HomeMy WebLinkAboutNCG030438_COMPLETE FILE - HISTORICAL_20130426PERMIT NO.
DOC TYPE
DOC DATE
STORMWATER DIVISION CODI
NCG PERMITS
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HISTORICAL FILE
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North Carolina Department of Environment and Natural Resources
Division of Water Quality
Pat McCrory Charles Wakild, P E
Governor Director
April 26, 2013
Mr Cary M Peterson, Jr, General Manager
South Atlantic Galvanizing
P O Box 1380
Graham, NC 27253
Subject Compliance Evaluation Inspection
NPDES General Stormwater Permit No NCG030438
South Atlantic Gaivanzing
Alamance County
Dear Mr Peterson
John E Skvada, III
Secretary
On April 25, 2013, Jenny Graznak of this office performed a Compliance Evaluation
Inspection at South Atlantic Galvanizing in Alamance County This facility holds General Stormwater
Permit No NCG030438 under the National Pollutant Discharge Elimination System (NIPDES) to
discharge Stormwater from Metal Fabrication activities David Moley and you were present for the
inspection This type of inspection consists of two basic parts a review of facility files and self -
monitoring data, and an on -site inspection of the facility and its outfalls This particular inspection
evaluated five (5) areas as designated on the EPA inspection form, and observations from each area
are addressed below
1 Permit
The permit became effective November 1, 2012 and expires October 31 2017 A copy of the permit
was available for review during the inspection
2_ Records/Reports
As required by the Permit, the facility has a complete Stormwater Pollution Prevention Plan (SPPP)
that was available for review during the inspection The SPPP is updated on an annual basis
Employee Training also occurs on an annual basis and is documented by signatures of participants
3 Facilily Site Review
South Atlantic galvanizes steel, which is necessary to deter rust The steel is used in bridges and
construction, mainly for state and federal projects Zinc oxide is collected during the galvanizing
process and stored in 55-gallon drums under the large shed on the property Once dried the zinc
oxide is sold as an additive to food and cosmetic industries All chemicals and materials are stored
indoors or under the large shed A 250-gallon diesel tank is kept outside, which is covered and has
secondary containment Unfinished (black steel) and finished (galvanized steel) products are also
stored outside on the yard No problems were noted with respect to housekeeping during the
inspection
4 Effluent/Receivinii Waters
Stormwater discharges from this site drain to an unnamed tributary to Meadow Creek (Class C,
NSW) in the Cape Fear River Basin The site has two stormwater discharge outfalls Oi_itfall 001
drains from the manufacturing area (— 8 acres) Outfall 002 drains the adjacent storage yard (--11
North Carolina Division of Water Quality Winston Salem Regional Office
Location 585 Waughtown St Winston Salem North Carolina 27107 One 1
Phone 336771 50005FAX 336771-46301Customer Service 1-877.6236748 NofffiCarollna
IntemeL www nowaterquality org Aaturally
An Equal Opportunity 1 Affirmative Action Employer
acres) Outfall 001 collects considerable silt from the gravel lot due to the high volume of truck traffic
coming through Since the last inspection, South Atlantic built a small catch basin and berm to
collect some of this silt before it can leave the property through Outfall 001 The basin appeared to
be functioning appropriately and is routinely cleaned out
5 Self -Monitoring Program
The stormwater permit requires semi-annual analytical and qualitative monitoring of stormwater
discharge outfails On -site vehicle maintenance monitoring requirements at the site are waived,
since an outside company (Lift One) performs these activities An on -site review of the monitoring
data during the inspection showed that all parameters were evaluated per the specifications of the
permit, and the results were all within the benchmark values specified in the permit Bill Villanueva
from Water Solutions of Siler City performed the last monitoring in December 2012
Please note that the permit was re -issued on November 1, 2012 and now has the following analytical
monitoring requirements
-pH
- Total Suspended Solids (TSS)
- Non -Polar Oil & Grease
- Copper, Total Recoverable
- Lead, Total Recoverable
- Zinc, Total Recoverable
Total Toxic Organics (TTO) — required for industries with SIC 34
These new requirements will be applicable for your next analytical monitoring event Please contact
our office if you have any questions or concerns about the new monitoring requirements
