NCGNE0649_COMPLETE FILE - HISTORICAL_20091104

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO. /V U& N E U �q
DOC TYPE WHISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE
YYYYMMDD

V
NC®ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
November 4, 2009
Grass America, Inc.
Attn: Dean Shores
1202 Highway 66 South
Kernersville, North Carolina 27284
Subject: No-Exposure Certification NCGNE0649
Grass America, Inc.
Forsyth County
Dear Mr. Shore:
The Division has reviewed your submittal of the No-Exposure Certification for Exclusion from NPDES Stormwater
Permitting form. Based on your submittal of signed certification of no exposure at the above referenced facility and the
site visit conducted by Ms. Jenny Graznak of the Division's Winston-Salem Regional Office on September 9, 2009, the
Division is granting your conditional exclusion from permitting as provided for under 40 CFR 126.22(g), which is
incorporated by reference in North Carolina regulations. We are also hereby rescinding your current permit Certificate of
Coverage, NCG30178.
Please note that by our acceptance of your no-exposure certification, you are obligated to maintain no-exposure
conditions at your facility. If conditions change such that your facility can no longer qualify for no-exposure exclusion, you
are obligated to immediately obtain NPDES permit coverage for your Stormwater discharge. Otherwise, the discharge
becomes subject to enforcement as an un-permitted discharge. Your conditional no-exposure exclusion expires in five
years (November 1, 2014). At that time you must re-certify with the Division or obtain NPDES permit coverage for any
stormwater discharges from your facility.
Your conditional exclusion from permitting does not affect your facility's legal requirements to obtain environmental
permits that may be required under other federal, state, or local regulations or ordinances.
If you have any questions or need further information, please contact Jenny Graznak at (336) 771-5000 or
[e-mail].
Sincerely,
6
for Coleen H. Sullins
cc: SWP—Winston-Salem Regional Office Stormwater Permitting Unit File NCG30178
Stormwater Permitting Unit No- Exposure Files Fran McPherson-Budget Office
SWP—Central Files NCG30178
North Carolina Division of Water Quality,Winston-Salem Regional Office
Location:585 Waughtown St.Winston-Salem,North Carolina 27107 One
Phone:[phone] FAX:[phone] Customer Service:1-877-623-6748 NorthCarolina
Internet:www.ncwatergoality.org '�'] m1atu ly
An Equal Opportunity 1 Affirmative Action Employer �/ ►� Yi

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
November 4, 2009
Grass America, Inc.
Attn: Dean Shores
1202 Highway 66 South
Kernersville, North Carolina 27284
Subject: No-Exposure Certification NCGNE0649
Grass America, Inc.
Forsyth County
Dear Mr. Shore:
The Division has reviewed your submittal of the No-Exposure Certification for Exclusion from NPDES Stormwater
Permitting form. Based on your submittal of signed certification of no exposure at the above referenced facility and the
site visit conducted by Ms. Jenny Graznak of the Division's Winston-Salem Regional Office on September 9, 2009, the
Division is granting your conditional exclusion from permitting as provided for under 40 CFR 12622(g), which is
incorporated by reference in North Carolina regulations. We are also hereby rescinding your current permit Certificate of
-Coverage, NCG30178.
Please note that by our acceptance of your no-exposure certification, you are obligated to maintain no-exposure
conditions at your facility. If conditions change such that your facility can no longer qualify for no-exposure exclusion, you
are obligated to immediately obtain NPDES permit coverage for your stormwater discharge. Otherwise, the discharge
becomes subject to enforcement as an un-permitted discharge. Your conditional no-exposure exclusion expires in five
years (November 1, 2014). At that time you must re-certify with the Division or obtain NPDES permit coverage for any
Stormwater discharges from your facility.
Your conditional exclusion from permitting does not affect your facility's legal requirements to obtain environmental
permits that may be required under other federal, state, or local regulations or ordinances.
If you have any questions or need further information, please contact ,fenny Graznak at (336) 771-5000 or
[e-mail].
Sincerely,
r,
for Coleen H. Sullins
cc: SWP—Winston-Salem Regional Office Stormwater Permitting Unit File NCG30178
Stormwater Permitting Unit No- Exposure Files Fran McPherson-Budget Office
SWP —Central Files NCG30178
North Carolina Division of Water Quality,Winston-Salem Regional Office
Location:585 Waughtown St.Winston-Salem,North Carolina 27107 One
Phone:[phone] FAX:[phone] Customer Service:1-877-623-6748 North Caroli n a
Internet:www.ncwaterquality.org 'JtJ'ah yeay
An Equal Opportunity l Affirmative Action Employer �/ V L "

