipment; sites used for residual treatment, storage, or disposal; shipping and
receiving areas; manufacturing buildings; storage areas (including tank farms) for raw materials, and
intermediate and final products; and areas where industrial activity has taken place in the past and
significant materials remain and are exposed to storm water. For the purposes of this paragraph, material
handling activities include storage, loading and unloading, transportation, or conveyance of any raw
material, intermediate product, final product, byproduct or waste product. The term excludes areas
located on plant lands separate from the plant's industrial activities, such as office buildings and
accompanying parking lots as long as the drainage from the excluded areas is not mixed with storm
water [sic] drained from the above described areas."
Section 2. Monitoring Information and Compliance History:
• October 2011 to March 2022, benchmarks exceeded for:
o SW001: COD 12x, TN 2x, pH min not reached Ix
o SW002: Ammonia nitrogen 2x, COD Ix, TN Ix,pH min not reached Ix
o SW003: COD Ix, pH min not reached Ix
Page 2 of 8

• Per the permit file history, an underground line leak led to a methanol spill in 2008 (some
reaching surface waters)
o Duration: 3 months
o Amount spilled: 234,000 gallons
• Tier Two monthly monitoring was conducted in 2015 and again in 2017/2018 for outfall 001 due
to consecutive exceedances of COD
Threatened/Endangered Species:
There are no threatened/endangered species in the vicinity of discharge, however, there are other species
of concern at the location and in the surrounding area. These include: Shining Clubtail (Stylurus ivae;
NC status: SR), Coppery Emerald(Somatochlora georgiana;NC status: SR), Swamp Jessamine
(Gelsemium rankinii; NC status: SC-V), and Batesburg Hawthorn (Crataegus munda var. munda; NC
status: SR-T).
Section 3. Proposed Monitoring for Stormwater Discharges:
The Division considered potential pollutants from past and present industrial activities and data was
submitted for October 2011 to March 2022. Quantitative sampling included ammonia nitrogen, BOD,
COD, nitrate, nitrite, total nitrogen, TKN, methanol, and pH.
Parameters are based on potential pollutants in the drainage area, sampling results, and in some cases,
dependent upon future activities (e.g., ash removal through the drainage area). Below is a table of the
proposed monitoring for each outfall at the Hexion, Inc. site.
Outfalls SWO01 and SWO03
Quarterly monitoring
Total Suspended Solids BASIS: Potential pollutant from drainage area and BMP effectiveness
(TSS) indicator.
Quarterly monitoring
pH BASIS: Pollutant indicator
Quarterly monitoring
Total Rainfall BASIS: Discharge potential indicator
Quarterly monitoring
Non-Polar Oil &Grease BASIS: Potential pollutant from lubricants; Method 1664 SGT-HEM
targets petroleum-based O&G
Quarterly monitoring
Monthly Oil Usage BASIS: Potential pollutant from drainage area
Quarterly monitoring
BOD BASIS: Discharge potential indicator
Quarterly monitoring
COD BASIS: Discharge potential indicator
Page 3 of 8

Quarterly monitoring
Total Nitrogen BASIS: Discharge potential indicator
Quarterly monitoring
Methanol BASIS: Potential pollutant from drainage area
Quarterly monitoring
Formaldehyde BASIS: Potential pollutant from drainage area
Outfall SWO02
Quarterly monitoring
Total Suspended Solids BASIS: Potential pollutant from drainage area and BMP effectiveness
(TSS) indicator.
Quarterly monitoring
pH BASIS: Pollutant indicator
Quarterly monitoring
Total Rainfall BASIS: Discharge potential indicator
Quarterly monitoring
Non-Polar Oil &Grease BASIS: Potential pollutant from lubricants; Method 1664 SGT-HEM
targets petroleum-based O&G
Quarterly monitoring
Monthly Oil Usage BASIS: Potential pollutant from drainage area
Quarterly monitoring
BOD BASIS: Discharge potential indicator
Quarterly monitoring
COD BASIS: Discharge potential indicator
Quarterly monitoring
Total Nitrogen BASIS: Discharge potential indicator
Quarterly monitoring
Ammonia Nitrogen BASIS: Potential pollutant from drainage area
Quarterly monitoring
Formaldehyde BASIS: Potential pollutant from drainage area
Page 4 of 8

Per the previous permit fact sheet, the site has Urea, Phenol, Methanol, Formaldehyde, Anhydrous
Ammonia, and Hexamine in large amounts; however, the facility states that only methanol and ammonia
may have exposure to stormwater as all other areas with the chemicals drain to the WWTP.
Stormwater Benchmarks and Tiered Response: Rather than limits,North Carolina NPDES
Stormwater permits contain benchmark concentrations. Stormwater benchmarks are numerical action
levels for stormwater monitoring. Benchmarks are not effluent limits, and benchmark exceedances are
not permit violations. Benchmarks provide facilities a tool for assessing the significance of pollutants in
stormwater discharges and the effectiveness of best management practices (BMPs). Benchmark
concentrations are intended as guidelines for the facility's development and implementation of the
Stormwater Pollution Prevention Plan(SWPPP).
Benchmark exceedances require the permittee to increase monitoring, increase management actions,
increase record keeping, and/or install stormwater BMPs in a tiered program. The permit establishes a
tiered approach to specify actions the permittee must take in response to analytical results above
benchmark concentrations. The tiered structure of the permit provides the permittee and DEMLR wide
flexibility to address issues that may arise with one or more parameters and/or outfalls.
Metals benchmarks are calculated to mimic acute water quality standards and with the guidance of
DWR. NC DWR follows established federal procedures for calculating acute standards when developing
the benchmarks. Just like the acute standards, metals benchmarks normally reflect one half of the
calculated Final Acute Value (the "1/2 FAV"). In most cases, translation into total recoverable values is
based on an assumed hardness of 25 mg/L and a total suspended solids (TSS) concentration of 10 mg/L.
Acute standards protect aquatic life from negative impacts of short-term exposure to higher levels of
chemicals where the discharge enters a waterbody. The Stormwater Permitting Program applies this
approach because of the ephemeral nature of rainfall events.
The Division may evaluate results to determine if a smaller suite of parameters for some outfalls is
adequate to characterize potential pollution or BMP effectiveness. For example, one or more metals or
other parameters may serve as an adequate tracer for the presence of ash pollution during disturbance or
ash removal in specific drainage areas at this site. For parameters that do not have a stormwater
benchmark, the Division may develop a benchmark value if appropriate toxicity data become available
or if rising trends in concentrations suggest a persistent source.
A summary of the benchmarks in the draft permit, and their basis, is below:
Parameter Benchmark Basis
Total Suspended 100 mg/L National Urban Runoff Program(NURP) Study, 1983
Solids TSS
H 6 s.u. —9 s.u. NC Water Quality Standard(Range)
Non-Polar Oil & Review of other state's daily maximum benchmark
Grease 15 mg/L concentration for this more targeted O&G;NC WQS that
EPA Method 1664 does not allow oil sheen in waters
(SGT-HEM
BOD 30 mg/L BPJ; Based on Secondary Treatment Regulation(40 CFR
g 133.03
COD 120 mg/L BPJ; Generally found at levels 4x BOD5 in domestic
wastewaters
Page 5 of 8

