NCS000076_OTHER_20080201

STORIVIVIyATER-DIVISfO1V-CODING-SHEET
PERMIT NO.
[\j cS DnU07 (,
DOC TYPE
0 FINAL PERMIT
❑ MONITORING INFO
❑ APPLICATION
❑ COMPLIANCE
PrOTHER
DOC DATE
p 96OS 02-0(
YYYYMMDD

[i;wd: Re: proposed monitoring sheet.xisl
Subject: [Fwd: Re: proposed monitoring sheet.xls]
From: Ken Pickle <[e-mail]>
Date: Fri, 01 Feb 2008 11:59:16 -0500
To: [e-mail]
CC: Bethany Georgoulias<[e-mail]>
Jennifer,
Reading over my thoughts yesterday, I see that T- sort of rambled. Under the pressure
to come up with a hard recommendation here are my suggestions on the outfalls and
open questions from my email earlier. Adopt those that :Hake sense to you, ignore or
imrarove the others.
SEVEN SUGGESTIONS:
1) TN vs NO3-NO2 - - - I see our benchmarks are 30 rag/L TN, and 10 mg/L
nitrate -nitrite. After discussion w/ Bethany, I believe our beginning posture should
be that we write the draft permit for both TN and NO3--NO2 at every outfall.
Rationale outlined below.*
2)
Outfail
001 - -
as
you have
it.
3)
Outfall
002 - -
as
you have
it with the
addition of NO3-NO2.
4)
Outfall
003 - -
full
suite
of analyses,
parallel to other outfalls. Rationale
outlined
below."
5)
Outfall
004 - -
as
you have
it.
6)
Outfall
005 - -
as
you have
it with the
addition of NO3-NO2.
7)
Outfall
008 - -
full
suite
of stormwater
analyses, parallel to other stormwater
outfalls.
Rationale
outlined
below.***
* used on the large mass of NOx reported in the TRI, we are positing a potential
source of stormwater pollution either from particulate atmospheric deposition, or
from the solubility in rainfall of the in -air particulate and gaseous N species.
This supposition is open to revision based on further knowledge provided by others
(we've exhausted our ready resources.) Continuing: If it is dry atmospheric
deposition or rain solubility at work, then it's likely that the whole site should be
subject to consideration as a source, due to probable areal dispersion of the stack
emissions over the whole of the plant site. Absent better knowledge about the forms
of IV, it seems to me that we should test for all forms, by testing for TN and
NO3-NO2, and by subracting for the TKN forms if we ever want them. C Sw
classification does not really contribute to the argument for N testing one way or
the other. (Bethany, this is different from our discussion on nutrients in the Cape
Fear - have I missed something here?)
** My opinion - Corning's report that the area is not operational is insufficient by
itself to reduce the sampling that we would otherwise require in this area. They
have not asserted that they have cleaned up the area (residual exposure may still be
present); atmospheric deposition might still be an operative mechanism this close to
the operating plant portion; and their submittal drawing shows materials of concern
present in the drainage area. Perhaps we would be receptive to representative outall
status here, if Corning presents a strong argument, or corroborating data.
*** This outfall drains a good portion of the manufacturing facility. I think our
beginning posture should be that their obligation is to test all stormwater outfalls
for all parameters that we reasonably believe may constitute significant exposure in
the contributing drainage area. We should certainly be receptive to subsequent
requests for representative outfall status; and we should be receptive to
explanations that some materials are not present in the drainage area, but Corning
should make those requests and explanations at their initiative. (Like during the
1 of 4 2/4/2008 8:45 AM

[Fwd: Re: proposed monitoring, sheet.xls]
draft permit review period, or subsequently after accumulation of supporting data.)
SANITY CHECK - As before, if any of this doesn't pass the test of what's reasonable,
what has precedent, what's too burdensome, what's equitable, etc. then we need to be
sure to consider those valid counter arguments.
Ken
Subject: Re: proposed monitoring sheet.xls
From: Ken Pickle <[e-mail]>
Date: Thu. 31 Jan 2008 17:05:37 -0500
To: [e-mail]
Jen,
As you requested, here are my thoughts.
Outfall 001, a wastewater outfall:
a) I note the expansion from just TN to nitrate -nitrite also - [seems OK to me.]
b) I note that pH and TRC are already measured monthly on the wastewater discharge,
so no need to measure on the stormwater sampling - (OK.] (jut realize that
stormwater flows may mobilize the other materials, and we wouldn't necessarily
capture them with this wastewater sampling, but still, it seems to me a minor point
and that this is OK as you have revised it.)
Outfall 002, a wastewater AND STORMWATER outfall under the NCxxxxxx permit:
a) I note the expansion to include TSS and 0&G in a specific storm event - [OK]; I
agree this is an improvement over my intial suggestion.
b) I'm confused. Do we want NO3-NO2 here? Columns 4 and 11 seem to contradict. [OK
either way], it seems, because I don't understand what extra action or information
might result from comparison of TN and nitrate --nitrite analyticals. I'm not saying
there isn't something extra there, I just don't know what it is,or how it translates
into Tier 1 or Tier 2 management actions. This is a comment on my ignorance, not on
our required sampling for Corning.
Outfall 003, a wastewater outfall: Random thoughts - -
a) First question - this is an abandoned area, right? Do we know if the facility has
a regular wastewater discharge from this area? If not (?), then we shouldn't give
much weight to the "monthly monitoring" of the wastewater discharges - - there may
not be any wastewater discharges to sample.* Consequently, we might not have the
benefit of monthly TRC, pH, and temp on the wastewater (and by extension, on the
presumed occasional commingled stormwater either.) I mean, their NCxxxxxxxx permit
only obligates them to sample for wastewater discharges at this location, not for
stormwaters. So, we might never get monitoring on any fiow from here, except for O&G
on stormwater twice a year. Why select only 0&G? Perhaps we might want to include a
broader suite of stormwater monitoring.
b) We have the permittee's assertion that the area is shut down, and it appears our
monitoring scheme accepts his assertion as also meaning that there is not much
potential for pollution (hence O&G only.) But at some time in the past this was an
active manufacturing area. Do we have site visits or inspections to establish that
there is no exposure or no residuals on this part of the site? c) Further, consider
that Corning can eliminate monitoring parameters by asserting that the materials are
not present in the sub -drainage area. Have they done that? On the contrary, consider
that their submittal drawing shows materials present in the abandoned drainage area.
If you are persuaded that despite the submittal drawing those materials are not in
the drainage area, then I think it's ok to avoid some of those other parameters that
we believe are characteristic of the rest of the manufacturing facility - NO3-NO2,
TN, TSS, pH, TRC. (However, in my mind, pH, TSS, and 0&G) are basic stormwater
parameters that we should at least start out with at most manufacturing facilities.)
2 of 4 2/4/2008 8:45 AM