r7
GG-C3 -\j\j Spa
FOR AGENCY USE ONLY
A`"ia
Division of Water ualit 1 Surface `rater Protection Date Received Q Y Year O
ca
NCDENR National Pollutant Discharge Elimination System CrriiIINteofCovera e
NO EXPOSURE CERTIFICATION for Exclusion
FN✓3:^.YMf vT 4n�la��,y,Ftr:q„b;jp
NCGNEOOOO
NO EXPOSURE CERTIFICATION Please check here if this is a renewal: ❑ RENEWAL
National Pollutant Discharge Elimination System application for exclusion from a Stormwater Permit based
on NO EXPOSURE:
Submission of this No Exposure Certification constitutes notification that your facility does not require a
permit for stormwater discharges associated with industrial activity in the State of North Carolina because
it qualifies for a no exposure exclusion. A condition of no exposure at an industrial facility means all
industrial materials and activities are protected by a storm resistant shelter(with some exceptions)to
prevent exposure to rain, snow, snowmelt, and/or runoff.
For permitted facilities in North Carolina, DWQ must approve your application for No
Exposure Certification before this exclusion is effective. Until you are issued a No
Exposure Certification and your NPDES permit is rescinded, your facility must continue
to abide by the terms and conditions of the current permit.
Industrial materials or activities include, but are not limited to: material handling equipment or activities,
industrial machinery, raw materials, intermediate products, by-products, final products, or waste products.
Material handling activities include the storage, loading and unloading, transportation, or conveyance of
any raw material, intermediate product, final product or waste product. A storm resistant shelter is not
required for the following industrial materials and activities: drums, barrels, tanks, and similar containers
that are tightly sealed, provided those containers are not deteriorated and do not leak. "Sealed"means
banded or otherwise secured and with locked or non-operational taps or valves;adequately maintained
vehicles used in material handling;and final products, other than products that would be mobilized in
stormwater discharges(e.g., rock salt).
A No Exposure Certification must be provided for each facility qualifying for the no exposure exclusion. in
addition, the exclusion from NPDES permitting is available on a facility-wide basis only—not for individual
outfalls. If any industrial activities or materials are, or will be, exposed to precipitation, the facility is not
eligible for the no exposure exclusion. By signing and submitting this No Exposure Certification form,you
certify that a condition of no exposure exists at this facility or site and are obligated to comply w'@�)
terms and conditions of 40 CFR 122.26(g).
You are required to reapply for the No Exposure Exclusion once every five (5) ye'rosl. o
For questions,please contact the DWQ Regional Office for your area. (See page 6)
j ? ' c� u
(Please print or type) } o
1) Mailing address of owner/operator address to which all certification correspondence will be Hr�d ------ a
c
Name
Contact 1yeaAl .S
Street Address
City State _ ZIP Code
Telephone No. 3:?c !�Z23 :j�ao1 D Fax: 2 2 _ :,ta qff _
Page t of 7
SWU-NE-021309 Last revised 2/13/2009

NCGNE0000 No Exposure Certification
2) Location of facility producing discharge:
Facility Name G +r--os s AwyyV,� cc, F-t-r
Facility Contact )e r)
Street Address
City State G ZIP Code a-20- 8 q
County ar.
Telephone No. ,?& ':?9&.-0 YJ - � _— Fax: 600 3jV 3 -2-
3) Physical location information:
Please provide a narrative description of how to get to the facility (use street names, state road numbers, and
distance and direction from a roadway intersection).
(A copy of a map with the facility clearly located on it should be included with the certification application.)
4) Is the facility located on Native American Lands? ❑ Yes I No
5) Is this a Federal facility? ❑ Yes Id No
6) Latitude3la 5 Sa, ItDB Longitude 531) 3 5S, 97Z (deg., min., seconds)
7) This NPDES No Exposure Exclusion application applies to which of the following:
❑ New or Proposed Facility Date operation is to begin
If Existing Date operation began 3
❑ Renewal of existing No Exposure Certification- Certification No.: NCGNE
8) Was this facility or site ever covered under an NPDES Stormwater Permit? M'Yes ❑ No
If yes, what is the NPDES Permit Number? NC(S 03D [ -28
9) Standard Industrial Classification:
Provide the 4 digit Standard Industrial Classification Code (SIC Code) that describes the primary industrial
activity at this facility
SIC Code: 3
10) Provldlq a brief d scrip#tan of the types of industrial activities and products produced at this facility:
G� 0. 1 v
11) Does this facility have any Non-Discharge permits(ex: recycle permits)?
(%No
❑ Yes
If yes, list the permit numbers for all current Non-Discharge permits for this facility:
Page 2 of 7
SWU-NE-021309 Last revised 2/13/2009

