NCS000048_COMPLIANCE_20171214

STORMWATER-DIVISION-CODING-SHEET
PERMIT NO.
N ❑ oo0 o L11
DOC TYPE
❑ FINAL PERMIT
❑ MONITORING INFO
❑ APPLICATION
K COMPLIANCE
❑ OTHER
DOC DATE
❑ f� U I `l
YYYY M M D D

AGE
GREENSBORO
NORTH CAROUNA
WATER RESOURCES
December 14, 2017
William Newlin
Chemol Company, Inc.
P.O. Box 16286
Greensboro, NC 27416
RF: Industrial Compliance Inspection
Inspection location: Chemol Company, Inc.
2300 Randolph Ave.
SW Permit 1#: NCS000048
Dear Mr. Newlin:
On October 26, 2017, the City of Greensboro Stormwater Management Division completed an
industrial compliance inspection of Chemol Company, Inc. Local regulations pen -nit an
inspection of industrial facilities under authority granted by City of Greensboro Code of
Ordinance Chapter 30, Article 12, Section 7.1 (C-5). This inspection consisted of two parts: a
review of the facility files/records and an on -site facility inspection.
The inspection was performed by Zack MacKenzie and Peter Schneider, and the following
deficiencies/observations were noted during the inspection.
Stormwater Pollution Prevention PlawSpill Plan Review
Site Maps and SWP3
• No deficiencies noted.
Spill'Prevention and Response Plan
• During the inspection, City inspectors noticed an area of soil disturbance (with
recently added straw) adjacent to the secondary containment wall located on the south
side of the property. It is in the best interest of Chemol to document any spills or
discharges in the facility's SWP3 based on NPDES permit conditions.
Monitoring
• Based on the most recent analytical monitoring data (10/23/2017), the COD value for
Outfall.41 (146 mg/L) and the Total Phosphorous value for Outfall 42 (2.38 mg/L)
PO BOX 1170 • GREENSBORO NC 27402-1170 • WWW.GREENSSORO-NC.GOV • 336-373-CITY (2489)

exceeded the permit benchmark values. Please refer to the permit for actions needed
when excecdances occur.
Employee Training
• No deficiencies noted.
Site Inspection
Preventative Maintenance{Good Housekeeping
• As discussed during this inspection, and also observed by NCDENR on April 26,
2016, product has been tracked out of the secondary containment near the railcar
loading/unloading and is exposed to precipitation.
• It is in Chemol's best interest to address these areas and document any best
management practices in the SWP3.
Non-Stormwater Discharges
• No deficiencies observed.
It is recommended that Chemol Company, Inc. take appropriate actions to correct the noted
deficiencies. If you have any questions concerning this inspection, please contact me at (336)
373-2692 or [e-mail].
Sincerely,
Zack MacKenzie, Water Quality Specialist
City of Greensboro, Water Resources Department
cc: Peter Schneider, Water Quality Supervisor
Glen White, N.C. Dept. of Environmental Quality
Industrial Inspection File
PO BOX 1170 • GREENSBORO NC 27402-1170 • WWW.GREENS BORO-NC.GOV • 336-373-CITY 12489i
W R :J1M1S

White, Glen
From: MacKenzie, Zachary <[e-mail]>
Sent: Friday, December 22, 2017 2:16 PM
To: White, Glen
Subject: RE: [External] Chemol - NCS000048
Attachments: Chemol Inspection Letter 12-14-17.pdf; P1260218.JPG; P1260222.JPG; P1260224.JPG;
P1260234.JPG
CAUTION: External email. Do not click links or open attachments unless verified. Send ail suspicious email as an attachment to
[e-mail].
Glen,
Peter Schneider and I inspected Chemol on October 26"'. They had just taken their analytical samples so I waited to
send their letter until I could see the results from the samples. COD for Outfall #1 and Total Phosphorous for Outfall #2
exceeded the permit benchmark values.
They did have some stormwater issues, one of those being the product tracked out of the secondary containment near
the railcars, which you noted in your inspection. They have made some efforts to clean their site and have created an
incentive program for employees to keep their areas clean. We also noted an area that appeared to have soil removed
and covered with straw near a secondary containment wall on the south side of the property, although there were no
recent spills noted in the SWP3.
See attached photos.
Thanks,
Zack MacKenzie, Water Quality Specialist
Department of Water Resources
City of Greensboro
Ph: 336-373-2692; Fax:[phone]
PO Box 3136, Greensboro, NC 27402-3136
www.-greensboro-nc.gov
From: White, Glen [mailto:[e-mail]]
Sent: Friday, October 13, 2017 8:43 AM
To: MacKenzie, Zachary <[e-mail]>
Subject: RE: [External] Chemol - NCS000048
Zack
I did an inspection with Mr. Newlin as part of permit requirements before their new Individual Permit could be
written. Others from NCDEQ's Stormwater Permitting Unit were in attendance and were a part of that inspection. This
facility did have issues that I believe needed to be addressed.
A copy of my report is attached. I would go ahead and do a new inspection to see if you fin&issues that still need to be
corrected.
Glen White
Environmental Specialist

• NCDENR Winston-Salem Regional Office
Division of Energy, Minerals & Land Resources
450 Hanes Mill Rd — Suite 300
Winston-Salem, NC 27105
glen, white(a ncdenr.gov
[phone]
From: MacKenzie, Zachary [mailto:Zachary.MacKenzie @greensboro-nc.gov]
Sent: Thursday, October 12, 2017 9:16 AM
To: White, Glen <[e-mail]>
Subject: [Externall Chemol - NCS000048
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you verify that the
attachment and content are safe. Send all suspicious email as an attachment to [e-mail].
Glen,
I recently called William Newlin at Chemol to schedule a city inspection. He told me that people from the state had
been there in April. I was wondering if you had any information about that visit.
Thanks,
Zack MacKenzie, Water Quality Specialist
Department of Water Resources
City of Greensboro
Ph: 336-373-2692; Fax:[phone]
PO Box 3136, Greensboro, NC 27402-3136
www.areensboro-nc.gov
Please note that email sent to and from this address is subject
to the North Carolina Public Records Law and may be disclosed to third parties.

PAT McCRORY
Governor
DONALD R_ . VAN'DER VAART
Secretary
April 26, 2016
William Newlin
Chemol Co., Inc.
P.O. Box 16286
Greensboro, NC 27416 .
Subject: Compliance Evaluation Inspection
Individual Permit No. NCS 000048
Chemol Co., Inc.
Guilford County
Dear Mr. Newlin:
On April 26, 2016 Glen White & Sue White of the Winston-Salem office, Rick Riddle & Julie
Ventaloro of the Stormwater Permitting Unit in Raleigh and Mike Lawyer of the Fayetteville
office of the North Carolina Department of Environmental Quality; Department of Minerals and
Land Resources met with you at the Chemol facility located at 2300 Randolph Avenue in
Greensboro, to conduct a compliance inspection as one of the requirements of your Individual
Industrial Stormwater Permit renewal process. Inspection consist of review of the Stormwater
Pollution Prevention Plan, training and monitoring records and observation of the general
condition of the site and outfalls. Your assistance with the inspection was greatly appreciated.
Permit:
This facility holds individual Stormwater Permit NCS000048 to discharge stormwater from
industrial activity associated with the rendering of animal fat under the National Pollutant
Discharge Elimination System (NPDES). The permit became effective May 21, 2007 and
expired on May 20, 2012. The facility applied for renewal prior to expiration as required and has
been operating under the existing guidelines while waiting for new permit coverage. A copy of
the permit is required to be maintained with the Stormwater Pollution Prevention Plan (SPPP)
documents. It was available for review.
Records/Reports:
This facility was required to develop and maintain a Stormwater Pollution Prevention Plan
(SPPP) in accordance with Part II, Section A of the permit. The SPPP along with monitoring
and training records needs to be updated annually. Qualitative and Analytical Monitoring has
been performed bi-annually as required but has only been conducted at Outfall 001. Outfall one
does not receive any stormwater from production areas. It only picks up a very small area of
roof, the driveway and the City street.
Nothing Compares--\,
State of North Carolina [ Environmental Quality
217 West Jones Street 1 1601 Mal[ Service Center I Raleigh, North Carolina 27699-1601
919.707 8600