Total Nitrogen 30 mg/L TKN +Nitrate +Nitrite Benchmarks (Expressed in mg/L of
N
Ammonia Nitrogen At 7.5 s.u. pH and summer(26°C) temperature from
5.6 mg/L Wasteload Allocation document for the coastal plain region
(summer) worst-case scenario
Ammonia Nitrogen At 7.5 s.u. pH and winter(14°C) temperature from Wasteload
(winter) 15 mg/L Allocation document for the coastal plain region(worst-case
scenario)
Methanol 6,400 mg/L Species Mean Acute Value of two 96-hour equilibrium EC50
endpoints for Le omis machrochiris blue ill
Formaldehyde 0.5 mg/L '/2 FAV
Stormwater Pollution Prevention Plan: The proposed permit conditions reflect the EPA and NC's
pollution prevention approach to stormwater permitting. The Division's maintains that implementation
of Best Management Practices (BMPs) and traditional stormwater management practices that control the
source of pollutants meets the definition of Best Available Technology (BAT) and Best Conventional
Pollutant Control Technology(BCT). The permit conditions are not numeric effluent limitations but are
designed to be flexible requirements for implementing site-specific plans to minimize and control
pollutants in stormwater discharges associated with the industrial activity. Title 40 Code of Federal
Regulations (CFR) §122.44(k)(2) authorizes the use of BMPs in lieu of numeric effluent limitations in
NPDES permits when the agency finds numeric effluent limitations to be infeasible. The agency may
also impose BMP requirements which are "reasonably necessary" to carry out the purposes of the Act
under the authority of 40 CFR 122.44(k)(3). The conditions proposed in this draft permit are included
under the authority of both of these regulatory provisions. In essence, the pollution prevention and BMP
requirements operate as limitations on effluent discharges that reflect the application of BAT/BCT.
Flexibility in Tier Responses: Tier Two actions provide an opportunity for the permittee to propose an
alternative monitoring plan for approval by the Region:
• Alternatively, in lieu of steps 2 and 3, the permittee may, after two consecutive exceedances,
exercise the option of contacting the DEMLR Regional Engineer as provided below in Tier
Three. The Regional Engineer may direct the response actions on the part of the permittee as
provided in Tier Three, including reduced or additional sampling parameters or frequency.
• If pursuing the alternative above after two consecutive exceedances, the permittee may propose
an alternative monitoring plan for approval by the Regional Engineer.
The permit therefore allows the permittee to petition the Regional Office for monitoring changes sooner
than Tier Three (upon any four benchmark exceedances) and gives guidance on one option to take. For
example, the permittee may request that mercury only be monitored semi-annually under the tiers, or
that only parameters over the benchmark be monitored more frequently. In this way, changes to the
monitoring scheme for any outfall could be handled outside of a permit modification.
Other Proposed Requirements:
• It is standard for Stormwater Pollution Prevention Plan(SWPPP)requirements to include an
annual certification that stormwater outfalls have been evaluated for the presence of non-
stormwater discharges, and if any are identified, how those discharges are permitted or otherwise
authorized.
• Requirement to submit a request for permit modification if the facility identifies or creates any
new outfalls, removes outfalls, or alters any drainage area that changes potential pollutants.
Page 6 of 8

• The Division expects the permittee to apply best professional judgment and consider the safety
of its personnel in fulfilling sampling obligations under the permit.
• Federal regulations require electronic submittal of all discharge monitoring reports (DMRs). If a
state does not establish a system to receive such submittals, then permittees must submit DMRs
electronically to the EPA.
• Quarterly QualitativeNisual Monitoring to assure regular observation of outfalls throughout
year.
Section 4. Changes from previous permit to draft:
• Monitoring increased from semi-annually to quarterly for all parameters (qualitative and
quantitative)
• "No discharge" clarifications made
• eDMR requirement added
• Feasibility study removed
• Outfall specific monitoring implemented
• Boilerplate language moved into body of the permit; boilerplate no longer attached
• Monitoring for TKN removed as monitoring for total nitrogen is already required
• Monitoring for ammonia nitrogen removed as aqua ammonia is no longer delivered to the facility
• Monitoring for formaldehyde added for all outfalls as used in industrial processes and stored
onsite
• Benchmarks updated for parameters per guidance from DWR Standards group on stormwater
benchmarks
Section 5. Changes from draft to final:
• Monitoring for ammonia nitrogen added to SWO02 per permittee comments on draft permit
• Monitoring for methanol added to SWO03 per permittee comments on draft permit
• Outfall descriptions updated under Tables 1 and 2
• Solvent management plan included in Part B
Section 6. Discussions with the Facility and Regional Office:
• Initial contact with facility: 8/25/2022
• Initial contact with Regional Office: 8/25/2022
• Draft sent to CO peer review: N/A
• Draft sent to Regional Office: 6/14/2023
• Final permit sent for supervisor signature: 7/26/2023
Page 7 of 8

Section 7. Comments received on draft permit:
• Caleb Stoker (permittee; via email 7/17/2023): Hexion proposes the following updates to the
draft permit:
o Add Ammonia as Nitrogen to the analytical monitoring requirements for Outfall
SW002. Although anhydrous ammonia is no longer utilized onsite, aqueous ammonia is a
raw material that is offloaded from bulk tankers in the area of Outfall SW002.
■ DEMLR Response: Monitoring will be added to SW002.
o Add Methanol to the analytical monitoring requirements for Outfall SW003. The
methanol storage tank containment area is partially located in the drainage area for
Outfall SW003.
■ DEMLR Response: Monitoring will be added to SW003.
o Amend the Outfall descriptions. Hexion proposes the following:
■ Outfall SW001: Drainage area consists of employee parking lots, main office
buildings, main warehouse loading dock, methanol unloading and storage (have
secondary containment and sampled prior to release to stormwater), tanker trailer
and railcar parking/storage areas, a covered bulk urea unloading area, and finish
product tanker truck loading operations. It is adjacent to a tank farm storage area,
and finish product tanker truck loading operations—which all have containment
and any process contact stormwater would drain to onsite wastewater treatment.
■ Outfall SW002: Drainage area consists of aqueous ammonia tanker truck
offloading area, finish product tanker truck loading operations, and process
cooling towers (cooling tower water and blowdown go to onsite wastewater
treatment). It is adjacent to raw material and finished product tank farm storage—
which all have containment and any process contact stormwater would drain to
onsite wastewater treatment.
■ Outfall SW003: Drainage area consists of methanol unloading and storage (have
secondary containment and sampled prior to release to stormwater), tanker trailer
and railcar parking/storage areas, a covered flammable storage area for liquid
drums and totes (has secondary containment), and process cooling towers
(cooling tower water and blowdown go to onsite wastewater treatment). It is
adjacent to the MO formaldehyde processes and former(inactive)hexamine plant
—which all have containment and any process contact stormwater would drain to
onsite wastewater treatment.
■ DEMLR Response: The description of activities in the outfall drainage areas
within the permit are meant to be concise. The requested changes are more
descriptive than what is normally included in permits. The changes will be
included to correct items currently listed,but the full descriptions have been noted
in the permit file.
Page 8 of 8