NCGNE0000 No Exposure Certification
Exposure Checklists(12. - 14.)
12) Are any of the following materials or activities exposed to precipitation, now or in the foreseeable
future? (Please check either"Yes" or "No.") If you answer"Yes" to any of these items, you are not
eligible for the no exposure exclusion.
a. Using, storing, or cleaning industrial machinery or equipment, and areas where ❑ Yes V No ❑ NIA
residuals from using, storing or cleaning industrial machinery or equipment remain
and are exposed to stormwater
b. Materials or residuals on the ground or in stormwater inlets from spills/leaks ❑ Yes f�No ❑ NIA
c. Materials or products from past industrial activity ❑ Yes tp.No ❑ NIA
d. Material handling equipment(except adequately maintained vehicles) ❑ Yes ;Q No ❑ NIA
e. Materials or products during loading/unloading or transporting activities ❑ Yes X No ❑ NIA
f. Materials or products stored outdoors (except final products intended for outside ❑ Yes )Q No ❑ NIA
use [e.g., new cars] where exposure to stormwater does not result in the discharge
of pollutants)
g. Materials contained in open, deteriorated or leaking storage drums, barrels, tanks, ❑ Yes go No ❑ NIA
and similar containers
h. Materials or products handled/stored on roads or railways owned or maintained by ❑ Yes 9f No ❑ NIA
the discharger
i. Waste material (except waste in covered, non-leaking containers [e.g., dumpsters]) ❑ Yes i� No ❑ NIA
j.Application or disposal of process wastewater (unless otherwise permitted) ❑ Yes iX No ❑ NIA
k. Particulate matter or visible deposits of residuals from roof stacks and/or vents not ❑ Yes I No ❑ NIA
otherwise regulated (i.e., under an air quality control permit) and evident in the
stormwater outflow
I. Empty containers that previously contained materials that are not properly stored ❑ Yes No ❑ N/A
(i.e., not closed and stored upside down to prevent precipitation accumulation)
m. For any exterior ASTs, as well as drums, barrels, tanks, and similar containers ❑ Yes 11 No Cl NIA
stored outside, has the facility had any releases in the past three (3) years?
13) Above Ground Storage Tanks(ASTs): If you answer "No"to any of the following items, you are not
eligible for the no exposure exclusion.
a. Are exterior ASTs or piping free of rust, damaged or weathered coating, pits, or ❑ Yes ❑ No NIA
deterioration, or evidence of leaks?
b. Is secondary containment provided for all exterior ASTs? If so, is it free of any ❑ Yes ❑ No N/A
cracks, holes, or evidence of leaks, and are drain valves maintained locked shut?
Page 3 of 7
SWU-NE-021309 Last revised 2/13/2009