Representative Outfall status at 001 is hereby removed. Monitoring must be performed where
there is the most potential for stormwater contamination by industrial processes and activities. A
sample collection site must be created at or near Outfall 002 and samples need to be collected at
that location on a bi-annual basis.
Stormwater and Spills Training must be conducted annually. Please conducting this training and
have each employee sign off with pen/ink signature each year. Keep all records in the SPPP.
The facility missed collecting samples during some of the sampling periods when adequate
rainfall occurred during normal business hours. Sampling kits need to be on site with a
designated_ person that can conduct sampling on those occasions. pH has tested outside
benchmark range on occasion. This could be due to the length of time between collection and
testing. pH can be tested onsite at the time of collection using a pH meter or test strips.
Facility Site Review:
This is a facility that renders animal fats for the manufacture of esters and amides of fatty acids.
Transesteri fi cations (mixing chemicals to react and form another compound) of esters. Chemol
is involved in refining, bleaching and hydrogenation of fats and oils (triglicerides) and
distillation of esters. It has blending, packaging and warehouse operations. Packaging includes
flaking, prilling, drumming and loading bulk containers. There is a laboratory that supports
manufacturing.
Effluent Receivinp, Waters:
Stormwater effluent from this facility drains to Mile Run Creek, class C, NSW of the Cape Rear
River Basin.
Self -Monitoring Program:
This facility has two (2) outfalls. Outfall 001 is located at the end of the driveway at the street
entrance. It receives little industrial exposure but has been the only outfall sampled. Outfall 002
is located at the rear of the facility and is exposed to the majority of exposure from industrial
processes. A collection point must be created at or near Outfall 002 and samples taken at that
location as the permit requires.
The current expired permit did not contain a Tiered Response for exceeding parameters on a
consecutive basis. New Individual and General Permits require a tiered response that will be
included when the new permit is finalized. Additional testing parameters may be required.
Improved housekeeping in the rear of the site is needed. Heavy oils, fat and grease coat the
asphalt and concrete drives, the metal staircase and handrails that lead to the railcar product
loading/unloading. The heavy oil/grease is a safety hazard for those working in the area and for
anyone needing to gain access to and through this location. Please develop improved
housekeeping procedures to improve.the condition of this area. Regular pressure washing the
asphalt, stairway and rails with a hot water solution is suggested.
Nothing Compares�,
State of North Carolina I Environmental Quality
217 West Jones Street 1 1601 Mail Service Center I Raleigh, North Carolina 27699-1601
419 707 8600

Environmental
Quality
April 26, 2016
William Newlin
Chemol Co., Inc.
P.O. Box 16286
Greensboro, NC 27416
Subject: Compliance Evaluation Inspection
Individual Permit No. NCS 000048
Chemol Co., Inc.
Guilford County
Dear Mr. Newlin:
PAT McCRORY
Governor
DONALD R. VAN DER VAART
Secretary
On April 26, 2016 Glen White & Sue White of the Winston-Salem office, Rick Riddle & Julie
Ventaloro of the Stormwater Permitting Unit in Raleigh and Mike Lawyer of the Fayetteville
office of the North Carolina Department of Environmental Quality; Department of Minerals and
Land Resources met with you at the Chemol facility located at 2300 Randolph Avenue in
Greensboro, to conduct a compliance inspection as one of the requirements of your Individual
Industrial Stormwater Permit renewal process. Inspection consist of review of the Stormwater
Pollution Prevention Plan, training and monitoring records and observation of the general
condition of the site and outfalls. Your assistance with the inspection was greatly appreciated.
This facility holds Individual Stormwater Permit NCS000048 to discharge stormwater from
industrial activity associated with the rendering of animal fat under the National Pollutant
Discharge Elimination System (NPDES). The permit became effective May 21, 2007 and
expired on May 20, 2012. The facility applied for renewal prior to expiration as required and has
been operating under the existing guidelines while waiting for new permit coverage. A copy of
the permit is required to be maintained with the Stormwater Pollution Prevention Plan (SPPP)
documents. It was available for review.
Records/Reports:
This facility was required to develop and maintain a Stormwater Pollution Prevention Plan
(SPPP) in accordance with Part II, Section A of the permit. The SPPP along with monitoring
and training records needs to be updated annually. Qualitative and'Analytical Monitoring has
been performed bi-annually as required but has only been conducted at Outfall 001. Outfall one
does not receive any stormwater from production areas. It only picks up a very small area of
roof, the driveway and the City street.
`-'Nothing Compares- %,
State of North Carolina I Environmental Quality
217 West Jones Street 1 1601 Mail Service Center I Raleigh. North Carolina 27699-1601
919,707 8600 '

This inspection was conducted as part of the renewal process for Individual Stormwater Permit
coverage at this facility. The remaining time expected to complete the permitting process will be
approximately 45 days which includes a 30 day Public Notice period and your opportunity to
review the draft permit before the final is issued. If you have questions or need additional
information, please contact Glen White at [phone].
Enclosures:
Inspection Report
Sincerely,
Matthew E. Gantt, P.E.
Regional Engineer
Land Quality Section
Winston-Salem Regional Office
cc: 1WR4TPile_Copy.�.
Division of Energy, Mineral and Land Resources (WSRO)
Nothing Comparesh,
State of North Carolina I Environmental Quality
217 West Jones Street 1 1601Mail Service Center I Raleigh, North Carolina 27699-1601
919 707 8600 '

This inspection was conducted as part of the renewal process for Individual Stormwater Permit
coverage at this facility. The remaining time expected to complete the permitting process will be
approximately 45 days which includes a 30 day Public Notice period and your opportunity to
review the draft permit before the final is issued. If you have questions or need additional
information, please contact Glen White at [phone].
Enclosures:
Inspection Report
Sincerely,
Matthew E. Gantt, P.E.
Regional Engineer
Land Quality Section
Winston-Salem Regional Office
cc: WSRO File Copy
Division of Energy, Mineral and Land Resources (WSRO)
Nothing Compares.`
State of North Carolina I Environmental Quality
217 West Jones Street 1 1601 Mail Service Center I Raleigh, North Carolina 27699-1601
90 7078600

Compliance Inspection Report
Permit: NCS000048 Effective: 05/21/07 Expiration: 05/20112 Owner; Chemol Co Inc
SOC: Effective: Expiration: Facility: Chemol Co Incorporated
County: Guilford 2300 Randolph Ave
Region: Winston-Salem
Greensboro NC 27402
Contact Person: Spencer Foster Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 04/26/2016 Entry Time: 10:OOAM
Primary Inspector: Glen White
Secondary Inspector(s):
Reason for Inspection: - Routine
Permit inspection Type: Stormwater Discharge, Individual
Facility Status: ® Compliant [] Not Compliant
Question Areas:
® Storm Water
(See attachment summary)
Certification:
Phone:
Exit Time: 12:OOPM
Phone: [phone]
Inspection Type: Compliance Evaluation
Page: 1

