NCG210058_COMPLETE FILE - HISTORICAL_20070302

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT N0.
DOC TYPE
HISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE
❑ �czq (O3 & a
YYYYMMDD
A

Nelson Frames Inc Friday, March 02, 2007
Subject: Response to Notice of Violation & Recommendation for Enforcement
Dated February 16, 2007
NPDES General Permit No. NCG210058-Nelson Frames Inc.
Dear Mr. Tedder:
I have received above notice and inspection summary. I find the summary to be
representative of our non-compliance status as I understand it. This letter is intended to
serve as my required timely response concerning these violations. It is my sincere
objective to supply all needed information and explanations and any omissions of such is
unintended and will certainly be corrected if given opportunity to do so.
1. These violations occurred from perhaps some
misunderstanding of the requirements, but will admit that mainly they
occurred because of a lack of necessary diligence on my part.
Implementing and maintaining our permit has not received the priority
status needed to fully meet our obligation.
2. To satisfy Records/Reports requirements, all (9) nine points under part II
section A. of our SPPP are currently being revisited and any omissions or
incompletion of these requirements will be brought into compliance. This
includes all training, inspection, prevention, scheduling, mapping, etc.
3. Our Self -Monitoring program will be implemented including required
documentation. I have scheduled the spring (April -June) Qualitative
monitoring to take place on a workday on or as near to April 151h of each
year as is possible. Fall monitoring (September -November) on October
15rh or as near to it as possible.
4. Any sawdust buildup around dumpster will be monitored and kept to a
minimum.
5. Oil stain at delivery truck will be tilled to ensure biodegradation.
6. We plan to possibly use an approved catch basin (tray) for our 275 gal.
kerosene tank. It is currently is less than 1/3 full. (approx. 75 gal.) We
should use this amount during the remaining cooler weather and would
like to wait until it is empty to avoid transferring the kerosene. At that
time the tank will be moved out of the way, and the site prepared for either
the catch tray or other approved option. We will not apply for No
Exposure status until we have set up a replacement heating fuel storage
system that will be acceptable.
7. To prevent• future violations we are taking the following steps:
a. A posted schedule of all dates for monitoring, reviews,
training, etc.
b. Placing a Preventive Maintenance/Good<Housekeeping or other
relevant topic on agenda for each monthly safety meeting. (not to
replace annual training but as a reminder)
C. I have set as a priority to bring all areas of our permit into
compliance as quickly as possible but spending the time necessary
to understand and create sensible plans and procedures for our site.
I also am committed to making every effort to then stay in
compliance.
Page 1 of 2

TIME LINE FOR COMPLETION
March & monthly thereafter -- Reminder - monthly safety meeting.
March 20'h — Oil stain tilled. (Sooner If Posibile)
April 2ND — All parts of SPPP completed and implemented. (SIP) (next Facility
Inspection April 16'h)
April 16`h — Facility Inspection. (Yearly Scheduled Event)
April 161h — Spring Self -Monitoring with documentation (YSE)
May I" - Kerosene tank emptied and stored. (SIP)
September 28'h — Acceptable heating fuel storage in place (exploring other options
than kerosene.) (SIP)
October — Check on possible No Exposure status.
October 15'h — Facility Inspection (YSE)
October 15'h — Fall Self -Monitoring with documentation. (YSE)
I understand that I have not fully complied with my permit obligations, but I feel
that the steps described above are a reasonable approach to correcting our deficiencies
and would like any consideration possible concerning my current status. If I have omitted
any needed information or if any information I have supplied is unacceptable, or unclear,
I would appreciate the opportunity to correct or clarify it.
Sincerely,
Norman O. Nelson
President
Nelson Frames Inc.
[phone]
[e-mail]
Page 2 of 2

