NCS000315_Nexeo Solutions CMSWS Inspection 2018_20180110

MCharlotte -Mecklenburg
STORM
W WATER
Services
January 10, 2018
Tim Nightwine, Senior Facility Manager
Nexeo Solutions
3930 Glenwood Drive
Charlotte, NC 28208
Subject: Industrial Facility Inspection
Nexeo Solutions
Dear Mr. Nightwine:
2145 Suttle Avenue
Charlotte, NC 28208-5237
On November 28, 2017, Chad Broadway 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.
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 been developed, recorded, and implemented.
2) Qualitative Monitoring
Qualitative monitoring has been conducted and recorded at Outfall #001; however, the facility has
not conducted qualitative monitoring at the other regulated outfalls during this permit term. As
per guidance from NCDEQ-DEMLR personnel, NPDES Permit NCS000315 requires qualitative
monitoring to be completed at all regulated outfalls.
3) Analytical Monitoring
Analytical monitoring has been conducted and recorded.
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To report pollution or drainage problems, call: 311
http://stormwater.charmeck.org
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m

Mr. Tim Nightwine, Senior Facility Manager
Page 2
January 10, 2018
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 704-280-1497 if you have any questions or need additional information. For
questions specifically regarding your NPDES stormwater permit, please contact James Moore
with NCDEQ — DEMLR at 704-663-1699.
Sincerely,
Chad Broadway
Environmental Specialist
Charlotte -Mecklenburg Storm Water Services
cc: Kristen O'Reilly, Charlotte Storm Water Services
James Moore, NCDEQ — DEMLR
Attachment
ObTo report pollution or drainage problems, call: 311
http://stormwater.charmeck.org
CHARLOTTE_ 0.