You are found to be in compliance with General Permit No NCG030438 Please refer to the
attached report for further details from the inspection If you have any questions concerning this
report, please contact Ms Graznak or me at (336) 771-5000
Sincerely,
�V W Corey Basinger
Regional Supervisor
Surface Water Protection Section
cc WSRO_= SWP
Central Files — SWP
Compliance Inspection Report
Permit NCG030438 Effective 11101M2 Expiration 10/31/17 Owner South Atlantic Galvanizing
soc Effective Expiration Facility South Atlantic Galvanizing
County Alamance 3025 Steelway Dr
Region Winston-Salem
Graham NC 27253
Contact Person R W Beard Title Phone 910-295 7300
Directions to Facility
System Classifications
Primary ORC
Secondary ORC(s)
On Site Representative(s)
Related Permits
Certification Phone
Inspection Date W2512013 Entry Time 09 30 AM Exit Time 1100 AM
Primary Inspector Jennifer F Graznak Phone 336-771-5000
Secondary Inspector(s)
Reason for Inspection Routine Inspection Type Compliance Evaluation
Permit Inspection Type Metal Fabrication Stormwater Discharge COC
Facility Status ■ Compliant ❑ Not Compliant
Question Areas
N Storm Water
(See attachment summary)
Page 1
Permit NCGO30438 Owner Facility South Atlantic Galvanizing
On AW14o4n;N0, p o,;jraznatkyAjgp" Ft�dkf @„Qppoiance Evaluation InspectiqQtSgt0,&lapW1fie
P�,Elimination System (NPDES) to discharge Stormwater from Metal Fabrication activities David Moley
anyou were present for the inspection This type of inspection consists of two basic parts a review of facility files and
self -monitoring data, and an on -site inspection of the facility and its outfalls This particular inspection evaluated five (5)
areas as designated on the EPA inspection form and observations from each area are addressed below
1 Permit
The permit became effective November 1, 2012 and expires October 31 2017 A copy of the permit was available for
review during the inspection
2 Records/Reports
As required by the Permit, the facility has a complete Stormwater Pollution Prevention Plan (SPPP) that was available for
review during the inspection The SPPP is updated on an annual basis Employee Training also occurs on an annual
basis and is documented by signatures of participants
3 Facility Site Review
South Atlantic galvanizes steel, which is necessary to deter rust The steel is used in bridges and construction, mainly for
state and federal projects Zinc oxide is collected during the galvanizing process and stored in 55-gallon drums under the
large shed on the property Once dried, the zinc oxide is sold as an additive to food and cosmetic industries All
chemicals and materials are stored indoors or under the large shed A 250-gallon diesel tank is kept outside, which is
covered and has secondary containment Unfinished (black steel) and finished (galvanized steel) products are also
stored outside on the yard No problems were noted with respect to housekeeping during the inspection
4 Effluent/Receiving Waters
Stormwater discharges from this site drain to an unnamed tributary to Meadow Creek (Class C NSW) in the Cape Fear
River Basin The site has two stormwater discharge outfalls Outfall 001 drains from the manufacturing area (— 8 acres)
Outfall 002 drains the adjacent storage yard (-11 acres) Outfall 001 collects considerable silt from the gravel lot due to
the high volume of truck traffic coming through Since the last inspection, South Atlantic built a small catch basin and
berm to collect some of this silt before it can leave the property through Outfall 001 The basin appeared to be functioning
appropriately and is routinely cleaned out
5 Self Monitonng Program
The stormwater permit requires semi-annual analytical and qualitative monitoring of stormwater discharge outfalls
On -site vehicle maintenance monitoring requirements at the site are waived, since an outside company (Lift One)
performs these activities An on -site review of the monitoring data during the inspection showed that all parameters were
evaluated per the specifications of the permit, and the results were all within the benchmark values specified in the
permit Bill Villanueva from Water Solutions of Stier City performed the last monitoring in December 2012
Please note that the permit was re -issued on November 1 2012 and now has the following analytical monitoring
requirements
-pH
- Total Suspended Solids (TSS)
- Non Polar Oil & Grease
- Copper Total Recoverable
- Lead, Total Recoverable
- Zinc Total Recoverable
- Total Toxic Organics (TTO) — required for industries with SIC 34
Page 2
Permit NCG030438 Owner Facility South Atlantic Galvanizing
Inspection Date 04/25/2013 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?
