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HomeMy WebLinkAboutNCG210078_Inspection Report_20230921 Compliance Inspection Report Permit:NCG210078 Effective: 06/01/23 Expiration: 05/31/28 Owner: West Fraser Inc SOC: Effective: Expiration: Facility: Seaboard Lumber Mill County: Northampton 4400 NC Hwy 186 Region: Raleigh Seaboard NC 27876 Contact Person:Christine Jenkins-Jordan Title: Phone: 252-589-8210 Directions to Facility: System Classifications: SWNC, Primary ORC: Certification: Phone: Secondary ORC(s): On-Site Representative(s): Related Permits: Inspection Date: 09/21/2023 Entry Time 10:30AM Exit Time: 12:45PM Primary Inspector:Thaddeus W Valentine Phone: Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Timber Products Stormwater Discharge COC Facility Status: Compliant ❑ Not Compliant Question Areas: Storm Water (See attachment summary) Page 1 of 4 Permit: NCG210078 Owner-Facility:West Fraser Inc Inspection Date: 09/21/2023 Inspection Type:Compliance Evaluation Reason for Visit: Routine Inspection Summary: I meet on site with Christine Jenkins-Jordan (EHS)and Kevin DeBerry(General Manager.We walked the site and identified some issues and made a call for the requested moving of sample point SDO1 from within Carolina Bark facility boundary back to the SW corner of the West Frazer facility. Outfall #1 is approved to move from the outfall location at the culvert outlet on Bluejay Trail to the culvert pipe across the ditch located on the NW corner of the Carolina Bark facility and adjacent to the Scale Yard entrance lot(it is recommended that a sample be taken from the head of the ditch just North of where the two facilities property lines join to get an idea of what runs off the West Frazer facility before co-mingling with Carolina Bark runoff). The sample data for this outfalls shows ultra high readings for COD. I am requesting an assesment of the cause of these high readings and a plan for reducing count. SDO-#2 outlets from the facility through a plastic corrugated pipe next to the train track. I recommend that the sample be taken right at the mouth of the discharge pipe if not slightly inside the pipe opening. I would also request that there is an assesment of the cause of the very high COD readings. SDO-#3 outlets from tht facility through a plastic corrugated pipe next to the train track.) recommend this sample be taken at the very end of the pipe as well to be sure the sample is run off from teh facility only. COD is not being tested at this outfall and should be according to the requirements of the permit. SDO-#4 outlets as a ditch just inside the tree line below the maintenance shop. This outfall has not been sampled in the past and should be. The additional sample requiremenst for vehicle maintenance should be added to the other sample requirements. Outfall-#5 was not found. The area where the sample outlet should be is a flat grassy area with no discernable concentrated flow (not sampled) Outfall-#6 is a grass lined ditch that runs along the fenceline on the NE side of the facility.It appeared the ditch was runoff conveyance for the office trailer area with a unknown 15inch RCP pipe at the upper end (not sampled) Outfall-#7 This outfall is shown on the map at the NE edge of the parking lot. After thoroughly searching that area, no outfall was found. (not sampled) All the sample points should be tested for all the required protocols. SDO-1 should include COD and SDO-3 &SDO-4 for vehicle maintenance along with the other required samples. The SP3 is missing a number of key elements: The site map should include all areas (accordingto to there activities) including the maintenance area, drum storgae area, OWS location with materail storage areas, disposal areas, processing areas,drainage areas etc.. Include drainage flow direction for all areas and outfall areas with latitude and longitude positions along with all other required features stated in the permit. Provide a narative description of processes to include storage and loading and unloading practices, outdoor process areas, waste disposal processes along with the list of potential pollutants expected to be present in the discharge point for each outfall Include additional information in the BMP summery that list all structural and non-structual practices for the facility and especially the vehicle maintenance area The secondary containment plan should include not only tanks, but should list all materials that should