NCGNE0000 No Exposure Certification
14) Secondary Containment: If you answer "No" to any of the following items, you are not eligible for the
no exposure exclusion.
a. Is secondary containment provided for single above ground storage containers ❑ Yes ❑ No NIA
(including drums, barrels, etc.) with a capacity of more than 660-gallons?
b. Is secondary containment provided for above ground storage containers stored ❑ Yes ❑ No NIA
in close proximity to each other with a combined capacity of more than 1,320-
gallons?
c. Is secondary containment provided for Title III Section 313 Superfund ❑ Yes ❑ No NIA
Amendments and Reauthorization Act (SARA)water priority chemicals'?
d. Is secondary containment provided for hazardous substances— designated in 40 ❑ Yes ❑ No NIA
CFR §116?
e. Are release valves on all secondary containment structures locked? ❑ Yes ❑ No $,NIA
15) Hazardous Waste:
a. Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility? ❑ Yes ❑ No NIA
b. Is this facility a Small Quantity Generator (less than 1000 kg, of hazardous waste ❑ Yes ❑ No NIA
generated per month) of hazardous waste?
c. Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste ❑ Yes ❑ No NIA
generated per month) of hazardous waste?
If you answered yes to questions b. or c., please provide the following information:
Type(s) of waste:
How is material stored:
Where is material stored:
How many disposal shipments per year:
Name of transport/disposal vendor:
Vendor address:
Footnotes to Questions 14) c. & d.
'Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require
secondary containment. However, some exceptions may be made for de minimis amounts of certain substances,
and/or other qualifiers, as described in the exemptions from reporting requirements of Title III SARA 313 in 40 CFR
§372.38.
"Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require
secondary containment. However, some exceptions may be made for amounts less than the Reportable Quantities
of the hazardous substances listed in 40 CFR §117.3.
Page 4 of 7
SWU-NE-021309 Last revised 2/1 312 0 09

NCGNE0000 No Exposure Certification
16) Other information: If you answer "Yes" to any of the following items, you might not be eligible for the
no exposure exclusion. A more in-depth evaluation of the site circumstances may be required.
a. Does your facility store used, recycled, or otherwise reclaimed pallets outside? 1B.Yes ❑ No ❑ NIA
b. Does your facility have coal piles on site? ❑ Yes VNo ❑ NIA
c. Does your facility stare other fuel sources outside in piles, such as wood chips, ❑ Yes 01 No ❑ NIA
sawdust, etc.?
d. Does your facility have air emissions associated with its industrial activity(e.g., ❑ Yes (A No ❑ NIA
degreasing operations, plating, painting and metal finishing)? If so, describe the
industrial activity:
e. If you answered yes to d., are those emissions permitted by an Air Quality Permit? ❑ Yes ❑ No El NIA
Please specify:
f. Please list any other environmental program permits (federal, state, etc.) not
specified earlier in this application (such as Hazardous Waste Permits, etc.):
Permit: Program: Tv%duAr.d i1i ynF f
Permit: Program:
Permit: Program:
Permit: Program:
Permit: Program:
Permit: Program:
Permit: Program:
Page 5 of 7
SWU-NE-021309 Last revised 2/1 312 0 09

NCGNEOOOO No Exposure Certification
17) Certification:
I certify under penalty of law that I have read and understand the eligibility requirements for claiming a condition of"no
exposure"and obtaining an exclusion from NPDES stormwater permitting.
I certify under penalty of law that there are no discharges of stormwater contaminated by exposure to industrial activities
or materials from the industrial facility or site identified in this document(except as allowed under 40 CFR 122.26(g)(2)).
I understand that I am obligated to submit a no exposure certification form once every five (5)years to the North Carolina
Division of Water Quality and, if requested,to the operator of the local municipal separate storm sewer system (MS4) into
which the facility discharges (where applicable). l understand that I must allow the North Carolina Division of Water
Quality,or MS4 operator where the discharge is into the local MS4, to perform inspections to confirm the condition of no
exposure and to make such inspection reports publicly available upon request.
In the event that the site no longer qualifies for a No Exposure Exclusion, I understand that I must obtain coverage under
an NPDES permit prior to any point source discharge of stormwater from the facility.Additionally, I certify under penalty of
law that this document and all attachments were prepared under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my
inquiry of the person or persons who manage the system,or those persons directly responsible for gathering the
information,the information submitted is to the best of my knowledge and belief true,accurate and complete. I am aware
that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for
knowing violations.
certify that I am familiar with the information contained in this application and that to the best of my knowledge and belief
such information is true, complete,and accurate. I
Printed Name of Person 5ignin : De a r) -SAD�e
Title: ./f 4 Gi +'
ignature of Applicant) (Dale Signed)
Please note: This application for the No Exposure Exclusion is subject to approval by the
NCDENR Regional Office prior to issuance. The Regional Office may inspect your facility for
compliance with no exposure conditions prior to that approval. The Regional Office may also
inspect your facility at any time in the future for compliance with the No Exposure Exclusion.
North Carolina General Statute 143-215.6 B(i) provides that:
Any person who knowingly makes any false statement,representation,or certification in any application,record,report,plan,or other
document filed or required to be maintained under this Article or a rule implementing this Article;or who knowingly makes a false
statement of a material fact in a rulemaking proceeding or contested case under this Article;or who falsifies,tampers with,or knowingly
renders inaccurate any recording or monitoring device or method required to be operated or maintained under this Article or rules of the
(Environmental Management)Commission implementing this Article$hall be guilty of a Class 2 misdemeanor which may include a fine
not to exceed ten thousand dollars($10,000).
There is currently no fee for a No Exposure Exclusion.
Page 6 of 7
SWU-NE-021309 Last revised 2/13/2009