® n
0 n
# Does the Plan include a General Location (USGS) map?
®
n
# Does the Plan include a Narrative Description of Practices ?
n
❑
n n
# Does the Plan include a detailed site map including outfall locations and drainage areas?
®
n
n n
# Does the Plan include a list of significant spills occurring during the past 3 years?
®
Q
❑
# Has the facility evaluated feasible alternatives to current practices?
®
n
❑ n
# Does the facility provide all necessary secondary containment?
®l]
n n
# Does the Plan include a BMP summary?
®n
n n
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
®
❑
Q Q
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
®
D
❑ ❑
# Does the facility provide and document Employee Training?
®
Cl
11 0
# Does the Plan include a list of Responsible Party(s)?
®
0 ❑
0
# Is the Plan reviewed and updated annually?
®
D ❑
Q
# Does the Plan include a Stormwater Facility Inspection Program?
®
D n
n
Has the Stormwater Pollution Prevention Plan been implemented?
®
n n
n
Comment
Qualitative Monitoring
Yes
No NA
NE
Has the facility conducted its Qualitative Monitoring semi annually?
®
n ❑
❑
Comment Bill Villanueva from Water Solutions of Siler City performed the last
monitoring in December 2012
Analytical Monitoring
Yes No
NA
NE
Has the facility conducted its Analytical monitoring?
® 0
❑
n
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
0 U
®
❑
Comment Bill Villanueva from Water Solutions of Siler City performed the last
monitoring in December 2012
Permit and Outfalls
Yes No
NA
NE
# Is a copy of the Permit and the Certificate of Coverage available at the site?
®❑
❑
Q
# Were all outfalls observed during the inspection?
® n
n
n
# If the facility has representative outfall status is it properly documented by the Division?
n n
Ilia
n
# Has the facility evaluated all tllicit (non stormwater) discharges?
n n
n
■
Page 4
Permit NCG030438 Owner Facility South Atlantic Galvanizing
Inspection pate 04/25/2013 Inspection Type Compliance Evaluation Reason for Visit Routine
Page 3
Graznak, Jenny
From Tedder Steve
Sent Monday March 15 2010 7 03 AM
To Wakild Chuck
Cc Graznak, Jenny, Knight Sherri
Subject FW pollution problem in Alamance County
Chuck,
Jenny has been to the site to follow up on complaints in 2007 and 2008 From a WQ position,
we have no issues
Tedder
E-mail correspondence to and from this address may be subject to the North Carolina Public
Records Law and may be disclosed to third parties
Steve Tedder
Steve Tedder@NCDENR gov
INC DENR Division of Water Quality
585 Waughtown Street
Winston-Salem, NC 27107
(336)-771-4950
Fax (336) 771-4630
-----Original Message-----
FromGraznak, Jenny
Sent Friday, March 12, 2010 10 41 AM
To Tedder, Steve
Subject RE pollution problem in Alamance County
Steve,
South Atlantic Galvanizing Steel holds permit # NCGO30438 I did my 1st storm water
inspection out there on June 14, 2007 - they were found to be in compliance I received a
complaint about them (from Ms Kerr that owns the daycare mentioned below) the Following year
so I did another storm water inspection of the facility on March 12, 2008 Thev were found
to be in compliance once again All galvanizing is done under a large shed (about the size
of an airplane hangar) They collect the zinc oxide in 55-gallon drums and keep inside
Finished product (galvanized steel) is stored outside in large gravel lot The only issue I
have with them is that their outfalls do collect silt from the gravel storage lot But the
monitoring data is under the benchmark value, mainly because their outfall is a long ditch
through the woods and offers opportunity for settling