LOCAU0
StarNews I The Dispatch I Times-News PO Box 631697 Cincinnati, OH 45263-1697
Sun Journal I The Daily News I The Star
The Free Press I Gaston Gazette
The Fayetteville Observer
NORTH CAROLINA ENVI-
PROOF OF PUBLICATION RONMENTAL
MANAGEMENT
COMMISSION INTENT TO
Joyce Sanford ISSUE
TORMWATER
LAURAALEXANDER D SOCHARGE PERMITS
Ncdeq Demlr The North Carolina Environ-
1612 Mail Service CTR commission Proposesmeto
Raleigh NC 27699-1600 is d scharge sue PIDES Pe mit(s)storrto ater
the
Person(s) listed below.
Public comment or objection
STATE OF NORTH CAROLINA, COUNTY OF CUMBERLAND to the draft permits is
invited. Written comments
regarding the proposed
until
The Fayetteville Observer, a newspaper distributed in the county 3o d days afterit willbtheccepte publsh date
of Cumberland, published in the City of Fayetteville,County of of this notice and considered
Cumberland, State of North Carolina printed and published and in the final determination
regarding permit issuance
personal knowledge of the facts herein state and that the notice and permit provisions. The
hereto annexed was Published in said newspapers in the issues Director of the NC Division
dated oft: Land Energy: eral
may hold a public hearing
06/21/2023 should there be a significant
degree of public interest.
Please mail comments
and that the fees charged are legal. The Fayetteville Observer o and/or
DEMLRinformation
requests Mail
was a newspaper meeting all the requirements and qualifications service Center, Raleigh, NC
prescribed by Sec. No. 1-597 G.S. of N.C. 27699a612.
us-
Sworn to and subscribed before on 06/21/2023 Hexion, Inc. [tan
tri al Drive, Fayettevillee,, NC NC
283011 has requested renewal
of permit NCS000088 for the
Hexion, Inc. facility in
Cumberland County. This
facility discharges to the
Cape Fear River in the Cape
Fear River Basin.
Interested persons may visit
DEMLR at 512 N. Salisbury
street, Raleigh, NC 27604 to
review on
Legal Cleric s Addit onalforon in information on file.on
NPDES permits and this
notice may be found an our
Notary,State of W! oun of 8r webs:]/d
> https:Ildeq.nc.goV/about/divis
ions/energy-mi nerai-and-
land-resourceslstarmwa-
ter-
M commision expires pros armworm
y p program/stormwater-public-
Publication Cost: $199.47 notices, or by contacting
Brianna Young at
Order No: 8943580 brianna.young0deq.nc.gov or
rr of Copies: 919-707-3647.
Customer No: 929332 7 6/21/23 8943580
PO#:
THIS IS NOT AN INVOICE!
Please do not use this furor far paj merit remittance.
VICKY FELTY
Notary Public
State of Wisconsin
Page 1 of 1

Young, Brianna A
From: Stoker, Caleb <[e-mail]>
Sent: Monday,July 17, 2023 4:22 PM
To: Young, Brianna A
Cc: Hamilton, Jeff, Tyler, Ben
Subject: [External] Hexion, Inc. - Fayetteville (NCS000088) stormwater permit renewal
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Ms. Young,
Thank you again for taking the time to speak with Jeff and I last week in regards to the permit renewal.
As discussed on the call, Hexion proposes the following updates to the draft permit, dated June 14, 2023.
1. Add Ammonia as Nitrogen to the analytical monitoring requirements for Outfall SW002. Although anhydrous
ammonia is no longer utilized onsite, aqueous ammonia is a raw material that is off loaded from bulk tankers in
the area of Outfall SW002.
2. Add Methanol to the analytical monitoring requirements for Outfall SW003. The methanol storage tank
containment area is partially located in the drainage area for Outfall SW003.
3. Amend the Outfall descriptions. Hexion proposes the following:
• Outfall SW001: Drainage area consists of employee parking lots, main office buildings, main warehouse
loading dock, methanol unloading and storage (have secondary containment and sampled prior to
release to stormwater),tanker trailer and railcar parking/storage areas, a covered bulk urea unloading
area, and finish product tanker truck loading operations. It is adjacent to a tank farm storage area, and
finish product tanker truck loading operations—which all have containment and any process contact
stormwater would drain to onsite wastewater treatment.
• Outfall SWO02: Drainage area consists of aqueous ammonia tanker truck offloading area, finish product
tanker truck loading operations, and process cooling towers (cooling tower water and blowdown go to
onsite wastewater treatment). It is adjacent to raw material and finished product tank farm storage—
which all have containment and any process contact stormwater would drain to onsite wastewater
treatment.
• Outfall SWO03: Drainage area consists of methanol unloading and storage (have secondary containment
and sampled prior to release to stormwater),tanker trailer and railcar parking/storage areas, a covered
flammable storage area for liquid drums and totes (has secondary containment), and process cooling
towers (cooling tower water and blowdown go to onsite wastewater treatment). It is adjacent to the
MO formaldehyde processes and former(inactive) hexamine plant—which all have containment and
any process contact stormwater would drain to onsite wastewater treatment.
Regards,
Caleb Stoker
Regional EHS Leader-ENVIRONMENTAL, HEALTH&SAFETY
9104859229 OFFICE
9103645064 MOBILE
1

Hex
Vt HEXI 1411 I Inc
411 INDUSTRIAL DR
Responsible Chemistry FAYETTEVILLE, NORTH CAROLINA 28301
DOQ
This message,including attached files,is confidential and intended for the addressees.It may contain information that is proprietary,privileged or exempt for disclosure under
applicable law.Any unauthorized use and dissemination of the information or copying of this message is strictly prohibited.Any views,opinions or conclusions expressed in this
message are those of the individual sender and do not necessarily reflect the views of Hexion or its affiliates.If you received this message in error,please immediately advise the
sender by reply email,delete all copies of this message and refrain from printing,copying,or disseminating this message or otherwise using the information in it.Thank you.
Although Hexion routinely screens incoming and outgoing mail messages for viruses,addressees should scan this e-mail and any attachments for viruses themselves.Hexion
does not guarantee in any way the absence of viruses in this e-mail or any attachments and disclaims any liability in case of security problem that this message may cause to any
system.
2

Young, Brianna A
From: Hamilton, Jeff <[e-mail]>
Sent: Thursday, September 22, 2022 4:19 PM
To: Young, Brianna A; Stoker, Caleb
Cc: Tyler, Ben
Subject: RE: [External] RE: [External]Hexion, Inc. (NCS000088) stormwater permit renewal
Attachments: Summary Sample Results and BMP - 8.2022 RFI for renewal.xls; NCDEP SW request for
info for renewal.docx
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Brianna,
I apologize for the delay in the submittal. Due to transitioning of environmental responsibilities the information was not
sent to you. Please see the attached files and advise if any additional information is required.
Respectfully,
Jeff Hamilton
EHS
HEXII '
Resporksible Chemistry
Hexion Inc.
5329 Buck Creek Road
Finchville, KY 40022, United States
[phone] Mobile
0eff.hamilton()hexion.com
From:Young, Brianna A<[e-mail]>
Sent:Thursday,September 22, 2022 3:47 PM
To: Stoker, Caleb<[e-mail]>
Cc:Tyler, Ben <[e-mail]>; Hamilton,Jeff<[e-mail]>
Subject: RE: [External] RE: [External]Hexion, Inc. (NCS000088) stormwater permit renewal
EXTERNAL:This message is from be CAUTIOUS, particularly with links and
Good afternoon,
I am following up on my previous email as I have not received the requested information (original email sent August 25,
2022). Please note that this information is required before review of the permit renewal application can proceed. Please
let me know if you have any questions.
Thank you,
i

Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647(office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From: Stoker, Caleb<[e-mail]>
Sent:Thursday,August 25, 2022 11:06 AM
To:Young, Brianna A<[e-mail]>
Cc:Tyler, Ben <[e-mail]>; Hamilton,Jeff<[e-mail]>
Subject: [External] RE: [External]Hexion, Inc. (NCS000088) stormwater permit renewal
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Brianna,
Thanks for reaching out. I wanted to acknowledge your request and we will get this to you in approximately a week,
perhaps sooner.
Regards,
Caleb Stoker
EHS Leader
It HEXI N'
Responsible Chemistry
Hexion Inc.
1411 Industrial Drive
Fayetteville, NC 28301
[phone] Mobile
[phone] Office
caleb.stoker()hexion.com
2

From: Young, Brianna A<[e-mail]>
Sent:Thursday,August 25, 2022 9:26 AM
To:Tyler, Ben <[e-mail]>
Cc: Stoker, Caleb <[e-mail]>
Subject: [External]Hexion, Inc. (NCS000088) stormwater permit renewal
EXTERNAL:This message is from an EXTERNAL SENDER- be CAUTIOUS, particularly
Good morning,
I am working on renewing the individual stormwater permit for Flexion, Inc. (NCS000088). I need additional
information in order to 1) confirm that the information I have is correct and 2) make sure the permit adequately
serves the needs of the facility. Please provide the following:
• Confirm the number of outfalls and associated coordinates;
• SIC (NAICS) code and category;
• Description of site operations;
• Description of industrial activity in each drainage area;
• List of chemicals/pollutants that have the potential to come into contact with rain/stormwater;
• An electronic spreadsheet summarizing all of the monitoring data that has been collected since the
effective date of the current permit;
• Verification that the information in the renewal application is still complete and correct; and
• An explanation of any operational changes since the renewal application was submitted.
Enter your stormwater permit number into the Stormwater Permit Summary Report and you will see a form that
includes the address of the facility, contact information for the permit, and the regulated stormwater outfall(s) for the
facility. Please review the facility information to make sure it is correct. Information can be updated using the links
provided below, where applicable:
• Facility/Company name or ownership: Name/Ownership Change Form
• Owner Affiliation (Legally responsible person; i.e., someone with the company who is designated to
represent the company per signatory requirements or another authorized representative): Permit Contact
Update Request Form
• Delegation of Signature Authority (DOSA): Permit Contact Update Request Form
• Billing contact: Permit Contact Update Request Form
• Permit contact: Permit Contact Update Request Form
• Facility contact: Permit Contact Update Request Form
• Facility address only: Email Bethany og ulias
• Stormwater outfall information: Email Bethany Georgoulias
• Visit the eDMR Six Steps website and complete Steps 1 and 2.
• Pay outstanding permit fees: Stormwater ePUment website
Once I have the above listed information, I can continue my review. You will receive a draft permit for a 30-day
comment period. During this time we will be able to address any comments or concerns you have. During the
same 30-day period, the draft will be sent to a Regional Office staff member for review as well as out to public
notice. Once all comments and concerns are addressed, you may be issued a final permit.
3

Please contact me if you have any questions.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts.
Please check with the appropriate staff before visiting our offices,as we may be able to handle your requests by phone or email.We
appreciate your patience as we continue to serve the public during this challenging time.
This message,including attached files,is confidential and intended for the addressees.It may contain information that is proprietary,privileged or exempt for disclosure under
applicable law.Any unauthorized use and dissemination of the information or copying of this message is strictly prohibited.Any views,opinions or conclusions expressed in this
message are those of the individual sender and do not necessarily reflect the views of Hexion or its affiliates.If you received this message in error,please immediately advise the
sender by reply email,delete all copies of this message and refrain from printing,copying,or disseminating this message or otherwise using the information in it.Thank you.
Although Hexion routinely screens incoming and outgoing mail messages for viruses,addressees should scan this e-mail and any attachments for viruses themselves.Hexion
does not guarantee in any way the absence of viruses in this e-mail or any attachments and disclaims any liability in case of security problem that this message may cause to any
system.
4

Stormwater permit for Hexion, Inc. (NCS000088) follow up information request.
• Confirm the number of outfalls and associated coordinates;
• Outfall#1 - 35.029170 lat, -78.863890 long.
• Outfall#2 - 35.028060 lat, -78.860830 long.
• Outfall#3 - 35.027780 lat, -78.862780 long.t
• SIC (NAICS) code and category;
• 2821 Plastic Material and Resin Manufacturing,
• 2869 Industrial Organic Chemicals,Not Elsewhere Classified,
• 2891 Adhesives and sealants.
• Description of site operations
• Hexion is a chemical manufacturing facility that produces Formaldehyde for
internal use and sale. Formaldehyde produced on site is used in the manufacturing
of urea-formaldehyde concentrate, urea-formaldehyde resins,
methanol/formaldehyde blend called methaform and phenol-formaldehyde
resins/adhesives. Some resins manufactured on sit are mixed with various dry
ingredients to create a "Ready-To-Use"resins. The site also produces wax
emulsions. On-site there is also a hexamine manufacturing facility which has not
been in use for several years.
• Description of industrial activity in each drainage area;
• Outfall 1 drains from employee parking lots, tanker truck parking area, adjacent to
covered bulk urea unloading area, and near the formaldehyde truck loading area.
• Outfall 2 drains area outside of secondary containment in the raw material and
phenol-formaldehyde and ready to use resin tank farms.
• Outfall 3 general surface flow for the south side of the facility, including tank
truck parking and the edge of the phenol-formaldehyde and ready to use resin
processes.
• List of chemicals/pollutants that have the potential to come into contact with
rain/stormwater;
• In addition to the products listed above, the following raw materials are handled
on site and have the potential to come into contact with stormwater.
Acetic Acid, Glacial Potassium Carbonate
Alpha Olefin Wax A Potassium Hydroxide
Ammonia Aqua Rhodoline
Borax Slack Wax
Boric Acid Sodium Bicarbonate
Crude Glycerine Sodium Carbonate-Anhydrous
Molasses Sodium Hydroxide
Diethylene Glycol Sodium Sulfate Anhydrous
Dry Material Additive HS-100 solution
FC-414 Antifoam Corn Starch
Foam-A-Tac 611 Stearic Acid, Liquid
Formic Acid Sulfonated Naphthalene
Formaldehyde Sulfuric Acid
GN 8-Low Chloride Defoamer

Guar Gum Triethanolamine
Magnesium Chloride Urea,
Melamine, Water-Based Silicone Emulsion
Methanol Wheat Flour,
Methocel Wil - Fil
Phenol
• An electronic spreadsheet summarizing all of the monitoring data that has been collected
since the effective date of the current permit;
• See attached spreadsheet
• Verification that the information in the renewal application is still complete and correct;
• Owner Name is different, correct on the on-line Stormwater Permit Summary
Report (Ben Tyler)
• Permit contact person changed to Jeff Hamilton, address 1411 Industrial Dr.,
Fayetteville,NC 28301, Phone [phone], Email jeff.hamiltonkhexion.com
Online contact update submitted 8/30/2022
• An explanation of any operational changes since the renewal application was submitted.
• Have stopped the production of Hexamine so no currently receiving aqua
ammonia.

