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HomeMy WebLinkAboutNCG050379_COMPLETE FILE - HISTORICAL_20100701 (FIX)STORMWATER DIVISION CODII NCG PERMITS PERMIT NO. / V DOC TYPE 5/-HISTORICAL FILE MONITORING REPOR DOC DATE G Qol D D -7 'o YYYYMMDD Nisel , M ri From: Andrew Rodak, P.E. [andy@dunckleedunham.com] Sent: Thursday, July 01, 2010 9:57 AM To: Myrl.Nisely@ncmail.net Cc: 'Britton Ledford' Subject: Response to June 28, 2010 Letter, AirBoss Rubber Compounding (NPDES Storm Water Permit No. NCG050379) Mr. Nisely: Britt Ledford sent me a copy of the letter you submitted to AirBoss dated June 28, 2010. The letter provided two additional comments on responses I provided to the inspection report. Herewith are my responses to those comments: With regards to the absence of qualitative monitoring conducted during the period May 29, 2009 —June 30, 2009 (the remainder of the first monitoring period under the effective date of the permit coverage), I filled out discharge monitoring forms for all three outfalls at the facility indicating that no representative storm event occurred during the monitoring period. I sent them to Mr. Ledford and instructed him to insert them into the facility's SP3 manual; With regards to the sheet flow runoff on the southeast side of the site that flows along and under the fence line, as I indicated in my e-mail to you dated June 17, 2010, during the June 16 monitoring event I identified an outfall (outfall 03) east (on the outside) of the fence line that discharges into a vegetated ditch and eventually into the unnamed tributary to Deep Creek. The sheet flow runoff on the southeast side of the property eventually flows into this ditch as well. Therefore, when I monitored Outfall 03, I also monitored the sheet flow runoff from that area. I believe this satisfies the DWQ's request to include this runoff as a discharge point during a qualitative monitoring event. I submitted the discharge monitoring forms to AirBoss following the June 16 event, and they signed and submitted the forms to the DWQ in advance of the .tune 30 deadline. I am also informing you that I conducted an annual storm water training event at the facility yesterday for pertinent personnel. The training highlighted the elements of the facility's SPCC and SWPP Plans, inspections of outdoor storage areas and outfalls, spill response procedures, and good housekeeping measures. All attendees signed a log sheet that is kept in the facility's SP3 and SPCC Manuals. Please let me know if you have any questions or comments. Please also note my new phone number, mailing and e-mail addresses for future correspondence. Regards, Andy M. Rodak, PE Senior Engineer Duncklee & Dunham, PC Environmental Consultants 511 Keisler Drive -Suite 102 Cary, North Carolina 27518 919-858-9898 Office 919-649-7769 Mobile Email: andy-Ounckleedunham.com Website: www.dunckleedunham.coni ^-,WDODED —/—y SHEET FLOW W INTO MUNICIPAL Q STORM SEWER F-ENCELiNE cr AiRB055 PARKWAY i FORMERLY 7TH ST) . . - . - CARBON BLACK TRAI I.ER STORAGE. �!� r,'PAS'S �/y nvWA.LT DITCH — — 001FALE _— JJJjjj antes : ,� p0 y Q� +l a ACE FLOW P4RCTgh PETROLEUM AST MVENTORT 13 l tirc +Ics IY-. o to ALAt °y1Wu� P7 . DUMPSTER _ , - -_ �. ..�.>.'r; ,• • y... X OUTFAI.L n 03 _. Ir rl m GRASS.- II < — GRASS r n SHEET FLOW kol OUTFACE -#- h.1.liEi. LAhY VI'1(1,.•11. TN a1NYliN�� ya•W� IHURiIk ARC' FENCELINE iwnTfl �lyN- Iaa:Lti GRASS GRA55 `ty F� 40 0 40 SO 120 i 2 S.A�� NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary June 28, 2010 Airboss of America Rubber Compounding Attn: Mr. Britt Ledford 500 Airboss Parkway Scotland Neck, NC 27874-1567 Subject: Airboss Response to Compliance Evaluation Inspection NPDES Stormwater Permit NCG050379 Airboss Rubber Compounding Scotland Neck Halifax County Dear Mr. Ledford: Rodak Engineering submitted responses to the DWQ inspection issues noted during the April 22, 2010 inspection. The improvements made in housekeeping and regular inspections of conditions around the outside of the plant, along with the addition of containment structures where trucks unload carbon black satisfy this office. There are two comments on other topics we wish to make, however: 1. Qualitative monitoring could not be carried out at the times specified in a table in the permit because there was no rain. When this happens, please insert an observation form into the SP3 manual showing the time period involved and stating that no flow occurred. In this way, inspectors will know why data was not available, and can see that this permit requirement was not being forgotten or ignored. 