NCS000009_Compliance Inspection Report_20180523

Energy, Mineral
and Land Resources
ENVIRONMENTAL QUALITY
May 23, 2018
SGL Carbon Corporation
Attention: Rick Ives
307 Jamestown Road
Morganton, North Carolina 28655
Subject: Compliance Evaluation Inspection
Permit: NCS000009
Burke County, North Carolina
Dear Mr. Ives:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
WILLIAM E. VINSON, JR
Interim Director
Enclosed please find a copy of the Compliance Evaluation Inspection Report for the inspection I conducted at
the subject facility on May 8, 2018.
The report should be self-explanatory; however, should you have any questions concerning this report,
please do not hesitate to contact me at [phone] or by email at [e-mail].
Enclosure: Inspection Report
Sin ly,
Isaiah eed, CRPSCI
Environmental Specialist
Land Quality Section
State ofNorth Carolina I Environmental Quality I Energy, Mineral and Land Resonrces
2090 US 70 Highway I Swannanoa, NC 28778-8211
828 296 4500 T

Permit: NCS000009
SOC:
County: Burke
Region: Asheville
Contact Person: Rick Ives
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Compliance Inspection Report
Effective: 03/01/09 Expiration: 02/28/14 Owner: Sgl Carbon LLC
Effective: Expiration: Facility: SGL Carbon Corporation
307 Jamestown Rd
Inspection Date: 05/08/2018
Primary Inspector: Isaiah L Reed
Secondary Inspector(s):
Title:
Certification:
Morganton NC 28655
EntryTime: 10:OOAM Exit Time: 02:30PM
Linda S Wiggs
Bethany Georgoulias
Rick L Riddle
Reason for Inspection: Follow-up
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ❑ Compliant 0 Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Phone: [phone]
Phone:
Phone: [phone]
Phone :[phone] Ext.4653
Phone :[phone] Ext.529
Inspection Type: Compliance Evaluation
Page: 1

Permit: NCS000009 Owner - Facility: 991 Carbon LLC
Inspection Date: 05/0812018 Inspection Type : Compliance Evaluation Reason for Visit: Follow-up
Inspection Summary:
On May 8, 2018 this facility was inspected for compliance. Bethany Georgiolas, Rick Riddle, Linda Wiggs and myself were
present for DEQ. Jim Smith, EHS Manager and Lee Gjetley, Corp NA EHS Manager with SGL Carbon were also present.
During the inspection, the following items were noted.
1) The "Tar -Pitch" area discussed on site merits secondary containment. While the material stored in the container will
become a solid when reduced to outside temperature, it is stored in a liquid state. Also, with the presence of liquid material
in the trench drain, it is likely that liquid material can escape from this area. Secondary containment should be installed as
soon as possible.
2) The area where "used oil' containers are staged and pumped out on a regular basis shall meet the Secondary
Containment requirements in Section A-2, (b) of the Industrial Stormwater Permit.
3) Material from the industrial process on site was observed in the storm drains. These drains should be cleaned out
frequently and as soon as possible in order to meet the permit requirements for Preventative Maintenance and Good
Housekeeping.
4) Two additional stormwater outfalls were observed on site. In part VI of your Industrial Stormwater permit, the areas these
outfalls collect from are covered in number 28 'The discharge from any point source which is used for collecting and
conveying stormwater and which is directly related to manufacturing, processing or raw material storage areas at an
industrial site." These outfalls shall be added to the Analytical/Qualitative monitoring list immediately.
5) It is recommended that you verify the potential for stormwater runoff from the staging/laydown area at the far east
perimeter of the site.
6) Be advised that grab samples should be obtained withing 30 minutes of discharge if possible.
If you have any questions, please contact me at [phone].
Page: 2

Permit: NCS000009 Owner - Facility: Sgl Carbon LLC
Inspection Date: 05/0812018 Inspection Type : Compliance Evaluation
Stormwater Pollution Prevention Plan
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?
# 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: See Summary for further information.
Reason for Visit: Follow-up
Yes No NA NE
■❑❑❑
■❑❑❑
■❑❑❑
■❑❑❑
s❑❑❑
❑ ❑ ❑
❑ ❑ ❑
❑ ❑ ❑
®❑ ❑ ❑
❑ N ❑ ❑
Page: 3

Permit: NCS000009
SOC:
County: Burke
Region: Asheville
Contact Person: Rick Ives
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Compliance Inspection Report
Effective: 03/01/09 Expiration: 02/28/14 owner: Sgl Carbon LLC
Effective: Expiration: Facility: SGL Carbon Corporation
307 Jamestown Rd
Inspection Date: 05/08/2018
Primary Inspector: Isaiah L Reed
Secondary Inspector(s):
Title:
Entry Time: 10:OOAM
Linda S wiggs
Bethany Georgoulias
Rick L Riddle
Reason for Inspection: Follow-up
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Storm water
(See attachment summary)
Morganton NC 28655
Phone: [phone]
Certification: Phone:
Exit Time: 02:30PM
Phone: [phone]
Phone :[phone] Ext.4653
Phone :[phone] Ext.529
Inspection Type: Compliance Evaluation
Page: 1