The folks around this place (its next door to Buckner Steel on Hwy 54) do complain a lot
about this facility but I have never found any major issues on my visits I expect that it s
just really noisy because they are working on huge pieces of steel, the type used for bridges
and large buildings Although some of that noise could be from Buckner Steel next door but
I've never received a complaint about them I am happy to re -visit the facility if you think
I should
Jenny Graznak
NC DENR Winston-Salem Regional Office
Division of Water Quality
585 Waughtown Street
Winston-Salem, NC 27107
Voice (336) 771-4960
FAX (336) 771-4630
E-mail correspondence to and from this address may be subject to the North
Carolina Public Records Law and may be disclosed to third parties
-----Original Message-----
FromTedder, Steve
Sent Friday, March 12, 2010 9 44 AM
To Graznak, Jenny
Subject FW pollution problem in Alamance County
Please check out sometime next week Its sounds like a local zoning issue but since that did
not work they are trying other avenues Let s just make sure they have the proper permits
from us
Thanks
E-mail correspondence to and from this address
may be subject to the North Carolina Public Records
Law and may be disclosed to third parties
Steve Tedder
Steve Tedder@aNCDENR gov
NC DENR Division of Water Quality
585 Waughtown Street
Winston-Salem, NC 27107
(336)-771-4950
Fax (336) 771-4630
-----Original Message -----
From Wakild, Chuck
Sent Friday, March 12, 2010 9 24 AM
To Tedder, Steve, Knight, Sherri, Overcash, Keith
Cc Sullins, Coleen, Biser, Elizabeth, Matthews, Matt, Bush, 'fed
Subject FW pollution problem in Alamance County
Keith - From Mr Kerr's description of the problem it appears to be air emissions related
We will also look at what water quality issues may also be present
Steve and Sherri - Please look into this to see if there are any water quality issues which
need to be addressed and let me know what you find Mr Kerr has some concern about metals
contamination of his well water Thanks'
-----Original Message-----
FromWakxld, Chuck
Sent Thursday, March 11, 2010 6 06 PM
To Sullins, Coleen
Cc Biser, Elizabeth
Subject RE pollution problem in Alamance County
No I dropped the ball and didn t respond to your email I dad call and talked with Julius
Kerr this evening and got more detail on the problem and tomorrow will ask the region and DAQ
to investigate Mr Kerr appreciated the call
2
-----Original Message -----
From Sullins, Coleen
Sent Wednesday, March 10, 2010 6 13 PM
To Wakild, Chuck
Subject FW pollution problem in Alamance County
Importance High
Did this get addressed? I have another email and a request for a response ASAP Coleen
Coleen H Sullins, Director
Division of Water Quality
Phone 919/807-6357
Email correspondence to and from this address may be subject to the North Carolina Public
Records
Law and may be disclosed to third parties
-----Original Message-----
FromSullins, Coleen
Sent Monday, March 01, 2010 9 12 PM
To Wakild, Chuck
Subject FW pollution problem in Alamance County
Importance High
Chuck - we probably need to get both APS and SWPS RO involved Thanks Coleen
From Biser, Elizabeth
Sent Monday, March 01, 2010 9 57 AM
To Overcash, Keith, Sullins, Coleen
Subject FW pollution problem in Alamance County
Keith and Coleen,
Please see the email below from Ms Pendergraph regarding the South Atlantic Galvanizing Co
located east of Graham They would like contacts from your divisions to talk with Ms Kerr
(referenced in the email) I'm thinking the regional office may be best, Can you send me
the names/contact info for folks who could talk to Ms Kerr?
