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HomeMy WebLinkAboutNCG160036_COMPLETE FILE - HISTORICAL_20160111STORMWATER DIVISION CODING SHEET NCG PERMITS PERMIT NO. DOC TYPE. L HISTORICAL FILE ❑ MONITORING REPORTS DOC DATE ❑ C)w YYYYMMDD TL -3 1 y PAT MCCRORY Governor DONALD R. VAN DER VAART Secretary January 11, 2016 Mr. George Marsh, President Gelder & Associates Incorporated 3901 Gelder Drive Raleigh, NC 27603 Subject: Multimedia Compliance Inspection Gelder & Associates Incorporated Wake County Dear Pernuttee: Department of Environment and Natural Resources staff conducted a multimedia compliance inspection of Gelder & Associates Incorporated on November 20, 2015 for permitted and/or other activities administered by the following Divisions: Division of Air Division of Energy, Division of Water Division of Waste Quality(DAQ) Mineral, and Land Resources (DWR) Management (DWM) Resources DEMLR We hope that you have enjoyed the benefit of our initiative to provide a single inspector capable of handling multiple areas of environmental compliance at your facility. The results of each applicable inspection area and any associated response actions or necessary corrective measures are detailed in the Division specific areas of the attached report. If there are no notes or comments under each Division header, you may assume compliance with that particular Division's rules and regulations at the time of inspection. Should violations be noted in the attached report, you may receive separate enforcement related correspondence in addition to this report. If you have any questions regarding this multimedia inspection, please contact me at Cheng Zhang (cheng.zhang@ncdenr.gov). Thank you for your cooperation. cc: ^DAQ RACi Piles DEMLR RRO Files DWR RRO Files Department of Environmental Quality, Raleigh Regional Office httt)I/ponahicdenmorg 1628 Mail Service Center, Raleigh, NC 27699-1628 Phone: (919) 791-4200 Location: 3800 Barrett Drive, Raleigh, NC 27009 Pax: (919) 571-471 N -.fir;:. 1 •. PAT MCCRORY Gowmm Environmental Quality January 11, 2016 CERTIFIED MAIL 70143490000188214109 RETURN RECEIPT REQUESTED Mr. George Marsh, President Gelder & Associates Incorporated 3901 Gelder Drive Raleigh, NC 27603 Subject: Notice of Deficiency, Case No.: NOD-2016-0003 NPDES Stormwater Compliance Evaluation Inspection Certificate of Coverage No. NCG160036 Gelder & Associates Incorporated Wake County Dear Mr. Marsh: DONALD R. VAN DER VAART secmtory Staff from the Department of Environmental Quality (DEQ) conducted a stormwater inspection on November 20, 2015, as part of a multimedia inspection of your facility. Your assistance during the inspection was greatly appreciated. The inspection report is attached. Findings during the inspection were as follows: 1. Certificate of Coverage (COC) No. NCG160036 under NPDES General Permit NCG160000 was issued to Gelder & Associates. Incorporated to discharge stormwater runoff to an unnamed tributary to Mills Branch, a Class C, NSW stream, in the Neuse River Basin. 2. The facility has developed,a stormwater pollution prevention plan (SPPP). A review of the plan indicated that it included most components required by the general permit. However, the following items were noted: a) The plan has not been reviewed/updated annually as required by the General Permit. Annual plan review/update must be documented. b) Employee training has not been conducted and documented; c) The General Permit in the stormwater file was an -expired version; please replace it with a current effective version, which is available from DEQ website. d) Secondary containments were provided to all above -ground storage tanks Division of Energy, Mineral, and Land Resources Land Quality Section Raleigh Regional Officel628 Mail Service Center, Raleigh, North Carolina 27699-1628 Phone: 919-791-4200 / FAX: 919-571-4718 / Internet: http://portal.nedenr.org/web/Ir/ An Equal Opportunity \ Affirmative Action Employer — 50% Recycled \ 10% Post Consumer Paper Page 2 of 2 (except for the 1000-gallon used oil tank (provided by Noble Oil), which has no containment). Itwas noted that drain valves were left open at all containments. Please ensure these valves are closed and locked. An inspection log shall be developed to document visual inspections when stormwater from the containments is released. 