Summary of Analytical Monitoring
Outfal 1001
Total
Ammonia Total Kjeldahl
as N BOD COD Nitrogen Nitrogen Methanol Rainfall
Sample Date (mg/L) (mg/L) (mg/L) (mg/L) (mg/L) (mg/L) pH (inches)
12/7/2015 <0.100 8.85 98.4 16.80 14.00 <1.0 6.90 0.39
1/10/2016 <0.100 10.3 97.7 6.28 4.15 <1.0 6.95 0.29
9/2/2016 <0.100 4.95 172 5.65 3.84 <1.0 7.50 0.77
4/24/2017 <0.100 4.07 138 1.14 1.00 <1.0 7.50 1.5
5/23/2017 <0.100 3.4 41.7 4.70 3.69 <1.0 7.11 2.06
6/20/2017 <0.100 7.03 131 4.73 3.81 <1.0 6.92 0.68
8/7/2017 <0.100 11.7 30.2 3.84 2.42 <1.0 6.90 0.59
9/6/2017 <0.100 7.31 133 5.43 5.43 <1.0 6.97 0.55
10/7/2017 <0.100 12.1 52.9 5.87 3.92 <1.0 0.52
12/8/2017 <0.500 13.4 79 5.9 3.52 <1.0 1.47
1/23/2018 <0.500 10.9 135 6.94 4.51 <1.0 6.97 0.3
2/10/2018 0.373 4.39 51 3.75 2.31 <1.0 0.34
3/1/2018 0.9 5.65 70.8 3.818 2.16 <1.0 6.9 0.36
4/8/2018 2.7 6.25 28.9 8.52 5.85 <1.0 6.91 0.81
10/11/2018 0.5 11 27 1.9 1.9 <5.00 6.25 0.51
1/24/2019 0.3 4 33 2.0 1.4 <5 6.36 0.81
10/14/2019 0.8 6 35 5.0 4.4 <5 6.57 0.92
3/5/2020 0.4 8 68 2.5 2 <5 6.42 0.24
11/11/2020 0.5 4 58 3.7 3.7 <5 6.47 0.27
4/1/2021 1 7 51 3.4 3.4 <5 6.49 0.34
9/21/2021 1.3 9 71 5.4 4.5 <5 6.93 0.35
3/17/2022 0.9 5 45 3.7 2.5 <5 6.85 1.18
Outfal 1002
Total
Ammonia Total Kjeldahl
as N BOD COD Nitrogen Nitrogen Methanol Rainfall
Sample Date (mg/L) (mg/L) (mg/L) (mg/L) (mg/L) (mg/L) pH (inches)
4/1/2016 <0.100 15.5 177 10.1 4.77 <1.0 6.71 0.16
9/2/2016 <0.100 2.24 26 3 2.66 <1.0 7.55 0.77
4/24/2017 <0.100 3.71 61.9 <1.10 <1.0 <1.0 7.37 1.5
10/29/2017 <0.1 6.21 28.6 <1.1 <1 <1.0 0.1
1/29/2018 <0.500 4.71 24 0.817 1.12 <1.0 6.85 2.26
8/13/2018 <0.500 5.8 20.2 1.54 1.06 <1.0 0.81
1/24/2019 <0.2 <2 <20 1.0 0.7 <5 6.64 0.81
10/14/2019 4.2 6 37 25.4 18.5 <5 6.67 0.92
3/5/2020 0.5 3 38 2.8 2.8 <5 6.62 0.24
11/11/2020 5.8 4 52 22.2 22.1 <5 6.51 0.27
4/1/2021 0.4 6 23 1.7 1.7 <5 6.46 0.34
9/21/2021 8.5 5 82 40.8 39 <5 6.98 0.35
3/17/2022 <0.2 3 21 1.4 1 <5 6.98 1.18
Outfall 003
Total
Ammonia Total Kjeldahl
as N BOD COD Nitrogen Nitrogen Methanol Rainfall
Sample Date (mg/L) (mg/L) (mg/L) (mg/L) (mg/L) (mg/L) pH (inches)
4/1/2016 <0.100 13.1 144 5.81 5.81 <1.0 6.35 0.16
9/2/2016 <0.100 4.91 69.6 4.15 3.25 <1.0 7.58 0.77
4/24/2017 <0.100 3.71 64.1 <1.10 <1.0 <1 7.39 1.5
10/29/2017 <0.100 5.34 40.7 <1.1 <1.0 <1 0.1
1/29/2018 <0.100 4.69 26.9 1.01 1.14 <1.00 6.93 2.26
10/11/2018 0.4 7 74 4.9 2.6 <5 6.67 0.51
1/24/2019 <0.2 2 32 1.5 1.1 <5 6.95 0.81
10/14/2019 0.4 6 41 3.6 3.2 <5 6.22 0.92
3/5/2020 <0.2 5 81 4.8 4.3 <5 6.7 0.24
11/11/2020 0.2 8 104 0.7 0.7 <5 6.55 0.27
4/1/2021 <.2 9 46 3.3 3.3 <5 6.48 0.34
9/21/2021 0.9 12 95 9 7.8 <5 6.51 0.35
3/17/2022 0.2 4 43 2.7 2.1 <5 6.73 1.18

Summary of Visual Monitoring
Outfall 001
Floating Suspended Erosion or Other Indicators of Rainfall
Sample Date Color Odor Clarity Solids Solids Foam Oil Sheen Deposition Pollution (inches)
12/7/2015 Light Brown None 3 3 1 No No No None 0.39
1/10/2015 Light Brown None 2 2 1 No No No None 0.29
9/2/2016 Light Brown None 3 2 1 No No No None 0.77
4/24/20171 Light Brown None 3 21 2 No No No INone 1.50
5/23/2017 Light Brown None 2 2 1 No No No None 2.06
6/20/2017 Light Brown None 2 2 1 No No No None 0.68
8/7/2017 Light Brown None 3 1 2 No No No None 0.59
9/6/2017 Light Brown None 2 2 2 No No No None 0.55
1/24/2019 Clear None 1 1 1 No No No None 0.81
Light/Clear
10/14/2019 Brown None 4 1 1 No No No None 0.92
3/5/2020 light-clear None 2 2 1 No No No None 0.24
clear/light
11/11/2020 brown None 2 1 1 No No Yes None 0.27
Light/Clear
4/1/2021 Brown None 3 1 1 No No No None 0.34
9/21/2021 light-clear None 2 2 1 No No No None j 0.35
3/17/2022 light-clear None 2 2 1 No No No None 1.18
Outfall 002
Floating Suspended Erosion or Other Indicators of Rainfall
Sample Date Color Odor Clarity Solids Solids Foam Oil Sheen Deposition Pollution (inches)
Clear/light
4/16/2016 brown None 1 1 1 No No No None 0.16
9/2/2022 Light brown None 1 1 1 No No No None 0.77
4/24/20171 Light brown None 3 1 2 No No No INone 1.50
1/24/2019 Clear None 1 1 1 No No No None 0.81
Light/Clear
10/14/2019 Brown None 4 1 2 No No No None 0.92
3/5/2020 light-clear None 1 1 1 No No Yes None 0.24
11/11/2020 clear/light None 1 1 1 No No No None 0.27
Clear/Slightly
4/1/2021 Brown None 2 1 1 No No No None 0.34
9/21/2021 light-clear None 1 1 1 No No Yes None 0.35
3/17/2022 light-clear None 1 1 1 No No Yes None 1.18
Outfall 003
Floating Suspended Erosion or Other Indicators of Rainfall
Sample Date Color Odor Clarity Solids Solids Foam Oil Sheen Deposition Pollution (inches)
Clear/light
4/1/2016 brown None 1 1 1 No No No None 0.16
9/2/2022 Light brown None 2 1 1 No No No None 0.77
4/24/20171 Light brown None 2 1 1 No No No INone 1.50
1/24/2019 Clear None 1 1 1 No No No None 0.81
Light/Clear
10/14/2019 Brown None 2 2 1 No No Yes None 0.92
Mud from wet
3/5/2020 Medium-clear None 2 2 1 No No Yes grass/truck ruts 0.24
clear/light
11/11/2020 brown blank 3 2 3 No No Yes None 0.27
Clear/light
4/1/2021 Brown None 2 1 1 No No No None 0.34

