NCG030235_Response to NOV_20190301

Sa FT
a company of
TOTAL
February 26,2019
Stanley E. Aiken, PEGA
Regional Engineer
Land Quality Section
Subject: Notice of Violation (Nov-2019-PC-0058
NPDES Stormwater General Permit NCG030235
Inspection Violations
Dear Mr. Aiken:
On January 29, 2019, our site located at 313 Crescent Street, Valdese NC 28690, was the subject of
a site inspection conducted by Isaiah Reed. During this inspection, two permit condition violations
were uncovered. These violations are:
1. Stormwater Pollution Protection Plan (SPPP)
A. The SPPP was not updated and contained outdated maps.
2. Inspection Observations
A. Stormwater discharge appeared foamy.
B. Damaged lock on one of the secondary containment areas.
C. Sodium Hydroxide did not appear to be in secondary containment, the tank in
question appeared to not be double walled. 4= C; vecl
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Explanation for the violations observed and corrections :
MAR - 1 2019
313 Crescent St NE, Valdese, NC 28690 USA . 828-874-4111 - 828-874-24:&G!1 d
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Sa FT
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a company of
TOTAL
1. SPPP: At the time of the inspection the SPPP was out of date. When I took over the duties
of EHS Manager I noticed the plan needed to be updated and hired INENCO to rewrite the
program. At the time of the inspection, and as of now, the plan is still with INENCO being
rewritten to include new site maps and a better outfall mapping system. At this time, I have
gone through the current plan and have updated it to the best of my ability as a stop -gap
measure. INENCO is still working on the new SPPP and should have it to us soon. In
addition, we have added the SPPP to our internal yearly task list and have instructed
INENCO to do the same.
2. Outfalls discharging foamy water: During the inspection, the inspector noted some foam at
the outfah locations. We have tried to find the cause to this but as of now, it has been
elusive. In the weeks since the inspection, we have gone out and checked the outfall during
rain vents and have not observed any further foam. In order to correct this issue, we will be
monitoring the outfalls closely and if the foam is observed again we will take a sample and
have it analyzed.
3. Lock broken on secondary containment area: The lock was found to be broken during the
inspection. After having our engineers look at the lock, they stated it appeared to be wear
and tear. We have replaced the lock with a new one and have ordered spares to have on hand
if we need to replace it again.
4. Sodium Hydroxide tank not appearing to have secondary containment: The tank in question
is being provided to our site by an outside vendor. When we reached out to them they stated
that the tank is double walled. Since we do not have verification of this on site, I have asked
them to forward the information to myself and our facilities manager. Once the documents

Sa FT
a company of
TOTAL
are received we will review them to ensure they meet regulations. If they do not we will take
all necessary action to correct it.
We will continue to work to ensure these violations do not occur again and will update your
office if any new information comes to light. If you have any further questions or concerns
please feel free to contact me.
Respect y,
Michael J. McGuire
EHS Manager
Saft America, Inc.
Valdese, NC 28690
E : Michael.MCGuire(a saftalnerlca.com P : 828-874-4111