2. Mr. Rodak plans to make observations during a significant rain to identify and/or evaluate all stormwater discharge points. He expressed a judgment that sheet flow traveling to one of the fence lines is not a discharge point even though it concentrates and flows along that fence. It is DWQ's position that reconcentration of the water is a stormwater discharge from the property. Since this permit requires monitoring that only involves a simple visual observation of the water quality during a rain (no gathering of samples for analysis), this office insists that Airboss include this concentrated runoff as another discharge point. When Mr. Rodak completes his survey, please contact RRO again with his findings. This summary is an effort to ensure that all points of stormwater release are fully understood by this office. Thank you for responding to the deficiencies identified by this inspection. If you have comments or questions about this inspection, please contact me at 919-7914200. Sincerely, MyrlrA. Nisely Environmental Chemist Raleigh Regional Office cc SWP/RRO Files Central Files None hCarolina ;atura!!y North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone (919) 791-4200 Customer Service Internet: www ncwaterquality.org 1628 Mail Service Center Raleigh, NC 27699.1628 FAX (919) 788-7159 877-623-6748 An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper ENGINEERING June 14, 2010 Mr. Myrl Nisely Environmental Chemist North Carolina Division of Water Quality 3800 Barrett Drive Post Office Box 27687 Raleigh, North Carolina 27609 Reference: Response to Compliance Evaluation Inspection NPDES Storm water Permit Number NCG050379 AirBoss Rubber Compounding (NC), Inc. Scotland Neck, Halifax County, North Carolina RE Document R 10020 Dear Mr. Nisely: ENVIRONMENTAL ENGINEERING 511 KEISLER DRIVE - SUITE 101 CARY, NORTH CAROLINA 27518 NC LICENSE NO'. C-2691 OFFICE: (919)235-4560 a Rodak Engineering, P.C. (Rodak Engineering), on behalf of our client AirBoss Rubber Compounding, Inc. (AirBoss) submits this letter of response to address findings of a recent compliance inspection at their facility in Scotland Neck, Halifax County, North Carolina. Rodak Engineering is AirBoss's consultant, and presents this letter to address and correct four findings of the inspection, thereby bringing the facility into compliance with the requirements of their General Storm Water Permit. The findings were noted during a site inspection conducted by the Division of Water Quality on April 22, 2010. For clarification purposes, the intended course of action to address each of the findings noted is provided after the finding. (Finding 2 in the letter) There were two requirements not adequately documented. Qualitative monitoring of all four outfalls is to be performed twice per year, on the schedule outlined in Table 2 in the permit. Documents showed only one observation in November 2009 for one outfall. Be sure to give this the attention required especially in light of housekeeping comments in points 3 and 4. The other missing document was the annual employed training. Since the SP3 was written in May 2009, this training needs to he accomplished as soon as possible. MAILING ADDRESS — Posr OrMCI_ Box 33366 — RALI,161 L. NORTI I CAROLINA 27636 Response to Compliance Evaluation inspection AirBoss Rubber Compounding Scotland Neck, North Carolina June 14, 2010 Page 2 of 4 AirBoss's permit was issued and became effective on May 29, 2009. There was not a representative rain event that occurred at the facility during normal facility operating hours during the two months remaining under the Year 2, Period 1 interval as listed in Table 2, Monitoring Schedule of the facility's stone water permit. Therefore, the first monitoring event was conducted during the Year 2, Period 2 interval (November). The next monitoring event will be conducted, weather permitting, in advance of the June 30, 2010 deadline for Year 3, Period 1. AirBoss will make every attempt to comply with the monitoring schedule for the remainder of the permit's effective coverage. During the November 2009 monitoring event, two outfalls (identified as Outfalls 01 and 02 in the SWPPP) were monitored. These were the only two outfalls identified by Rodak Engineering during the preparation of the Storm Water Pollution Prevention Plan (SWPPP). You indicated two additional potential outfalls in the marked -up figure attached to your e-mail dated May 25, 2010, that were based on your inspection. These outfalls are indicated to be northeast of AirBoss Parkway (formerly 71h Street) on the east side of the property, and on the south side of the property. Rodak Engineering did not identify these two outfalls during our development of the SWPPP. Surface runoff on the east and northeast side