NCGNE0000 No Exposure Certification
Final Checklist
This application should include the following items:
❑ This completed application and all supporting documentation.
❑ A map with the location of the facility clearly marked.
o If this is a renewal, indicated current NCGNE number in Question 7.
fl If the site currently has an NPDES Stormwater Permit, be sure to indicate the permit number in Question 8.
Mail the entire package to:
Stormwater Permitting Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Note
The submission of this document does not guarantee the issuance of a No Exposure Exclusion.
For questions, please contact the DWO Regional Office for your area.
DWQ Regional Office Contact Information:
Win ion tole ' 4
Asheville Office ...... [phone]
Fayetteville Office ... [phone] a 19h
Mooresville Office ... [phone]ra„~
Raleigh Office ........ [phone] s „•tle ' _
14�oorvsv la
Washington Office ...[phone]
Wilmington Office ... [phone]
Winston-Salem ...... [phone] \Fayen 7 ilte ..`
Central Office .........(919) $07 fi300
-:
Wil ngtssn
Page 7 of 7
SWU-NE-021309 Last revised 2/13/2009

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2:32 PM
Thursday,Sep 24, 2009 02:32 PM

NC®ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
September 14, 2009
Mr. Dean Shore
Grass America, Inc.
1202 Highway 66 South
Kernersvilie, North Carolina 27284
Subject: NOTICE OF VIOLATION — General Stormwater Permit Inspection.
NPDES General Permit No. NCG030178— Grass America, Inc.
Forsyth County
On September 9, 2009, Jenny Graznak of this office performed a Stormwater Permit
Inspection at Grass America located at 1202 Highway 66 South in Kernersville, North Carolina. This
facility holds General Stormwater Permit No. NCG030178 under the National Pollutant Discharge
Elimination System (NPDES) to discharge Stormwater associated with activities classified as Metal
Fabrication. Specifically, Grass America manufactures cabinet hinges and drawer slides. You were
present for the inspection. This type of inspection consists of two basic parts: a review of facility files
and self-monitoring data and an inspection of the facility's discharge points. This particular
inspection evaluated five (5) areas, and observations from each area are addressed below:
1. Permit
The permit became effective November 1, 2007 and expires October 31, 2012. This facility has had
the storm water General Permit NCG030178 since 1994. A copy of an old permit was available
during the inspection. You may access the most recent copy of your General Permit here:
http://h2o.enr.state.nc.us/su/documents/final NCG030000.pdf.
2- Records/Reports
During the inspection, it was determined that your facility has developed a Stormwater Pollution
Prevention Plan (SPPP), dated November 30, 2001, as required by the permit. However, it appears
that the last update to the SPPP was made in 2005.
3. Facility Site Review
The only items maintained outside at this plant are new pallets for product delivery, a covered trash
compactor, a metal dumpster underneath a storm-resistant shelter, and metal storage racks for
holding excess inventory. A few old pallets were sitting on the loading dock awaiting recycling pick-
up.
Therefore, it was determined during the visual inspection of the property that a condition of No
Exposure exists at this facility. All chemicals and materials at the facility are covered by a storm
resistant shelter to prevent exposure to rain, snow, snowmelt, and runoff. Therefore, it is
recommended that you apply for a No Exposure Certification for Exclusion from NPDES Stormwater
Permitting. A No Exposure application is attached to this letter should you choose to proceed in that
direction. If you wish to proceed in this route, please complete and send the application to:
North Carolina Division of Water Quality,Winston-Salem Regional Office
Location:585 Waughtown St.Winston-Salem,North Carolina 27107 One
Phone:[phone] FAX:[phone] Customer Service:1-877$23-6748 NorthCarolina
Internet:www,ncwaterquality.org naturally
Aa Equal Opportunity l Affirmative Action Employer

