NCS000156_Email correspondence_20231010

Young, Brianna A
From: Sara Hlatky <[e-mail]>
Sent: Tuesday, October 10, 2023 11:06 AM
To: Young, Brianna A
Subject: Re: [External] Bakelite Synthetics NPDES Permit NCS000156
Attachments: Outlook-agOdwo5q
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
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Hello Brianna,
Thank you for clarifying the questions, I truly appreciate it!
Sara Hlatky
Compliance Specialist
e. Sara.Hlatky(@ehs-support.com
p. 724-998-6691
o. Morgantown, WV
w. ehs-support.com
EIHS Support'
From:Young, Brianna A<[e-mail]>
Sent: Friday, October 6, 2023 11:00 AM
To: Sara Hlatky<[e-mail]>
Cc:Amy Bauer<[e-mail]>;Thompson, Emily<[e-mail]>
Subject: RE: [External] Bakelite Synthetics NPDES Permit NCS000156
Good afternoon,
I apologize for the delay in responding as I wanted to confirm some information with other staff first. Please see below
for responses to your questions.
Does the permit reissuance restart the clock for the Tier Responses?
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If facilities are already in Tiered Response at the time a new permit is issued,they should continue to follow those
actions under the new permit. However,the count (number of exceedances)towards Tiered Response resets at the
issuance of a new permit.
Toxicity testing frequency if a facility is in Tier 2 or Tier 3: Does toxicity testing increase frequency or remain
quarterly?
Per Appendix A of the permit,the below actions should be followed when monitoring for aquatic toxicity:
II. Actions for Failure of Pass/Fail Testing
Should any single scheduled monitoring indicate a failure to meet toxicity benchmark levels,
within thirty(30)calendar days from availability of the test results,the permittee shall contact
the Division of Energy, Mineral,and Land Resources(DEMLR)Stormwater permitting Unit
(SPU)Central Office and the Regional Office Supervisor in writing.
l) If other stormwater monitoring parameters have exceeded benchmark values,the
Regional Office may exempt the permittee from additional acute toxicity monitoring
(other than regularly scheduled test periods)at the Regional Office's discretion,The
perminee shall continue to address all other s€orm titer parameter benchmark
exceedances,
2) If the permittee has not exceeded other benchmark values,or if the Regional Office does
not exempt the permittee from additional monitoring, the permittee shall immediately
institute monthly acute toxicity monitoring with a 48-hour multiple dilution test per U.S.
EPA Method 204 .0."Methods for Measuring the Acute Toxicity of Effluents to
Freshwater and Marine Organisms,"EPA 821-R-02-012(October 2002).
Measurable storm event: If an outfall has continuously flow,for example outfall 006 drains to the natural pond and
the outfall has continuous flow,when to sample?Would this be on the schedule for the others in which have flow
during a storm event
Sampling at a stormwater outfall that has continuous flow should occur like that of other stormwater outfalls, within 30
min of rain event discharge.
Preventative Measures and Good Housekeeping inspections: Does there need to be a physical record of such
inspections? For example,equipment inspections are to be conducted daily before use,trucks inspected prior to
loading, pumps inspected per manufacturers specifications, etc.
Per Section B-10 of the permit, "A record of inspections, maintenance, and housekeeping activities" must be kept.
Please see Sections B-7 and B-10 of the permit for more information.
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
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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.
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.
From: Sara Hlatky<[e-mail]>
Sent:Wednesday, October 4, 2023 12:21 PM
To:Young, Brianna A<[e-mail]>
Cc:Amy Bauer<[e-mail]>;Thompson, Emily<[e-mail]>
Subject: [External] Bakelite Synthetics NPDES Permit NCS000156
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.
Hello Brianna,
Below is a submittal of questions on the behalf of Bakelite Synthetics in Columbus County for the approved NPDES
permit NCS000156 effective October 1, 2023. Clarification is requested for the following:
• Does the permit reissuance restart the clock for the Tier Responses? Conflicting information is found within the
permit:
o Page 2 of the new permit cover page states "Per the policy of the Stormwater Permitting Program,
Tiered Response relief effectively ends at the new permit cycle. Conditions start over at baseline
monitoring, and permittees will have to seek relief again if/when appropriate."
o D-2 of the permit states "If the facility was in Tier 2 or Tier 3 status under the previous permit, the
facility shall continue monthly monitoring and reporting requirements until relieved by the provisions of
this permit of the Division."
• Toxicity testing frequency if a facility is in Tier 2 or Tier 3: Does toxicity testing increase frequency or remain
quarterly?
• Measurable storm event: If an outfall has continuously flow, for example outfall 006 drains to the natural pond
and the outfall has continuous flow, when to sample?Would this be on the schedule for the others in which
have flow during a storm event
• Preventative Measures and Good Housekeeping inspections: Does there need to be a physical record of such
inspections? For example, equipment inspections are to be conducted daily before use,trucks inspected prior to
loading, pumps inspected per manufacturers specifications, etc.
Please let me know if you have any questions.
Thank you,
Sara Hlatky
Compliance Specialist
e. Sara.Hlatky(c�ehs-support.com
p. 724-998-6691
o. Morgantown, WV
w. ehs-support.com
EFHS -Support'
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Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.
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