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HomeMy WebLinkAboutNCS000255_Inspection Report_20190627ROY COOPER Governor MICHAEL S. REGAN Secretary S. DANIEL SMITH Director Grede II, LLC Attn: Christopher Kurtz, General Manager 530 East Main Street Biscoe, NC 27209 NORTH CAROLINA Environmental Quality July 1, 2019 Subject: COMPLIANCE EVALUATION INSPECTION NPDES Stormwater Permit NCS000255 Grede II, LLC Montgomery County Dear Mr. Kurtz: On June 27, 2019, a site inspection was conducted for the Grede II, LLC facility located at 530 East Main Street in Biscoe, Montgomery County, North Carolina. A copy of the Compliance Inspection Report is enclosed for your review. Ms. Alexandra Fertel, Sr. Environmental Health & Safety Representative, along with Mr. Bobby Woolwine, EHS Specialist, and Mr. Kirk Batsel, EHS Specialist with Willoughby & Associates, Inc. were also present during the inspection and their time and assistance is greatly appreciated. The site visit and file review revealed that the subject facility is covered by NPDES Stormwater Permit NCS000255. Permit coverage authorizes the discharge of stormwater from the facility to receiving waters designated as Lick Creek, a class WS-III stream in the Cape Fear River Basin. As a result of the inspection, the facility was found to be in compliance with the conditions of NPDES Stormwater Permit NCS000255. Please refer to the enclosed Compliance Inspection Report for additional comments and observations made during the inspection. Please be advised that violations of the NPDES Stormwater Permit are subject to a civil penalty assessment of up to $26,000 per day for each violation. If you or your staff have any questions, comments, or needs assistance with understanding any aspect of your permit, please contact me at (910) 433-3394 or by e-mail at mike.lawyer@ncdenr.gov. Sincerely, 4ichael Lawyer, CPSWQ Environmental Program Consultant Division of Energy, Mineral and Land Resources Enclosure ec: Alexandra Fertel, Sr. Environmental Health & Safety Representative — AAM/Grede II, LLC Bobby Woolwine, EHS Specialist — Willoughby & Associates, Inc. Kirk Batsel, EHS Specialist —Willoughby & Associates, Inc. cc: FRO — DEMLR, Stormwater Files V North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources E Q�/� Fayetteville Regional Office 1 225 Green Street, Suite 7141 Fayetteville, North Carolina 28301 NGN"N CAYiC'IINA oe MAMwEmmm [UNRY 910.433.3300 Compliance Inspection Report Permit: NCS000255 Effective: 10/01/17 Expiration: 09/30/22 Owner: Grede II LLC SOC: Effective: Expiration: Facility: Grede II LLC 530 E Main St County: Montgomery Region: Fayetteville Biscoe NC 27209 Contact Person: Alexandra Fertel Title: Sr. EH&S Representative Phone: 910-428-2111 Ext.3268 Directions to Facility: System Classifications: Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): On -site representative Bobby Woolwine 434-534-9834 On -site representative Kirk Batsel 434-534-9834 On -site representative Alexandra Fertel 910-428-2111 ext 326l Related Permits: Inspection Date: 06/27/2019 Entry Time: 09:55AM Primary Inspector: Mike Lawyer%j`�C..���----t 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) Exit Time: 01:45PM Phone: 910-433-3300 ExtT 339Y Inspection Type: Compliance Evaluation Page 1 of 3 Permit: NCS000255 Owner - Facility: Grede II LLC Inspection Date: 06/27/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine Inspection Summary: Inspection conducted to determine compliance with conditions of Individual Stormwater Permit NCS000255. Met with Ms. Alex Fertel, Sr EH&S Representative with AAM/Grede as well as Mr. Bobby Woolwine, EHS Specialist, and Kirk Batsel, EHS Specialist with Willoughby & Associates, Inc, which is the facility's consultant. Reviewed facility's Stormwater Pollution Prevention Plan (SWPPP) and monitoring records for 2018 through first half of 2019. Facility's SWPPP was last updated in November 2018 and contains all permit -required components and associated documentation. A recommendation was made to incorporate additional documentation into the SWPPP related to corrective actions taken to address any deficiencies noted by internal audits. Facility has been in Tier Two monthly monitoring for outfalls 1 and 3 since January 2019 due to consecutive exceedances of the benchmark values for TSS and Copper in May 20.18 and December 2018. Due to actions taken by the facility such as installing concrete barriers around their waste sand and waste slag piles and cleaning out their retention pond on a regular basis, monitoring results have indicated lower values. Outfall 3 has returned to the semi-annual monitoring schedule starting with the second half of 2019 as results for all parameters were below benchmarks in March, April and June 2019 (there was no discharge in May 2019). Outfall 1 is still being monitored monthly, however monitoring results were below all benchmarks in June 2019. Should the next two monitoring events for outfall 1 result in meeting all benchmarks, outfall 1 would return to the semi-annual monitoring schedule. Outfall 2 has remained in the semi-annual monitoring schedule. The option and process for requesting Representative Outfall Status was discussed. After the records review, site observations were made including the waste slag and waste sand pile areas, designated areas for other wastes and empty totes with applicable sigange as well as some of the internal storm drains and stormwater discharge outfalls. At the time of inspection, facility appeared to be well operated and maintained. Page 2 of 3 Permit: NCS000255 Owner - Facility: Grede II LLC Inspection Date: 06/27/2019 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? 0 ❑ ❑ ❑ # Does the Plan include a General Location (USGS) map? 0 ❑ ❑ ❑ # Does the Plan include a "Narrative Description of Practices"? M ❑ ❑ ❑ # Does the Plan include a detailed site map including outfall locations and drainage areas? 0 ❑ ❑ ❑ # Does the Plan include a list of significant spills occurring during the past 3 years? M ❑ ❑ ❑ # Has the facility evaluated feasible alternatives to current practices? 0 ❑ ❑ ❑ # Does the facility provide all necessary secondary containment? M ❑ ❑ ❑ # Does the Plan include a BMP summary? 0 ❑ ❑ ❑ # 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? M ❑ ❑ ❑ Comment Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? M ❑ ❑ ❑ Comment: Analytical Monitorinq Yes No NA NE Has the facility conducted its Analytical monitoring? 0 ❑ ❑ ❑ # 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? 0 ❑ ❑ ❑ # Were all outfalls observed during the inspection? 0 ❑ ❑ ❑ # If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ 0 ❑ # Has the facility evaluated all illicit (non stormwater) discharges? M ❑ ❑ ❑ Comment: Page 3 of 3