NCG200347_Inspection_20191121

W
Charlotte•Mecklenburg
STORM
WATER
Services
November 21, 2019
Southern Metals Company
Attn: Andy Helbein, President
P.O. Box 668923
2200 Donald Ross Road
Charlotte, NC 28266
Subject: Industrial Facility Inspection
Southern Metals Company
Dear Mr. Helbein:
2145 Suttle Avenue
Charlotte, NC 28208-5237
On November 18, 2019, Dustin Moffitt 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.
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:
1) Stormwater Pollution Prevention Plan (SPPP)
A Stormwater Pollution Prevention Plan (SPPP) has been developed, recorded, and implemented.
However, several components were missing from the SPPP that are required under NPDES
General Permit NCG200000. The facility's SPPP should include documentation of a non-
stormwater discharge evaluation, documentation of annual employee training, documentation of
semi-annual stormwater facility inspection, and the SPPP should be reviewed and updated
annually.
2) Qualitative Monitoring
Qualitative monitoring has been conducted and recorded for the first monitoring period of 2019.
The facility should conduct monitoring for the July -December monitoring period.
•
obTo report pollution or drainage problems, call: 311
http://stormwater.charmeck.org
C1IARLOT'IT.
0

Southern Metals Company
Attn: Andy Helbein, President
Page 2
November 21, 2019
3) Analytical MonitorinE
Analytical monitoring has been conducted and recorded with a benchmark exceedance of Copper
and Zinc during the first monitoring period. However, the facility has not been testing for all the
required parameters required by the NCG200000 Permit. The facility should test all parameters
listed in Part II, Section B, Table I of the NCG200000 Permit.
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 704-654-1869 if you have any questions or need additional information. For questions
specifically regarding your State -issued NPDES Stormwater Certificate of Coverage 200347,
please contact James Moore with NCDEQ — DEMLR at [phone].
Sincerely,
Dustin Moffitt
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

ChWottaMeckkmburg 2 1 4 5 S u t t l e Avenue
STORMCharlotte, NC 28208
- WATER Facility Inspection
Services
Facility Name: Southern Metals Company Inspection #: 47497
Contact: Andy Helbein, President Permit #: NCG200347
Inspector: Dustin Moffitt Receiving Stream: Irwin Creek
Inspection Date: 11/18/2019 Entry Time: 1:30 pm Exit Time: 3:00 pm SIC #:
I ME
Facility Description: Southern Metals Company is located at 2200 Donald Ross Road on approximately 35.7 acres. The
facility is a processor of ferrous and non-ferrous scrap metal products. Materials purchased and processed at the facility
include automobile bodies, appliances, steel, wire, radiators, copper, brass, and aluminum.
File Review/History: Southern Metals Company has been previously inspected by Charlotte -Mecklenburg Storm Water
Services (CMSWS) on 2/27/2009, 10/22/2013, and 9/7/2017. During the 2017 inspection, the facility's Storm Water
Pollution Prevention Plan (SPPP) had several missing elements and was missing some monitoring events.
Inspection Summary: During the inspection, Southern Metals Company was observed to be in compliance with the City
of Charlotte Storm Water Pollution Control Ordinance. Several recommendations for protecting and improving water quality
are provided in the report. Several components of the SPPP were missing. Please refer to the attached report for
comments and recommendations.
Site Inspection Deficiency Comments
Stormwater system (catch basins,
No
Stormwater runoff flows through the site via sheet flow and
inlets, outfalls, etc.)
several stormwater inlets to a detention basin best
management practice (BMP). The discharge from this BMP
is the facility's outfall. Flocculant logs and coconut wattles
are utilized to remove metals and solids from runoff. No
problems were observed with the stormwater system.
Erosion issues
Recommendation
Due to the nature of the business erosion is to be expected
as heavy machinery moves throughout the site. Sediment
can fill in detention ponds and reduce the effectiveness of
other BMPs. CMSWS recommends a consistent schedule of
inspection and maintenance for BMPs at each stormwater
inlet and an assessment of the sedimentation ponds for
potential dredging of sediment.
Structural stormwater BMPs
Recommendation
No stormwater issues were observed at the detention pond. A
detention/stormwater recycling collection system and erosion
control socks were observed near the drainage channel
closest to the Shredder area. A consistent schedule of
inspection and maintenance for erosion control BMPs in this
area is recommended. CMSWS also recommends that the
facility add this structure to the SPPP.
Illicit discharges/connections
No
No illicit discharges or connections were observed during the
inspection.
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CHARLOTTE_
11/25/2019 2:21:53PM
To report pollution or drainage problems call: 311
http://stormwater.charmeck.org
Page 1 of 4

