NCG030627_CEI_20191220

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
ERICO International Corporation
Attn: Katrina Clark, Plant Manager
188 Carolina Road
Aberdeen, ,NC 28315
NORTH CAROLINA
Environmental Quality
December 20, 2019
Subject: COMPLIANCE EVALUATION INSPECTION
NPDES Stormwater General Permit NCG030000
ERICO International Corporation
Certificate of Coverage NCG030627
Moore County
Dear Ms. Clark:
On December 19, 2019, a site inspection was conducted for the ERICO International Corporation facility located at 188
Carolina Road in Aberdeen', Moore County, North Carolina. A copy of the Compliance Inspection Report is enclosed for
your review. Mr. Bob Calegan, EH&S Manager, was also present during the inspection and his time and assistance is
greatly appreciated. The site visit and file review revealed that the subject facility is covered by NPDES Stormwater
General Permit NCG030000 under Certificate of Coverage NCG030627. Permit coverage authorizes the discharge of
stormwater from the facility to receiving waters designated as Quewhiffle Creek, class C waters in the Lumber River
Basin.
As a result of the inspection, the facility was found to be compliant with the conditions of the NCG030000 permit. Please
refer to the enclosed Compliance Inspection Report for additional comments and observations made during the
inspection.
Please be advised that violations of the NPDES Stormwater General Permit are subject to a civil penalty
assessment of up to $25,000 per day for each violation. If you or your staff have any questions, comments, or needs
assistance with understanding any aspect of your permit, please contact me at [phone] or via e-mail at
[e-mail].
Sincerely,
Michael Lawyer, CPSWQ
Environmental Program Consultant
DEMLR
Enclosure: Compliance Inspection Report
ec: Bob Calegan, EH&S Manager— ERICO International Corporation
cc: FRO — DEMLR, Stormwater Files
North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
Fayetteville Regional Office 1 225 Green Street, Suite 7141 Fayetteville, North Carolina 28301
NOR' J.;AROLINA
oeoem m 0 Emtrwm l weed 910.433.3300

Compliance Inspection Report
Permit: NCG030627 Effective: 11/01/18 Expiration: 05/31/21 Owner: Erico International Corporation
SOC: Effective: Expiration: Facility: ERICO International Corporation
188 Carolina Rd
County: Moore
Region: Fayetteville
Aberdeen NC 28315
Contact Person: Bob Calegan Title: EH&S Manager Phone: [phone]
Directions to Facility:
US-1 S to Aberdeen - turn left on NC-211 - in 2.7 mi turn rt on Carolina Rd - ERICO facility is on right just past RR crossing
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
On -site representative Bob Calegan
Related Permits:
Inspection Date: 12/19/2019 Entry Time: 09:50AM
Primary Inspector: Mike Lawyer�G
Secondary Inspector(s):
910-944-4127
Exit Time: 12:40PM
Phone: [phone]
Penny Markle 1��1
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Metal Fabrication Stormwater Discharge COC
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 3

Permit: NCG030627 Owner - Facility: Erico International Corporation
Inspection Date: 12/19/2019 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Inspection conducted to ensure compliance with the conditions of NPDES Stormwater General Permit NCG030000. Met
with Bob Calegan, EH&S Manager. Verified current facility and personnel contact information and provided a general
overview of the NCG030000 permit conditions. Reviewed the facility's Stormwater Pollution Prevention Plan (SPPP), which
was initially drafted in 2012 with subsequent amendments as necessary. The SPPP contains all permit -required
components and is updated annually per the conditions of the permit. Monitoring records for the facility's two stormwater
discharge outfalls were reviewed. Facility has been conducting monthly monitoring under the Tier Two response actions
since 2014 due to consecutive and on -going exceedances of the benchmark values for copper and zinc as well as pH
readings below 6. Due to the use of copper in the facility's processes, there are on -going efforts to address the copper
values in the stormwater discharges that include increased house -keeping and cleaning practices of the roof and facility
grounds. Additionally, limestone rock has been placed within the stormwater outfalls, which has helped to raise pH values to
within the benchmark range of 6-9. Monitoring results from the two most recent monitoring periods indicated zinc values
below the associated benchmark. All other discharge characteristics listed in the monitoring requirements table of the permit
have consistently met benchmark values. Facility has implemented a Solvent Management Plan, which waives the
requirement for TTO monitoring. Discussed facility personnel monitoring pH themselves using a properly calibrated pH meter
within the 15-minute hold time. After the records review, observations were made of site conditions including the stormwater
discharge outfalls, catch basins, loading docks, covered waste material bins and raw material storage areas. At the time of
inspection, facility appeared to be well operated and maintained.
Due to the number of benchmark value exceedances, facility falls under the Tier Three response actions of the permit. Tier
Three conditions allow the Division, among other things, to revise, increase, or decrease the monitoring and reporting
frequency for some or all of the parameters. Based on the facility's compliance with permit conditions and on -going efforts to
address generally consistent benchmark value exceedances as noted above as well as discussion with the DEMLR
Regional Engineer, the subject facility under Certificate of Coverage NCG030627 is hereby authorized to revise their
monitoring schedule for all stormwater discharge outfalls as follows.
1) Conduct and record analytical monitoring for copper, zinc and pH on a quarterly basis.
2) Conduct and record analytical monitoring for TSS, lead and non -polar oil & grease on a semi-annual basis.
3) Conduct and record qualitative monitoring on a quarterly basis.
4) Continue with efforts to address benchmark value exceedances via investigation of potential pollutant sources (i.e.
facility grounds, catch basins, stormwater piping, roof vents, etc.), implementation of best management practices, third -party
consultation, etc.
5) Provide progress reports via e-mail or other correspondence to the Regional Office on a semi-annual basis pertaining to
monitoring results/trends, implementation and maintenance of best management practices, etc.
*Please note that the Division reserves the right to modify or revoke this monitoring schedule revision as deemed necessary.
All other conditions of the NCG030000 permit remain in effect.
Page 2 of 3

Permit: NCG030627 Owner - Facility: Erico International Corporation
Inspection Date: 12/19/2019 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?
M
❑ ❑ ❑
# Does the Plan include a General Location (USGS) map?
0
❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
0
❑ ❑ ❑
# 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?
0
❑ ❑ ❑
# Does the facility provide all necessary secondary containment?
❑
❑ E ❑
# Does the Plan include a BMP summary?
0
❑ ❑ ❑
# Does the Plan include. a Spill Prevention and Response Plan (SPRP)?
N
❑ ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
0
❑ ❑ ❑
# Does the facility provide and document Employee Training?
0
❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
0
❑ ❑ ❑
# Is the Plan reviewed and updated annually?
0
❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
E
❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
0
❑ ❑ ❑
Comment: Facility has no ASTs or other bulk storage containers of liquid products stored outside that would
require secondary containment.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? 0 ❑ ❑ ❑
Comment: Facility has been conducting Qualitative Monitoring monthly along with Analytical Monitorin
under the Tier Two conditions of the NCG030000 permit.
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? ❑ ❑ E ❑
Comment: Facilitv currently in Tier Two monthly monitoring schedule. Onsite vehicle/equipment
maintenance is performed by an outside contractor, however less than 55 -gallons of new motor
oil and/or hydraulic oil is used per month.
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? 0 ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ 0 ❑
# Has the facility evaluated all illicit (non stormwater) discharges? 0 ❑ ❑ ❑
Comment:
Page 3 of 3