Re: proposed monitoring sheet.xls
Subject: Re: proposed monitoring sheet.xls
From: Ken Pickle <[e-mail]>
Date: Thu, 31 Jan 2008 17:05:37 -0500
To: [e-mail]
Jen,
As you requested, here are my thoughts.
Outfall 001, a wastewater outfall:
a) 1 note the expansion from just TN to nitrate -nitrite also - (seems OK to me.l
b) 1 note that p?? and TRC are already measured monthly on the wastewater discharge,
so no need to measure on the stormwater sampling - [OK.] (But realize that
stormwater flows may mobilize the other materials, and we wouldn't necessarily
capture them with this wastewater sampling, but still, it seems to me a minor point
and that this is OK as you have revised it.)
outfall 002, a wastewater AND STORMWATER outfall under the NCxxxxxx permit:
a) I note the expansion to include TSS and 0&G in a specific storm event - [OK]; 1
agree this is an improvement over my intial suggestion.
b) I'm confused. Do we want NO3-NO2 here? Columns 4 and 11 seem to contradict. (OK
either way}, at seems, because I don't understand what extra action or information
might result from comparison of TN and nitrate -nitrite analyticals. I'm not saying
there isn't something extra there, I just don't know what it is,or how it translates
into Tier 1 or Tier 2 management actions. :his is a comment on my ignorance, not on
our required sampling for Corning.
Outfall 003, a wastewater outfall: Random thoughts - -
a) First question - this is an abandoned area, right? Do we know if the facility has
a regular wastewater discharge from this area? If not (?), then we shouldn't give
much weight to the "monthly monitoring" of the wastewater discharges - - there may
not be any wastewater discharges to sa_mple.R Consequently, we might not have the
benefit of monthly TRC, pH, and temp on the wastewater (and by extension, on the
presumed occasional commingled stormwater either.) I mean_, their NCxxxxxxxx permit
only obligates them to sample for wastewater discharges at this location, not for
stormwaters. So, we might never get monitoring on any flow from here, except for 0&G
on stormwater twice a year. Why select only O&G? Perhaps we might want to include a
broader suite of stormwater monitoring.
b) We have the permittee's assertion that the area is shut down, and it appears our
monitoring scheme accepts his assertion as also :leaning that there is not much
potential for pollution (hence O&G only.) But at some time in the past this was an
active manufacturing area. Do we have site visits or inspections to establish that
there is no exposure or no residuals on this part of the site? c) Further, consider
that Corning can eliminate monitoring parameters by asserting that the materials are
not present in the sub -drainage area. Have they done that? On the contrary, consider
that their submittal drawing shows materials present in the abandoned drainage area.
if you are persuaded that despite the submittal drawing those materials are not in
the drainage area, then I think it's ok to avoid some of those other parameters that
we believe are characteristic of the rest of the manufacturing facility - NO3-NO2,
TN, ISS, pf?, TRC. (However, in :ray mind, pH, TSS, and O&G) are basic stormwater
parameters that we should at least start out with at most manufacturing facilities.)
* - - On the other hand, if there are wastewater discharges, is it really an
abandoned area for our purposes? I don't think so.
Outfall 004, stormwater only outfall:
a) I note the expansion to include NO3-NO2. [ OK]
b) I concur that O&G probably can be safely eliminated for this roof area runoff. No
need to sample• [ OK]
outfall 005, stormwater only outfall, a very large portion of the facility drains
though 005:
E of 2 2/4/2008 8:44 AM