3. Semi-annual qualitative monitoring has' been conducted at one stormwater discharge outfall (SDO1). However, four more SDOs.were identified during the site visit (see Figure 1). As discussed during the inspection, runoff at SD05 could be diverted to SD02, runoff at SD05 could be diverted to SDOL Once flow diversions are completed, qualitative and analytical monitoring must be conducted at SDO1, SD02, and SD03. Outfall locations shall tie marked on the updated site map. The facility also needs to develop a log to document monthly usages of new motor oil. 4. Oil and grease accumulated on the ground were noted in the equipment power, wash area (see Figure 1), process wastewater from the area was contained in a small catch basin, which was almost full at the time of inspection. The wastewater generated in this area needs to be appropriately,collected and treated, contaminated soil shall be removed. Please explain in your response to this letter how you plan to properly dispose of the process, wastewater. Ploaea ra¢pnnrl.in writinor in, TWO Raleigh Revinnnl Qf_fi_ce regardine Item g 2s-3,-anrl 4 within 30 days of receipt of this letter. If you have any questions regarding the attached report or any of the findings, please contact Cheng Zhang at 919-791-4200 (or email: cheng.zhang(@ncdenr.g_ov). Sincerely, Re 'onal Engineer; NC Depf. of Environment Quality Division of Energy, Mineral and Land Resources Land Quality Section, Raleigh Regional Office Enclosure: Compliance Evaluation Inspection Form , cc: Central Files RROSWPfiles Compliance Inspection Report Permit: NCG160036 Effective: 10/02/14 Expiration: 09/30/19 Owner: Gelder&Assoclnc SOC: Effective: Expiration: Facility: Gelder & Assoc Incorporated County: Wake 3901 Gelder Dr Region: Raleigh Raleigh NC 27603 Contact Person: George Marsh Title: Phone: 919-772-6895 Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 11/20/2015 Entry Time: 09:30AM Primary Inspector: Thaddeus W Valentine Secondary Inspector(s): Certification: Phone: Exit Time: 12:30PM Phone: Gary Perlmutter Phone: Chang Zhang Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Asphalt Paving Mixture Stormwater Discharge COC Facility Status: ❑ Compliant . Not Compliant Question Areas: Storm Water (See attachment summary) Page: 1 Permit: NCG160036 Owner- Facility: Gelder B Assoc Inc Inspection Data: 1112012015 Inspection Type: Compliance Evaluation Reason for Visit- Routine Inspection Summary: Page: 2 Permit: NCG160038 Owner- Facility: Gelder B Assoc Inc Inspection Date: 11/20/2015 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? 0 ❑ ❑ ❑ # Does the Plan include a list of significant spills occurring during the past 3 years? ❑ ❑ ® ❑ # Has the facility evaluated feasible alternatives to current practices? 0 ❑ ❑ ❑ # Does the facility provide all necessary secondary containment? ❑ 0 ❑ ❑ # Does the Plan include a BMP summary? 0 ❑ ❑ ❑ # Does the Plan include a Spill Prevention and Response Plan (SPRP)? 0 ❑ ❑ ❑ # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? 0 ❑ ❑ ❑ # Does the facility provide and document Employee Training? ❑ 0 1:1 ❑ # 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? 0 ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? ❑ 0 ❑ ❑ Comment: The SPPP was developed in 1999 and does appear to be reviewed or updated since. Secondary containment was Provided to all storage tanks that exposed to stormwater, except for the 1000-gallon used oil tank provided by Noble Oil however we observed that drains on the containment walls were left open. Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ❑ 0 ❑ ❑ Comment: Five potential Stormwater Discharge Outfalls were identified during the inspection semi-annual qualitative monitoring has been conducted at iust one SDO (SD01). 