NCG030591_Inspection Letter with Report_20191008

kw�=Charlotfe-Mecklenburg
STORM
WATER
Services -
October 8, 2019
Ward Vessel and Exchanger Corporation
Attn: Bob Besh, VP of Production
6670 East WT Harris Boulevard
Charlotte, NC 28215
Subject: Industrial Facility Inspection
Ward Vessel and Exchanger Corporation
Dear Mr. Besh:
2145 Suttle Avenue
Charlotte, NC 28208-5237
On September 26, 2019, Julianna Hawley and Kristen O'Reilly 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; however, the following observations were made:
1) Charlotte Storm Water Pollution Control Ordinance Review
• Stormwater System — Four outfalls were observed, but the facility's Stormwater Pollution
Prevention Plan (SPPP) only notes three outfalls. CMSWS recommends updating the
SPPP to reflect a total of four outfalls and notifying the State of this change or modifying
practices onsite to eliminate the additional outfall observed.
• Erosion Issues — Outfall #002 had recently been re -dug, and bare soil was exposed in the
drainage pathway. CMSWS recommends regrading and vegetating the channel to avoid
exceeding the Total Suspended Solid benchmark at this outfall.
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:
2) Stormwater Pollution Prevention Plan (SPPP)
A Stormwater Pollution Prevention Plan (SPPP) has been developed, recorded, and implemented.
3) Qualitative Monitoring
The most recent qualitative monitoring occurred on 5/11/19. Several parameters have exceeded
analytical monitoring benchmarks indicating Tier II status, but monthly monitoring records were
not observed. Qualitative monitoring should occur monthly along with analytical monitoring when
•
o' To report pollution or drainage problems, call: 311
http://stormwater.charmeek.org y`
CHARIM' F_

Ward Vessel and Exchanger Corporation
Attn: Bob Besh, VP of Production
Page 2
October 8, 2019
in Tier II. The facility should ensure that monitoring frequency reflects the correct Tier as
indicated in the permit.
4) Analytical Monitoring
The most recent analytical monitoring occurred on 5/11/19 at Outfall #002. Several parameters
have exceeded benchmarks, including TSS in 2018, and TSS, copper, and zinc in 2016 indicating
Tier II status, but monthly monitoring records were not observed. The facility should ensure that
monitoring frequency reflects the correct Tier as indicated in the permit.
5) Permit and Outfalls
The facility submitted a representative outfall application and received a conditional letter from
the State (October 23, 2013) instructing the facility to sample for zinc and copper at all outfalls
for two additional events, after which the State would make its final determination. No records
were observed granting final approval and monitoring at the other two outfalls has occurred
intermittently. The facility should verify the status of this approval from the State.
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 [phone] if you have any questions or need additional information. For
questions specifically regarding your State -issued NPDES Stormwater Certificate of Coverage
NCG030594, please contact James Moore with NCDEQ — DEMLR at [phone].
Sincerely,
Julianna Hawley
Environmental Specialist
Charlotte -Mecklenburg Storm Water Services
cc: Kristen O'Reilly, Charlotte Storm Water Services
James Moore, NCDEQ — DEMLR
Zahid Khan, NCDEQ — DEMLR
Lily Kay, NCDEQ — DEMLR
Attachment