of the property is directed in toward the center of the property based on surface grade, and there likely is no on -site runoff directed toward the presumed northeast outfall. We observed surface runoff on the south side of the site to be sheet flow, off of the impervious surface and across a pervious (grassed) area into a vegetated ditch that runs outside the fence line along the southern property line. We did not observe a distinctive outfall (pipe, culvert) into this ditch during our development of the SWPPP. You indicated in our phone conversation on May 25 that you also did not observe the two outfalls depicted on the e-mailed site map, but presumed them to be there based on the surface flow depictions on the site map contained in the SWPPP. Rodak Engineering will conduct another site walkover during our next storm water qualitative monitoring event sometime between the date of this letter and June 30, 2010, to verify surface flow directions and attempt to locate outfalls in the areas identified on your marked -up site map. If we identify distinctive outfalls in those areas, we will conduct qualitative monitoring on the outfalls and update the SWPPP to reflect their presence. With regards to employee training, Rodak Engineering will provide training for pertinent personnel during our next monitoring event. We will use the monitoring event as part of the training module, instructing personnel on the outfall locations, what to look for in the discharge from those outfalls, and how to prevent on -site runoff from becoming contaminated with pollutants. The training will be conducted in accordance with the protocol described in the facility's SWPPP, and verification of the training will be logged in the SWPPP. Additional training will be conducted during new employee orientation, whenever changes in facility design or operations affect the facility's chemical storage capability, and annually as part of the facility's HAZWOPER training program. 2. (Finding 3 in the letter) A visual inspection of the plant perimeter included the loading dock, equipment storage and staging areas. There were deficiencies in housekeeping. For example, black material (carbon black) at the storage pad had either been carried through the fence by rainwater or was deposited by a plastic device that had landed outside the fence. This is the kind of contamination the permit is meant to prevent. The storage area needs to be specifically addressed to ensure wastes are not leaving that area. IZQDAK F.,NGING1"RING, P.C. Response to Compliance Evaluation Inspection AirBoss Rubber Compounding Scotland Neck, North Carolina June 14, 2010 Page 3 of 4 Immediately after your inspection, AirBoss implemented housekeeping measures to address the area of concern noted in your inspection report. Attached are photos of the loading dock and storage area around the cooling tower taken after the housekeeping measures, indicating the removal of waste carbon black and other debris from these areas. AirBoss will implement a regular housekeeping schedule that will include weekly inspections of all outdoor raw material and waste storage and transfer areas to identify potential sources of storm water pollution and to clean them up before they impact storm water runoff. The inspection log sheets will be kept in the facility's SWPPP for review. 3. (Finding 4 in the letter) Also observed was clear evidence of'black contamination from under a semi truck parked near the stream we walked, dropping into a channel to that stream (see the attached picture). This constitutes an illegal discharge in violation of'the permit. A cleanup is needed where the truck was parked. Since the location where the semi truck was parked will be utilized as a parking/material loading and unloading area for an indeterminate period, AirBoss is in the process of constructing a concrete pad in this area on which the trucks will be parked. Structural measures may be implemented as part of this construction to contain spills and releases on the pad; these measures may include concrete curbing around the perimeter of the pad with drainage provisions, and/or installation of filter media (straw, hay, or absorbents) around the pad or outfall to reduce pollutant impacts on storm water runoff. At the very minimum, AirBoss will implement general housekeeping measures that will include weekly inspections of the truck parking area and immediately cleanup of spills and releases of carbon black material from the area around the trailers. The SWPPP will be updated when the pad is complete and passive/active measures are implemented. 