NCG030589_CEI with cover letter_20190325

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Interim Director
Elkay Plumbing Products Company
Attn: Gregg Baran, Plant Manager
880 Caton Road
Lumberton, NC 28360
NORTH CAROLINA
Environmental Quality
March 25, 2019
Subject: COMPLIANCE EVALUATION INSPECTION
NPDES Stormwater General Permit NCG030000
Elkay Plumbing Products Company
Certificate of Coverage NCG030589
Robeson County
Dear Mr. Baran:
On March 21, 2019, a site inspection was conducted for the Elkay Plumbing Products Company facility located at 880
Caton Road in Lumberton, Robeson County, North Carolina. A copy of the Compliance Inspection Report is enclosed for
your review. Mr. Rodney Vernon, Environmental Lead, was also present during the inspection and his time and assistance
is greatly appreciated. The site visit and file review revealed that the subject facility is covered by NPDES Stormwater
General Permit NCG030000 under Certificate of Coverage NCG030589. Permit coverage authorizes the discharge of
stormwater from the facility to receiving waters designated as Raft Swamp, class WS-IV;Sw waters in the Lumber River
Basin.
As a result of the inspection, the facility was found to be in compliance with the conditions of the NCG030000 permit.
Please refer to the enclosed Compliance Inspection Report for additional comments and observations made during the
inspection.
Please be advised that violations of the NPDES Stormwater General Permit are subject to a civil penalty
assessment of up to $25,000 per day for each violation. If you or your staff have any questions, comments, or needs
assistance with understanding any aspect of your permit, please contact me at [phone] or by e-mail at
[e-mail].
Sincerely,
Michael Lawyer, CPSWQ
Environmental Program Consultant
DEMLR
Enclosure
cc: Rodney Vernon, Environmental Lead — Elkay Plumbing Products Company (via e-mail)
FRO — DEMLR, Stormwater Files-NCG030589
�EQNorth Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
ip� Fayetteville Regional Office 1 225 Green Street, Suite 7141 Fayetteville, North Carolina 28301
NORTH CAROU
Ueputrnentat EnMrommenletU®pty 910.433.3300

Compliance Inspection Report
Permit: NCG030589 Effective: 11/01/18 Expiration: 05/31/21 Owner: Elkay Plumbing Products Company
SOC: Effective: Expiration: Facility: Elkay Plumbing Products Company
880 Caton Rd
County: Robeson
Region: Fayetteville
Lumberton NC 28360
Contact Person: Rodney Vernon Title: Environmental Lead Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
On -site representative Rodney Vernon 910-737-3112
Related Permits:
Inspection Date: 03/21/2019 E try Time: 1� Exit Time: 11:30AM
Primary Inspector: Mike Lawy Phone: [phone] ExV-2r
Secondary Inspector(s): 337Y
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 of 3

Permit: NCG030589 Owner - Facility: Elkay Plumbing Products Company
Inspection Date: 03/21/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Inspection conducted to determine compliance with the conditions of NPDES Stormwater General Permit NCG030000.
Facility has maintained permit coverage under Certificate of Coverage NCG030589 and there are no outstanding permit fees.
Met with Mr. Rodney Vernon, Environmental Lead. Mr. Vernon relayed that through some research into the history of the
facility's construction he had discovered sometime in 2016 that the pond on the facility's property is in fact a stormwater
retention pond. What had previously been indentified as the facility's stormwater discharge outfalls 1 and 2 are actually inlets
to the retention pond, which has no outlet structure and there have been no observable discharges. Mr. Vernon also relayed
that the storm drains located on and around the loading dock have been tied into the facility's evaporator system for process
water thereby eliminating any leaks or spills in the area from entering the facility's stormwater system. The facility's
Stormwater Pollution Prevention Plan (SPPP) and monitoring records were provided for review. The SPPP appears to contain
all permit -required components and is reviewed and updated on an annual basis per the permit requirements. Monitoring has
been conducted and recorded as required by the permit. Facility previously conducted monthly monitoring per the Tier Two
response actions due to consecutive exceedances of the benchmark value for zinc. Upon discovery of the onsite stormwater
retention pond in 2016, monitoring records indicate no discharges. Mr. Vernon was advised that reporting of no discharges
throughout a monitoring period should be done within 30 days of the end of the respective monitoring period. At the time of
inspection, the facility appeared to be very well operated and maintained and determined to be in compliance with the
conditions of the NCG030000 permit.
Page 2 of 3

Permit: NCG030589 Owner - Facility: Elkay Plumbing Products Company
Inspection Date: 03/21/2019 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?
0 ❑ ❑ ❑
# Does the Plan include a General Location (USGS) map?
❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
❑ ❑ ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
❑ ❑ ❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
❑ ❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
❑ ❑ ❑
# Does the facility provide all necessary secondary containment?
❑ ❑ ❑
# Does the Plan include a BMP summary?
❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
❑ ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
0 ❑ ❑ ❑
# Does the facility provide and document Employee Training?
❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
❑ ❑ ❑
# Is the Plan reviewed and updated annually?
❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
❑ ❑ ❑
Comment
Qualitative Monitoring
Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ❑ ❑ ❑
Comment: See Inspection Summary for details.
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? M ❑ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ 0 ❑
Comment: See Inspection Summary for details.
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? 0 ❑ ❑ ❑
# Were all outfalls observed during the inspection? M ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ 0 ❑
# Has the facility evaluated all illicit (non stormwater) discharges? 0 ❑ ❑ ❑
Comment:
Page 3 of 3