be stored in secondary containment. That includes drums and containers of pollutants when full, empty and in use, but not being used. All drums should be in secondary containment unless activily being used. Any drums in use should be kept under cover. Page 2 of 4 Permit: NCG210078 Owner-Facility:West Fraser Inc Inspection Date: 09/21/2023 Inspection Type:Compliance Evaluation Reason for Visit: Routine Any dumpsters or containers exposed to stormwater should be covered and maintained in structurally sound non-leaking containers A list of significant spills should be provided and if no significant spills occur, list"No Spills"for each year. All leaks and spills should be documented and provide where, when, how it occur and how it was fixed when. The matersil cleaned up should be stored for disposal and that should be noted as to how it was stored where and when was it disposed of by who. Detailed tracking is paramount. Training of personnel that have responsibilities for any of the facility operations is required which includes spill response and preventive maintenance and good housekeeping of the fscility operations. This should focus on any areas, machinary or processes that could create a spill or cause a pollutant to be released into the stormwater. They should all be trained and they should sign off on their training. Provide training that covere all those areas. Inspections of the site should occur at least twice yearly and be documented. More frequent inspections are recommended and should cover any and all areas that have the potential for spills, leaks or releases. The maintenance shop should always be included in that inspection and should include inspections for leaks under equipment, containers and materials stationed outside. The shop itself should be part of the inspection and should look for open containers or drums with the potential to spill or leak or be punctured and any spills should be cleaned up immediately and stored properly for disposal. Page 3 of 4 Permit: NCG210078 Owner-Facility:West Fraser Inc Inspection Date: 09/21/2023 Inspection Type:Compliance Evaluation Reason for Visit: Routine Stormwater Pollution Prevention Plan Yes No NA NE Does the site have a Stormwater Pollution Prevention Plan? ❑ ❑ ❑ #Does the Plan include a General Location (USGS) map? ❑ ❑ ❑ #Does the Plan include a"Narrative Description of Practices"? ❑ ❑ ❑ #Does the Plan include a detailed site map including outfall locations and drainage areas? ❑ ❑ ❑ #Does the Plan include a list of significant spills occurring during the past 3 years? ❑ ❑ ❑ #Has the facility evaluated feasible alternatives to current practices? ❑ ❑ ❑ #Does the facility provide all necessary secondary containment? ❑ ❑ ❑ #Does the Plan include a BMP summary? ❑ ❑ ❑ #Does the Plan include a Spill Prevention and Response Plan (SPRP)? ❑ ❑ ❑ #Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ❑ ❑ ❑ #Does the facility provide and document Employee Training? 0 ❑ ❑ ❑ #Does the Plan include a list of Responsible Party(s)? 0 ❑ ❑ ❑ # Is the Plan reviewed and updated annually? 0 ❑ ❑ ❑ #Does the Plan include a Stormwater Facility Inspection Program? 0 ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? 0 ❑ ❑ ❑ Comment: The facility has an SP3 plan but it needs to be updated with any changes and include any missing documents or documents that don't fully provide the permit requirements. Additional comments in summery Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring? 0 ❑ ❑ ❑ Comment: Provided for all outfalls being sampled. Outfall (SDO)#4 is being added with additional samples for vehicle maintenance Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? 0 ❑ ❑ ❑ #Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? 0 ❑ ❑ ❑ Comment: All analytical documentation was provided with very high COD readings for outfalls 2 & 3. Outfall #4 has not been sampled in the past and it is located iust below the maintenance shop. Outfall #4 should be added to the outfalls sampling regiment. Additional comments in summery Permit and Outfalls Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? ❑ ❑ ❑ #Were all outfalls observed during the inspection? ❑ ❑ ❑ # If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ❑ #Has the facility evaluated all illicit(non stormwater)discharges? ❑ 0 ❑ ❑ Comment: We viewed all outfalls that could be found. Outfall #5 and #7 could not be located. Outfalls should be clearly marked with durable signage. Page 4 of 4