4. (Finding 5 in the letter) Likelihood of contamination was also evident at the storm water drain for the loading dock. Configuration of piping at the dock has been reported by the local wastewater treatment authorities a bit differently than what you described. The tan tank housing a pump station receives only sanitary wastewater from AirBoss, and is compliant with the Seiner Use Ordinance. Storm water entering the drain at the side of the dock ramp goes into an 8 inch line and then a 36 inch storm drain that continues on a straight path under the building and out the back of the site, instead of going to the pump station. A conscientious on -going commitment to keeping the dock area clean is therefore required to assure a compliant storm water discharge. The dumpster on the dock is a potential liability, too, so employees must maintain good housekeeping around it. As stated in the response to your Finding Number 2, Rodak Engineering will attempt to determine if an outfall exists through which the 36-inch line drains, and, if so, we will conduct qualitative monitoring of the outfall to evaluate the quality of the storm water discharge from the dock areas. As stated in the response to (2), AirBoss will implement a facility -wide housekeeping program that will involve weekly inspections of outdoor raw material and waste handling and storage areas, and will include the dock area and dumpster. Spills and releases in this area will be promptly cleanup up with spill absorbent and removal materials. RoDAK ENGINEERING. P.C. Response to Compliance Evaluation Inspection AirBoss Rubber Compounding Scotland Neck, North Carolina June 14, 2010 Page 4 of 4 Rodak Engineering understands that AirBoss has been granted a 30-day deadline for correcting the noted violations and achieving compliance with the provisions of their storm water permit. As stated previously, Rodak Engineering will attempt to conduct semi-annual monitoring, weather permitting, by the end the of Year 3, Period 1 schedule (June 30, 2010) At the time the monitoring is conducted, we will attempt to locate the two additional outfalls indicated on your marked -up site plan, and, monitor those is necessary. AirBoss has performed housekeeping measures already to address the findings of the inspection, and will implement a housekeeping program following the training. They will also consider structural measures for preventing pollutant impacts on storm water at the trailer parking area, but, at the very least, will implement housekeeping measures in that area to minimize impacts on storm water from spills in that area. Therefore, AirBoss requests an extension of that the compliance deadline until June 30, 2010, to coincide with the deadline for the next monitoring event. If you have any questions or require and additional information, please do not hesitate to call Mr. Britt Ledford of AirBoss at (252) 826-4919, or me at (919) 235-4560. Sincerely, RODAK ENGINEERING, P.C. An Crew Rodak, F.E. Senior Engineer Senior Peer Review: DUNCKLEE & DUNHAM, P.C. Bryso D. Trexler, Jr., Ph.D., F.G. Senior Hydrogeologist cc: Britt Ledford, AirBoss Rubber Compounding Attachments POPROJECrS\AirBoss\Scotland NecklStormwater-R2009291Correspondence\Response Letter to Compliance Inspection-R10020.doc IZODAK ENGINFERING, P.C. Photo of Area around Dumpster, East Loading Dock W Photo of Area around Cooling Tower, South Fence Line. Debris formerly noted in this area during the DWQ inspection has been removed. Photo of Area around Cooling Tower, South Fence Line. Pallets formerly noted in this area during the DWQ inspection have been removed. Photo of Area along western fence line, near carbon black trailer storage pad, showing spill containment/absorbent materials (hay bales) placed upstream of outfall. a Iry North Carolina Department of Environn.-lont aid Naturai Resources Division of VVater.Guality Beverly Ewes Perdue Ooieer7 H. Sullilis Governor DirKtoi- May 29, 2009 Mr. Britton Ledford, Plant Manager Airboss Rubber Compounding, Inc. - 500 Airboss Parkway Scotland Neck, NC 27874 Subject: General Permit No. NCG050000 Airboss Rubber Compounding, Inc. COC-NCGO50379 Halifax County Dear Mr. Ledford: Dee Freeman Secretary In accordance .with your application fora discharge permit received on April G, 2009, we are forwarding herewith the subject certificate ofcovefage to discharge under the subject state — NPDES general permit. This permit, is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memoranduni.of-A�,reement between North Carolina and the US Environmental Protection Agency dated October 15', 2007 (or as subsequently amended). Please take notice that this certificate of coverage is not transferable except after notice to the Division of Water Quality. The Division