NCG210444_Inspection Report with Letter_20091008

Charlotte -Mecklenburg
STORM 2145 Suttle Avenue
WATER Charlotte, NC 28208-5237
Services
October 8, 2019
Novem Industries, Inc.
Attn: Mr. Brad Bennett, President
3901 North Graham Street
Charlotte, NC 28206
Subject: Industrial Facility Inspection
Novem Industries
Dear Mr. Bennett
On September 24, 2019, Matt Santiago and Ron Eubanks of Charlotte -Mecklenburg Storm
Water Services (CMSWS) conducted an inspection of the above referenced facility as a
requirement of the City of Charlotte's NPDES Permit, NCS000240, Part II, Section H. Inspection
authority is granted by Charlotte City Code Chapter 18, Article III, Section 18-82. At the time of
inspection, the facility was observed to be in compliance with the City of Charlotte Storm Water
Pollution Control Ordinance; however, the following observations were made:
1) Charlotte Storm Water Pollution Control Ordinance Review
• Aboveground Storage Tanks ASTs) — The facility operates a 500-gallon diesel AST for
onsite vehicle and equipment fueling. CMSWS recommends storing the AST within
secondary containment to prevent potential storm water pollution.
• Outdoor Material Storage Area — Several used batteries were observed on open ground in
the central area of the facility. CMSWS recommends storing the used batteries in a
manner that eliminates stormwater contact.
• Waste Storage — The facility utilizes multiple waste roll -away bins without covers to
store nails and metals that have been separated from the pallets during the mulching
process. CMSWS recommends utilizing either a roll tarp or a cover for the waste
containers to prevent potential storm water pollution.
The inspection was also conducted as part of a cooperative working agreement between
Mecklenburg County and the North Carolina Department of Environmental Quality (NCDEQ) —
Division of Energy, Mineral and Land Resources (DEMLR). NCDEQ — DEMLR has been copied
on this report and made aware of the following observations regarding the facility's NPDES
stormwater permit:
1) Stormwater Pollution Prevention Plan (SPPP)
A Stormwater Pollution Prevention Plan (SPPP) has not been developed, recorded, and
implemented. The facility should develop and implement a SPPP as per the facility's NCG210000
permit.
•
To report pollution or drainage problems, call: 311
http://stormwater.charmeck.org
c11ARLOTrr. 0.

Novem Industries
Attn: Brad Bennett, President
Page 2
October 8, 2019
2) Qualitative Monitoring
Qualitative monitoring has not been conducted and recorded. The facility should conduct
qualitative monitoring semi-annually.
3) Analytical Monitoring
Analytical monitoring has not been conducted and recorded. The facility should conduct
analytical monitoring semi-annually.
Thank you for the assistance and cooperation with the site inspection. The attached
report provides details about inspection observations and should be self-explanatory. Please
contact me at [phone] if you have any questions or need additional information. For
questions specifically regarding your State -issued NPDES Stormwater Certificate of Coverage
NCG210443, please contact James Moore with NCDEQ — DEMLR at [phone].
Sincerely,
Matt Santiago
Environmental Specialist
Charlotte -Mecklenburg Storm Water Services
cc: Kristen O'Reilly, Charlotte Storm Water Services
James Moore, NCDEQ — DEMLR
Zahid Khan, NCDEQ — DEMLR
Lily Kay, NCDEQ — DEMLR
Attachment