Permit: NCS000048 Owner - Facility; Chemol Co Inc
Inspection Date: 04/26/2016 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
(See Compliance Report)
Page: 2

f
Compliance Inspection Report
Permit: NCS000048 Effective: 05121 /07 Expiration: 05/20/12 Owner; Chemol Co Inc
SOC: Effective: Expiration: Facility: Chemol Co Incorporated
County: Guilford 2300 Randolph Ave
Region: Winston-Salem
` Greensboro NC 27402
Contact Person: Spencer Foster Title: Phone: [phone]
Direciions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 04/26/2016
Primary Inspector: Glen White
Secondary Inspector(s):
Entry Time: 10700AM
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: Compliant n Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Certification:
Phone:
Exit Time: 12:OOPM
Phone: [phone]
Inspection Type: Compliance Evaluation
Page: 1

Permit: NCS00004B Owner -Facility: Chemol Co Inc
Inspection Date: 0412fil2016 Inspection Type : compliance Evaluation
Reason for Visit: Routine
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? ® ❑ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ ® ❑
Comment: * Facility needs to have Sampling Kits onsite and available for staff to collect samples when an
adequate rainfall event occurs. Current collection practices by an outside party does not seem
to be adequate as samples are not taken when there is adequate rainfall and a sample could
have been grabbed. pH also has not been tested within time constraints. pH needs to be
anal ed with 15 minutes of sample collection for an accurate reading.
* Facility has two outfalls but is oniv monitoring at one outfall. One outfall is at the street/drive
Very little area, virtually no drainage from industrial use drains to this outfall but it is the outfall
used as representative. The other outfall is at the rear of site along the railroad.
* The stairway and rail leading to the tank farm area is covered with accumulated heavy
greaseloil and is a safety hazard. Stairs and rails need to be pressure washed to remove. -
grease. .
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? 9 ❑ ❑ ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ❑ ®Ell]
Comment:
Qualitative Monitorinq Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ❑ ❑ ❑
Comment:
Stormwater Pollution Prevention Plan
Yes No NA N
Does the site have a Stormwater Pollution Prevention Plan?
a ❑ ❑ ❑
# 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?
M ❑ ❑ ❑
Page: 3

Permit: NC5000048 Owner - Facility: Chemol Co Inc
Inspection Date: 0412612016 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan Yes No NA NE
# 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? ❑ ❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)? ❑ ❑ ❑ ❑
# Is the Plan reviewed and updated annually? ❑ ❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program? ❑ ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented? ❑ ❑ ❑ ❑
Comment: * Some secondary containment needs repairs.
*Add a revision sheet. Go through the SPPP annually noting any changes.__Sign off on_
revision/annual update.

Permit: NCS000048 owner - FaCility: Chemol Co Inc
Inspection Date: 0412612016 inspection Type : Compliance Evaluation Reason for Visit: Routine
Analytical Monitoring Yea No NA NE
Has the facility conducted its Analytical monitoring? ® ❑ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ i ❑
Comment: * Facili needs to have Sampling Kits onsite and available for staff to collect samples when an
adequate rainfall event occurs. Current_ collection practices by an outside party does not seem
to be adequate as samples are not taken when there is adequate rainfall and a sample could
have been grabbed. pH also has not been tested within time constraints. PH needs to be
analyzed with 15 minutes of sample collection for an accurate reading.
* Facility has two outfalls but is onlv monitorina at one outfall. One outfall is at the street/drive.
Very little area, virtually no drainage from industrial use drains to this outfall but it is the outfall
used as representative. The other outfall is at the rear of site along the railroad.
* The stairway and rail leading to the tank farm area is covered with accumulated heavy_
grease/oil and is a safetv hazard. Stairs and rails need to be pressure washed to remove
grease, .
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? E ❑ ❑ ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ❑ E ❑ ❑
Comment:
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? E ❑ ❑ ❑
Comment:
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 13MP summary?
® ❑ ❑ ❑
Page: 3

r
Ad City of Greensboro
� ,d North Carolina
November 5, 2013
Chemol Company, Inc.
Attn: Mr. William Newlin, Purchasing Manager
P.O. Box 16286
Greensboro, NC 27416
RE: Industrial Compliance Inspection
Inspection location: Chemol Company, Inc.
2300 Randolph Avenue, GSO-NC
SW Permit 4: NCS000048
Dear Mr. Newlin:
On October 9, 2013 the City of Greensboro Stormwater Management Division completed an
industrial compliance inspection of Chemol Company, Inc.. Local regulations permit an
inspection of industrial facilities under authority granted by City of Greensboro Code of
Ordinance Chapter 30, Article 12, Section 7.1 (C-5). This inspection consisted of two parts: ;
review of the facility files/records and an on -site facility inspection.
The inspection was performed by Peter Schneider, and the following deficiencies/observations
were noted during the inspection.
Stormwater Pollution Prevention Plan/Spill Plan Review
Site Maps and SWP3
♦ Update Chemol's SWP3, it is recommended to follow guidance material that was sent
on 10/15/13 to assist with this process (i.e. EPA's SWP3 Template & NC DENR's
Document).
Spill Prevention and Response Plan
♦ No deficiencies observed.
Monitoring
♦ No current Qualitative Monitoring Outfall Reports were present in Chemol's SWP3,
using State form SWU-242 (enclosed) evaluate stormwater outfalls per permit
conditions.
P.U. Box 3136 • Greensboro, NC 27402-3136 . www.greeensboro-nc.gov_.-(336).373-CI-T-Y-(2489)-•-TTY #-333=6930

Employee Training
♦ No deficiencies observed.
Site Inspection
Preventative Maintenance/Good Housekeeping
♦ Periodic inspections of secondary containment systems at
railroad spur line where product is off loaded from rail cars and perform
maintenance when needed..
Non-Stormwater Discharges
♦ A non-stormwater substance was observed at an old valve that passes through the
secondary containment wall on the south side of the property (photo enclosed). Please
investigate and correct the issue to prevent further discharges.
It is recommended that Chemol Company, Inc. take appropriate actions to correct the noted
deficiencies. If you have any questions concerning this inspection, please contact me at 336-373-
2737 or'[e-mail].
Si erely,
Pcter Schneider, :Water Qua i y Supervisor
City of Greensboro, Water Resources Department
Enclosure: State Form S WU-242
Photos from Inspection
cc: Aana Taylor -Smith, N.C. Dept. of Environment and Natural Resources
Frank Skee, Utilities Pre -Treatment Coordinator
Industrial Inspection File
P.O. Box 3136 � Greensboro, NC 27402-3136 , www.greensboro-ne.gov (336) 373-CITY (2489) , TTY # 333-6930

old drain that is leaking non-stormwater product outside of the secondary containment area.