INSPECTION
Site Inspection Deficiency Comments
Above ground storage tank(s), and
Recommendation
The facility has the following aboveground storage tanks
any associated venting — list size and
(AST) located indoors with secondary containment: one
contents
500-gallon hydraulic oil, one 500-gallon shear oil, one
500-gallon motor oil, and one 200-gallon gear oil. One
500-gallon used oil AST is located in a covered area near the
vehicle maintenance shed over secondary containment. ASTs
were observed on site that were not reflected in the SPPP.
CMSWS recommends updating the SPPP to reflect all
ASTs.
Underground storage tank(s) - fill port
No
The facility has one 6,000-gallon off -road diesel fuel
area; list tank sizes & contents
underground storage tank (UST), one 6,000-gallon on -road
diesel UST, and one 1,000-gallon gasoline UST. No problems
were observed at the fill ports or fuel dispensers.
Outdoor material storage area(s)
Recommendation
Various types of scrap metal are stored throughout the
facility in large piles for storage and processing. The facility
requires all fluids to be drained from scrap vehicles before
they are purchased from customers. CMSWS observed an
area where multiple car batteries were stacked on top of a
pallet. CMSWS recommends moving the car batteries to a
covered storage area or removing them from the site.
Outdoor processing area(s)
No
Processing of scrap metal (shredding, shearing, etc.) is
performed outdoors. No stormwater issues were observed in
these areas.
Loading/unloading area(s)
No
No stormwater issues were observed in the facility's
loading/unloading areas.
Vehicle/equipment area(s) - fueling,
No
Vehicle fueling is conducted onsite, and general repairs and
washing, storage, etc.
maintenance are conducted onsite at the facility's
maintenance shop. No stormwater issues were observed in
the vehicle/equipment areas.
Oil/water separator and/or
No
According to facility personnel, the facility's oil/water
pretreatment
separator is serviced approximately three times a year. No
stormwater issues were observed in regards to the oil/water
separator.
Waste storage/disposal area -
No
The facility has multiple dumpsters throughout the facility for
dumpsters, scrap metal bins, etc.
municipal waste and scrap metal. No stormwater pollution
issues were observed in these areas.
Food service area(s)
N/A
Indoor material storage area(s)
No
Sorted and processed recyclables are stored indoors at the
facility along with large containers of oil and 55-gallon drums.
No stormwater issues were observed in the indoor material
storage area.
Indoor processing area(s)
No
Recyclable scrap metal is sorted and baled indoors. No
stormwater issues were observed in the indoor processing
areas.
Floor drains
No
A floor drain is located next to the vehicle maintenance shop
in an area where the facility's cranes are maintained. The
floor drain is plumbed to the oil/water separator. No
stormwater issues were observed.
Spill response equipment
Recommendation
Oil dry is located in the vehicle maintenance building.
CMSWS recommends placing a spill kit at each of the fuel
islands as well as the area where some vehicles are drain of
automotive fluids.
stormwater Pollution Plan Observed Comments
•
CHARLOTTE
11/25/2019 2:21:53PM
To report pollution or drainage problems call: 311
http://stormwater.charmeck.org
6
Page 2 of 4