Charlott&Meck *V9
STORM
FFy..e.. WATER Facility
Services
Inspection
2145 Suttle Avenue
Charlotte, NC 28208
Facility Name: Nexeo Solutions, LLC (Formely Ashland Inc.) Inspection #: 34244
Contact: Tim Nightwine, Senior Facility Manager Permit #: NCS000315
Inspector: Chad Broadway Receiving Stream: IRWIN
Inspection Date: 11/28/2017 Entry Time: 9:00 am Exit Time: 11:40 am SIC #: 5169
Facility Description: Nexeo Solutions is located at 3930 Glenwood Drive on approximately 12.9 acres. The facility
receives, repackages, and distributes hazardous and non -hazardous chemicals and materials.
File Review/History: Charlotte -Mecklenburg Storm Water Services (CMSWS) previously inspected Nexeo Solutions on
March 31, 2014.
Inspection Summary: At the time of inspection, this facility was observed to be in compliance with the City of Charlotte
Stormwater Pollution Control Ordinance. Please see the inspection report for comments and recommendations.
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Site Inspection Deficiency Comments
Stormwater system (catch basins,
Recommendation
Stormwater flows through the site via sheet flow to a series of
inlets, outfalls, etc.)
catch basins and drainage swales, discharging from the site
via 6 primary outfalls located along the eastern portion of the
site. An unlabeled, deteriorating 55 -gallon drum was located
just below Outfall #001. The drum was partially filled with soil
and no evidence of pollution was observed in the area;
however, CMSWS recommends prompt removal and disposal
of this drum to prevent stormwater contact with any residual
contents.
Erosion issues
Recommendation
Moderate to severe erosion was observed below the
discharge point of Outfall #001. CMSWS recommends
monitoring this area to evaluate the rate of erosion. Repair or
stabilization of the affected area may be necessary to prevent
damage/displacement of the outfall pipe from continued
erosion.
Structural stormwater BMPs
No
The facility has one containment basin equipped with a gate
valve that keeps the discharge orifice closed until the valve is
opened by designated facility personnel. Facility personnel
confirmed after the inspection that the containment basin
receives flow from containment devices at the rail car
loading/unloading area.
Illicit discharges/connections
No
No illicit discharges or connections were observed during the
inspection.
Aboveground storage tank(s) - list
No
The facility stores numerous tanks, totes, and drums of
tank sizes & contents
various chemicals outdoors in several designated areas. A
full listing of all permanent tanks, including contents and
capacity volume, is maintained in the facility's SPCC plan.
Totes, drums, and other smaller volume containers are
temporarily stored on site at residence times that are
regulated by NCDEQ. All bulk fluid storage areas were
observed to have adequate secondary containment.
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Site Inspection Deficiency Comments
Underground storage tank(s) - fill port
N/A
area; list tank sizes & contents
Outdoor material storage area(s)
No
The facility stores drums and totes of various hazardous and
non -hazardous chemicals in outdoor areas throughout the
property. No stormwater issues were observed in these
areas.
Outdoor processing area(s)
N/A
Loading/unloading area(s)
No
The facility receives bulk liquids via rail car at an unloading
area that is equipped with a containment system that pipes
any discharged material to a containment basin. Bulk liquids
and other materials are also received via tractor trailer at
designated loading docks.
Vehicle/equipment area(s) - fueling,
No
No vehicle fueling or washing is conducted on site. Trailers,
washing, storage, etc.
tankers, and yard -dog tractors are stored outdoors. No
stormwater issues were observed in these areas.
Oil/water separator and/or
N/A
The facility does not conduct treatment or processing of
pretreatment
chemicals on site.
Waste storage/disposal area -
Recommendation
The facility has one open -top dumpster for disposal of pallets,
dumpsters, scrap metal bins, etc.
packaging materials, and general waste. CMSWS
recommends covering the dumpster to prevent accumulation
of stormwater if any materials containing residual pollutants
are placed in the dumpster.
Food service area(s)
N/A
Indoor material storage area(s)
No
The facility has several designated areas throughout the
facility where chemicals of similar characteristics and/or
hazard are grouped together for storage. An automated
secondary containment system prevents discharges outdoors
or to other storage areas. All indoor material storage areas
were observed to be well -kept.
Indoor processing area(s)
No
Bulk chemicals are repackaged into smaller containers within
a designated portion of the facility. No issues were observed
at the repackaging area.
Floor drains
N/A
No floor drains were observed during the inspection.
Spill response equipment
No
Spill kits are located in all areas of the facility where spills
may occur. The facility conducts periodic inspections of the
spill kits and secures the kits to ensure they are adequate for
use in the event of a spill. Additionally, many of the trailers
stored on site were observed to be equipped with over -pack
drums.
Stormwater Pollution Plan Observed Comments
Does the facility have a stormwater
Yes
pollution prevention plan?
General location (USGS) map
Yes
Narrative description of practices
Yes
Detailed site map
Yes
List of significant spills (past 3 years)
Recommendation
Per the facility manager, no significant spills have occurred
within the previous three years. The facility should make a
"notation of no spills" for years in which no spills occur, as
per Part II, Section A(7) of the permit.
Non-stormwater discharge evaluation
Yes
of outfall(s)
Feasibility study
Yes
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Stormwater Pollution Plan Observed Comments
All necessary secondary
Yes
containment provided
Collected water evaluated and
Yes
documented prior to release
BMP Summary
Yes
Spill prevention and response plan
Yes
Preventative maintenance and good
Yes
housekeeping plan
Facility provides and documents
No
The facility has previously conducted and documented
employee training
employee training; however, the most recent documented
training event occurred on May 2016. The facility should
provide employee training at least once every 12 months.
List of responsible parties
Yes
Reviewed and updated annually
Recommendation
At the time of inspection, the on-site copy of the stormwater
pollution prevention plan (SPPP) was outdated and included
incorrect facility contacts. An updated electronic version was
provided during the inspection. CMSWS recommends taking
steps to ensure that any updates to the electronic version of
the SPPP are immediately incorporated into the hard copy
version of the SPPP maintained on site.
Stormwater facility inspection
Yes
The facility conducts weekly and monthly inspections of the
program conducted semi-annually
tank storage areas and facility grounds.
Qualitative/Analytical Monitoring Observed Comments
Qualitative monitoring conducted
No
The facility conducted qualitative monitoring at Outfall #001
semi-annually
on 2/5/2017 and 11/29/2016. While Section B of the permit
specifies that analytical monitoring is only required at Outfall
#001, Section C (Qualitative Monitoring Requirements) does
not specify that qualitative monitoring only applies to this
outfall. CMSWS discussed this issue with NCDEQ-DEMLR
personnel and verified that the facility should conduct
qualitative monitoring at all regulated outfalls.
Analytical monitoring conducted
Yes
Analytical monitoring was conducted on 2/5/2017 and
semi-annually
11/29/2016. All parameters were within permit benchmarks.
As specified in Footnote 3 of Part Il, Section B of the facility's
NPDES permit, analytical monitoring is only required to be
conducted at Outfall #001.
Analytical monitoring from vehicle
N/A
maintenance
Permit and Outfalls Observed Comments
Copy of permit and certificate of
Yes
coverage onsite
All outfalls observed
Yes
Moderate erosion was observed on the slope below the
discharge point of Outfall 4001.
Number of Outfalls Observed
6
Representative outfall status
Yes
Per the facility's NPDES Permit (NCS000315), Outfall #001 is
documented by NCDWQ
the only outfall that requires analytical monitoring. The
facility should conduct qualitative monitoring at all regulated
outfalls on site.
Annual no -exposure self
N/A
re -certification documented
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