Chadoffe-uKklert m 2 14 5 S u t t l e Avenue
STORMCharlotte, NC 28208
1 E'ER Facility Inspection
-- services;
Facility Name: Ward Tank Inspection # : 46582
Contact: Bob Besh, VP of Production Permit #: NCG030591
Inspector: Julianna Hawley Receiving Stream: McALPINE
Inspection Date: 09/26/2019 Entry Time: 10:00 am Exit Time: 11:30 am SIC #:
Facility Description: Ward Vessel and Exchanger Corporation is located at 6670 East WT Harris Boulevard on
approximately 5 acres. Ward Vessel and Exchanger Corporation offers design and fabrication of custom shell, tube heat
exchangers, and pressure vessels.
File Review/History: Charlotte Mecklenburg Storm Water Services (CMSWS) previously inspected this facility 11/24/15,
and the report was issued as satisfactory.
Inspection Summary: The facility was observed to be in compliance with the City of Charlotte Storm Water Pollution
Control Ordinance. However, several recommendations have been provided. Please see the inspection for comments and
recommendations.
Site Inspection Deficiency Comments
Stormwater system (catch basins,
Recommendation
Stormwater conveys through the site via sheet flow. Four
inlets, outfalls, etc.)
outfalls were observed, but the facility's Stormwater Pollution
Prevention Plan (SPPP) only notes three outfalls. CMSWS
recommends updating the SPPP to reflect a total of four
outfalls and notifying the State of this change or modifying
practices onsite to eliminate the additional outfall observed.
Erosion issues
Recommendation
Outfall #002 had recently been re -dug, and bare soil was
exposed in the drainage pathway. CMSWS recommends
regrading and vegetating the channel to avoid exceeding the
Total Suspended Solid benchmark at this outfall.
Structural stormwater BMPs
Recommendation
The detention basin at Outfall #001 was observed to have
areas of limited vegetation. CMSWS recommends seeding
bare areas and mowing vegetation no less than 6 inches to
prevent erosion.
Illicit discharges/connections
No
No illicit discharges/connections were observed.
Above ground storage tank(s), and
N/A
No above ground storage tanks (ASTs) were observed.
any associated venting — list size and
contents
Underground storage tank(s) - fill port
N/A
area; list tank sizes & contents
Outdoor material storage area(s)
No
Steel pipes, raw material, and finished products were
observed to be stored outdoors. No stormwater pollution
issues were observed.
Outdoor processing area(s)
N/A
Loading/unloading area(s)
No
Vehicle/equipment area(s) - fueling,
No
According to facility personnel, no fueling or washing occurs
washing, storage, etc.
onsite. Forklifts are stored under cover. No stormwater
pollution issues were observed.
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Ob To report pollution or drainage problems call: 311
CHARLOTTE_ http://stormwater.charmeck.org
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Site Inspection Deficiency Comments
Oil/water separator and/or
No
Floor drains are connected to an oil/water separator, which is
pretreatment
serviced by Crystal Clean. No stormwater pollution issues
were observed.
Waste storage/disposal area -
Recommendation
The facility has one municipal trash container and one mixed
dumpsters, scrap metal bins, etc.
recyclable container. The drain plug on the recyclable
container was observed to have been damaged. CMSWS
recommends that the drain plug be replaced. The facility also
has five open top containers for scrap metal. Three of the
containers were observed to not have covers. According to
facility personnel, these containers only store raw material
that is already stored outdoors.
Food service area(s)
N/A
Indoor material storage area(s)
No
Empty barrels, paint, and other supplies were observed to be
stored indoors. No stormwater pollution issues were
observed.
Indoor processing area(s)
No
According to facility personnel, all metal fabrication and metal
working occurs indoors. No stormwater pollution issues were
observed
Floor drains
No
According to facility personnel, the floor drains are connected
to an oil/water separator. No stormwater pollution issues
were observed.
Spill response equipment
No
Spill kits were observed to be stored throughout the facility.
Stormwater Pollution Plan Observed Comments
Does the facility have a stormwater
pollution prevention plan?
Yes
The facility contracts Stormwater Services Group, LLC to
manage and update the SPPP.
General location (USGS) map
Yes
Narrative description of practices
Yes
Detailed site map
Yes
List of significant spills (past 3 years)
Recommendation
The facility had noted that there were no spills in 2019, 2020
and 2021. The facility should not record "no spills" for a year
that has not ended yet or for years that have not yet begun.
Non-stormwater discharge evaluation
of outfall(s)
Yes
The most recent evaluation occurred on 6/13/19.
Feasibility study
Yes
All necessary secondary
containment provided
N/A
Collected water evaluated and
documented prior to release
N/A
BMP Summary
Yes
Spill prevention and response plan
Yes
Preventative maintenance and good
housekeeping plan
Yes
Facility provides and documents
employee training
Yes
The most recent employee training was conducted and
documented on 6/30/19.
List of responsible parties
Yes
The list of responsible parties was updated on 6/13/19.
Reviewed and updated annually
Yes
The SPPP was updated on 6/13/19.
Stormwater facility inspection
program conducted semi-annually
Yes
The most recent inspection was conducted and recorded on
6/17/19. It was noted that Stormwater Services, LLC will
conduct the second inspection in December 2019.
Qualitative/Analytical Monitoring Observed Comments
ObTo report pollution or drainage problems call: 311 ''����
CHARIATTE. http://stormwater.charmeck.org ��j v
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Qualitative/Analytical Monitoring Observed Comments
Qualitative monitoring conducted
Recommendation
The most recent qualitative monitoring occurred on 5/11/19.
semi-annually
Several parameters have exceeded analytical monitoring
benchmarks indicating Tier II status, but monthly monitoring
records were not observed. Qualitative monitoring should
occur monthly along with analytical monitoring when in Tier ll.
The facility should ensure that monitoring frequency reflects
the correct Tier as indicated in the permit.
Analytical monitoring conducted
Recommendation
The most recent analytical monitoring occurred on 5/11/19 at
semi-annually
Outfall #002. Additionally, several parameters have exceeded
benchmarks, including TSS in 2018, and TSS, copper, and
zinc in 2016 indicating Tier II status, but monthly monitoring
records were not observed. The facility should ensure that
monitoring frequency reflects the correct Tier as indicated in
the permit.
Analytical monitoring from vehicle
N/A
maintenance
Permit and Outfalls Observed Comments
Copy of permit and certificate of
Yes
The Certificate of Coverage (COC) is NCG030591.
coverage onsite
All outfalls observed
Yes
The facility only has three outfalls recorded, but a fourth
outfall was observed during the inspection. The facility should
eliminate the fourth outfall or notify the state of the additional
outfall. See the "Structural Stormwater BMPs" and "Erosion
Issues" sections of this report for additional observations at
Outfalls #001 and #002.
Number of Outfalls Observed
4
Representative outfall status
Recommendation
The facility submitted a representative outfall application and
documented by NCDWQ
received a conditional letter from the State (10/23/13)
instructing the facility to sample for zinc and copper at all
outfalls for two additional events, after which the State would
make its final determination. No records were observed
granting final approval and monitoring at the other two outfalls
has occurred intermittently. The facility should verify the
status of this approval from the State.
Annual no -exposure self
N/A
re -certification documented
•
ObTo report pollution or drainage problems call: 311
CttARIAI'TE_ http://stormwater.charmeck.org
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