WCharlotte-Mecklenbwrg 2 1 4 5 S u t t 1 e Avenue
STORMCharlotte, NC 28208
--'-�-'--�'.WATERFacifity Inspection
Services
Facility Name: Novem Industries Inspection # : 46506
Contact: Brad Bennett, President Permit #: NCG210443
Inspector: Matthew Santiago Receiving Stream: Irwin
Inspection Date: 09/24/2019 Entry Time: 9:30 am Exit Time: 11:00 am SIC #:
Facility Description: Novem Industries is located at 3901 North Graham Street on 4.8 acres. The facility receives pallets
and other lumber waste to be grinded into mulch for resale.
File Review/History: Charlotte Mecklenburg Storm Water Services (CMSWS) previously inspected Novem Industries on
12/13/2017. The facility was observed to be in compliance with the City of Charlotte Storm Water Pollution Control
Ordinance. The facility obtained NCG21000 permit on April 29, 2016.
Inspection Summary: At the time of inspection, no deficiencies were noted, only recommendations in accordance to the
City of Charlotte Stormwater Pollution Control Ordinance. However, violations were observed in regard to the National
Pollutant Discharge Elimination System (NPDES) permit.
INSPECTIONDETAILS
Site Inspection Deficiency Comments
Stormwater system (catch basins,
No
Stormwater flows throught the site via sheet flow and
inlets, outfalls, etc.)
discharges at the rear of the property onto an adjacent empty
lot and through the entrance of the facility on Starita Road.
Erosion issues
No
Structural stormwater BMPs
No
No structural stormwater BMPS were observed during the
inspection.
Illicit discharges/connections
No
No illicit connections were observed during the inspection.
Above ground storage tank(s), and
Recommendation
The facility utilizes one 4,000-gallon Aboveground Storage
any associated venting — list size and
Tank (AST) containing water for dust suppression and one
contents
500-gallon AST containing diesel for fueling of
vehicles/equipment. CMSWS recommended storing the
diesel AST in secondary containment
Underground storage tank(s) - fill port
N/A
area; list tank sizes & contents
Outdoor material storage area(s)
Recommendation
The facility stores wooden pallets in a central pile and plastic
pallets along the north fence. Used batteries were observed
near the fueling equipment. CMSWS recommends storing
used batteries in a manner that eliminates stormwater
contact.
Outdoor processing area(s)
No
Pallets and other wooden debris is loaded into a grinder
which discharges the mulched wood into a pile while
separating out nails and other metallic debris in to a
dumpster for recycling.
Loading/unloading area(s)
No
Vehicle/equipment area(s) - fueling,
No
Vehicles and equipment is fueled onsite. Vehicles and
washing, storage, etc.
equipment are taken to Blue Beacon for washing and
maintenance.
Oil/water separator and/or
N/A
Pretreatment
•
�� To report pollution or drainage problems call: 311
CILUUATTE. http://stormwater.charmeek.org
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r'IDA L14T I
Site Inspection Deficiency Comments
Waste storage/disposal area -
Recommendation
The facility utilizes multiple dumpsters used to store
dumpsters, scrap metal bins, etc.
cardboard, scrap wood and recovered metal and nails.
CMSWS recommends keeping a cover on the dumpsters to
prevent potential pollution from runoff.
Food service area(s)
N/A
Indoor material storage area(s)
N/A
Indoor processing area(s)
N/A
Floor drains
N/A
Spill response equipment
No
The facility maintains oil -dry spill kits near the area where
hazardous materials are stored.
Stormwater Pollution Plan Observed Comments
Does the facility have a stormwater
No
At the time of inspection, the facility did not have a working
pollution prevention plan?
Stormwater Pollution Prevention Plan (SPPP) in place.
However, CMSWS has been working with Jorge Rojas
(operations manager) to develop and implement the required
SPPP.
General location (USGS) map
No
The facility should create a general location (USGS) map as
per Part II, Section A, #1(a) of the NCG210000 permit.
Narrative description of practices
No
The facility should create a narrative description of practices
as per Part II, Section A, #1(b) of the NCG210000 permit.
Detailed site map
No
List of significant spills (past 3 years)
No
The facility should create a document to report any significant
spills (or a "notation of no spills") for the past three years as
per Part II, Section A, #1(d) of the NCG210000 permit.
Non-stormwater discharge evaluation
No
The facility should conduct and document an annual
of outfall(s)
non-stormwater discharge evaluation of the outfall as per Part
II, Section A, #1(e) of the NCG210000 permit.
Feasibility study
No
The facility should conduct a feasibility study of the facility's
operations and storage practices to eliminate or reduce
exposure of materials and processess to rainfall and run-on
flows as per Part II, Section A, #2(a) of the NCG210000
permit.
All necessary secondary
No
containment provided
Collected water evaluated and
No
documented prior to release
BMP Summary
No
The facility should create a document listing structural and
non-structural Best Management Practices (BMPs) as per
Part Il, Section A, #1(c) of the NCG210000 permit.
Spill prevention and response plan
No
The facility should create a document including an
assessment of potential pollutant sources and a list of facility
personnel responsible for implementing the Spill Prevention
and Response Procedures (SPRP) as per Part II, Section A,
#3 of the NCG210000 permit.
Preventative maintenance and good
No
The facility should develop and implement a preventative
housekeeping plan
maintenance and good housekeeping plan as per Part II,
Section A, #4 of the NCG210000 permit.
Facility provides and documents
No
The facility should provide and document employee training
employee training
as per Part II, Section A, #6 of the NCG210000 permit.
C& To report pollution or drainage problems call: 311
CHARLOYFE_ http://storniwater.charmeck.org
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11:9§ - T€IC--
Stormwater Pollution Plan Observed Comments
List of responsible parties
No
The facility should develop a document that identified a
specific position or positions responsible for the overall
coordination, development, implementation and revisions of
the SPPP as per Part Il, Section A, #7 of the NCG210000
permit.
Reviewed and updated annually
No
The facility should conduct and document annual reviews and
updates to the SPPP as per Part II, Section A, #8 of the
NCG210000 permit.
Stormwater facility inspection
No
The facility should conduct and document semi-annual facility
program conducted semi-annually
inspections as per Part II, Section A, #8(b) of the
NCG210000 permit.
Qualitative/Analytical Monitoring Observed Comments
Qualitative monitoring conducted
No
Conduct and document semi-annual qualitative monitoring as
semi-annually
required as per Part II, Section C of the NCG210000 permit.
Analytical monitoring conducted
No
Conduct and document semi-annual analytical monitoring as
semi-annually
required as per Part II, Section B of the NCG21000 permit.
Analytical monitoring from vehicle
N/A
maintenance
Permit and Outfalls Observed Comments
Copy of permit and certificate of
Yes
COG #NCG210443 dated August 1, 2018 and permit fee paid
coverage onsite
April 2018.
All outfalls observed
Yes
No stormwater issues were observed.
Number of Outfalls Observed
2
How many outfalls observed?
Representative outfall status
No
documented by NCDWQ
Annual no -exposure self
No
re -certification documented
o•4
/% To report pollution or drainage problems call: 311
CIiARLOTTE. bttp://stormwater.charmeck.org
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