of Water -Quality may require modification or revocation and reissuance of the certificate of coverage... Per the requirements of the Tar -Pamlico Riparian .Buffer Rule, all storinwater draina�,,e from portions of this site that have been constructed'after January 1, 2000 must be discharged through a correctly designed level spreader or aiiothei device that meets diffuse flow requirements per 15A NCAC 2B .0261. Diffuse flow requirchients are�described in Chapter 8 of the North Carolina Stormwater BMP Manual, available at: 1)ttL://l12o,enr.state,ncwus/su/bitty forms.htni This permit does not affect the legal requirements to obtain other permits which may be required by the Division of Water Quality or permits required by the Division of Land Resources, Coastal Area Management Act or any other federal or local governmental perinit that may be required. Wetlands and Stormwater Branch olle 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 O Location; 512 N. Salisbury St, Raleigh, North Carolina 2'N it.y'cli C?1.11�i 604 � I i Fhone: 919-807.63Q01 FAX: 919-807-641941 Customer Service: 1-871-623-6748 ��/�'�1��'��l'/ Internet, v&vw ncxaterquality.org An Equal Op; ortunity t Affirmative Anion Employer Mr. Britton Ledford Airboss RubbcrCompounding—NCGO50379 May 29, 2009 VW I If you have any questions concerning this permit, please contact Jennifer Jones at telephone number (919) 807-6379 ORIGII SIIGKNED 13Y SinifEWIFICF for Coleen H. Sullins cc: Raleigh Regional Office, Danny Smith Central Files ,Stormwater-Permitting Unit Files STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY GENERAL PERMIT NO. NCG050000 CERTIFICATE OF COVERAGE No. NCGO50379 STORMWATER DISCHARGES NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and_ regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Airboss Rubber Compounding is hereby authorized to discharge stormwater from a facility located at Airboss Rubber Compounding, Inc. 500 Airboss Parkway Scotland Neck Halifax County to receiving waters designated as a UT to Deep Creek, a class C, NSW water in the Tar -Pam Rivet-Basi', in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, I1, II1, IV, V, and VI of General Permit No. NCG050000 as attached. This certificate of coverage shall become effective May 29, 2009: This Certificate of Coverage shall remain in effect -for the duration of the General Permit. ORIGINAL SIGNED Err Signed this day. May 29, 2009, KEN PICKLF for Coleen H. Sullins., Director Division of Water Quality By the Authority of the Environmental Management Commission P_ 6.71 k111L. ,� '1�,�'I��� •fi "" '��r ' .- `� ' ""� wx � � �f k�lrffq�! ' '�i �j�^�_ '��S „ t '.:� • '` <s Ri ���, . J��� � 'vr�"'{'r}/, d s t� ri, & i!fiT114 i'k' �� 4. / i �'$.� t s � i � � i"i � •� ��lC / t�� .' ia1,-���\�\���1l �i `, � r' t •fa r� ���� 'yid I i + ..•...''�+�%'_ _ _ �� 3�� �� ��z�k�� } "''" f ,,� �f � �. J .� r � �'gr,'.af� fw y`��!!y?�t�` � xSri c" �:::e it5g� /✓'�! 4r, a r �x'� r���. � 2Nil ty � •r'"'w"�'� ..i ` � -�K' �i >#' ny,_ +C' �s � y�,� -:� �l F4j , `�� � till• �,t � f��t TA �,,_',�`• � �' ::� ��, � �e �3} � �y�! a� � ��� �' . � f,��„ - ' "�..' 6' lam/ Cj, � lylb :� r �} rr.• Sr°�__ r4 oh► �, L "'•, �• '� 7�"t'"rti�,.l,. Ef: i."aT' �71 1 � f I r fit..__ •..- I�� f• ii`?Is`cf,'✓ ' "K I Airboss Rubber Corn oundin ` r E 97 a 4 l � � � •'� � t •fit '�, � Fq���� 4g' �� )'.'�' . J �7y $j Il1�L�•{g 1 / 97',��_—f�Yr:°!4'.i°1.ef"� "��f �,O �i�v �} f '\ • \ � i Sr '��t� � •S J�f''' :� .� `.3y f��� F �I'��:t� titi�� \.F a�'q :9 tE -�i •`w! I• •" ���-.,:,.,..... "�,� � tit i I ,�`i zi iRadio Tovief Ci '" .et.'J'� r J fr` rr � t a� .''' Sl '•� � It 3 :n`",,.-;. 3t:-��.. Sri' ' 'r:�y J,.1- �,r, r"•.r:. �� 7, tj Or Ilk �-'\l .;j ,t� f / •�- --,:.-Yr_'-�-'-v_'w- � e � ='vim, 1 i r "�a.,ae• '�,: �a� n� r l _ �r_t.. . 2� ',_ '� � ate;` `rl .--yy`�u<f•'tsaw":���,5 �� 1 rf i • ll � "ems: ��--'.: -- J�'-�!� Hm- ;.t�9s'®•a9 �..�'I�>?5\ �� �41t`•.. �i1'. ��"� `•-tm`l �5's'��PF �� r18C NCGO50379 N W , E 5. Map Scale 1:20,864 Airboss Rubber Compounding Scotland Neck, NC Latitude: 36° 07' 20.6" N Longitude: 770 24' 59.9" W County: Halifax County Receiving Stream: UT to Deep Creek Stream Class: C, NSW Sub -basin: 03-03-04 (Tar -Pam River Basin) Facility Location Hi Danny, .00 We've received an NOI from Airboss Rubber Compounding for their site in Scotland Neck (Halifax County) for coverage of their rubber factory under NCG05. The site discharges stormwater into a UT to Deep Creek (C, NSNV). The NOI is attached. ' This facility is in the,Tar Pam River Basin. I am not sure if they are a new facility or not — I have called them and left them a message. Does the Raleigh Regional Office have any