The Stormater Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
4. Effluent/Receiving Waters
The site has four outfalls. Only Outfall 004 was observed during the inspection. The other three
outfalls were obscured by high vegetation and have not been inspected since 2005. This winter
when visibility is better, you should inspect all four outfalls. Stormwater from the property discharges
to an unnamed tributary to the Abbots Creek in the Cape Fear River Basin.
5. Self-Monitoring Pro ram
It was determined during the inspection that you have not been performing the self-monitoring
requirements of the General Permit since 2005. The stormwater permit requires semi-annual
qualitative and quantitative monitoring of stormwater discharge outfalls and effluent. The last
analytical and qualitative monitoring events took place on April 22, 2005. Analytical samples were
analyzed by R & A Laboratories in Kernersville, and all results were within permit limits. Should you
apply for and receive No Exposure Certification, your facility would be exempt from these monitoring
requirements. On-site vehicle maintenance monitoring requirements at the site are waived
regardless, since these activities are not performed on site.
Please be aware that the failure to comply with monitoring requirements is a violation of the
General Permit. Therefore, this inspection report is being sent as a Notice of Violation. According to
permit text Part III Section A (2), "the permittee must comply with all conditions of this permit. Any
permit noncompliance constitutes a violation of the Clean Water Act and is grounds for enforcement
action; for permit termination, revocation and reissuance, or modification; or denial of a permit upon
renewal application." Under state law, a daily civil penalty of not more than twenty-five thousand
dollars ($25,000) per violation may be assessed against any person who violates or fails to act in
accordance with the terms, conditions, or requirements of a permit. [Ref: NC General Statutes 143-
215.6A]
You are required to either apply for a No Exposure Certification for Exclusion from
NPDES Stormwater Permitting or comply with the permit requirements as stated above.
Please respond to this office in fifteen (151 days alerting our office to your decision.
You may refer to the attached report for further details from the inspection. If you have any
questions concerning this report, please contact Mrs. Graznak or me at [phone].
Sincerely,
Steve W. Tedder
Regional Supervisor,
Surface Water Protection} Section
cc: NPS Assistance & Compliance Oversight Unit
SWP — Central Files
SWP—WSRO

Compliance Inspection Report
Permit: NCG030178 Effective: 11/01/07 Expiration: 10/31/12 Owner: Wurth Group of North America
SOC: Effective: Expiration: Facility: Grass America Incorporated
County: Forsyth 1202 Hwy 66 S
Region: Vhnston-Salem
Kernersville NC 27284
Contact Person: Sesep -Wi(toeker Title: EHS Mgr Phone: [phone]
Dean SInore
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 09//012009 Entry Time: 10:30 AM Exit Time: 12:00 PM
Primary Inspector: Jennifer F Graznak Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Metal Fabrication Stormwater Discharge COC
Facility Status: ❑ Compliant ® Not Compliant
Question Areas:
®Storm Water
(See attachment summary)
Page: 1