Re: proposed monitoring sheet.xfs
a) I note the addition of 0&G. ( OK]
b) On 001, 002, 003(?), 004 we ask for NO3-NO2. But not at the outfall that drains a
large portion of the manufacturing facility? is this an intuitive judgement that 3
(or 4) are enough, and that a 4th or 5th is redundant? Recall that we want them to
take Tier 1 or Tier 2 management actions based on benchmark exceedences at specific
outfalls. Do we have reason to suspect that a benchmark exceedence for NO3-NO2 in
005 is less likely than in the other outfalls? That NO3-NO2 forms are not present in
the drainage area?
Outfall 008, stormwater only:
a) I note that a large pond is present and no sampling suggested. Further comment:
b) Realize that these folks will have the opportunity to review and comment on the
draft permit. No sampling is de facto, pre-emptive representative outfall status_
It seems to me that we should make them make the argument for reduction in the number
of outfalls and/or parameters to be sampled; and that our first position should be
that they should sample all the sw outfalls for all the parameters that we reasonably
believe might be present up in the sub -drainage areas. It is true that we might be
very, very receptive to good arguments for representative outfall status, but it
doesn't seem to me that we should pre-empt their responsibility to make those
arguments and tell us about their site conditions. We don't know their site
conditions and manufacturing to the level that would allow us to judge what pollutant
sources might be present (or do we?).
c) The presence of a large pond is good, but I don't think it is a reason to
pre-emptively grant representative outfall status. Further, we can't tell from just
the site plan that the pond is good enough to bring the facility within benchmarks -
only testing can do that. It is possible that the pH and the soluble forms of
nitrogen and chorides will pass through the pond unaffected. It is possible that TSS
may pass through the pond at levels above the benchmark. Absent any engineering
substantiation, we don't have any basis to conclude that the discharge will meet
benchmarks, and that we can eliminate sampling.
SANITY CHECK - - - Are we over -regulating? Are we being unrealistic? Are we being
unjustifiably harsh on this particular facility? Can the permittee reasonably
accomplish the expanded sampling I'm suggesting? Is the expanded sampling a
disproportionate economic hardship for this permittee? Is this just too much
government regulation of a good environmental citizen and economic asset in
Wilmington? Are we authorized to impose these conditions? Has our process been fair
and open_? Are we treating other permittees the same way? Is our approach equitable
in all ways? Do we have precedent for all the actions contemplated?
- - - - Any problematic answer to the above questions, or similar questions deserves
further discussion. Again, the permittee has the opportunity to review the draft
permit. He has the opportunity to explain better to us the potential exposures in
outfall 003. He has the opportunity to ask for representative outfall status at 005
(or other outfall) based on either sampling, or good explanation of the site
circumstances.
Ken
Jennifer Jones wrote:
Hi Ken and Linda,
I went over Ken's suggestions with Mike Randall and this is
see attached xcel sheet. My thoughts are on the blue sheet.
I think Ken - you had good points about some of outfalls 003
we are sticking with mostly what we said for 001 and 002 as
some monitoring. Let me know what you think,
Jen
what we came up with -
and 004 -,but I think
WW is already doing
2 of 2 2/4/2008 8:44 AM

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stormwater Wastwoter
outfolls Monitoring?
Jen's SW
WW proposed
Monitoring Monitoring
Time (revised)
iSS, TRC, NO2-
pH, TRC, and
NO3, TN, pH,
001 temp Monthly
Oil & Grease
TSS, TRC, NO2-
pH, TRC, IN, TP,
NO3, IN, pH,
002 temp M, M, Q. Q
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SW proposed Total SW and WW
Monitoring Ken's Monitoring
Jen's Rational Time Fro me Suggestions Ken's Rational Agree? Why? Parameters
O & G, TSS, pH,
2x year TRC, IN
2x year x
no activity,
TSS, TRC. NO2- already
NO3, IN, pH, monitored
003 1RC, pll, temp Monthly &I & Grease monthly
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004 Nothing Nothing NO3, TRC, pH NOx and Cl 2x year
S, TRC, 1`102-
03, TN, pH,
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�r
008 Nothing Nothing ne
desiel
stormwater
discharge
already
permitted
O & G, TSS, pH, not sure if
TRC. IN cleaned?
TSS, pH, TRC, IN
pond drainage.
Manufacturing
TSS, pH, TRC, IN area
ISS, pH, TRC, TN
diesel is not a probem - 2ndary storage;
already have other monlloring, pH. TRC
phi, TRC. lemp,
already monitored by WW, Can look at
TSS, IN, NO2-NO3,
no in 91MS.
O&G
pH, TRC. Temp,
no TSS monitored by WW, bag house
TSS. IN. NO2-NO3,
no close to that area.
O&G, TV
There d really not very much coming
From this area. However O&G is an easy
test and this is an exposed oulfail. pH
and TRC are already being monitored by
iRC, pH, Temp,
kindo WW.
O&G
already on there, like to see NO2-No3
TSS. TN, NO2-NO3,
kinda because of NOx,
TRC, pH
It is coming from monufaci area. Oil and TSS, pH, TRC, IN,
yes Grease is easy. Oil & Grease
looks like it is going through fairly
extensive pond. ore all these parameters
appropriate? Already will have data
no from 001. 002, 003, 004 and 005 nothing

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te
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COTiNINt. �� axe.-n„n_ L, w

My SW
SW proposed
stoanweler
HPDES Wastwater
propasod
Monitoring Ken's
outsafls
Monitoring? WW Monitoring Time
Man[tering Rational
Time Frame Suggestions
Rallorro!
Agree? WW
diesel Is not a
probem - 2ndary
doo
pH, TRC, and
7S, TN, NO2-
O &
storage; already
have other
IOOl
mp TeMonthly
NO3
2xyear
desel
no monitoring
`
pi., TKC, TN. TP M, M, Q. Q
M O V
s armwer
dscharge already
2x year x pemutted
no monitored
by Ken. bog !wasp
no close to that area.
I am not sure if aS
these are
appilcable,
no activity.
monitor IN. pH and
already
TSS; However.
moNtored
,0 8 G
desO not stored
pOpUaS No�+ng
5 J n.1hing
aching
Monthly
hone monthly
r nc; sure if cleaned?
maybe
}here;
TSS TN O -
Nothing
T3RC, pH. (A roof. 2x year
TSS. pH, 7KC, TN
yes
ofready on there
ok - it Is coming
pond drainage.
from manutact
nothing
none
TSS, pH. TRC, TN Menufoctaring area
yes
area.
�,
looks��g
extensive pond,
ore all these
parameters
approp-late?
Monitor TSS, TN, TP
Nothing
none
TSS. pH. TI.C. TN pond present
not sure
and pH?