Compliance Inspection Report
Permit: NCS000048 Effective: 05/21/07 Expiration: 05/20/12 Owner: Chemol Co Inc
SOC: Effective: Expiration: Facility: Chemol Co Incorporated
County: Guilford 2300 Randolph Ave
Region: Winston-Salem
Greensboro NC 27402
Contact Person: Spencer Foster Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 10/09/2013 EntryTime: 10:00 AM Exit Time: 11:00 AM
Primary Inspector: Aana Taylor -Smith Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: n Compliant ■ Not Compliant
Question Areas:
0 Storm Water
(See attachment summary)
Inspection Type: Compliance Evaluation
Page: 1

Permit: NGS000048 Owner -Facility: Chemol Co Inc
Inspection Date: 1010912013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Please refer to City of Greensboro inspection letter.
Page: 2

Permit: NGS000048 Owner -Facility: Chemol Co Inc
Inspection Date: 10/09/2013 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?
■
❑
Cl
❑
# Has the facility evaluated feasible alternatives to current practices?
■
❑
❑
❑
# Does the facility provide all necessary secondary containment?
■
❑
n
n
# 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?
O
❑
❑
❑
# Does the Plan include a list of Responsible Party(s)?
■
❑
0
❑
# Is the Plan reviewed and updated annually?
❑
■
❑
❑
# Does the Plan include a Stormwater Facility Inspection Program?
■
❑
n
❑
Has the Stormwater Pollution Prevention Plan been implemented?
❑
■
❑
❑
Comment: Please refer to City of Greensboro inspection letter.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ❑ ■ ❑ ❑
Comment: Please refer to City of Greensboro inspection letter.
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? ■ ❑ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ ■ ❑
Comment:
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site?
■
❑
Cl ❑
# Were all outfalls observed during the inspection?
■
❑
Cl ❑
# If the facility has representative outfall status, is it properly documented by the Division?
❑
❑
■ ❑
# Has the facility evaluated all illicit (non Stormwater) discharges?
❑
■
❑ ❑
Comment: Please refer to City of Greensboro inspection letter.
Page: 3

SITE ASSESSMENT INSPECTION
Date: May 6, 2013
Chemol
During this inspection the following areas were observed:
1. Loading and Unloading Areas
2. Parking area and walkways
3. Above Ground Storage Areas
4. Wooden Pallet Storage Area
Comments:
5. Site Drainage
6. Process Areas
7. Drum Storage Area
8. Warehouse
1. Loading and Unloading Dumpster and dock area near street in good condition.
2. ParkinQ area and walkways: Clear
3. Above Ground Storage Areas: Tanks & secondary containment intact. All dike areas are
in good condition.
4. Wooden Pallet Storage Area: Clear.
5. Site Drainage: Good.
6. Process Areas: All exposed piping observed as intact and not Ieaking. Process materials
contained within plant sump drainage area.
7. Drum Storage Area: Area was observed to be clean and in good condition. No pollution
observed in this area.
8. Warehouse: Clear.

SITE ASSESSMENT CHECKLIST
Chemol
Completed by: Chasity Hart
Date: May 6, 2013
YES NO
❑
®
Corroded drums or drums without plugs or covers?
❑
®
Staining of soil or pavement from materials?
❑
®
Torn bags or bags exposed to rainwater?
❑
®
Corroded or leaking pipes?
❑
®
Soil erosion associated with the stormwater systems?
❑
®
Leaking pumps and/or hose connections?
❑
®
Windblown dry chemicals?
®
❑
Are outside and exposed areas kept in a neat and orderly condition?
®
❑
Is garbage removed regularly?
®
❑
Are walkways and passageways easily accessible, safe and free of protruding
objects, materials or equipment?
❑
®
Is there evidence of dust on the ground outside from operations or processes?
❑
❑
If yes, is the dust noted above in area(s) where it will be washed into a storm
water outfall?
Comments:
Small amounts of residue noted at rail area. See attached report for details. Facility is in good
condition overall.

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
CERTIFIED MAIL NO. 7004-1160-0002-2623-7535
RETURN RECEIPT REQUESTED
Mr. Mark Heimberger, Development Manager
Chemol Company, Inc.
PO Box 16286
Greensboro, NC 27416
SUBJECT: NOTICE OF DEFICIENCY
Chemol Company, Inc.
NPDES Permit No. NCS000048
Guilford County
Mr.. Heimberger:
Dee Freeman
18 January 2005 Secretary
On Thursday, January 13, 2005, Corey Basinger with the Division of Water Quality visited the subject facility
located off Randolph Avenue in Greensboro, NC. Ray Boettcher, William Newlin and Peter Sneider (Greensboro
.Stormwater Department) were also present during the inspection. The purpose of this inspection was to determine
whether or not the subject facility was in compliance with NPDES Stormwater Permit No. NCS000048. During this
site visit, the following deficiencies were documented.
1) The dyke wall protecting the acid tanks had significant cracking on both of the outside comers. The dyke
structure must be repaired immediately to prevent the release of any materials that might accumulate
inside the structure. The repairs niust be completer/ no Inter than February 11, 2005. You are
required to notify this Office when the repairs are completed:
2) The alarm system was not operating properly at the time of inspection. The visual and audible alarms did
function, but not in response to high levels in the tanks. The alarms must be repaired immediately. It is
highly recommended that the alarms have a manual "test" feature so that they can be tested on a routine
basis. The alarins must be properly operational no later than February 11, 2005. You are required to
notify this Office when the alarins are properly operational.
3) The Rail Line sump pump system was not operating properly. The containment structure was full and
beginning to overflow at the time of inspection. It was reset and began pumping the wastewater back up
to the plant site. The wastewater is actually pumped out onto the paved area at the truck
loading/unloading area and drains into the dyke structure, which empties into the wastewater collection
system. This process should be modified such that the wastewater is pumped directly into the wastewater
collection system or piped away from the truck loading/unloading area in order to prevent the truck tires
from carrying any wastewater out of the dyke area. The sump punip system must be repairedluzodified
no later than February 18, 2005.
4) All drums located at the facility must be properly labeled. The drums must also the segregated based on
their contents. If available, a Material Safety Data Sheet (MSDS) must be kept on file at the facility and
made readily available to staff and/or emergency personnel. The drums located in the fenced area
marked "flammable" should be arranged such that the drums placed on pallets are more toward the center
of the containment area to prevent spillage outside the dyke as result of a puncture/rupture. All drunis
must be labeled, segregated, and have the appropriate MSDS no later than February 25, 2005.
Nor!h Carolina Division of'Na ter Qoalit , Winston-Salem Regional Office
Location. 585 W2ughl0tivn St. Winston-Salem, North Carolina 27107 E}ttc
Phone: [phone]F.X:336-771-45301CustomerService: 1-877-623-6748 NOIrthCarohlZc`1
Internet: w nw,ncv.-aterquality.o;g
An Equal Oppo:mnitr 1 Rt`,nrtatire Rcfc:� EmDloyer
l�1 atur ally

a
5) The source of all pipes that discharge outside the dyke structure must be determined and properly labeled
(ie: roof drain). If no source can be determined, the pipe must be permanently capped. Also, the old
sanitary line and clean out pipe must be permanently capped to prevent accidental discharge to the
sanitary sewer. This must be completed no later than February 25, 2005.
6) Once the permit is reissued, the Stormwater Pollution Prevention Plan documentation should be updated
to reflect any changes or modifications.
7) It is recommended that all exposed piping at the facility be color coded or labeled such that it is clear
what materials are flowing through each pipe and which direction the materials are flowing in the pipe.
8) It is recommended that all drains at the facility be cleaned out to allow for maximum flow. The material
removed from the drains must be disposed of properly.
This Office will schedule a follow-up inspection in early March 2005 to ensure that the required corrected actions
are completed. Should you have questions or comments regarding this correspondence, please contact Corey
Basinger at [phone] x-288.
Sincerely,
Steve W. Tedder
Water Quality Supervisor
Cc: Mr. Rav Boettcher
Mr. William Newlin
Peter Sneider, Guilford County Stormwater Dept.
Central Files
WSRO