Permit: NCS000009 Owner- Facility: Sgl Carbon LLC
Inspection Date: 05/08/2018 Inspection Type : Compliance Evaluation Reason for Visit: Follow-up
Inspection Summary:
On May 8, 2018 this facility was inspected for compliance. Bethany Georgiolas, Rick Riddle, Linda Wiggs and myself were
present for DEQ. Jim Smith, EHS Manager and Lee Gjetley, Corp NA EHS Manager with SGL Carbon were also present.
During the inspection, the following items were noted.
1) The "Tar -Pitch" area discussed on site merits secondary containment. While the material stored in the container will
become a solid when reduced to outside temperature, it is stored in a liquid state. Also, with the presence of liquid material
in the trench drain, it is likely that liquid material can escape from this area. Secondary containment should be installed as
soon as possible.
2) The area where "used oil' containers are staged and pumped out on a regular basis shall meet the Secondary
Containment requirements in Section A-2, (b) of the Industrial Stormwater Permit.
3) Material from the industrial process on site was observed in the storm drains. These drains should be cleaned out
frequently and as soon as possible in order to meet the permit requirements for Preventative Maintenance and Good
Housekeeping.
4) Two additional stormwater outfalls were observed on site. In part VI of your Industrial Stormwater permit, the areas these
outfalls collect from are covered in number 28 'The discharge from any point source which is used for collecting and
conveying stormwater and which is directly related to manufacturing, processing or raw material storage areas at an
industrial site." These outfalls shall be added to the Analytical/Qualitative monitoring list immediately.
5) It is recommended that you verify the potential for stormwater runoff from the staging/laydown area at the far east
perimeter of the site.
6) Be advised that grab samples should be obtained withing 30 minutes of discharge if possible.
If you have any questions, please contact me at [phone].
Page: 2

Permit: NCS000009 Owner - Facility: Sgl Carbon LLC
Inspection Date: 05/08/2018 Inspection Type : Compliance Evaluation
Stormwater Pollution Prevention Plan
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?
# 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: See Summary for further information.
Reason for Visit: Follow-up
Yes No NA NE
■❑❑❑
❑ ❑ ❑
❑ ❑ ❑
❑■❑❑
Page: 3

Permit: NCS000009
SOC:
County: Burke
Region: Asheville
Contact Person: Rick Ives
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Compliance Inspection Report
Effective: 03/01/09 Expiration: 02/28/14 Owner: Sgl Carbon LLC
Effective: Expiration: Facility: SGL Carbon Corporation
307 Jamestown Rd
Inspection Date: 01/31/2018
Primary Inspector: Isaiah L Reed
Secondary Inspector(s):
Title:
EntryTime: 10:OOAM
Michael M Smith
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Storm water
(See attachment summary)
Morganton NC 28655
Phone: [phone]
Certification: Phone:
Exit Time: 11:45AM
Phone: [phone]
Inspection Type: Compliance Evaluation
Page: 1

Permit: NCS000009 Owner - Facility: Sgl Carbon LLC
Inspection Date: 01/31/2018 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On January 31, 2018 this facility was inspected for compliance with the NPDES permit issued. All records were available for
Analytical and Qualitative monitoring. No consistent benchmark excedences have been documented. A walkthrough of the
facility was conducted, during which the following issues were noted:
1) Storage of used oil, deisel fuel, and other materials were found to be without secondary containment.
2) Many of the storm drains on site were found to be full of material from industrial activity (graphite/carbon).
3) The wastewater from the site co -mingles with the stormwater before reaching a feasible sampling point.
4) The "Coal Tar Pitch" area was found to not be completely contained.
The address these issues:
1) Move all products subject to meet the secondary containment requirements outlined in your permit.
2) Clean out all storm drains on site which have accumulated product inside.
3) Persue alternative methods of routing stormwater to avoid co -mingling with waste water.
4) Install containment for the "Coal tar pitch" area sufficient to protect the area from any spills.
Page: 2

Permit: NCS000009 Owner - Facility: Sgl Carbon LLC
Inspection Date: 01/31/2018 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?
MMF1
# Does the Plan include a General Location (USGS) map?
❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
■El El ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
E ❑ ❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
❑ E ❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
❑ 11 N ❑
# 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?
0 ❑ ❑
# 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?
0 El El El
Comment: Storage of used oil, Deisel Fuel, and other chemicals was observed without secondar rV
containment.
Qualitative Monitoring
Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually?
Comment:
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? ❑
# Were all outfalls observed during the inspection? 0 D El El
# If the facility has representative outfall status, is it properly documented by the Division? 0 El ❑
# Has the facility evaluated all illicit (non stormwater) discharges? E❑ ❑
Comment:
Page: 3