My SW
SW proposed
stormwater
NPDES Wastwater
proposed
Monitorfng
Ken's
ouffalls
Monitoring?
WW Monitoring Time Monitorfng
Ratlonal
Time Frame
Suggestions
Rational
Agree?
Why?
diesel is not a
d [-�
probem - 2ndaryI'
PH, TRC, and
TSS, TN, k02
i 0 & T 5, pH
f� +
156� 1
storage; already
have other
001
Temp
Monthly
NO3
2x year
�—r T
Oesiel
no '�
monitoring
slormwater
no TSS monitored
discharge already
/
by Ken, bag house
002
pH, TRC, IN, TP
M, M. Q, Q
TSS)
2x year
-x
permitted
no
close to that area,
I am not sure if all
these are
applicable,
no activity,
/
monitor IN, pH
already
V
0
and 1SSV However,
monitored
TSS, pH,
diesel not stored
003
TRC, pH
Monthly
none
monthly
T�, IN ,j
not sure if cleaned?
maybe_
there?
- -
004
Nothing
Nothing
NO 7ti H
roof
2x year
TSS, pH, TRC, 7N
yes
already on there
pon dr[rinage.
/
ok - it is coming
Manufacturing
,/
from manulact
005
nothing
nothing
none
6� TSSt
TSS, pH, TRC, IN
J
area
yes
area.
looks like it is going
Ttuf YN
through fairly
extensive pond,
are all these
parameters
appropriale?
Monitor TSS, IN, TP
008
Nothing
Nothing
none
TSS, pH, tRC, IN
pond present
rye
and pH?

Site Drainage Controls
Introduction
The Coming Incorporated facility in Wilmington has two (3) NPDES outfalls for non -
contact wastewater and stormwater, four (4) existing NPDES outfalls for stormwater only, and
eight (8) stormwater outfalls serving areas exempt from NPDES permitting. Attachment A contains
a table listing the estimated total drainage area acreage for the outfalls discussed in the next sections.
Outfall 001 SCC currently services a constructed stormwater pond (Pond 5), however, future
construction of a cooling tower system is listed in permit NCO003794, but is not currently constructed.
NPDES Permitted Outfalls
Outfalls 001, 002 and 001 SCC U*OLf 00 Se--c
NPDES Permit No: NC0003794 covers wastewater discharges from the facility via NPDES
Outfalls 001 and 002 (see Drawing labeled "Overall Sheet"). Outfalls 001 and 002
also discharge stormwater runoff from portions of the facility where chemical storage, loading
and unloading occur. Outran 001 also receives stormwater runoff from a portion of the parking
area labeled Drainage Area 14. This drainage area is considered to be an exempt area since
it is only a parking lot (see Drawing Sheet labeled "Quad 3'). Outfall 001 has a 7 t 7
total drainage area of 2.24 acres. This total does not include the exempt Drainage Area 14. f WJ, -
Outfall 002 has a total drainage are of 9.78 acres with 6.81 acres being impervious.
Outfail 001 SC has a total drainage area of approximately 30.35 acres, with 4.56 being impervious.
Drainage Area 3 contains manufacturin . use. The property is bounded
o e no so an eas arge by the property lines. See Drawing Sheet labeled "Quad 1"
and "Quad 4')_ The total drainage area is 6.81 acres with 5.50 acres being impervious. Drainage
Area 3 discharges tMMUMoug2tMvia a stormwater retention pond constructed in 1998.
Cage Area 4 receives stormwater drainage from a portion p
roof see Drawing She-tJ.abeted "Quad ' j. All 2.12 acres of Drainage Area
4 are impervious. Drainage Area 4 discharges through Outfall 004. Also, exempt_Drainage
Area 5D discharges through Outfall 004n Drainage Area 5D}s 0.64 acres of impervious surface.
Drainage Areas" 5 B discharge to a stormwater retention:pond located. primto.Outfall.
005 The retention Eond was constructed ir.U996_ Drainage Area 5A contains 2.26 total acres �� I
it Guding 0.71 impervious acres. Drainage Area 58 is 6.14 acres with 4.53 acres impervious.
Two exempt drainage areas discharge through Outfall 005. Exempt Drainage Area 5C is
comprised of a manicured front lawn, with 2.21 total acres and 0.33 acres impervious. Exempt
Drainage Area 50 receives stormwater drainage from an administrative office building roof
(.64 acres p rvious).
Drainage Area 16 discharges to a stormwater pond constructed in 2001. See Drawing
Sheet labeled "Quad 4". The drainage area consist of 6.81 acres, with 5.50 being impervious.
The drainage area consists of manufacturing support equipment, pollution abatement equipment
and cooling towers.
Outfalls Exempt from NPDES Permitting
Eight (8) outfalls are identified on the storm drain piping drawings as "Exempt
Outfalls (EO)". These outfalls receive water from areas containing no industrial activity and no
potential for stormwater contamination; therefor outfalls.Ca�nd corresponding drainage
area are exempt under NPDES regulations. ,`,',�'sytwt—

Drainage Areas Not Being Discharged Through Outfalls
The remainder of the Coming Incorporated property, Drainage Area 6 and Drainage Area 9, ;
is completely pervious with no direct discharge points from the site. Drainage Area 6 is 0.49
acres and Drainage Area 9 is 10.22 acres.
Site Drainage Controls
The Wilmington plant system design standard requires storm drain systems to function during a
50-year storm event. ► he three (5) existing stcrmwater retention ponds meet the requirements of
NCDWQ State Stormwater Management Systems permit program.
All secondary containment systems located at the facility have been upgraded to retain the
capacity of the largest vessel plus a 24-hour/25-year storm event (defined as 8 inches of rainfall
for the Wilmington area), The Stormwater Pollution Prevention Plan (SP3) includes keyed lockouts
of the drain systems. The Area SP3 team identified "appropriate testing" and record keeping
provisions during Best Management Practices (BMP) development. Collected stormwater from all
secondary containment systems is evaluated prior to making a determination to discharge any
collected stormwater to the outfalls. There is an alternate system available for the discharge of
contaminated stomywater. Collected stormwater can be redirected, if required due to contamination,
to the Pollution Abatement Process for pretreatment prior to discharge to the City of Wilmington WWTP.