r
CITY OF GREENSBORO INDUSTRIAL USER INSPECTION FORM
Name of Industry: Chemol Company SIU Permit # P049
Address of Industry:
Telephone #
Email Address:
2300 Randolph Avenue
Greensboro, NC 27406
Industry Representatives:
Lynn Rose
Mark Heimberger
Ray Boettcher
Dave Grillo
Johnathan Kline
POTW Representatives:
Sharon H. Miller
Corey Basinger
Roy Graham
[phone]
mark(a7chemol.com
IUP Expiration Date 8/31/2008
Fax # [phone]
Title
President
Plant, Environmental & Safety Manager
Regulatory and ISO Coord., Seydel Companies
Title
Pretreatment Coordinator
Winston-Salem Regional Office
Water Quality Specialist - GSO
Date of This Inspection:
5I1112005 Time: 1:00 0opm
Date of Last Inspection:
6/30/2004
Purpose of Inspection:
Annual Other(describe):
Designated POTW:
T. Z. Osborne Wastewater Reclamation Facility
Is IU currently in SNC?
No Any violations since last inspection?
If yes? What?
Nature of Business Performed
Manufacture of esters and amides of fatty acids. Transesterifications ( mixing chemicals to react together to
form another compound) of esters. Refining, bleaching and hydrogenations of fats and oils (trigycerides) and
distillation of esters. Chemol also has a blending, packaging and warehouse operation. The packaging
operation includes flaking, prilling (injecting molten fluid in top of a reactor and inject air in the bottom, when two
come together fluid in cooled and solidifies), drumming and loading bulk containers. There are also laboratory
operations that support manufacturing and R&D activities.
NAICS or SIC Code 2899
Regulated Parameters
Chemol is cover under 40 CFR Part 414- Organic Chemical, Plastic and Synthetic Fibers (OCPSF). Federal
requlated parameters are pH, lead, zinc, cyanide, 45 Priority Pollutants and flow.
PART I - INITIAL INTERVIEW
Has anything changed since the last inspection or IUP application in the following?
Comments
Product
Yes
No
Raw Materials Used
Yes
No
Manufacturing Processes
Yes
No
Categorical, if applicable
Yes
No
Production Rate
Yes
No
Number of employees
Yes
No ,
Number of shifts
Yes
No
3-8 hour shifts Mon -Fri. III 2:01 am -12:00
some 5aturoays se

Other issues discussed during initial interview:
This inspection was taped due to the number of participates attending.
The major focus during this inspection were the problems that have been occurring at Chemol and what can be
done to reduce or eliminate these problems. Chemol has had several visits from the environmental community
trying to assist them in correcting the problems they have been having. Even after the visits there are still new,
reoccurring issues and citizen complaints. Every environmental contact has been addressing almost the same
issues.
The following items were discussed during the initial interview:
1) Letter from Corey Basinger to Mark Heimberger, January 18, 2005.
FLAMMABLE STORAGE AREA
a) Drums stored on wooden pallets
b) Accidental Spill or Drum Rapture -What would happen if one or more of the drums should rapture. How would
this area be contained? Mr. Heimberger stated that any drums that might rapture could be contained in the
containment area and the cleanup would be performed by Shamrock or Chemol. There was some discuss as to
whether the containment area was sufficient enough to hold a spill of all of the drums. Mr. Rose wanted to know
the requirements for a containment area that only contained drums. Mr. Basinger was not sure and said he
would provide the information to Chemol concerning secondary containment for drums.
c) Spill Kits - There are no spill kits in this area. There are 1-2 drums of hazardous waste from the lab and the
lab employees have specific training on handling that waste according to Mark.
PIPING FROM BUILDING
a) Labeling of piping to determine what was roof water and what was process. Mark stated that any piping that
extend beyond the containment area of the main plant have been labeled. Most of this piping is from roof drains
except for the pipe that goes to the discharge point to the sanitary sewer.
HIGH LEVEL ALARMS FOR THE PROCESS TANKS
Chemol has had a few incidents when the level alarms on their tanks were not operating causing overflows from
the tanks to the sanitary sewer and outside of the containment area. New alarms have been installed on the
process tanks. Jonathan Cline explained how and when the alarms are tested. Mr. Cline performs monthly
checks of the alarms by changing the programs to whatever level you have in the tank. The alarms are set for
28,500 gallons.
RAIL_ LINE SUMP
This sump was not operating properly. Changed out the pump and put in an automatic pump.
2) E-mail dated February 1, 2005 to Mark Heimberger and Ray Boettcher - NO RESPONSE
a) Wastewater System - Review Audit Log Sheet
I was informed that this sheet had been modified. I had asked in my e-mail for some changes to be made to the
sheet, but I did not get any response. The changes were specific to the calibration of the pH probes. The sheet
only notes that the probes will be checked to see if it is operating and not calibrated. Mark stated that the
neutralization of the tanks is made based on what the pH probes read in the tanks, but the dropping of the S-24
is made based on the pH from the lab. The lab pH probed in calibrated daily. The S-24 probe is calibrated and
if not within .2 of lab probe is changed out.
Verification was requested as to whether the hourly checks of S-24 were being performed. Mark said they were
suppose to be performed. This would be would be checked during the plant tour with Greg Long, Plant
Supervisor.
HOUSEKEEPING
Last time out discharge was flowing out in the back truck loading/unloading area.

SLUG DISCHARGE
Martie Groome came out because some of Chemol's product had been released and was noticeable at the
Osborne Plant. The Wastewater System - Review Audit Log Sheet [January 26, 2005] state that hourly checks
are to be performed to record the levels of tank S-24. If these readings were being taken, how could the drop of
the tank have occurred? According to Mark he went back and reviewed Chemol's records and Chemol only
dropped one batch during the timeframe of the grease slug to Osborne. Mark now starts that the sample Martie
brought over does not look A -typical of Chemol's discharge [8,000-10,000 gallons/ drop].
RETENTION TIME -TANK SPLITTING
Chemol was to have a plan of action submitted to the City of Greensboro that would get the temperature of their
discharge below 25 degrees or have a means of allowing for better splitting in their process tanks by January
2005. Reid Engineering, Inc. had submitted a proposal [December 2004] to Chemol, Mr. Rose said the cost of
$825,000 was too high and Chemol could not afford what was proposed. Chemol is currently considering other
options. Chemol has some other tanks onsite that may be put in service as holding tanks. The big Veg tank is
being considered, but Ray Boettcher needs to took at diking and requirements. Chemol will be putting in a
system that increases dwelling time. They will not be installing a cooling system for tanks but air cooling.
Chemol will not release until discharge reaches a certain temperature. Mr. Rose believes they will have the
capacity to hold a weeks worth of stuff.
Mark felt Chemol was not discharging grease, but the splitted material was just soap.
Chemol does not have set detention time to get a good split of material before the wastewater goes to S-24. I
am concern about the solidification of grease down the line. I will check with our people to see if we have had
any sewer problems downstream of Chemol. Chemol is required to check samples for two week period. They
allow these samples to cool to see what the split is at 25 degrees.
Chemol's split is based on a visual. If the temperature is hot the separation may look better than it is.
RAINWATER IN DISCHARGE
Chemol's discharge it affected my rainwater getting into the diked area. Mark states that there has never been
an correlation made between the rainwater and Chemol's discharge. Mr. Rose asked that Chemol study this
issue. Jonathan is to track this trend for the next month should there be sufficient rain. Rainwater is coming
from few down spouts that should be discharging outside the containment area, open loading area and part was
coming from CBP parking lot. The CBP rainwater issue has been resolved by extending the wall of Chemols
containment area.
SULFURIC ACID DIKE
Upon arriving at the site, I rode around the parameter and noticed one of the containment area was leaking
water that was flowing down on the CBP lot to the drain at the street. According to Mark, this area was being
cleaned for preparation to re -coat. Mark states that sometime during the pouring of concrete and clean-up
performed by Shamrock the valve was damaged. However, Chemol did not become aware of this issue until the
clean of the containment area began. The valve should be repaired by weeks end.
PART II - PLANT TOUR (Visit all areas where wastewater is generated or where there are drains to the POTW.)
1. Are there floor drains in the process areas? If yes, list areas
Yes, Packaging, process plant. These area go through pretreatment. Shop drain goes directly to sanitary.
2. Are process areas constructed in such a way to prevent harm to the POTW (spills/slugs)?
Yes X No Diked X Containment Other
3. Are there floor drains in the finish product storage areas?
Yes X No Diked Containment Other
3