Thanks,
Elizabeth
From Jackie Ray (Sen Foriest) [mailto Foriestla@ncleg net] On Behalf Of Sen Tony Foriest
Sent Friday, February 26, 2010 5 06 PM
To Biser, Elizabeth
Subject FW pollution problem in Alamance County
Importance High
Hello Elizabeth,
Could you please review 14s Pendergraph s concerns and let me know who is the best contact
(name, office, and telephone number) to address her concerns? Thanks
Jackie Ray
office of Senator Tony Foriest
(919) 301-1446
3
From Jane Pendergraph [mailto janependergraph@hotmail com]
Sent Tuesday, February 09, 2010 11 03 PM
To Sen Tony Foriest
Subject pollution problem in Alamance County
Dear Tony, Hope you can help me with an issue in our neighborhood We have a company
called South Atlantic Galvanizing Co located on Hwy 54 E 9 Miles east of Graham which has an
environmental issue as it emits galvanizing pollutin in our air, water and soil There is a
daycare within sight of the plant as our home is within 1 mile we see smoke, smell fumes
and hear clanging noise during the day and night We should have never allowed this type
company enter our county as I understand that they have been run out of several other
counties Hopefully you could guide our neighbors on how to deal with this problem We
would like to see them removed from the county but that might be too late but they should
have to abide by some very strict rules in order to remain as I do believe that in the future
we will have to deal with some serious health issues There is a lady that runs the daycare
that is trying to seek help Her name is Beverly Kerr @
beverlykerr@triad rr com<mailto beverlykerr@triad rr com>, tele
3363769060 She is having a meeting at her home this Saturday at 3 p m for neighbors
to find out more about this pollution problem Your advice or help would be appreciated
Thank you so much as I know that you listen'''
Sincerely
Jane and Leonard Pendergraph
We are friends of Lib Culp and take her to
some of her democratic meetings We have had the
pleasure of being with you and your wife at times but
I know that it is hard for you to remember all the people
that come your way Thanks JP
Hotmail Powerful Free email with security by Microsoft Get it
now <http //clk atdmt com/GBL/go/201469230/direct/01/>
4
Michael F Easle) Goiemor
Wdham G Ross k Secretary
North Carohria Department of] nvtronrrterit and Natural RLsouttes
Coleen S Ilins Ducctor
Nvimon oMlatu Qnaht) '
March 14 2008
Mr Cary M Peterson, Jr, General Manager
South Atlantic Galvanizing
P O Box 1380
Graham, NC 27253
Subject General Stormwater Inspection - NPDES General Permit No NCG030438
South Atlantic Galvanzing - Alamance County
Dear Mr Peterson
On March 12 2008, Jenny Graznak of this office performed a General Stormwater Permit
Inspection at South Atlantic Galvanizing located at 3025 Steel Way Drive in Graham, North
Carolina This facility holds General Stormwater Permit No NCG030438 under the National
Pollutant Discharge Elimination System (NPDES) to discharge Stormwater from metal
fabrication activities You were present for the inspection This type of Inspection consists of
two basic parts a review of facility files and self -monitoring data, and an on -site inspection of
the facility and its outfalls This particular Inspection evaluated five (5) areas as designated on
the EPA Inspection form, and observations from each area are addressed below
1 Permit
The permit became effective November 1, 2007 and expires October 31, 2012 A copy of the
permit was available during the inspection
2 Records/Reports
As required by the Permit, the facility has a complete Stormwater Pollution Prevention Plan
(SPPP) that was available for review during the inspection South Atlantic created the SPPP,
originally dated May 1999, and revised it in 2000 and 2005 Employee Training occurs on an
annual basis and is documented by signatures of participants The last training event occurred
August 15-16, 2007
3_ Facility -Site Review
This is a galvanizing steel operation, which involved coating steel to deter rust Zinc oxide is
collected from the galvanizing process and stored in 55-gallon drums under a weather -resistant
cover Once dried, the zinc oxide is sold as an additive to food and cosmetic industries All
chemicals are kept inside A 250-gallon diesel tank is kept outside, protected by secondary
containment Raw materials and products from the manufacturing process (i a steel) are also
maintained outdoors During the inspection no major problems were noted with respect to
housekeeping
4 Effluent/Receiving Waters
Stormwater discharges from this site drain to an unnamed tributary to Meadow Creek (Class C,
NSW) in the Cape Fear River Basin The site has two stormwater discharge outfalls Outfall
001 drains from the manufacturing area (- 8 acres) Outfall 002 drains the storage yard (-11