*�—X===N—N N N �N N�
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was
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sr

Discussions with permittee: Jennifer Adams, Discussion 1 on January 3,
2008
1. Is the legal name and owner of the facility still Corning
Incorporated?
a. yes
2. Have there been any facility or process changes in the past few
years? For instance, are you still making the same types of products
or have you had any considerable expansions?
a. Same products, no significant expansions.
3. Do we have newer monitoring data than last submitted (last was
6/15/04)?
a. **Corning will submit most current qualitative data - still
believes that it was no issues. Will send to us.* - Sent via
email 113108.
4. Did they used to do other analytical monitoring in the past? If so
what and when? Did they stop because they were not over the limit
and their permit did not require them to do more?
a. No stormwater analytical monitoring_
b_ One Stormwater [Waste Water permit actually] permit does
require
i_ From outfall 001: Flow, temperature, pH, Total residual
monitoring (monthly)
ii. From Outfall 002: Flow, temperature, pH, total
residual chlorine (all monthly); total nitrogen N & and
total P (quarterly). State Stormwater permit does not
require this. Do have analytical monitoring data from
the WW permitting.
Clarification - State NPDES Permit NC0003794 requires
i. OutfalI 001 - monthly flow, temp, pH, total residual
chlorine
ii. Outfall 002 -- monthly flow, temp, pH, total residual
chlorine; quarterly total nitrogen & totaI phosphorus
iii. Outfall 003 (Corning outfall 001SCC) - monthly flow,
temp, pH, total residual chlorine ONCE CONSTRUCTED.
Construction has never started, nor are there any plans
to.
List of outfalls:
1. Outfalls 001, 002 (monitored in state Waste Water permit - NC0003794)
2. Outfall 001:
a. Chemical storage, loading and unloading - All outside, r
waste storage and chem storage areas are
covered or double contained.
b. Outfall 001 receives from parking drainage area 14, lift
station overflow, parking area, water tank, water well,
treatment chemicals
C . rrliilf39t- all ef-z;va5:-t=rraide -6f - rc beilding--yvca rriez:gzr -zu x x
9G---cooling towers, water tank are outside and drain to this.
Does not go to pond 1. Directly out to outfall 001.
3. outfall 002:

a. Outfall 002 no exempt area, has "discharge structure", from
loose gravel and raw material storage area, chemical storage,
CP&L transmission substation, diesel fuel storage
3. Pond 2 is exempt outfall - #E04A
a. *Ms. Adams - Please clarify as to why exempt. Please email
back-
b. Clarification - Pond 2 discharges to outfall EO-4, exempt
since area contains no industrial activity. Pond emergency
overflow is labeled as outfall EO-4A
4. Outfalls 003, 004, 005, 008
a. Outfall 003: drainage area 3
i. Area 3 is not currently in use. Manufacturing building &
area.
1. Is this being used again since 2004? NO.
ii. BUT Stormwater from Area 3 drains to pond 3, then to
Outfall 003, via underground pipe - discharge is at
southeast corner.
iii. Pond 3 is being used to collect stormwater, but
manufacturing area 3 is not. ????
b. Outfall 004: Permitted outfall.
i. Goes down from roof, to gutters, pipe and then drainage
ditch to outside of property. Does not go to pond 1.
Directly leaves the property_
ii_ Does any of this go to Pond 1? No.
iii. Also exempt area 5D - /although on map it may drain
through 005. Need clarification./ Clarification - area 5D
not exempt, drains through outfall 005, via Pond 1
c. Outfall 005:
i. 5A and 5B drain to Pond 1 in quad 3 then to 005. Areas 5A,
5B, 5C, and 5D drain to Pond 1, discharge via outfall 005.
ii. /How does area 5A drain to outfall 005? Yes. This was
newer construction - 5B and 5D. 5A is drainage and piped to
pond 001. /
iii. /Area 5C is the grass area around the pond. /
iv. Pond 1 is the largest pond. All ponds are wet
detention ponds.
d. Outfall 008
i. Area 16 is the entire area surrounding pond 4 - all goes to
Pond 4, and then discharges out 008.
ii. Drains area 16: support equipment, pollution
abatement equipment and cooling towers.
5. Why is 5D exempt and other roof structure draining to 004 is not
exempt? - See clarification above - area not exempt.
6. 4 and 4a were "grandfathered" [We need to clarify this point as we
do not usually accept this term for stormwater permitting].
Clarification - area 4 receives stormwater draining from a portion
of the manufacturing building roof". Drains to permitted outfall
004. Area 4A also receives stormwater from the building roof, but
from an area without industrial activity, therefore exempt from
NPDES regulations, draining to outfall EO-6. Both are
"grandfathered" from Pond requirements.

7. Area SA and 3 appear to be linked by out falls/drains. //
clarification - no: linked, JusL ne L to each other. Drainage
system is separate.
*/ i. /**/Please clarify. /*

