NCGNE0629_Email and Response about No Exposure_20240830

Eplin, Jerry W
From: Eplin, Jerry W
Sent: Friday, August 30, 2024 3:34 PM
To: Ashleigh Morgan
Cc: DeCristofaro, Andrew; Schley, Michael; Troy Ratcliffe
Subject: RE: [External] Stormwater Inspection - Arjobex :: NCGNE0629
For clarification,the"No Exposure" is an "exclusion"from having a permit—facilities that otherwise need a
discharge permit but can meet the requirements of"no exposure" apply for the"No Exposure Exclusion". "No
Exposure" is a high standard. If you cannot meet that standard,then coverage under a permit would be
required. In your case, 1) scrap metal parts were observed to be stored outdoors uncovered, 2) plastic pellets and
flakes were observed on the ground (FYI,these are considered "significant materials" by the EPA), 3) staining was
observed on the ground in multiple locations. Any of these alone would prevent you from being able to qualify for
"no exposure".
Furthermore,just having an exterior baghouse would likely disqualify a facility from "no exposure" because it
represents an industrial activity exposed to stormwater.
Let me know if you need further clarification, and what your intent is about applying for a permit. The facility would
likely be able to qualify for coverage under on of the General Industrial Stormwater Permits.
https://www.deq.nc.gov/about/divisions/energy-mineral-and-land-resources/stormwater/stormwater-
program/npdes-industrial-program/general-industrial-permits
Regards,
Jerry W. Eplin, PE
Regional Engineer
North Carolina Department of Environmental Quality
Division of Energy, Mineral, and Land Resources
Office: [phone]
Email: lerry.eplin(a�deq.nc.gov
Physical and Mailing Address:
610 E. Center Ave. Suite 301
Mooresville, NC 28115
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Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
From:Ashleigh Morgan <[e-mail]>
Sent: Friday, August 30, 2024 12:14 PM
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To: Eplin,Jerry W<[e-mail]>
Cc: DeCristofaro, Andrew<[e-mail]>; Schley, Michael
<[e-mail]>;Troy Ratcliffe<[e-mail]>
Subject: RE: [External] Stormwater Inspection -Arjobex :: NCGNE0629
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Good afternoon Jerry,
Please see attached for our 3 most recent No Exposure Exclusion Self Re-certification forms (2022,2023,2024).
After reviewing the report,we'd like to request more information on what would put us into the category for a
Stormwater Discharge Permit.
• At the end of the report, it mentions the recommendation to see if an industrial stormwater permit is
required due to the"industrial operations outdoors"—what are the industrial operations outdoors in
reference to? During our walkaround I know that Michael and Andrew mentioned the railcar and baghouse
possibly being an issue. However, the railcar operations are the same as they were 30 years ago when we
were granted the No Exposure Certification, and the baghouse was required to be put outside by OSHA.
• Are there other factors that would put us into the category of needing a Stormwater Discharge Permit? If
so,are there steps we can take(i.e. installing coverings)that would keep us in the "No Exposure"
category?
Thanks for your help,
Ashleigh Morgan, GSP
EHS Manager
Arjobex America Inc.
Mobile:[phone]
Web:www.polyartusa.com
Email: [e-mail]
10901 Westlake Drive,Charlotte,N.C.28273
Part of the Polyart Group
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From: Eplin,Jerry W<[e-mail]>
Sent:Thursday, August 29, 2024 9:53 AM
To:Ashleigh Morgan <Ashleigh.Morgan @arjobexamerica.com>
Cc: DeCristofaro, Andrew<[e-mail]>; Schley, Michael
<[e-mail]>
Subject: RE: [External] Stormwater Inspection -Arjobex :: NCGNE0629
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You don't often get email from [e-mail] why this is important
Hello Ms. Morgan:
Given the observations listed in the emailed report, it appears unlikely that a "No Exposure Certification" is
appropriate for this location. Please email me a copy of your three most recent completed Annual No Exposure
Exclusion Self Re-Certification forms and explain your intent about whether you intend to apply for an N PDES
Stormwater Discharge Permit.
Please contact me with questions.
Jerry W. Eplin, PE
Regional Engineer
North Carolina Department of Environmental Quality
Division of Energy, Mineral, and Land Resources
Office: [phone]
Email: merry.eplina-deg.nc.gov
Physical and Mailing Address:
610 E. Center Ave. Suite 301
Mooresville, NC 28115
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Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
From: Schley, Michael <[e-mail]>
Sent:Tuesday,August 27, 2024 11:12 AM
To:Ashleigh Morgan <Ashleigh.Morgan @ariobexamerica.com>
Cc: DeCristofaro, Andrew<[e-mail]>; Eplin,Jerry W<[e-mail]>; Peterson,
Kathryn S<[e-mail]>; Swavely, Owen C<[e-mail]>
Subject: [External] Stormwater Inspection -Arjobex
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Subject: Industrial Facility Inspection
ArjobexAmerica, Inc
Dear Ashleigh Morgan:
On August 22, 2024, Michael Schley and Andrew DeCristofaro of Charlotte-Mecklenburg Storm Water
Services (CMSWS) conducted an inspection of the above referenced facility under authority granted by
Charlotte City Code Chapter 18, Article III, Section 18-82. At the time of inspection, the facility was
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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
• Outdoor Material Storage-Scrap metal parts and equipment were observed to be stored
uncovered outdoors. CMSWS recommends keeping outdoor scrap metal parts and
equipment covered to help protect water quality.
• Loading Area-Plastic pellets and flakes were observed on the ground at the loading bay
truck ramp. CMSWS recommends implementing additional containment methods and
good housekeeping practices at the truck loading bay doors to help protect water quality.
• Pretreatment-Staining was observed on the ground leading from the wastewater
treatment system. CMSWS recommends assessing the containment measures for the
wastewater treatment system and cleaning spills and leaks promptly and properly to help
protect water quality.
• Indoor Storage/Processing-Plastic pellets, granola, flakes, and dust were observed on the
ground in the indoor storage and processing areas. CMSWS recommends implementing
additional good housekeeping procedures to help protect water quality.
• Waste Storage-Staining was observed on the ground near the used oil AST, outside of the
containment berm. CMSWS recommends cleaningspills and leaks promptly and properly
to help protect water quality.
The facility currently has a No Exposure NPDES permit(NCGNE0629). Based on the nature of
outdoor industrial operations, CMSWS recommends that the facility contact the NCDEQ Division of
Energy, Mineral, and Land Resources to determine if a General or Individual National Pollutant
Discharge Elimination System(NPDES)industrial stormwater permit is required.
The attached report provides details about inspection observations and recommendations. Thank
you foryour cooperation with the site inspection. Please contact me at 910.523.8072 if you have any
questions or need additional information regarding the attached report. For questions specifically
regarding State NPDES Stormwater Permitting, please contact Jerry Eplin with NCDEQ-DEMLR at(704)
663-1699.
Thankyou,
Michael Schley
Environmental Specialist II
LUESA I Charlotte-Mecklenburg Storm Water Services
Mecklenburg County Government
910.523.8072 1 MeckNC.Gov
WATER StormWater.CharMeck ors+pan®
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Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.
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