Mud from wet
9/21/2021 light-clear None 2 2 1 No No Yes grass/truck ruts 0.35
3/17/2022 Medium-clear None 2 2 1 No No Yes Truck ruts/mud froi 1.18

Best Management Practices (BMP) Summary
Locked Storm Water Outfall Gates-only specific trained personnel are allowed to open the outfall gates after
following the draining procedure which involves evaluating the storm water and completing a storm water drain
clearance form.
Locked Secondary Containment Areas-the three secondary containment areas that can be drained to the storm
water outfall drainage area are locked closed. Only specific trained personnel are allowed to open the secondary
containment areas after following the draining procedure which involves evaluating the storm water and
completing a storm water drain clearance form.
Spill Response Kits-several spill kits are located throughout the facility.
Limit Exposure-chemicals are not stored in the storm water outfall drainage area unless there is secondary
containment. Also there is a truck station in the storm water drainage area with secondary containment that
drains to a sump that flows to waste water treatment system in order to capture any potential drips during the
connecting/disconnecting of the trailers.
Methanol Truck Unloading Station Design -the unloading station has secondary containment that drains into a
sump. The sump is only drained after trained personnel follow the draining procedure which involves evaluating
the water and completing a storm water drain clearance form.
Sediment and Erosion Control - currently there are no operations that routinely occur that warrant erosion and
sedimentation controls. A determination of the need for erosion and sedimentation control measures will be
made when any activity at the facility disturbs the existing ground surface.

8/24/22,5:25 PM North Carolina Secretary of State Search Results
• File an Annual Report/Amend an Annual Report • Upload a PDF Filing • Order a Document Online -
Add Entity to My Email Notification List • View Filings • Print a Pre-Populated Annual Report form • Print
an Amended a Annual Report form
Business Corporation
Legal Name
Hexion Inc.
Prev Legal Name
Borden Chemical, Inc.
Prev Legal Name
Borden, Inc.
Prev Legal Name
Hexion Specialty Chemicals, Inc.
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Momentive Specialty Chemicals Inc.
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Information
Sosld: 0018906
Status: Current-Active O
Date Formed: 10/6/1936
Citizenship: Foreign
State of Incorporation: NJ
Fiscal Month: December
Annual Report Due Date: April 15th
Currentgnnual Report Status:
Registered Agent: Corporation Service Company
Addresses
Mailing Principal Office Reg Office
180 East Broad Street 180 East Broad Street 2626 Glenwood Avenue, Suite 550
Columbus, OH 43215-3707 Columbus, OH 43215-3707 Raleigh, NC 27608
https://www.sosnc.gov/online_services/search/Business_Registration_ResuIts 1/2

8/24/22,5:25 PM North Carolina Secretary of State Search Results
Reg Mailing
2626 Glenwood Avenue, Suite 550
Raleigh, NC 27608
Officers
Vice President Controller Treasurer Vice President
John P Auletto Colette B Barricks Mark D Bidstrup Per Bjorkman
180 East Broad Street 180 East Broad Street 180 East Broad Street 180 East Broad Street
Columbus OH 43215 Columbus OH 43215 Columbus OH 43215 Columbus OH 43215
Vice President Vice President Secretary Chief Financial Officer
Nathan E Fisher Michelle H. Hughes Douglas A Johns George F. Knight
180 East Broad Street 180 East Broad Street 180 East Broad Street 180 East Broad Street
Columbus OH 43215 Columbus OH 43215 Columbus OH 43215 Columbus OH 43215
Vice President Assistant Treasurer President
John Kompa Jeffrey A Marx Craig A Rogerson
180 East Broad Street 180 East Broad Street 180 East Broad St
Columbus OH 43215 Columbus OH 43215 Columbus OH 43215
Chief Information Officer Executive Officer Assistant Treasurer
Dennis Ryan Matthew Sokol Thomas J Sullivan
180 East Broad Street 180 East Broad Street 180 East Broad Street
Columbus OH 43215 Columbus OH 43215 Columbus OH 43215
Stock
Class: 99 SEE CERT
Shares: 0
Par Value 0
https://www.sosnc.gov/online_services/search/Business_Registration_ResuIts 2/2

® HEXION 1411 In inc.
411 In Inc.
Drive l Fayetteville,NC 28301
hexion.com
November 20, 2015
NCDEQ
Division of Water Quality
1617 Mail Service Center
Raleigh,NC 27699-1617
RE. 2015 NPDES Storm Water Permit Renewal
Hexion Inc.
Permit Number NCS000088
Cumberland County
Dear Sir or Madam:
Hexion Inc. owns and operates a chemical manufacturing operation in Fayetteville,North
Carolina(Fayetteville facility). The facility is currently operating in accordance with Permit#
NCS000088, issued on May 23, 2011 with an effective date of June 1, 2011.
Attached are the permit renewal application and attachments for our facility. Also included is a
copy of the delegation of authority. Hexion appreciates the review of this permit application. If
there are any questions or more information is required,please contact Michelle West at
[phone].
Sincerely,
HEX
DEC 012015
Kevin orris
Site Leader
Enclosures
cc: M. West

Permit Coverage
©* Renewal Application Form I�
—A National Pollutant Discharge Elimination System NPDES Permit Number ���i I
NCDENR Stormwater Individual Permit NCS000088
Please provide your permit number in box in the upper right hand corner, complete the information in the space provided
below and return the completed renewal form along with the required supplemental information to the address indicated.
Owner Information * Address to which permit correspondence will be mailed
Owner/Organization Name: Hexion Inc.
Owner Contact: Kevin Morris
Mailing Address: 1411 Industrial Drive
Fayetteville, NC 28301
Phone Number: 910-485-9225
Fax Number: 910-483-3147
E-mail address: [e-mail]
Facility Information DEC O 1
Facility Name: Hexion Inc. 20115
Facility Physical Address: 1411 Industrial Drive
Fayetteville, NC 28301
Facility Contact: Kevin Morris
Mailing Address: 1411 Industrial Drive
Fayetteville, NC 28301
Phone Number: 910-485-9225
Fax Number: 910-483-3147
E-mail address: [e-mail]
Permit Information
Permit Contact: Michelle West
Mailing Address: 1411 Industrial Drive
Fayetteville, NC 28301
Phone Number: 910-485-9221
Fax Number: 910-483-3147
E-mail address: [e-mail]
Discharge Information
Receiving Stream: Cape Fear River
Stream Class: C
Basin: Cape Fear
Sub-Basin: 03-06-15
Number of Outfalls: 3
Facility/Activity Changes Please describe below any changes to your facility or activities since issuance of your permit. Attached a
separate sheet if necessary.
Replaced several older formaldehyde storage tanks with new tanks and new secondary containment. Increased automation in the
facility. Expanded secondary containment for the methanol tanks and for the tank farm on the southeastern side of the facility.
CERTIFICATION
I certify that I am familiar with the information contained in the application and that to the best of my knowledge and belief
such information is true, co let nd accurate.
Signature Date
Sites I aafiar
Print or type name of person signing above Title
Please return this completed application form SW Individual Permit Coverage Renewal
p pp Stormwater Permitting Program
and requested supplemental information to: 1612 Mail Service Center
Raleigh, North Carolina 27699-1612