Site Drainage Controls
Introduction
The Coming Incorporated facility in Wilmington has two (3) NPDES outfalls for non -
contact wastewater and stormwater, four (4) existing NPDES outfalls for stormwater only, and
eight (8) stormwater outfalls serving areas exempt from NPDES permitting. Attachment A contains
a table listing the estimated total drainage area acreage for the outfalls discussed in the next sections.
Outfall 001 SCC currently services a constructed stormwater pond (Pond 5), however, future
construction of a cooling tower system is listed in permit NC0003794, but is not currently constructed.
NPDES Permitted Outtalk
Outfalls 001, 002 and 001 SCC 4*0,f 0V
NPDES Permit No: NC0003794 covers wastewater discharges from the facility via NPDES
Outfalls 001 and 002 (see Drawing labeled "Overall Sheet"j. Outfalls 001 and 002
also discharge stormwater runoff from portions of the facility where chemical storage, loading
and unloading occur. Outfall 001 also receives stormwater runoff from a portion of time parking
area labeled Drainage Area 14. This drainage area is considered to be an exempt area since
it is only a parking lot (see Drawing Sheet labeled "Quad 31. Outfall 001 has a f'
total drainage area of 2.24 acres. This total does not include the exempt Drainage Area 14. P fwf, " t
Outfall 002 has a total drainage -are of 9.78 acres with 6.81 acres being impervious.
Outfall 00_ 1�Q has a total drainage area of approximately 30,35 acres, with 4.56 being impervious.
Drainage Area 3 contains manufacturin use. The property is bounded
o e no so an eas arge by the property lines. See Drawing Sheet labeled "Quad 1"
and "Quad 4l. The total drainage area is 6.81 acres with 5.50 acres being impervious. Drainage
Area 3 discharges tfi'[ou�BEk via a stormwater retention pond constructed in 1998.
Drainage Area 4 receives stormwater drainage from a portion of_the_ larwfacturing.Building_
roof (see Drawing SheeLjabeled "Quad "). All 2.12 acres of Drainage Area
4 are impervious. Drainage Area 4 discharges through Outfall 004. Also, exempt Drainage
Area 5D discharges through Outfall 004. Drainage Area 5D.is 0,64 acres of impervious surface.
Drainage Areas &5A and:5S(discharge to a stormwater retention pond located prior to Outfall
005. The retention pond was constructed in 1996_ Drainage Area 5A contains 2.26 total acres
including 0.71 impervious acres. drainage)Area 5B is 6.14 acres with 4.53 acres impervious.
Two exempt drainage areas discharge through Outfall 005. Exempt Drainage Area 5C is
comprised of a manicured front lawn, with 2.21 total acres and 0.33 acres imperious. Exempt
Drainage Area 5D receives stormwater drainage from an administrative office building roof
(.64 a impervious).
Drainage Area 16 discharges to a stormwater pond constructed in 2001. See Drawing
Sheet labeled "Quad 4". The drainage area consist of 6.81 acres, with 5.50 being impervious.
The drainage area consists of manufacturing support equipment, pollution abatement equipment
and cooling towers.
Outfalls Exempt from NPDES Permitting
Eight (8) outfalls are identified on the storm drain piping drawings as "Exempt
Outfalls (EO)". These outfalls receive water from areas containing no industrial activity and no
potential for stormwater contamination; therefore, these outfalls and cones nding drainage
area are exempt under NPDES regulations. `'� �` jt�y

Drainage Areas Not Being Discharged Through Outfalls
The remainder of the Coming Incorporated property, Drainage Area 6 and Drainage Area 9,
is completely pervious with no direct discharge points from the sfte. Drainage Area 6 is 0.49
acres and Drainage Area 9 is 10.22 acres.
Site Drainage Controls
The Wilmington plant system design standard requires storm drain systems to function during a
50-year storm event. The three (5) existing stormwater retention ponds_ meet the requirements of
NCDWQ State Stormwater Management Systems permit program.
All secondary containment systems located at the facility have been upgraded to retain the
capacity of the largest vessel plus a 24fiour/25-year stomp event (defined as 8 inches of rainfall
for the Wilmington area). the Stormwater Pollution Prevention Plan (SP3) includes keyed lockouts
of the drain systems. The Area SP3 team identified "appropriate testing" and record keeping
provisions during Best Management Practices (BMP) development. Collected stun-nwater from all
secondary containment systems is evaluated prior to making a determination to discharge any
collected stormwater to the outfalls. There is an alternate system available for the discharge of
contaminated stormwater. Collected stormwater can be redirected, if required due to contamination,
to the Pollution Abatement Process for pretreatment prior to discharge to the City of Wilmington WWTP.

k

j 4 - mill" arscElFllmf six tuVt l= � f3 MIf4ATES
� AL7[A IDA
1 KINITTO MOTALL P-24 AC 2-24 Ac f3A LAT- 3r-Ir-14- LDS 7r-W-Ir
FEAKIITm a;IIfA,L } 7e & III ac aa2 LA7- 3A•-IT-Ir LLK m-W-
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PLANT i t - QUAD 1 AREA NO, �• E' �'� A z GO &Cr lip ac a 00 41C am AC W4 W 3 :ire uwA Yrr -W -ir
j SA Fl�lllTTO WIT L26 At a 71 At OM LAT. 3r-Ir-llr cub 7r-St-Ir
NORTH EMERGE .- :.-_-_-_-_.-•. _-. - •. NOOUTFALL 7i MMKInE3ajw&L L14At 4.wAC am LAI- 3r-IS-vrUWA 77-w-Ir
I jSPILLWAY _ 029AC x C904" awL, M5 Z Ar am c om LAT- 3r-Ir-L0' U36 rr-sr-Ir
�-' PEE2VIOUS w E17TVI &WA, am ai4 K a64 At am LAT. 3r-15'-17 La,b rr-'3r-ir
__. E C1WI dfFA a 49 4C a AC AVA AAA
E Row 7 EIDIFT dak C" 1.44 A: a 05 AC WA LAI- 3r-Tr3• LM Tr-W L7'
j
.ago 7 _ B OWN ALGA. Efli a54 AC 0 A[ VA LAI. 3r-17-Or LDS 7r-w-IT w„ AREA NO.2 AREA ND- a AREA MWSA. 9 CKW ATIrA it 22 AC a AT: VA
FXEND. Iv11
OUTFALL. OUTFALL002 NOOUTFAl1 1 lTF - _ .- y -'-y., la ExWI Aft Mi 1.I2 AC 1.0 AC VA LAI. 3r-IT-Ir LIM 7r-W-IV
EO-4 9-78 AC 0.49 AC -� AC :� . - . _ -1 1! []Dr- �A m 2 M- I AC 1. 1 AC w LAI. 3AC 3- SO 4C ova Lo 2112 -17 � 7r-W -Ir
6.81 IMP PE3tV101JS 0.71 AC WW \� . 13 COPI NFA. 13) 4 4. 71 AC 3 67 AC VA LAi. 3r-17-11' WWI 7r-la -W
QUAD 2 p __ _EXDM
f N t - '' ,t- .� ` 15 sM � M7 2a.90 AC P_ 75 K Iv ul 33rr-is-IL Deb rr sr-0f
16 7�tW � � nM 1C 3 o AC OW LAT. Dr-Tr-m• LDS Tr-W-Ir
i AREA NO. 13 I , _ 'A�� ; . _ ® _ 1 6S fi AC 40 97 AC
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CONSULTING EWIrEM. INC. '•�'��"'
CORNING o,seA-ttlSat�V Ia
6:

V
ri
Air Duality Impact Analysis for the
Corning, Wilmington T40 Application, Ffilmina ton, North Carolina
1.0 INTRODUCTION
Corning Incorporated is proposing to rnodir}r its operations at its fiber optics manufacturin¢ plant in
Wilmington\ ? Forth Carolina_ Prior to commencing construction or modification ofany air pollutant
emission source, Corning Incorporated must submit an "Application for Air Permit to
Construct/Operate" to the North Carolina Department of Environment, and Natural Resources
ri (INTCDENR)_ As part of the permit application process, the applicant must demonstrate that the
facility will comply with the North Carolina Air Toxic Standards. The modification will affect the
facility's potential to emit of chlorine, hydrogen chloride, hydrogen fluoride, and total fluorides.
The potential for these pollutants to be emitted in quantities Greater than the NCDEN-R toxic air
pollutant permitting :missions rates (TPERs) will remain after the modification. Because of these
changes, it was necessary to perform an Air Quality Impact Analysis (AQIA) to demonstrate
s' compliance with the AALs. This report presents the AQL:k methodology and dispersion modeling
results that were used to estimate all quality impacts from the proposed project. The predicted
pollutant impacts of interest were evaluated with respect to the AALs as defined in the current North
Carolina Air Toxic Standards. There are no modifications to existing buildings/structures, additions
of any buildings or structures. or prope-,ty boundary changes being made as part of the proposed
modification project.
Section 2.0 of this document presents both a description of the site and a description of the
poll utants/locati.ons that require dispersion modeling for air toxic emissions. Section' .0 presents the
methodologies that were used for dispersion modeling. Section 4.0 presents the dispersion modeling
results for the five air emissions sources that were evaluated. Sections 5.0 and 6_0 present the
general analysis conclusions and references used, respectively. The modeling analysis has
conformed to the NCDENR Division of Environmental Management's Guidelines for Evaluatins the
Air Quality Impacts of Toxic Pollutants in North Carolina (Reference 1). and the North Carolina
Toxics Modeling Protocol Checklist has beencompleted and is included in Appendix A.
Prepared by Page 4
Corning Incorporated AD VEMBER 2004

9 1
,sir Ouali4! Impact Analysis for the
Corning ffllmington T40A lication. f{'ilnrin ton, .Forth Carolina
2.0 SITE AND FACILITY REPRESENTATION
2.1 Site Representation
Corning Incorporated is proposing to modify a fiber optics manufacturing plant located in
Wilmington. North Carolina. The plant UTM coordinates are 235,741 E and 3,793,48; N at an
elevation of approximately 36.8 feet above mean sea level. The. plait is located at 310 North
College Road in New Hanover County. The property terrain is generally flat with a gentle
downward slope towards the seashore to the south and east. The terrain does not increase more than
I5 feet within three (3) kilometers (km) of the facility. Therefore, the terrain is considered to be
"simple" since the terrain within three (3) krn of the facility is below the five stack heights to be
modeled. For dispersion modeling purposes, .the terrain was treated as flat terrain. Furthermore, the
land use within three (3) km of the site can be characterized using the Auer technique (Reference 2)
as being rural. The overall facility site plan and the USGS topographic map; included in this
application (see Roof Diagram, Plant Layout, Plot Plan, and Area Map), show the site plan with
simaifica:nt structures and site location for the project. The site survey/certified plat map for the
property can be found in Appendix E of this report.
2.2 Pollutant Characteristics and Locations
Physical site parameters such as the stack elevations and the controlling building dimensions were
obtained from facility layouts, plot plans. and existing source information consistent with
source/stack information provided in previous permit application packages. Stack exit velocities,
exit temperatures, and emission rates for the proposed expansion and modifications are consistent
with those provided in this permit application package.
The Corning Incorporated facility manufactures fiber optics. The manufacturing processes are
currently permitted to emit hydrogen chloride, chlorine. hydrogen fluorides, and fluorides in
quantities greater than the TPERs. As shown in Table I at the end of this docurnebt, the only air
toxics which both exceed the trace emission values specified in the current North Carolina Air
Prepared by Page 5
Corning Incorporated NOVEMBER 2004