VN A 7�9
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February 16, 2007
CERTIFIED MAIL 7006 2150 0003 9643 6309
RETURN RECEIPT REQUESTED
Norman Nelson, Owner
Nelson Frames, Inc.
3819 Nelson Road
Sophia, NC 27350
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
Subject: NOTICE OF VIOLATION & RECOMMENDATION FOR ENFORCEMENT
General Stormwater Permit Inspection
NPDES General Permit No. NCG210058 — Nelson Frames, Inc.
Randolph County
Dear Mr. Nelson:
On February 15, 2007, Jenny Freeman of this office performed a Stormwater Permit
Inspection at Nelson Frames, Inc. located at 3819 Nelson Road in Sophia, North Carolina. This
facility holds General Stormwater Permit No. NCG210058 under the National Pollutant
Discharge Elimination System (NODES) to discharge Stormwater from activities classified as
Timber Products. 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 inspection of the facility's
discharge points. This particular inspection evaluated five (5) areas, and observations from
each area are addressed below:
1. Permit
The permit became effective May 1, 2003 and expires April 30, 2008. A copy of the permit was
available during the inspection.
2..Records/Reports
The North Carolina Forestry Association has prepared a general Stormwater Pollution
Prevention Plan (SPPP) for companies that involved in Timber Products. However, the SPPP is
not complete and therefore, does not entirely satisfy the requirements of the permit in its current
state. Permit text Part II Section A describes the requirements for the SPPP. Please refer to
these requirements to complete the SPPP.
3. Facility Site Review
Sawdust from the production process is sent to an outside dumpster, which is emptied every 2-3
weeks through a contract with Republic Waste Services. Although there was some evidence of
sawdust on the ground surrounding the dumpster, it was not present in large enough amounts
to cause concern. A large oil stain on the ground was discovered under a delivery truck. You
can clean up small spills such as these by tilling the soil to ensure biodegradation of the
petroleum substance.
The site also includes one 275-aallon kerosene tank without secondary containment.
Due to the lack of secondary containment around this tank, you are ineligible for No
Exposure Certification. If you wish to proceed with application for No Exposure status,
you will need to build a containment wall for the tank. NUCH
,
North Carolina Division of Water Quality 585 Waughtovm Street Winston Salem, NC 27107 Phone [phone] Customer Service
Internet: h1p91h2o.enr.state.n0.us FAX [phone]
An Equal Opportunity/Aff rmatve Action Employer — 50% Recycled/10% Posl Consumer Paper

Page 2
February 16, 2007
4. Effluent/Receiving Waters
Stormwater from the property discharges to an unnamed tributary to Caraway Creek (Class C)
in the Yadkin -Pee Dee River Basin. The site has two stormwater discharge outfalls.
5. Self -Monitoring Proaram
It was determined during the inspection that you have not been performing the self -monitoring
requirements of the General Permit. Permit text Part II Section B describes the qualitative
monitoring requirements, which are to be performed on a semi-annual basis. Qualitative
monitoring records should be maintained at the facility andmade available to Division of Water
Quality staff upon request. You are exempt from the annual analytical monitoring requirements
since your vehicle maintenance activities occurring on -site do not use more than 55 gallons of
new motor oil per month when averaged over the calendar year.
The failure to comply with the above requirements is a violation of the General
Permit. Therefore, this inspection report is being sent as a Notice of Violation. According to
permit text Part III Section A, "the permittee must comply with all conditions of this permit. Any
permit noncompliance constitutes a violation of the Clean Water Act and is grounds for
enforcement action; for permit termination, revocation and reissuance, or modification; or denial
of a permit upon renewal application." Under state law, a daily civil penalty of not more than
twenty-five thousand dollars ($25,000) per violation may be assessed against any person who
violates or fails to act in accordance with the terms, conditions, or requirements of a permit.
[Ref: NC General Statutes 143-215.6A]
In closing, allow me to'reiterate the seriousness of this matter. This office is considering
sending a recommendation for enforcement to the Director of the Division of Water Quality.
Your response to this correspondence will be considered in this process. You must respond
in writing to this office within 15 days of receipt of this letter, advising us of the actions
taken to abate the violations. Failure to do so will result in a recommendation by this office in
favor of the pursuit of formal enforcement actions against you. Please include in your response
a detailed description of why these violations occurred and how they will be prevented in the
future. If you have any questions concerning this letter or the attached inspection report, please
contact Ms. Freeman or me at [phone].
Sincerely,
Steve W. Tedder
Regional Supervisor
Surface Water Protection Section
cc: SWP — Central Files
SWP -- WSRO
NPS Assistance and Compliance Oversight

Compliance inspection Report
Permit: NCG210058 Effective: 05/01/03 Expiration: 04/30/08 Owner: Nelson Frames Inc
SOC: Effective: Expiration: Facility: Nelson Frames Incorporated
County: Randolph 3819 Nelson Rd 27350-8629
Region: Winston-Salem
Sophia NC 27350
Contact Person: Norman O Nelson Phone: [phone]
Directions to Facility:
Primary ORC:
Secondary ORC(s)!
On -Site Representative(s):
On -site representative
Related Permits:
Norman O Nelson
Inspection Date: 0211512007 Entry Time: 10A5 AM
Primary Inspector: Jennifer M. Freeman
Secondary Inspector(s):
Certification: Phone:
Exit Time: 11:15 AM
Phone: [phone]
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Stormwater
Permit Inspection Type: Timber Products Stormwater Discharge COC
Facility Status: ❑ Compliant ■ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page: 1