Permit: NCGO30178 Owner-Facility: 4'Jurfh Group of North America
Inspection Date: Og11012009 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
1. Permit
The permit became effective November 1, 2007 and expires October 31, 2012. This facility has had the storm water
Genera4 Permit NCG030178 since 1994. A copy of an old permit was available during the inspection. You may access
the most recent copy of your General Permit here: http://h2o.enr.state.nc.us/su/documentsifinal_NCG030000.pdf.
2. Records/Reports
During the inspection, it was determined that your facility has developed a Stormwater Pollution Prevention Plan (SPPP),
dated November 30, 2001, as required by the permit. However, it appears that the last update to the SPPP was made in
2005.
3. Facility Site Review
The only items maintained outside at this plant are new pallets for product delivery, a covered trash compactor, a metal
dumpster underneath a storm-resistant shelter, and metal storage racks for holding excess inventory. A few old pallets
were sitting on the loading dock awaiting recycling pick-up.
Therefore, it was determined during the visual inspection of the property that a condition of No Exposure exists at this
facility All chemicals and materials at the facility are covered by a storm resistant shelter to prevent exposure to rain,
snow, snowmelt, and runoff. Therefore, it is recommended that you apply for a No Exposure Certification for Exclusion
from NPDES Stormwater Permitting. A No Exposure application is attached to this letter should you choose to proceed in
that direction. If you wish to proceed this route, please complete and send the application to:
The Stormater Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
4. Effluent/Receiving Waters
The site has four outfalls. Only Outfall 004 was observed during the inspection. The other three outfal4s were obscured
by high vegetation and have not been inspected since 2005 This winter when visibility is better, you should inspect all
four outfalls. Stormwater from the property discharges to an unnamed tributary to the Abbots Creek in the Cape Fear
River Basin.
5. Self-Monitoring Program
It was determined during the inspection that you have not been performing the self-monitoring requirements of the
General Permit since 2005. The Stormwater permit requires semi-annual qualitative and quantitative monitoring of
stormwater discharge outfalls and effluent. The last analytical and qualitative monitoring events took place on April 22,
2005. Analytical samples were analyzed by R &A Laboratories in Kernersville, and all results were within permit limits.
Should you apply for and receive No Exposure Certification, your facility would be exempt from these monitoring
requirements. On-site vehicle maintenance monitoring requirements at the site are waived regardless, since these
activities are not performed on site.
Page: 2

Permit: NCGO30178 Owner-Facility: Wunh Group of North America
Inspection Date: 0 911 012 0 0 9 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? ® Q 0 0
#Does the Pian include a General Location (USGS) map? ® 0 0
#Does the Plan include a"Narrative Description of Practices"? ® 0 0 rl
#Does the Plan include a detailed site map including outfall locations and drainage areas? a 0 n
#Does the Plan include a list of significant spills occurring during the past 3 years? U E3 D n
#Has the facility evaluated feasible alternatives to current practices? ® 1) Cl n
#Does the facility provide all necessary secondary containment? ® Cl Q ❑
#Does the Plan include a BMP summary? ® n
#Does the Plan include a Spill Prevention and Response Plan (SPRP)? ® ❑ ❑ rl
#Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ® n ❑ n
#Does the facility provide and document Employee Training? n ® ❑ Cl
#Does the Plan include a list of Responsible Party(s)? ❑ M 0 n
#Is the Plan reviewed and updated annually?
#Does the Plan include a Stormwater Facility Inspection Program? n ® ❑ n
Has the Stormwater Pollution Prevention Plan been implemented? 0 W 0 n
Comment: The SPPP has not been updated since 2005.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? I_l m ❑ ❑
Comment: Qualitative monitoring has not been conducted since 2005.
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? 0 a 0 0
#Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
Comment: Analytical monitoring has not been conducted since 2005.
Permit and Outfalis Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? ® ❑ ❑ fl
#Were all outfalls observed during the inspection? ❑ ® 00
#If the facility has representative outfall status, is it properly documented by the Division? ❑ n ® U
#Has the facility evaluated all illicit(non stormwater)discharges? n n on
Page: 3

t
Permit: NCGO30178 Owner-Facility: Wurth Group of North America
Inspection Date: 09/10/2009 inspection Type: Compliance Evaluation Reason for Visit: Routine
Comment: The site has four outfalls. Only Outfall 004 was observed during the
inspection. The other three outfails were obscured by high vegetation and have not
been inspected since 2005. This winter when visibility is better, you should inspect all
four outfalls. 5tormwater from the property discharges to an unnamed tributary to the
Abbots Creek in the Cape Fear River Basin.
Page: 4

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1
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Wnaton•S�I�m
Ragicnal office
U"GRASS
Grass America Inc.
1202 Highway 66 South
KernQrSvil€e,NC 27284
Local 336-996-4041
Fax [phone]
Toll-Free 800-33,1-3512
September 21, 2009
(!!�Jenny nak
ental Specialist
Division of Water Quality
585 Waughtown Street
Winston-Salem, NC 27107
NPDES Stormwater Permit: NCG030178
Dear Ms. Graznak,
The management of Grass America, Inc. is of the opinion that we should now meet the state's
qualifications for a no exposure industrial facility. This letter is to notify you of the company's
intent to apply for the No Exposure Certification by completing and submitting form SWU-NE-
021309.
Sincerely,
az� j4u,
Dean Shore
Maintenance Manager
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