4. Are storage tanks labeled?
Are process tanks labeled?
Is piping in process areas labeled?
5. Are there drains in the chemical storage areas?
_X_ Yes —No
_X Yes —No
Yes X_ No except sulfuric
and caustic
Yes, all sumps in these areas pump back to plant
6. Has there been any changes in chemicals used/disposed of via sanitary sewer since last
inspection? If yes what are these changes.
7. How are off -spec raw materials disposed of? Not applicable almost always use anyway
How are off -spec products disposed of? Sold as a by-product stream or burned in boiler
(not much normally recovered and fixed)
8. When is the production area cleaned? weekly
What chemicals, if any, are used in this cleaning process? TSP occasionally
(used to cut grease)
9. What other areas are cleaned (equipment, etc.) Boil outs
What chemicals, if any, are used in this cleaning process? TSP and water
10. Is the wastewater from cleaning the process areas discharged to the POTW? Yes via pretreatment
+PiuL'�I �.>t��1�_liril�P1:3
A. #2 Process Area Construction
Even through the process area is contained, the process tanks have in the past overflowed and escaped the
containment wall. The final process tank has also been discharged to the City without proper treatment.
B. #5 Flammable Storage Area
-Side gate to flammable storage area open upon inspection. (chained and locked prior to departure)
-Front gate to flammable storage area had no lock
-Some barrels in flammable storage area not properly labeled.
-Some barrels in flammable storage area stacked too high on pallets. If barrels are to be stored on pallets,
they must be moved away from the edge of the containment structure to prevent spillage outside the
containment area.
-Flammables stored adjacent to electric motor.
Mr. Rose stated that he thought all this material could be disposed of by the end of the month per Mr. Rose.
C. Chemol is planning to move from drums to bulk
D. The appearance of the plant was better than I had seem it in a long long time. There was little to no grease
on the floor, the wastewater discharge was not flowing outside into the parking lot. Someone has done a lot of
work. The goal is to keep it as clean or better in the future.
E. The high level alarms were tested manually. It took awhile to get this going, but it did go off. There is no
alarm on 5-24 the wastewater discharge tank.
F. Pipes that discharge outside the diked areas were labeled (roof drain, wastewater, etc.)
G. Rail line sump pump had been repaired (observed). The tanks in the containment at the rail car area
need to be re -labeled.
H. Barrels had been removed from the trailer area (requested by Mr. Basinger in letter).
I. Additional (presumed empty) barrels stored at rear of facility. These should be labeled or disposed of.
4

G. Rail line sump pump had been repaired (observed). The tanks in the containment at the rail car area
need to be re -labeled.
H. Barrels had been removed from the trailer area (requested by Mr. Basinger in letter).
I. Additional (presumed empty) barrels stored at rear of facility. These should be labeled or disposed of.
J. Sulfuric acid tank dike structure was being cleaned prior to applying sealant/coating for prevent leaks. Mark
could not verify that the flow getting in the drain was actually going to the storm or sanitary sewer since he did
not confirm that the direction of the valve that allows the flow to go to the sanitary or sewer was open. Any
wastewater discharge from the Chemol property could only leave the property via the appropriate
piping. There could be on runoff of wastewater from the facility.
K. Curb added in area draining toward warehouse. Plan is to add pump at drain to pump water to a tote and
then to properly dispose.
L. Stained area outside dike structure (from prior spills) is to be cleaned up after all repairs are made to
dike wall and piping.
M. The daily log sheets that were to contain the hourly readings were not available for each month. There
were hit and miss days that the readings were being taken. In the future these, log sheets are to be
submitted to the City of Greensboro on a monthly bases.
N. The process tank that overflowed in November because of the agitator speed has been locked out so that
the agitators can only run at 45-50%. The agitator will not run too slow or too fast.
O. Chemol was interested in knowing what size lien they discharged into, whether there had been an sewer
blockages downstream of their facility. I will obtain this information from construction and maintenance.
PART III- NON -PROCESS DISCHARGES
What non -process wastewater are discharged to the POTW?
X Domestic Other
POTW, if so is it? Place an X in space if applicable
ooling water that is recycled; only system bleed -off
P:3ooling
water is once through (not recycled); all system water that is not evaporated is
discharged to sewer
X Cooling system is for:
Air conditioning/humidification
X Machinery
X Product Formulation
Other (indicate)
If any Boiler Water is discharged to the POTW, if so is it?
Excess boiler feed water discharged directly to sewer
X Excess boiler feed water recycled to make-up tank
Make-up tank overflow is discharged to:
X Public sewer system
Storm sewer system
Other (indicate)
5

PART III- NON -PROCESS DISCHARGES - Cont.
Boiler blowdown is:
X Automatic
Manual operation
X Discharged to POTW
Discharged to storm
COMMENTS- NON -PROCESS DISCHARGES
None
PART IV - SAMPLING POINT(S) AND FLOW MEASUREMENT
1. How many hours per day does your plant discharge wastewater? 3-4
2. How many days per week does your plant discharge process wastewater? 5-7
3. Flow meter information: Brand: ISigma Model: 1950
Last calibrated: 211812005 By Whom:
(flow meters are to be calibrated every 6-months by an independent contractor and records are to be
maintained by the Industrial User of such)
4. Industrial User is obtaining flow readings from:
Incoming City Water Meter
X Effluent Flow Meter
Indicate type of flume/weir and angleldimensions
5. Flow Control Point: Fiume Type (shape) 10" Palmer Bowlus
Weir Type (shape)
6. Sampler type: Sigma
7. Sampling location (written)
OCPSF -grab sample at S-24 Tank, Compliance samples- Weir box on right side of Driveway downhill
from the tank farm.
8. Does the sampling location contain any domestic waste (bathrooms, showers, cafeteria)? No
If Yes, What is included?
9. Is sampling performed by industry or outside lab? If outside lab, name of lab. Industry
Name of NC Certified Lab
10. Are analyses performed by an outside lab or the industry?
Name of NC Certified Lab Research and Analytical, Kernersville, NC
11. If any analyses are performed by industry what are these and does the industry have NC
certification or other approval?
(If outside lab used, remember you are ultimately response for ensuring that samples are collected in
accordance with your permit requirements)
12. Totalizer type: Brand: Sigma Model: 1950
mechanical totalizer is non-resettable electronically (digital) totalizer is resettable