concerns about issuing this facility a COC for this general permit? If we don't receive any objections, we'll issue the COC in 30 days, Thanks, Jen B-1 NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary May 18, 2010 Airboss of America Rubber Compounding Attn-. Mr. Britt Ledford 500 Airboss Parkway Scotland Neck, NC 27874-1567 Subject: Compliance Evaluation Inspection NPDES Stormwater Permit NCG050379 Airboss Rubber Compounding Scotland Neck Halifax County Dear Mr. Ledford: On April 22, 2010 I conducted an inspection of the stormwater program at your facility. Your help was greatly appreciated. Attached is a copy of the checklist used. Highlights are as follows: 1. The Stormwater Pollution Prevention Plan (SP3) created in May 2009 was well written with all the required elements. The plan is to be reviewed and revised each year. You indicated that your consultant is expecting to do so soon. 2. There were two requirements not adequately documented. Qualitative monitoring of all four outfalls is to be performed twice per year, on the schedule outlined in Table 2 in the permit. Documents showed only one observation in November 2009 for one outfall. Be sure to give this the attention required, especially in light of housekeeping comments in points 3 and 4 below. The other missing document was the annual employee training. Since the SP3 was written in May 2009, this training needs to be accomplished as soon as possible. A visual inspection of the plant perimeter included the loading dock, equipment storage and staging areas. There were deficiencies in housekeeping. For example, black material (carbon black) at the storage pad had either been carried through the fence by rainwater or was deposited by a plastic device that had landed outside the fence. This is the kind of contamination the permit is meant to prevent. The storage area needs to be specifically addressed to ensure wastes are not leaving that area. 4. Also observed was clear evidence of black contamination from under a semi truck parked near the stream we walked, dropping into a channel to that stream (see the attached picture). This constitutes an illegal discharge in violation of the permit. A cleanup is needed where the'truck was parked. NonhCarolina Naturally North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone (919) 791-4200 Customer Service Internet: www.ncwaterquality.org 1628 Mait Service Center Raleigh, NC 27699-1628 FAX (919) 788-7159 877-623-6748 An Equal Opportunity/Affirmative Action Employer — 50% Recycled110% Post Consumer Paper Airboss CEI, April 2010 Pagc 2 of 2' 5. Likelih'ood of cantamina ion was also evident at the stormwater drain for the loading dock. Configuration.of.piping at the dock has been reported by the local wastewater treatment authorities a bit differently than what you described. The tan tank housing a pump station receives only sanitary wastewater from Airboss, and is compliant with the Sewer Use Ordinance. Stormwater entering the drain at the side of the dock ramp goes into an 8 inch line and then a 36 inch storm drain that continues on a straight path under the building and out the back of the site, instead of going to the pump station. A conscientious on -going commitment to keeping the dock area clean is therefore required to assure a compliant stormwater discharge. The dumpster on the dock is a potential liability, too, so employees must maintain good housekeeping around it. Please respond in writing to this office within 30 days of receipt of this letter with plans for correcting items 2, 3, 4 and 5. If you have comments or questions about this inspection, please contact me at 919-791-4200 or by email myrLnisely(tDncdenr.gov. Sincerely, Myr A. Nisely Environmental Chemist Raleigh Regional Office Attachments cc: SWP/RRO Files Central Files James Pittman, Scotland Neck WWTP ORC Larry Smith, Scotland Neck Collection System ORC Permit: NCGO50379 SOC: County: Halifax Region: Raleigh Compliance Inspection Report Effective: 05/29/09 Expiration: 05/31/13 Owner: Air Boss Rubber Compounding Effective: Expiration: Facility: Air Boss Rubber Compounding 500 Air Boss Pkwy Contact Person: Britt Ledford Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 04/22/2010 Primary Inspector: Myrl Nisely Secondary Inspector(s): Title: Entry Time: 01:05 PM Scotland Neck NC 27874 Phone: 252-826-4919 Certification: Exit Time: 02:35 PM Phone: Phone: 919-791-4200 Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Apparel/Printing/Paper/Leather/Rubber Stormwater Discharge COC Facility Status: ❑ Compliant ■ Not Compliant Question Areas: Storm water (See attachment summary) Page: 1 Permit: NCG050379 Owner - Facility: Air Boss Rubber