DETAILSINSPECTION
tormwater Pollution Plan Observed Comments
Does the facility have a stormwater
Yes
pollution prevention plan?
General location (USGS) map
Yes
Narrative description of practices
Yes
Detailed site map
Yes
List of significant spills (past 3 years)
Yes
According to facility records, no significant spills have
occurred in the past three years.
Non-stormwater discharge evaluation
No
No documentation of non-stormwater discharge evaluations of
of outfall(s)
outfalls were provided. The facility should visually inspect the
outfall atleast once annually during a period of at least 72
hours without precipitation. Refer to Part 11, Section A, #1(e)
of the NCG200000 Permit.
Feasibility study
Yes
All necessary secondary
Recommendation
Records of secondary containment were available in the
containment provided
SPPP but have not been updated. The facility should update
the SPPP to reflect any new secondary containment.
Collected water evaluated and
N/A
ASTs with secondary containment are located indoors and do
documented prior to release
not collect stormwater. A stormwater detention system
located near the Shredder recycles water and according to
facility personnel, the comingled water is never released.
BMP Summary
Yes
Spill prevention and response plan
Yes
Preventative maintenance and good
Yes
housekeeping plan
Facility provides and documents
No
No documentation of employee training was observed during
employee training
the inspection. The facility should conduct annual employee
training as per Part 11, Section A, #6 of the NCG200000
Permit.
List of responsible parties
Recommendation
Contact information has not been updated. The facility should
update the list of responsible parties as per Part 11, Section
A, #7 of the NCG200000 Permit.
Reviewed and updated annually
Recommendation
Elements of the SPPP are updated annually. The facility
should fully review and update the SPPP annually as per Part
11, Section A, #8 of the NCG200000 Permit. The facility
should add a page to the SPPP to document the annual
review/update.
Stormwater facility inspection
No
No documentation of a semi-annual stormwater facility
program conducted semi-annually
inspection was observed at the time of inspection. The facility
should conduct and document semi-annual stormwater
facility inspections as per Part 11, Section A, #5 of the
NCG200000 Permit.
Qualitative/Analytical Monitoring Observed Comments
Qualitative monitoring conducted
Recommendation
Qualitative monitoring was conducted on 2/18/2019. The
semi-annually
facility should conduct qualitative monitoring for the July -
December monitoring period of 2019 as per Section C of the
NCG200000 Permit.
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C[IU"TTC.
11/25/2019 2:21:53PM
To report pollution or drainage problems call: 3 1 1
http://stormwater.charmeck.org
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Page 3 of 4

Qualitative/Analytical Monitoring Observed Comments
Analytical monitoring conducted
Recommendation
Analytical monitoring was conducted on 8/27/2019 and
semi-annually
2/18/2019. A benchmark exceedance of Copper and Zinc
were reported during the 2/18/2019 monitoring event.
Additionally, the facility has not been testing for all
parameters required in the permit. Please refer to Part II,
Section B of the NCG200000 for Analytical Monitoring
requirements. Table 1 in this section lists all required
monitoring parameters.
Analytical monitoring from vehicle
Recommendation
The facility's average oil use for 2018 was 85 gallons per
maintenance
month. The facility should continue to measure the amount of
new oil used per month and document it semi-annually as per
Part II, Section B, Table 1 of the NCG200000 Permit.
Permit and Outfalls Observed Comments
Copy of permit and certificate of
Yes
200347
coverage onsite
All outfalls observed
Yes
The outfall from the BMP is outfall for the facility. The water
was turbid due to the rain during the inspection. No problems
were observed.
Number of Outfalls Observed
1
Representative outfall status
N/A
documented by NCDWQ
Annual no -exposure self
N/A
re -certification documented
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CII UOTTE.
11/25/2019 2:21:53PM
To report pollution or drainage problems call: 31 1
http://storrnwater.cliarmeck.org
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Page 4 of 4