NCS000339_RO Comments_20190919

Georgoulias, Bethany
From: Reed, Isaiah L
Sent: Thursday, September 19, 2019 5:26 PM
To: Garcia, Lauren V; Georgoulias, Bethany; Lucas, Annette; Khan, Zahid; Aiken, Stan E;
Moore, James; Morman, Alaina; Kay, Lily C
Subject: Individual Permit inspections.
Lauren et al.,
Below are my comments on the two facilities I inspected yesterday, September 18, 2019.
NCS000339:
I met with Mr. Barksdale at the Durable Wood Preservers facility.
During the inspection, the following items were noted:
1) The facility is not currently in operation.
2) Hazardous waste efforts continue on site, and exposure of those products to stormwater could, if not
continually monitored, impact stormwater.
3) Analytical and Qualitative monitoring has not been conducted at the facility since 2015.
4) The SWPPP, while complete, has not been maintained and updated.
5) When monitoring was being performed, several redundant monitoring locations were sampled. Different
locations in the same ditch.
I recommend that the facility be sent a Notice of Violation, and that they be required to monitor and keep the permit
open and payed up until all efforts to remove hazardous waste have been completed. What I am unsure of, is whether
the referenced NOV would be sent from this office or the MRO.
NCS000259:
I met with Christopher Flemming and Jerry McMurray on site.
During the inspection, the following items were noted:
1) The SWPPP has been maintained and implemented on site with one exception; The Annual non-stormwater
discharge evaluations had not been performed.
2) The facility had a great deal of secondary containment areas, due to the amount of liquid products they
produce, use, and store on site. Several issues were observed in various locations (to be included in the
inspection report).
3) An area on site where they have used concrete curbs to provide secondary containment has been modified, and
a section of the curb removed to allow for better access. This has greatly reduced secondary containment
capacity in that area.
4) There were several areas on site where the containment walls were damaged, and needed repair.
5) Additional Outfall locations were observed on site. Mr. Flemming said that the additional outfall locations will be
evaluated and added to the site map and monitoring list.
I recommend that a section be added to their permit to specifically require increased inspections (perhaps monthly) of
all secondary containment structures, and document repairs to secondary containment structures at the facility. Mr.
Flemming says that they have weekly inspections of those areas as it is, but that they are not documented. I feel that
increased inspections and perhaps an O&M plan for these structures would benefit the facility a great deal.
Please advise on how you would like the NOV to be sent. Written by me and signed by Zahid?
I will have the reports ready to go out next week.

Thanks,
Isaiah
ygp rn`gnl 01%ny+om Lpfq"Ld' K
Isaiah L H"d. CPSA'Q, HSAE1:1. LEPSCI
En►irownpittal Speciafisl
Division oL Energy-. Hineral and Land Resaurm
lorllk Carolina Deparlinent of Envirowitenlal QaaliIV
I nd Qualilr SKIiort. ksheiiIle Ifegiond Office
Rhone: [phone] Email: J%a�ah.needQNCDENR.sgov 2094 US Hwy 70. Swaninanaa, North Carolina 28778
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.