acres) It was noted that Outfall 001 collects considerable silt from the gravel lot More silt
fence or riprap could be used to collect this silt
North Carolina Division of Water Quality 585 W'tughtown Strect Phone (336) 771 5000 Customer Service
Inlemet hnp 1110 enr state nc us Winston Salem NC 27107 rA\ (336) 7714630 1 877 623 6748 One
N'o�thCaroltna
An Equal Opporiunly/Affirmative Action Employer— 50% Recycledll0% Post Consumer Paper "Yalurally
South Atlantic Galvanizing
Page 2
March 14 2008
5 Self-Monitormq_Program
The stormwater permit requires semi-annual qualitative and quantitative monitoring of
stormwater discharge outfalls and effluent On -site vehicle maintenance monitoring
requirements at the site are waived, since an outside company (Barloworld) performs these
activities An on -site review of the monitoring data during the inspection showed that all
parameters were evaluated per the specifications of the permit Bill Villanueva from Water
Solutions of Sller City performed the analytical monitoring on February 13, 2008, and some of
the results were as follows
Oil &
Total
Lead (ug/L)
Outfall
Grease
Suspended
(m IL)
Solids m IL)
001
< 3 0
35
23
002
< 3 0
76
<2 0
The facility also sampled for pH and Total Toxic Organics These results do not exceed
benchmark values, as listed in the permit text All qualitative monitoring is also performed as
required by the permit The last monitoring event occurred March 7 2008
You are found to be in compliance with General Permit No NCGO30438 Please refer to
the attached report for further details from the inspection If you have any questions concerning
this report please contact Ms Graznak at (336) 771-4960 or me at (336) 771-4950
Sincerely,
Steve W Tedder
Regional Supervisor
Surface Water Protection Section
cc WSRO -- SWP
Central Files — SiNP
NPS Assistance and Compliance Oversight
/_�w 0r 7 e
Permit NCGO30438
SOc
County Alamance
Region Winston-Salem
Compliance Inspection Report
Effective 09/01/02 Expiration 08/31/07 Owner South Atlantic Galvanizing
Effective Expiration Facility South Atlantic Galvanizing
3025 Steelway Dr
Contact Person R W Beard
Directions to Facility
System Classifications
Primary ORC
Secondary ORC(s)
On Site Representative(s)
On site representative
24 hour contact name
Related Permits
Cary Peterson
Cary Peterson
Title
Inspection Date 06114/2007 Entry Time 0900 AM
Primary Inspector Jennifer M Freeman
Secondary Inspector(s)
Graham NO 77253
Phone 910 295 7'_00
Certification
Extt Time 10 00 AM
Phone
Phone
Phone
Phone 336 771 5000
Reason for Inspection Routine Inspection Type Stormwater
Permit Inspection Type Metal Fabrication Stormwater Discharge COC
Facility Status ® Compliant ❑ Not Compliant
Question Areas
® Storm Water
(See attachment summary)
Page 1
Permit NCG030438 Owner Facility South Atlantic Galvanizing
Inspection Date 06114/2007 Inspection Type Stormwater
Reason for Visit Routine
Stormwater Pollution Prevention Plan
Yes
No
NA
NE
Does the site have a Stormwater Pollution Prevention Plan?
®
n
n
n
# Does the Plan include a General Location (USGS) map?
®
o
n
n
# Does the Plan include a Narrative Description of Practices ?
®
n
n
n
# Does the Plan Include a detailed site map including outfall locations and drainage areas?
®n
n
n
# Does the Plan include a list of significant spills occurring during the past 3 years?
®n
n
n
# Has the facility evaluated feasible alternatives to current practices?
®
n
n
n
# Does the facility provide all necessary secondary containment?
®
n
n
n
# Does the Plan include a BMP summary?
®
o
n
n
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
®n
n n
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
® n
n n
# Does the facility provide and document Employee Training?
n ®
n n
# Does the Plan fnclude a list of Responsible Party(s)?
®n
n n
# Is the Plan reviewed and updated annually?
®n
n n
# Does the Plan include a Stormwater Facility Inspection Program?
® n
n n
Has the Stormwater Pollution Prevention Plan been implemented?
® n
n n
Comment Employee Training must be documented in the SPPP All employees
should be trained on the SPPP, including company procedures for handling spills and
environmental contaminants
Qualitative Monitoring
Yes
NO
nK
Nr
Has the facility conducted its Qualitative Monitoring semi annually?
®
n
n
n
Comment
Analytical Mcinitor!nij
Yes
No
NA
NE
Has the facility conducted its Analytical monitoring?
®
n
n
n
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
n
n
®
o
Comment
Permit and Outfalls
Yes
No
NA
NE
# Is a copy of the Permit and the Certificate of Coverage available at the site?
®
n
n
n
# Were ah outfalls observed during the inspection?
®
n
n
n
# If the facility has representative outfall status is it properly documented by the Division?
n
n
i
n
# Has the facility evaluated all illicit (non stormwater) discharges?
n
n
n
Page 3