COMMENTS- SAMPLING POINT(S) AND FLOW MEASUREMENT
February 16, 2005 Mark e-mailed that loaner flowmeter was being installed? Chemol is still using this loaner flow
meter. Mark is not sure when theirs will be returned. The Chemol flow meter was last calibrated 10/25/04.
Chemol is performing field calibration of their sampler to ensure they are getting 1000 gallons per 1 pulse.
However, the jug is not always full when samples are taken. Please verify that the sampler is operating
correctly or make the necessary adjustments to the sampler to collect at a minimum a half a jug of
sample. If you only have 1 L of sample in the jug for a 24 hour composite and you have dropped 2 or more
batches a day, we are not getting a representative sample. The sampler set-up needs to be reset to account for
the changes in flow.
During last years inspection, Chemol stated that the sampler is set for 100mi/1,000 gallons of flow.
Which is correct?
PART V. PRETREATMENT SYSTEM
Pretreatment devices or processes - Place an X in space if still operational?
(Inspector should review permit and list below any devices or process. Verify status with operator)
X Grease Trap (acidification process in tank -splitting off water)
X Spill Protection
X pH Adjustment
1. Is operator(s) knowledgeable of system? "How long has he/she been operating the system?
Name of Operator Shift Leader Shift every shift "monthslyears
Name of Operator Shift `monthslyears
2. How often does operator or maintenance person check pretreatment devices or processes?
Daily
3. What is your Preventive Maintenance schedule for the pretreatment devices or processes?
The pH probe in the discharge tank is inspected and calibrated (see initial interview). The tank pH probe is
changed out when there is a discrepancy between the reading in the lab and the reading from the tank probe.
Chemol has a backup tank probe in stock. The pH meter in the lab that is used to make the determination as to
whether a discharge pH is in range.
4.
Sludge Disposal, if applicable
How? Hauled off -site
When? 1-2 year
With Whom? Langeloth Metallurgical Co., Langeloth, PA
COMMENTS- PRETREATMENT SYSTEM
Spent nickel catalyst (DOT haz-waste, EPA non-hazwaste)
Lab waste is disposed of with Southeastern Chemical Co., Sumter, SC. Approximately 4 drums are disposed
of per year Grease trap reprocessed back into system and sold as finished material or burned in boiler as per
Air Permit.
Solid waste (plant/office) goes to landfill other solid waste hauled off -site by Republic.

PART VI. FILE REVIEWISPILL NOTIFICATION
Filing System:
a. Were files accessible? Yes
b. Is correspondence from the POTW or IU filed in a manner that events can be followed
(date order, type of correspondence, etc.) Yes
c. Are files being maintained in the notebook provided by the City of Greensboro? Yes
d. Is permit information (correspondence, NOVs, SNC, COC, etc) being maintained
for a minimum of 3 years on -site? Not available
e. Does iU have current copy of permit? Yes
f. Are Chain -of -Custody forms filled out properly? Yes
g. is Spill/Slug Plan current, if required? Revise and submit in 30 days No
(This Plan must be reviewed every 2 years to determine if changes are needed per EPA)
h. Is sampling data and spill correspondence consistent with information submitted
to POTW? Yes
i. When and/or how are employees trainedlinformed of facility's spill/slug plan?
Annual training is performed not all personnel attend. Attendance is based on topic to be discussed. City of
Greensboro Soill Poster is also used to inform emplovees as to who to notify.
j. Should the City of Greensboro require of to shutdown your discharge to us, who would
have the authority to authorize a shutdown.
Mark Heimberger, any Shift Leader, Dave Grillo, and Greg Long
COMMENTS- FILE REVIEWISPILL NOTIFICATION
Was not able to observe that files were being maintained for three years. Please ensure in the future that you
have all the necessary paperwork available and filed in a manner that is easy to follow.
PART VII - INSPECTION SUMMARY AND FOLLOW-UP INFORMATION
There were a lot of issues that were discussed from previous inspections and from other environmental
agencies in attendance. Most of these issues have been resolved. There was remarkable improvement to the
overall appearance of the facility.
Copy of secondary containment requirements provided courtesy of Mr. Basinger.
NOTICE OF DEFICIENCY -The daily log sheets that are to contain the hourly readings for S-24 are not being
maintained. These log sheets are to be submitted monthly to the City of Greensboro Industrial Waste Section
by the 15th of the month for the previous month. This is to begin immediately. THIS SHALL SERVE AS YOUR
OFFICIAL NOTICE OF DEFICIENCY.
All items highlighted in red require a response/action.
Please be mindful that any items/changes requested during the inspection must be completed/provided. If
there is a problem with what has been required/requested of you, please don't just ignore the request. Either
call or write with us to let us know the status. Failure to respond, could be grounds for enforcement action to be
taken against Chemol per the City of Greensboro Enforcement Response Plan.
Inspection Report Prepared by:
City of Greensboro Industrial Waste Section
Inspector's Phone Number: 336-433-7227

Initial the appropriate box indicating that you have reviewed the following documentation
prior to the inspection
X Review of last year's inspection
X Reviewed schematic of facility
X Reviewed last permit application (Take copy along)
X Checked and noted date of last spill/slug plan _5115102_ (date)
X Reviewed most recent permit/modifications
X Reviewed facility's compliance history for past year
X Reviewed correspondence file
EQUIPMENT REQUIRED FOR INSPECTION INSPECTION TIME
X Safety shoes 2.0-2.5 hrs.
X Hard hat
X Safety Glasses
Protective clothing
Ear plugs

DIKE
CONC WALL
TANK FARM,
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STORAGE AREA
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DATE
JUNE 1999
LEGEND
— - - �- PROPERTY BOUNDARY
— - -- CONCRETE WALL
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AREA
OUTFALL DRAINAGE
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— -- — — — DRAINAGE BOUNDARY
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CHEMOL SPCC PLAN
GREENSBORO, NC
SITE MAP
60012
50' '0 10o. HSMM ENVIRONMENTAL DIVISION
i_�t - ROANOKE, VIRGINIA

State of North Carolin#
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
Kerr T. Stevens, Director
June 24, 1999
CHEMOL, COMPANY, INC.
ATTN: SPENCER FOSTER
P.O. BOX 16286
GREENSBORO, NORTH CAROLINA 27416-6286
Subject
Dear Mr. Foster:
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NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RE50URCE5
PEcEIVED,
N.C. €_:r:pt. of EHNR
J U N 2 9 1999
--,.-Salem
,
NPDES Permit Renewal AiRplication '`='f►C�
Permit Number NCS000048
Individual Stormwater Permit
Guilford County
The Division of Water Quality's Stormwater and General Permits Unit hereby acknowledges receipt of your renewal
application for coverage under NPDES Permit Number NCS000048 on 6/16/99. The submitted renewal package
contained the following items:
Signed application
Site map
Analytical monitoring results summary
Visual monitoring results summary
i Best Management Practices summary
Narrative describing significant changes at the permitted facility
Signed Stormwater Pollution Prevention Plan certification
Application Fee $715,00
A preliminary review of the submitted renewal application package has been conducted and it appears to be
complete. No further information is required at this time. The application fee of $715.00 cannot be processed with
the renewal application; therefore, it is being returned to you and will be requested under a separate cover. If you
have any questions about the renewal process or would like to discuss this letter, please contact me at (919) 733-
5083, extension 584.
c rely
Antonio V. Evans, P.E.
Environmental Engineer
cc: Winston Salem Regional Office
Stormwater and General Permits Unit
Central Files
SWLi-'38-032499
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone]_FAX-9.1.9-73379919
An -Equal -Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