SUPPLEMENTAL INFORMATION REQUIRED FOR RENEWAL OF INDIVIDUAL
NPDES STORMWATER PERMIT
Two copies of each of the following shall accompany this submittal in order for the application
to be considered complete:
(Do not submit the site Stormwater Pollution Prevention Plan)
Initials
�. A current Site Map from the Stormwater Pollution Prevention Plan. The location of
industrial activities (including storage of materials, disposal areas,process areas and
loading and unloading areas), drainage structures, drainage areas for each outfall,
building locations and impervious surfaces should be clearly noted.
2. A summary of Analytical Monitoring results during the term of the existing permit
(if your permit required analytical sampling). Do not submit individual lab reports.
The summary can consist of a table including such items as outfall number,
parameters sampled, lab results, date sampled, and storm event data.
3. A summary of the Visual Monitoring results. Do not submit individual monitoring
reports. The summary can consist of a table including such items as outfall number,
parameters surveyed, observations, and date monitoring conducted.
4. A summary of the Best Management Practices utilized at the permitted facility.
Summary should consist of a short narrative description of each BMP's in place at
the facility. If the implementation of any BMP's is planned,please include
information on these BMP's.
5. A short narrative describing any significant changes in industrial activities at the
permitted facility. Significant changes could include the addition or deletion of
work processes, changes in material handling practices, changes in material storage
practices, and/or changes in the raw materials used by the facility.
6. Certification of the development and implementation of a Stormwater Pollution
Prevention Plan for the permitted facility (Sign and return attached form).
If the final year analytical monitoring of the existing permit term has not been completed
prior to filing the renewal submittal, then the last years monitoring results should be submitted
within 30 days of receipt of the laboratory reports. (i.e. do not withhold renewal submittal
waiting on lab results)

Summary of Analytical Monitoring
Outfall 001
Total
Ammonia Total Kjeldahl
as N BOD COD Nitrate as Nitrite as Nitrogen Nitrogen Methanol Rainfall
Sample Date (mg/L) (mg/L) (mg/L) N(mg/L) N(mg/L) (mg/L) (mg/L) (mg/L) pH (inches)
10/11/2011 2.4 6.81 38.7 4.07 0.199 11.3 7 <1 7.01 0.24
3/26/2012 2.24 5.24 67.3 7.2 0.404 12.6 5.04 <1 6.97 0.35
10/8/2012 <0.1 5.33 101 3.31 1.39 8.55 3.84 <1 5.9 0.54
2/26/2013 1.56 7.88 47.1 2.11 0.712 6.89 4.07 <1 6.22 0.91
11/2/2013 2.5 4.92 50.1 5.91 0.295 35.6 29.4 <1 6.07 0.81
4/15/2014 <0.1 12 124 2.61 0.0992 7.56 4.85 <1 6.39 0.58
9/2/2014 0.91 15.7 162 5.64 0.604 18.1 11.8 <1 6.24 0.45
12/6/2014 3.04 6.6 54.6 2.48 0.246 156 154 <1 8.8 0.2
1/4/2015 3.05 4.36 123 3.62 0.425 7.91 3.87 <1 8.31 0.23
2/2/2015 2.93 5.78 33.4 2.05 0.33 9.42 7.04 <1 6.84 0.5
3/5/2015 <0.1 15.8 268 4.53 <0.05 10.9 6.33 <1 6.61 0.36
4/9/2015 <0.1 25.1 105 1.27 0.55 6.66 4.84 <1 6.11 0.23
5/9/2015 <0.1 9.48 218 1.85 0.615 3.84 1.38 <1 6.65 0.54
6/2/2015 <0.1 14.6 128 2.5 0.278 6.73 3.95 <1 7.59 0.42
7/13/2015 <0.1 17.9 126 1.88 0.246 7.29 5.17 1 7.45 0.29
8/6/2015 <0.1 19.8 82.9 1.72 <0.05 5.95 4.23 <1 7.15 0.16
9/24/2015 4.24 9.15 43.6 1.65 <0.05 10.1 8.47 <1 7.09 0.15
10/10/2015 <0.1 5.18 158 1.04 <0.05 8.3 7.26 <1 6.88 0.36
11/1/2015 2.42 3.9 25.6 10.4 <0.05 18.7 8.21 <1 7.3 0.15
Outfall 002
Total
Ammonia Total Kjeldahl
as N BOD COD Nitrate as Nitrite as Nitrogen Nitrogen Methanol Rainfall
Sample Date (mg/L) (mg/L) (mg/L) N(mg/L) N(mg/L) (mg/L) (mg1L) (mg/L) pH (inches)
10/11/2011 11.6 6.89 70.4 2.5 0.109 14.7 12 0.695 7.24 0.24
3/26/2012 0.56 3.28 36.3 6.61 0.25 12.2 5.32 15.8 7.04 0.35
10/8/2012 <0.1 2.32 26.2 1.27 0.644 1.91 <0.14 <1 5.93 0.54
2/26/2013 <0.1 3.43 27.8 0.72 0.687 2.66 1.25 <1 6.72 0.91
11/2/2013 1.91 4.61 48 4.92 0.352 15.1 9.79 <1 6.21 0.81
4/15/2014 <0.1 6.78 64.2 1.06 0.0845 3.26 2.12 <1 6.59 0.58
9/2/2014 <0.1 7.27 48.7 1.71 0.505 5.24 3.03 <1 7.88 0.45
2/2/2015 1.17 2.8 18 1.05 0.252 4.47 3.17 <1 7.16 0.5
9/24/2015 7.26 12 41.6 1.14 0.346 19 17.6 1.3 7.1 0.15
Outfall 003
Total
Ammonia Total Kjeldahl
as N BOD COD Nitrate as Nitrite as Nitrogen Nitrogen Methanol Rainfall
Sample Date (mg/L) (mg/L) (mg/L) N(mg/L) N(mg/L) (mg/L) (mg/L) (mg/L) pH (inches)
10/11/2011 2.63 7.55 84 8.37 0.235 20.1 11.5 <1 6.98 0.24
3/26/2012 0.56 6.56 89.5 1.02 0.679 5.9 4.2 12.8 7 0.35
10/8/2012 <0.1 3.97 50.3 2.02 1.37 5.75 2.36 2.47 5.82 0.54
2/26/2013 1.09 3.17 60 1.7 0.694 7.08 4.69 <1 6.41 0.91
11/2/2013 1.62 4.86 50.1 4.7 0.359 13.3 8.26 <1 6.13 0.81
4/15/2014 0.91 10 70.8 2.2 0.111 8.68 6.37 <1 6.56 0.58
9/2/2014 <0.1 11.4 79.1 3.56 0.573 9.59 5.46 <1 6.76 0.45
2/2/2015 1.41 4.99 36.3 2.45 0.332 15.5 12.7 <1 6.81 0.5
9/24/2015 <0.1 18.6 73.4 4.52 0.237 16.9 12.1 <1 7.13 0.15