r -qt
Permit: NCG210058 Owner - Facility: Nelson Frames Inc
Inspection Date: 02/15/2007 Inspection Type: Stormwater Reason for Visit: Routine
Inspection Summary:
1. Permit
The permit became effective May 1, 2003 and expires April 30, 2008, A copy of the permit was available during the
inspection.
2. Records/Reports
The North Carolina Forestry Association has prepared a general Stormwater Pollution Prevention Plan (SPPP) for
companies that involved in Timber Products. However, the SPPP is not complete and therefore, does not entirely satisfy
the requirements of the permit in its current state. Permit text Part II Section A describes the requirements for the SPPP.
Please refer -to these requirements to complete the SPPP.
3. Facility Site Review
Sawdust from the production process is sent to.an outside dumpster, which is emptied every 2-3 weeks through a contract
with Republic Waste Services. Although there was some evidence of sawdust on the ground surrounding the dumpster, it
was not present in large enough amounts to cause concern. A large oil stain on the ground was discovered under a
delivery truck. You can clean up small spills such as these by tilling the soil to ensure biodegradation of the petroleum
substance. The site also includes one 275-gallon kerosene tank without secondary containment. Due to the lack of
secondary containment around this tank, you are ineligible for No Exposure Certification. If you wish to proceed with
application for No Exposure status, you will need to build a containment wall for the tank.
4. Effluent/Receiving Waters .
Stormwater from the property discharges to an unnamed tributary to Caraway Creek (Class C) in the Yadkin -Pee Dee
River Basin. The site has two stormwater discharge outfalls.
5. Self -Monitoring Program
It was determined during the inspection that you have not been performing the self -monitoring requirements of the
General Permit. Permit text Part iI Section B describes the qualitative monitoring requirements, which are to be
performed on a semi-annual basis. Qualitative monitoring records should be maintained at the facility and made available
to Division of Water Quality staff upon request. You are exempt from the annual analytical monitoring requirements since
your vehicle maintenance activities occurring on -site do not use more than 55 gallons of new motor oil per month when
averaged over the calendar year.
Page: 2

Permit: NCG210058 Owner - Facility: Nelson Frames Inc
Inspection Date: 02/15/2007 inspection Type: Stormwater
Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Yes
No
NA
NE
Does the site have a Stormwater Pollution Prevention Plan?
■
❑
❑
❑
# Does the Plan include a General Location (USGS) map?
■
0
❑
❑
# 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?
■
❑
❑
Cl
# Has the facility evaluated feasible alternatives to current practices?
❑
■
❑
❑
# Does the facility provide all necessary secondary containment?
n
■
n
n
# 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?
❑
■
❑
❑
# 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?
❑
■
❑
Cl
# Does the Plan include a Stormwater Facility Inspection Program?
❑
■
❑
❑
Has the Stormwater Pollution Prevention Plan been implemented?
❑
■
O
❑
Comment: The North Carolina Forestry Association has prepared a general
Stormwater Pollution Prevention Plan (SPPP) for companies that involved in Timber
Products. However, the SPPP is not complete and therefore, does not entirely satisfy
the requirements of the permit in its current state. Permit text Part If Section A describes
the requirements for the SPPP. Please refer to these requirements to complete the
SPPP.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? Cl ■ ❑ ❑
Comment: It was determined during the inspection that you have not been performing
the self -monitoring requirements of the General Permit. Permit text Part II Section B
describes the qualitative monitoring requirements, which are to be performed on a
semi-annual basis. Qualitative monitoring records should be maintained at the facility
and made available to Division of Water Quality staff upon request. You are exempt
from the annual analytical monitoring requirements since your vehicle maintenance
activities occurring on -site do not use more than 55 gallons of new motor oil per month
when averaged over the calendar year.
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? ■ ❑ ❑ ❑
# Were all outfalls observed during the inspection? ■ ❑ ❑ ❑
Page: 3

Permit: NCG210058 Owner - Facility: Nelson Frames Inc
Inspection Date: 0211512007 inspection Type: Stormwater
# If the facility has representative outfall status, is it properly documented by the Division?
# Has the facility evaluated all illicit (non stormwater) discharges?
Comment: Stormwater from the property discharges to an unnamed tributary to
Caraway Creek (Class C) in the Yadkin -Pee Dee River Basin. The site has two
stormwater discharge outfalls.
Reason for Visit: Routine
Q ■ ❑
0 E 0 0
Page: 4