NCG030607_Technical Assistance_20190923

MROY COOPER
Governor
MICH.AEL_ S. PEGAN
Secretary
S. DANIEL SMITH
Director
O'Neal Manufacturing Services
Attn: Matthew Cox
105 East Florida Street
Greensboro, NC 27406
NORTH CAROLINA
Environmental Quality
September 23, 2019
Subject : Technical Assistance Report:
Permit No. NCG 030607
O'Neal Manufacturing Services — Greensboro
Guilford County
Dear Permit Holder:
On September 17, 2019, Brandon Wise, inspector with the North Carolina Department of
Environmental Quality (NCDEQ) — Division of Energy, Minerals, and Land Resources, met with facility
contacts at the facility located at 105 E. Florida Street in Greensboro. The purpose of this visit was to
assist the facility in addressing some issues that had come up in recent samples and internal audits. The
facility and Stormwater Pollution Prevention Plan (SWPPP) were also inspected during this inspection.
Permit:
This facility has General Stormwater Permit NCG030607 to discharge stormwater from industrial
activity associated with Fabricating or Working of Metal Products [SIC(s) 33, 34, 35, 36, 37, 38]
under the National Pollutant Discharge Elimination System (NPDES). This version of the permit was
issued on November 1, 2018 and will expire on May 31, 2021. The facility has been permitted since May
25, 2011.
Records/Reports:
This facility is required to develop and maintain a SWPPP in accordance with Part II, Section A
of the permit. All qualitative and analytical monitoring records are required to be maintained with the
SWPPP for a minimum of five (5) years. Under this permit, analytical monitoring is required under
current operating procedures. The facility records are kept up to date and kept with the SWPPP in the
main office. Recent monitoring was having some issues with zinc exceedances however prior to this
inspection it was discovered that part of the issue was coming from sample location. The sample location
will be updated to help reduce the zinc issue. The SWPPP at the facility during this inspection was out of
date and a new one was being put together. The new SWPPP was sent to NCDEQ for review and was a
much more well-rounded SWPPP. The facility is required to maintain employee training records in
accordance with Part II, Section A, Item 6 of the permit. Along with implementation of the new SWPPP
training records should be kept with the SWPPP as well.
Facility Site Review:
This facility operates as manufacturer of multiple different metal products. The facility is graded
in a way that stormwater from the south side of the facility (non -industrial side) flows to two different
outfalls on the southeast and southwest corners of the facility. These outfalls will not require analytical
sampling as they do not have industrial activity in their drainage areas.
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NCiITH G;0.'ttOL'.Nti
Department of Eaviromme W Quality
North Carolina Department of Environmental Quality j Division of Energy. Mineral and Land Resources
Winston-Salem Regional Office ( 450 Hanes Mill Road, Suite 300 { Winston-Salem, North Carolina 27103
336.776,9800

Stormwater on the northern part of the facility flows east to a drop inlet near the railroad tracks. This
drop inlet will be the sample point for analytical samples. Previously samples were being taken directly
from roof drains and not from where the water discharged to the drop inlet. A majority of the industrial
activity is performed inside of the large warehouses at the facility. Some storage of materials is located at
the northern part of the site and this is where the potential for the pollutants to reach the stormwater
exists. Some of this storage area has stormwater that sheet flows off the eastern side of the site, NCDEQ
requests that when collecting samples from the other outfalls this area of sheet flow is inspected
qualitatively. This process should ensure that if an issues arises it will be discovered during regular rain
events. The northernmost part of the facility is shared with a leased warehouse. During the inspection it
was discovered that at one -point potential pollutants were stored at that warehouse. NCDEQ
recommends that should some issues arise and there be potential pollutants being stored at this warehouse
that samples be taken from the stormwater coming onto the facility from the other warehouse. The
general housekeeping for the facility was good as even the areas with storage remained relatively clean.
There were a few areas that needed to be swept up as sediment was present and exposed to the
stormwater.
Effluent Receiving Waters:
Effluent from this facility drains into Mile Run Creek, class "WS-V; NSW" waters of the Cape
Fear River Basin. Please note that currently this class of waters does have the nutrient sensitive waters
classification therefore impacts can be subject to penalties.
Self -Monitoring Program:
This facility is required to provide qualitative and analytical monitoring twice annually. The
outfall discharge from the facility is expected to be properly maintained and monitored. At the time of
the inspection monitoring was being done and the outfalls looked to be properly maintained. The two
outfalls at the southern edge of the facility are removed from analytical requirements unless changes
occur at the facility. NCDEQ recommends monthly facility inspections and the reports should be kept
with the SWPPP. All monitoring requirements were met during this inspection.
There are no additional comments or changes to the currently operating permit. Please continue
to keep up the facility and monitor stormwater discharges. If you have any questions or need additional
information, please contact Brandon Wise at [phone] or [e-mail].
Sincerely,
Brandon Wise
Stormwater Specialist
Land Quality Section
Winston-Salem Regional Office
Enclosures: Inspection Report
cc: NCDEQ — DEMLR (WSRO)

Compliance Inspection Report
Permit: NCG030607 Effective: 11/01/18 Expiration: 05/31/21 Owner: O'Neal Steel Inc
SOC: Effective: Expiration: Facility: O'Neal Steel Inc
County: Guilford 105 W Florida St
Region: Winston-Salem
Greensboro NC 27406
Contact Person: Ed Arceneaux Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 09/17/2019
Primary Inspector: Brandon L Wise
Secondary Inspector(s):
Entry Time: O:OOAM
Certification:
Exit Time: 11:OOAM
Reason for Inspection: Routine Inspection Type
Permit Inspection Type: Metal Fabrication Stormwater Discharge COC
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Phone:
Phone: [phone]
Technical Assistance
Page 1 of 3

Permit: NCG030607 Owner - Facility: O'Neal Steel Inc
Inspection Date: 09/17/2019 Inspection Type : Technical Assistance Reason for Visit: Routine
Inspection Summary:
Site has very good housekeeping. There were three designated outfalls at the site, only one will be required for analytical
sampling as the others do not include any industrial activity. These other outfalls should be visually monitored on the same
regular schedule. One other sheet flow area that could be subject to some industrial activity was requested to be visually
monitored regularly. New SWPPP is very well put together.
Page 2 of 3

Permit: NCG030607 Owner - Facility: O'Neal Steel Inc
Inspection Date: 09/17/2019 Inspection Type : Technical Assistance Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan?
0
❑ ❑ ❑
# Does the Plan include a General Location (USGS) map?
N
❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
N
❑ ❑ ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
0
❑ ❑ ❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
0
❑ ❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
E
❑ ❑ ❑
# Does the facility provide all necessary secondary containment?
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?
0
❑ ❑ ❑
# Does the facility provide and document Employee Training?
E
❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
M
❑ ❑ ❑
# Is the Plan reviewed and updated annually?
0
❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
0
❑ ❑ ❑
Comment: Old SWPPP had been implemented at time of inspection new SWPPP was sent for review.
All
aspects were included and it looked very well put together.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? 0 ❑ ❑ ❑
Comment:
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? 0 ❑ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ 0 ❑
Comment: Some Zinc issues as expected Gave recommendations on how to address these concerns.
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? 0 ❑ ❑ ❑
# Were all outfalls observed during the inspection? ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ N ❑
# Has the facility evaluated all illicit (non stormwater) discharges? 0 ❑ ❑ ❑
Comment:
Page 3 of 3