A-
NCDENR •
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
PERMIT COVERAGE RWAL APPLICATION
National Pollutant DiscHWe Elimination System
Stormwater NPDES Permit NCS000048
Chemol Co., Inc.
Permit Number NCS000048
Guilford County
THIS APPLICATION MUST BE SIGNED AND RETURNED ALONG WITH THE REQUESTED
SUPPLEMENTAL INFORMATION TO THE DIVISION OF WATER QUALITY IN ORDER FOR YOUR
FACILITY TO QUALIFY FOR RENEWAL OF YOUR STORMWATER PERMIT NCS000048
PERMIT RENEWAL INFORMATION
The following is the information currently in our database for your facility_ Please review this information carefully
and make all corrections as necessary in the space provided to the right of the current information.
Facility Name: Chemol Co., Inc.
Mailing Address*: PO BOX 16286
GREENSBORO, NC 27416
Location Address:
GREENSBORO, NC 27406
Facility Contact: SPENCER FOSTER
Phone Number: -
Fax Number: Ne ffafftbe rii_
E-mail address: ' e a4d_e& -
* This is the address to which all permit correspondence will be mailed
CERTIFICATION
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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, complete and accurate. 4
SignatureDate <
i
'PC 14 ij r "14-x),*G r�i2
Print or type name of person signing above Title
Please return this completed renewal form, the information as requested on the next page, and any relevant
documentation to:
Individual Permit Renewal
Division of Water Quality/ WQ Section
Stormwater and General Permits Unit
Post Office Box 29535
Raleigh, North Carolina 27626-0535
Attn: Tony Evans
1 4 1999
UENR - WATER QUALITY
pptf�T 50URCE BRANCH

SUPPLEA'IENTAL 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
! 1. 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 struc[ures, drainage areas for each outfall, building
-locations and impervious surfaces should be clearly noted.
J 1`I 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 BVIP's is planned. please include information on these BiVLP's.
SS_ 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 (Sian 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)
Representative storm sampling may nox be conducted anytime during the year (the April to
November window has been eliminated) and the representative rainfall event is now
defined as a storm event that measures greater than 0.1 inches and is preceded by at least 72
hours in which no storm event measurinu greater than 0.1 inches has occurred.

CHEMOL CO., INC. - PERMIT NO. NCS000048
SUPPLEMENTAL INFORMATION
ITEM 5 THERE HAVE BEEN NO SIGNIFICANT CHNAGES IN THE ACTIVITIES AT THIS
FACILITY SINCE THE PERMIT WAS ORIGINALLY AUTHORIZED ON DECEMBER 19, 1996.
SPENCER FOSTER

STORMWATERPOLLUTION PREVENVION PLAN
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
N.C. Division of Water Quality, Stonnwater and General Permits Unit
Facility Name: CHEMOL CO., INC.
Permit Number: NCS000048
Location Address: 2300 RANDOLPH R4 SAD AM,
GREENSBORO, NC 27406
County: GUILFORD
"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"
" 1 certify that the SPPP has been developed, signed and retained at the facility location and the SPPP has been fully
implemented at the named facility location in accordance with the terms and conditions of the stormwater general
permit."
"I am aware that there are significant penalties for falsifying information, including the possibility of fines and
imprisonment for knowing violations" V
Sign (according to pernvt signatory requirements) and return this Certification. DO NOT SEND THE
STORNIWATER POLLUTION PREVENTION PLAN WITH THE CERTIFICATION.
:;
Stynature: �'s
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Print or type name of person signing above
Date //V1.9 J
-L4 �jT 011t0J.467ele-
Title
SPPP Certification 2199
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

0
CHEMOL CO., INC. - PERMIT NO. NCS000048
SUPPLEMENTAL INFORMATION
ITEM 3 VISUAL MONITORING RESULTS
STORMWATER DISCHARGE 7/21/97 12/24/97
CHARACTERISTICS
COLOR
CLEAR
NONE
ODOR
NONE
NONE
CLARITY
1
I
FLOATING SOLIDS
1
I
SUSPENDED SOLIDS
NO
NO
FOAM
NO
NO
OIL SHEEN
NO
NO
OTHER OBVIOUS INDICATORS
NONE
NONE
6I11199

Narrative Description of Best Management Practices Utilized at Chemol
Good Housekeeping
Standard Housekeeping
Employees are required to immediately cleanup any spills or leaks, and report the
incident to a supervisor. If specialized cleanup is required, Chemol immediately
contracts the services of Shamrock Environmental Corporation of Browns
Summit, NC to provide emergency remediation and response services. Enhanced
plant inspections are implemented, using experienced supervisory personnel to
perform quality control inspections. Inspections are performed twice per work
shift.
Wooden Pallets
Chemically stained pallets are washed before being moved outside. On a routine
basis (once per month) unused pallets are collected by a recycler, reducing the
number of pallets stored outside.
Tracking of Fat/Oils Driveway Entrance
Fat and oils tracked from material transfer points at the Main Plant by transport
vehicle wheels are washed down before leaving the transfer point. The entrance
driveway is routinely washed down to minimize any fat/oil buildup on the
driveway.
Rail Car Tankers Awaiting Unload or Transport ='
Chemol places drip pans beneath the valve connections of each rail car tanker
awaiting unload or transport. Each drip pan has a four -gallon capacity and is
visually inspected twice per work shift.
Preventative Maintenance
Chemol has an effective preventative maintenance program involving scheduled
maintenance and replacement on all equipment. All equipment, especially those
involving hose connections and valves, is routinely checked for signs of damage, fatigue
and wear on a weekly basis by the operators. In addition to these inspections, scheduled
monthly inspections and testing are performed by the maintenance staff.
Secondary Containment
Rail Car Containment
Chemol has an effective rail car tanker containment system for loading/unloading
rail car tankers. The containment system is designed to contain minor leaks and
spills which can be easily controlled by a sump pump. Chemol plans to upgrade
the containment to be able to handle a larger spill.
Main Plant Containment System
Chemol has implemented a secondary containment system within the Main Plant.
Routine maintenance activities consisting of visual inspections, systems testing
and replacement of defective equipment ensure that the secondary containment

0
•
and sanitary sewer wastewater pretreatment system remain in operation at all
times. Any spilled liquid would flow into the trench drains located throughout
the Main Plant and would be conveyed by gravity to the sewer lift station located
on the southeast side of the Main Plant. The pumps in the sewer lift station
convey the wastewater to tank S-31 which is used as an acidification
pretreatment tank to separate the oils and greases from the wastewater. The
separated, acidified wastewater is then pumped to Tank S-24 for neutralization.
When full, the contents of Tank S-24 are manually released to the City of
Greensboro's sanitary sewer system.
Tanker Truck Loading[Unloading Containment
The tanker truck loading/unloading area is within the drainage area of the main
plant's secondary containment. Any spill that would occur in this area will flow
into the wastewater pretreatment system.
Loading/Unloading Dock and Dumpster Containment at Front of Plant (East Side)
A trench drain is in place to catch any spills from the loading dock. Water in the
trench drain flows to the containment surrounding the waste dumpster. The
water collected in the containment area is then pumped into the wastewater
pretreatment system.
Tank Farm Containment
The Tank Farm Area has an adequately sized concrete secondary containment ,
system that will contain a spill from the release of the full contents of any single
tank in this area.
Alcohol Tank Farm
The tanks at the Alcohol Tanis Farm are constructed with secondary containment
of sufficient capacity to contain a spill from the release of the full contents of any
single tank in the Alcohol Tank Farm.
Vegetable Oil Tank (BV-1)
Neither the 92.000 gallon Vegetable Oil Tank nor the vegetable oil tank transfer
Pump, located adjacent to the Vegetable Oil Tank, are located in a localized
secondary containment structure. However, the area immediately surrounding
the Vegetable Oil Tank, which is located on a high point on the site, drains to a
secondary containment area that can hold approximately 107,000 gallons. The
secondary containment area is located approximately 100 feet from the tank.
Drum Storage Area
The Drum Storage Area has a concrete lined and bermed secondary containment
area that prevents a release to the environment from spills in this tank area. The
secondary containment area has 166 cubic feet of storage or approximately 1,240
gallons. This is equivalent to approximately twenty-two 55-gallon drums.
Chemol is planning to construct a cover to prevent precipitation from entering the
drum storage area.

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