Compounding Inspection Date: 04/22/2010 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: Housekeeping needs to be improved to keep carbon black from polluting rainwater. Employee training has not been provided since the SPPP was completed in May 2009. Qualitative observations twice per year at every outfall are to be documented. See cover letter for full discussion. Page: 2 Permit: NCGO50379 Owner - Facility: Air Boss Rubber Compounding Inspection Date: 04/22/2010 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? ■ ❑ ❑ ❑ # Does the Plan include a General Location (USGS) map? ■ ❑ ❑ ❑ # 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? ■ ❑ ❑ ❑ # Has the facility evaluated feasible alternatives to current practices? ■ Cl ❑ ❑ # Does the facility provide all necessary secondary containment? ■ ❑ ❑ ❑ # 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 gaining? ■ ❑ ❑ ❑ # Does the Plan include a list of Responsible Party(s)? ■ ❑ ❑ ❑ # Is the Plan reviewed and updated annually? ■ ❑ ❑ ❑ # Does the Plan include a Stormwater Facility Inspection Program? ■ ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? ❑ ■ ❑ ❑ Comment: Employee training has not yet been accomplished in the year since the SPPP was created. In light of observations outside the building, this should be accomplished as soon as possible. Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ONOO Comment: All outfalls are to be observed and documented twice per year. See Table 2 in the permit for the schedule. Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? ❑ ❑ ■ ❑ # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ ■ ❑ Comment: None required. Permit and Outfalls Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? ■ ❑ 110 # Were all outfalls observed during the inspection? ■ ❑ ❑ ❑ # If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ■ ❑ # Has the facility evaluated all illicit (non Stormwater) discharges? ■ ❑ ❑ ❑ Page: 3 ':we. .raw .. rrrM V�i r�cr " �P n 1 ^ ±'•(l . ii 13- 56, ....,�`.�'�3�e.;•rv�"vW-,.IF,v.�J1���'"�.fiC�JS:!�d�,k�,�,'C'x�"...r:a � �=:.1i'�., �";., I ' _T,'s. .'{y Ili ,� � � f �� , i��,.` � i ` : � •. ,1 1 t ), , '�, FYI, '{F'ffi y'r NcGos a31q NANCY JACKSON,CMC TOWN ADMINISTRATOR -CLERK Tofun of iraflaub Nrrh P.O. Box 537 1310 MAIN STREET SCOTLAND NECK, NC 27874 www.townofscotlandneck.com May 11, 2010 TO: Myrl A. Nisely Environmental Chemist NC DENR - Div. Water Quality Raleigh Regional Office 1628 Mail Service Center Raleigh, NC 27699-1628 MAYOR JAMES E. MILLS, SR. COMMISSIONERS FORREST BRADLEY, JR. BRYAN DOBSON VERTIA EVANS CHARLIE SHIELDS RAYMOND WATSON SUBJECT: Inspection performed at AirBoss site in Scotland Neck, NC Fri 4/22/2010 Per your request the Town and United Water has completed an investigation and sampling evaluation of the AirBoss site. Result are as follows: Q la. There is a pump station (the tan tank seen in the pictures) that was reported to be taking stonnwater from the truck dock area and Pumping it into the sanitary sewer. Q9b. We need to know if that pump station may also include sanitary waste from the building. Ala. The site investigation was performed to determine if the pump station included stormwater. As you can see in the attached drawing the 8 inch storm drain from the loading area drains back into a 36 inch storm drain pipe. The drain then exits as a storm drain under the building and out the back of the site. Al b. As the drawing indicates the pump station does handle the sanitary waste only. ****Please note the 8 inch cross connect between sanitary and storm has been plugged. See Attachment 1. Q2. If it does NOT, there may be opportunity for the pump station discharge to be rerouted out of the sewer to a stormwater conveyance that is in the yard just to the_ri_ght of the entrance gate. Further_ if it is ONLY stormwater, this is likeIV a violation of the Scotland Neck Sewer Use Ordinance. A2. As best determined there are no violations of the Scotland Neck Sewer Ordinances. As indicated in (Attachment 1) the storm water goes to storm water drains and the sewer goes to sewer pump station and into the town's sewer treatment system. ! �c Al Phone: (252) 826-3152 Fax: (252) 826-2107 email: scotneck@embargmail.com Q3. Mr. Ledford Britt of Airboss related to me that a contaminated plume of groundwater exists under the building. There are several wells inside the buildinq that serve topump and treat the groundwater to remove methyl ethyl ketone (MEK). My question would be, where is that treated water being discharged? Perhaps it is being put back into the ground, but it also may be that it too, is coming to the WWTP via the sewer. A3. This is not a pump and treat site. See Figure #1. Chemicals are periodically injected into the wells. See figure #2 and all residential homes downstream of the plume have had the wells removed and are placed on city water. Figure 1 PUMP AND TREAT Figure 2 Chemicaf Injection United Water took grab samples checking pH and all were within limits of the Scotland Neck WWfP permit. We hope that this will clear up your concerns and we thank you for your diligence in protecting our environment. Nancy Jackson, CMC Town Administrator/Clerk cc: James Pittman, ORC cc: Larry Smith, Public Works Supervisor - 2 - MAY I ? 