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
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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_
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NCGO50379
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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
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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+
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DOMESTIC LIFT STATE
1 4
KEDS DICK -UP PUMP
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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
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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