I I j
Air Quality Impact Analysis for the
Corning Wilmington T40Application, HYlrnington, North Carolina
Quality Regulations 17 \ CAC 2Q .0711 Permit Requirements for Air Toxic Pollutants (Ref rence
a) and are affected by this project are hydrogen chloride. hydrogen fluoride, and total fluorides:
Table 2 summarizes the emission source parameters for the five emission points that have been
modeled. Stacy I is a standalone structure located on the northeast side of the main plant building.
Stack 2A is a standalone structure located on the northeast side of the main plant building_ Stack 3 is
; a standalone structure located on the southeast side of tahe main plant building. Stack 5 is a
standalone structur: located on just north of the proposed expansion site of the property. Stack 6 is a
standalone structure located on the northeast side of the main plant building. Stacks I, 2A, and 3
-- have the potential to emit chlorine, hydrogen chloride, hydrogen fluoride, and total fluorides. Stack
5 has the potential to emit chloride and hydrogen chloride. Stacie 6 has the potential to emit
hydrogen fluoride and total fluorides. All stack parameters, such as volumetric flow rate, stack
,y diameter, stack exit velocity, stack height gas temperature and location, as well as parameter
= derivation have been defined and are consistent with the p=it application package. Overall facility
isite plans can be found in this application (Roof Diagram, Plant Layout; and PIot Plan).
1 Conversion of pollutants to other species; depletion and deposition were not considered in the
dispersion modeling.
Prepared By Page 6
Corning Incorporated NOVEMBER 2004

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1. AMORPHOUS SILICA (SOOT DUST)
2.
3.ARGON
4. NITROGEN
5. CARBON DIOXIDE
6. CHLORINE
7. DESOLITE FIBER COATINGS
8. OXYGEN
9. CHLORINE
10. CHLORINE
11. GERMANIUM TETRACHLORIDE
12. HELIUM
13. HELIUM
14. HYDROCHLORIC ACID
15. HYDROCHLORIC ACID
16. HYDROGEN
17. ISOPROPYL ALCOHOL
18. ISOPROPYL ALCOHOL
19. METHANE (NATURAL GAS)
20. METHYLENE CHLORIDE
21. NITROGEN
22. OXYGEN
23. PAINTS
24- DIESEL
25. SILICON TETRACHLORIDE
26. SILICON TETRACHLORIDE
27. SODIUM HYDROXIDE
28. SULFURIC ACID
29. SULFURIC ACID
30. SULFUR HEXAFLUORIDE
31. TITANIUM TETRACHLORIDE
32. METHYLENE CHLORIDE
33. SILICONE FLUID
34. SILICONE FLUID
35. GERMANIUM TETRACHLORIDE
36. ETHANOL
37.
38. SODIUM HYDROXIDE
39- SILICONE FLUID
40. HYDROGEN PEROXIDE
41. SODIUM HYDROXIDE
42. HYDROCHLORIC ACID
43. ISOPROPYL ALCOHOL
V
D
A
D
C
C
A
A
B
C
A
D
B
D
C
A
B
C
C
D
D
B
C
B
D
D
B
A
B
B
A
B
C
B
A
B
D
C
C
C
C
NOTES:
1. CATEGORIES OF MATERIALS
CLASS A - LESS THAN 55 GALS. OR 500 LBS.
CLASS B - 55-550 GALS. OR 500-5000 LBS.
CLASS C - 550-5500 GALS. OR 5000-50,000 LBS.
CLASS D - OVER 5500 GALS. OR 50,000 LBS.
17 ADD H2O2 TANK (JS)
16 CORRECTED FOR 2002 PERMITTING (JS)
15 ADD CONCRETE PAD FOR CO/He MIXER (RLW)
14 ADD T5X EXPANSION
13 ADD COOLING TOWERS
13 REV. OR RDDED MATERIALS, REV. MAT'UCLASS TABLE
12 ADDED CORE EXPANSION PROJECT, REV. MAT'L/GLASS TABLE
11 GENERAL UPDATES (LAP)
10 GENERAL UPDATES (LCL)
9 GENERAL UPDATE MAV
8 UPDATE FOR T-5 EXPANSION
7 GENERAL UPDATES
6 ADDED SILICONE FLUID BLDGS, TANKS
5 CORRECTED WALL LOCATIONS IN WAREHOUSE AREA
4 ADDED 33-37 & UPDATES MHW
3 GENERAL UPDATES
2 UPDATED & ADDED MATERIALS LIST. DSM
1 UPDATED
LATEST
FEVISION
REVISION DESCRIPTION
815/03
1123/02
8/27/01
1 100
4/16/99
2/ 12/98
2110197
2/12/95
2/16/95
10/24/94
3/25/94
2/22194
2/9193
2119/92
2119/91
DATE
CDG ' 3147
ADA 2994
SRS 2948
JWP -
HL 2686
MIME 2521
MMF 2355
JRL -
AKS 2065
MHW 1999
MHW -
WMC 1902
ME 1714
MT -
SS -
APPV'D I EEC NO
17 DIVISION CORNING OPTICAL FIBER
THIS DRAWING IS THE EXCLUSIVE PROPERTY OF CORNING, INC.
THIS DRAWING MUST NOT BE REPRODUCED OR COPIED IN ANYWAY WHATSOEVER WITHOUT THE EXPRESS CONSENT IN WRITING OF CORNING, INC. THE DRAWING
IS TO BE USED ONLY FOR THE PURPOSE FOR WHICH IT IS SUPPLIED AND MUST BE RETURNED ON DEMAND. THE CONTENTS OF THE DRAWING MUST MOREOVER BE
TREATED AS STRICTI.Y CONFIDENTIAL AND MUST NOT BE DISCLOSED TO ANY THIRD PARTY WITHOUT THE EXPRESS CONSENT IN WRITING OF CORNING, INC_
DRAWING DESCRIPTION HAZARDOUS MATERIAL LOCATIONS - AUGUST 2003
AREA OF PLANT CHEMICAL STORAGE BUILDING & MISC
PROJECT NAME DSGN/INIT DRAWN NA EEC NO. NA DATE NA SCALE NTS
DISCIPLINE LAYOUT DATE PLOTTED q/� FACILITIES DRAWING NUMBER
VENDOR REF No. Oct 1 9, 2004 1013556-115621 - E ■p
FAC_LAYOUT.1
TBLOCK REV. 08/23100