9nin I_ Attachment #1 EX 36' MIL RCP qt*- -T-R.UG Ex. OV *FLOW LIK NOTE+ r� DOMESTIC LIFT STATE 1 4 KEDS DICK -UP PUMP +�------- - - - - -- &/ �`� / M ERGS OF PAVVq( y -3- V ��qq 14M AIM MCDEN . North Carolina Department of Environment and Natural Resources Division of Water.Quality Beverly Eaves Perdue Governor Mr. Britton Ledford, Plant Manager Airboss Rubber Compounding, Inc. 500 Airboss Parkway Scotland Neck, NC 27874 Dear Mr. Ledford: Coleen H. Sullins A Dee Freeman Director Secretary May 29, 2009 1•, JUN - 2 2009 A DELI~ VLEIG ONFIGE Subject: General Permit No. NCG050000 Airboss Rubber Compounding, Inc. COC NCGO50379 Halifax County In accordance -with your application fora discharge permit received on April 6, 2009, we are fornvarding herewith the subject certificate of covera—Te to discharge under the subject state — NPDES general permit. This permit is issued p>_u-s>_ia6t to the requirements of North Carolina General Statute 143-215.1 and the Memorandutn.of Afree�ment between North Carolina and the US Environmental Protection Agency dated October 15", 2007 (or as subsequently amended), Please take notice that this certificate of coverage is not transferable except after notice to the Division of Water Quality. The Division of Water Quality may require modification or revocation and reissuance of the certificate of coverage.. Per the requirements of the Tar -Pamlico Riparian Buffer Rule, all stormwater drainage from portions of this site that have been cotistructed after January 1, 2000 must be discharged through a correctly designed level spreader or another device that meets diffuse flow requirements per 15A NCAC 213 .0261. Diffuse flow requirements arc dcscribed in Chaptcr 8 of the North Carolina Stortnwater BMP Manual, available at: littp:Hli2o.eiir.state.iic.tis/su/biiip fortns.httn This permit sloes not affect the legal requirements to obtain other permits which may be required by the Division of Water Quality or permits required by the Division of Land Resources, Coastal Area Management Act or any other federal or local governmental permit that may be required. Wetlands and Stormwater Branch 1617 Mail Service Center, Raleigh, North Carolina 27699-16!7 Location: 512 N. Sa4sbury St. Raleigh, North Carolina 27604 Phone; 919-807-6300 4 FAX 919-807-6494'� Customer service. 1-877-623-6748 Internet: mwi.ncwaterquality.org An Equal Opportunity S Affirmative Action Employer Nort.hC arolina N- atuilily Mr. Britton Ledford Airboss Rubber Compounding—NCGO50379 May 29, 2009 me If you have any questions concerning this permit, please contact Jennifer Jones at telephone number (919) 807-6379 Sincerely, SIGNED BY KEN PICKLE for Coleen H. Sullins cc: Raleigh Regional Office, Danny Smith Central Files Stormwater Permitting Unit Files STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY GENERAL PERMIT NO. NCG050000 CERTIFICATE OF COVERAGE No. NCG050379 STORMWATER DISCHARGES NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Airboss Rubber Compounding is hereby authorized to discharge stormwater from a facility located at Airboss Rubber Compounding, Inc. 500 Airboss Parkway Scotland Neck Halifax County to receiving waters designated as a UT to Deep,Creek, a class C, NSW water in the Tar -Pam River Basin', in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts 1, II, III, IV, V, and VI of General Permit No. NCG050000 as attached. This certificate of coverage shall become effective May 29, 2009. This Certificate of Coverage shall remain in effect for the duration of the General Permit. Signed this day May 29, 2009, ORIGINAL SIGNED BY KEN PICKLE for Coleen H. Sullins., Director Division of Water Quality By the Authority of the Environmental Management Commission Tour � Seat Ck C., T K V Airboss Rubber Compounding V6 J , e .01 i p 97 J-k TI, 97 104 4� FaCLO Y,3VM( A6, I 40- Aq /4 "A. 74, - NCG0503:79 N w E S Map Scale 1:20,864 Airboss Rubber Compounding Scotland Neck,, NC Latitude: 360 07' 20.6" N Longitude: 770 24' 59.9" W County: Halifax County Receiving Stream: UT to Deep Creek Stream Class: C, NSW Sub -basin: 03-03-04 (Tar -Pam River Basin) P Facility Location