Summary of Visual Monitoring
Outfall 001
Other
Floating Suspended Erosion or Indicators of Rainfall
Sample Date Color Odor Clarity Solids Solids Foam Oil Sheen Deposition Pollution (inches)
Medium
10/11/2011 Brown None 3 3 3 No No No None 0.24
Medium
3/26/2012 Brown None 3 3 3 No No No None 0.35
Medium
10/8/2012 Brown None 5 3 4 No No No None 0.54
Medium
2/26/2013 Brown None 3 2 3 No No No None 0.91
Light
11/2/2013 Brown None 3 2 2 No No No None 0.81
Light
4/15/2014 Brown None 3 2 2 No No No None 0.58
9/2/2014 Tan None 3 1 1 No No No None 0.45
Light
12/6/2014 Brown None 3 2 1 No No No None 0.2
Clear-
Light
1/4/2015 Brown None 1 2 1 No No No None 0.23
Light
2/2/2015 Brown None 2 2 1 No No No None 0.5
Light
3/5/2015 Brown None 3 2 1 No No No None 0.36
Light
4/9/2015 Brown None 3 2 1 No No No None 0.23
Light
5/9/2015 Brown None 3 2 1 No No No None 0.54
Light
6/2/2015 Brown None 4 2 1 No No No None 0.42
Light
7/13/2015 Brown None 3 2 1 No No No None 0.29
Light
8/6/2015 Brown None 3 2 1 No No No None 0.16
Light
9/24/2015 Brown None 2 3 1 No No No None 0.15
Light
10/10/2015 Brown None 3 1 2 No No No None 0.36
Clear/Light
11/1/2015 Brown None 1 2 1 No No No None 0.15
Outfall 002
Other
Floating Suspended Erosion or Indicators of Rainfall
Sample Date Color Odor Clarity. Solids Solids Foam Oil Sheen Deposition Pollution (inches)
10/11/2011 Clear None 2 2 2 No No No None 0.24
3/26/2012 Clear None 2 2 2 No No No None 0.35
Clear&
10/8/2012 light tint None 3 2 2 No No No None 0.54
Light
2/26/2013 brown None 2 2 2 No No No INone 0.91

Light
11/2/2013 brown None 2 2 2 No No No None 0.81
Light
4/15/2014 brown None 3 2 2 No No No None 0.58
9/2/2014 Tan None 3 1 1 No No No None 0.45
Light
2/2/2015 Brown None 2 2 1 No No No None 0.5
Light
9/24/2015 Brown None 2 3 1 No No No I None 0.15
Outfall 003
Other
Floating Suspended Erosion or Indicators of Rainfall
Sample Date Color Odor Clarity Solids Solids Foam Oil Sheen Deposition Pollution (inches)
Light
10/11/2011 Brown None 3 3 3 No No No None 0.24
Light
3/26/2012 Brown None 3 3 3 No No No None 0.35
Medium
10/8/2012 Brown None 5 3 4 No No No None 0.54
Medium
2/26/2013 Brown None 3 3 3 No No No None 0.91
Light
11/2/2013 Brown None 3 3 3 No No No None 0.81
Light
4/15/2014 Brown None 3 2 2 No No No None 0.58
9/2/2014 Tan None 4 2 1 No No No None 0.45
Light
2/2/2015 Brown None 2 1 1 No No No None 0.5
Light
9/24/2015 Brown lNone 1 21 3 1 No jNo No None 1 0.15

Best Management Practices (BMP) Summary
Locked Storm Water Outfall Gates-only specific trained personnel are allowed to open the outfall gates after
following the draining procedure which involves evaluating the storm water and completing a storm water drain
clearance form.
Locked Secondary Containment Areas-the three secondary containment areas that can be drained to the storm
water outfall drainage area are locked closed. Only specific trained personnel are allowed to open the secondary
containment areas after following the draining procedure which involves evaluating the storm water and
completing a storm water drain clearance form.
Spill Response Kits-several spill kits are located throughout the facility.
Limit Exposure-chemicals are not stored in the storm water outfall drainage area unless there is secondary
containment. Also there is a truck station in the storm water drainage area with secondary containment that
drains to a sump that flows to waste water treatment system in order to capture any potential drips during the
connecting/disconnecting of the trailers.
Methanol Truck Unloading Station Design-the unloading station has secondary containment that drains into a
sump. The sump is only drained after trained personnel follow the draining procedure which involves evaluating
the water and completing a storm water drain clearance form.
Sediment and Erosion Control-currently there are no operations that routinely occur that warrant erosion and
sedimentation controls. A determination of the need for erosion and sedimentation control measures will be
made when any activity at the facility disturbs the existing ground surface.

STORMWATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
North Carolina Division of Energy, Mineral, and Land Resources -Stormwater Permitting
Facility Name: Hexion Inc.
Permit Number: NCS000088
Location Address: 1411 Industrial Drive
Fayetteville, NC 28301
County: Cumberland County
"I certify, under penalty of law, that the Stormwater Pollution Prevention Plan (SPPP) document and all attachments were
developed and implemented under my direction or supervision in accordance with a system designed to assure that
qualified personnel properly gather and evaluate the information required by the SPPP. Based on my inquiry of the
person or persons who manage the system, or those persons directly responsible for gathering the information, the
information gathered is, to the best of my knowledge and belief, true, accurate and complete."
And
"I certify that the SPPP has been developed, signed and retained at the named facility location, and the SPPP has been
fully implemented at this facility location in accordance with the terms and conditions of the stormwater discharge
permit."
And
"I am aware that there are significant penalties for falsifying information, including the possibility of fines and
imprisonment for knowing violations."
Sign (according to permit signatory requirements) and return this Certification. DO NOT
SEND STORMWATER POLLUTION PREVENTION PLAN WITH THIS /CERTIFICATION.
Signature Date c
Kevin Morris Site Leader
Print or type name of person signing above Title
SPPP Certification 10/13

Hex
on
HEXION 180EaslBro MEMO
1-1 C/� 1 V 180 East Broad Street MEMO
�
Columbus,OH 43215
hexion.com
Date: February 5, 2015
To: Site Leaders and Regional Manufacturing Directors of Forest Products Division Sites
From: Dale Plante, President-Forest Products Division
CC: Rick Springer,VP EHS-Forest Products Division
Subject: Delegation of Environmental, Health and Safety Authority
As President of Hexion Inc.'s Forest Products Division("FPD"), I confirm that I have authorized you to
interface with appropriate governmental authorities, media representatives and the public(in a manner
consistent with applicable Hexion policies and standards)on environmental, health, and safety related
matters relating to the FPD Site or Sites for which you are responsible,as a responsible official of Hexion.
You are further authorized to sign on behalf of Hexion, as a responsible corporate official, all environmental,
health, and safety related:
- applications(including, but not limited to, permit applications);
- transportation documents(including, but not limited to, manifests and shipping papers);
- periodic reports; and
- correspondence.
relating to the FPD Site or Sites for which you are responsible. This delegation of authority is effective
immediately, is consistent with Hexion policies and standards, supersedes all prior delegations of authority
which may have been in place, and shall continue to be effective until explicitly revoked or otherwise
superseded.
Note that this delegation is not effective when otherwise prohibited or superseded by applicable law or
regulation,and does not eliminate the need to submit any legally-mandated delegation of authority form
that locally applicable laws or regulations may require to effectuate delegation of authority. Note also that
this delegation of authority authorizes you to further delegate the authority granted hereunder-except
where otherwise prohibited by Hexion policies or standards, or by applicable laws or regulations.
Sincerely,
Dale Plante
President, Forest Products Division

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