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: Five potential Stormwater Discharge Outfalls were identified during the inspection semi-annual analytical monitoring has been conducted at iust one SDO 9SO01) Non -polar oil & grease was not analyzed since the new permit cycle began (October 1 2014) 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? ❑ ®❑ ❑ Page: 3 Permit: NCG160036 Owner -Facility: Gelder &Assoc Inc Inspection Date: 11/20/2015 Inspection Type: Compliance Evaluation Reason for Visit Routine Comment: Wastewater generated from equipment power wash has been collected in a catch basin which was almost full at the time of inspection and might overflow over the berm. Soil contamination in the area is a concern. The facility needs to collect and treat the wastewater appropriately. Page: 4 5377 NORTH CAROLINA DIVISION OF AIR QUALITY Inspection Report Date: 11/20/2015 Facility Data Gelder & Associates Incorporated 3901 Gelder Drive Raleigh, NC 27603 Lot: 35d 39.7870m Long: 78d 42.3690m SIC: 2951 / Paving Mixtures And Blocks NAICS: 324121 / Asphalt Paving Mixture and Block Manufacturing I Contact Data Facility Contact Authorized Contact Technical Contact Robert Davis Asphalt Quality Control George Marsh President (919) 772-6895 Comments: Appeared to be in comP=7 Inspector's Signature: ' Ow V 2 S• Date of Signature: II1' George Marsh President (919)772-6895 Gelder & Associates Incorporated NC Facility ID 9200314 County/FIPS: Wake/183 Permit 00379 / RI6 Issued 5/22/2015 Expires 1/31/2017 Classification Synthetic Minor Permit Status Active Current Permit Application(s) None Program Applicability SIP NSPS: Subpart I Compliance Data Inspection Date 11/20/2015 Inspector's Name Gary Perlmutter Operating Status Operating Compliance Code Compliance - inspection Action Code FCE On -Site Inspection Result Compliance I Total Actual emisslons In TONS/YEAR: I TSP SO2 NOX VOC CO PM10 HAP 2010 2.67 0.0100 2.63 3.10 9.14 1.86 435.90 2005 9.48 0.0100 4.40 6.34 17.44 5.16 832.67 Ive Year Violation History: None Date Letter Type 'erformed Stack Tests since lost F Date Test Results Rule Violated Test Method(s) Violation Resolution Date Source(s) Tested (1) DIRECTIONS TO SITE: Gelder and Associates, Incorporated is located at 3901 Gelder Drive, Raleigh, Wake County. From PRO, take Six Forks to Old Wake Forest. Tura right on Old Wake Forest and follow to merge with Capital Blvd. Take Capital Blvd. to US-70 E / US401 S. At the split of US-70 E / US401 S, follow US401 S. Gelder Drive is on the right just after Ten -Ten Rd. '?'00314 In>pc•Cti0it Report I';�ge�2 (II) FACILITY DESCRIPTION: Gelder & Associates, Inc. (Gelder) operates a multiple fuel -fired drum hot mix asphalt (HMA) plant in Wake County. The HMA plant is rated 350 tons per hour capacity, but is currently permitted to run up to 280 tons / hr resulting from a source test conducted in 2013. Established in 1996, plant currently operates 8 hr/day, 5 days/week. Gelder employs —58 personnel, 6 of whom are actually involved in the daily operation of the asphalt plant. Safety Notes: Be attentive to moving vehicles and conveyor belts when on site. Use standard safety equipment including a hard hat, steel -toed shoes, safety glasses, and earplugs. (111) INSPECTION SUMMARY: On March 27, 2015,1(Gary Perlmutter) with Thaddeus Valentine (DEMLR-RRO) and Cheng Zheng (DWR-RRO) visited the Gelder HMA plant in Raleigh for a multimedia inspection addressing air and stormwater media. This report addresses the air medium component of the inspection. Upon approaching the facility, we detected no odors from the facility; we observed only a steam plume emitting from the plant's baghouse stack. The weather was clear, but the site was wet from the previous day's rain. We met with Mr. George Marsh, President and Authorized / Technical Contact. Mr. Marsh informed us that he had replaced the asphalt drum about a year ago, and reconfigured the recycled asphalt plant equipment (i.e. conveyors and bins) in an effort to increase recycled asphalt production up to 40%. 1 advised Mr. Marsh to consult with DAQ permitting staff to determine if this warrants a pemdtmodification. We reviewed the permit stipulations then toured the facility. The plant was operating, and while a steam plume was observed from the baghouse, a particulate plume of about 15% VE was observed beyond the steam. Records were reviewed in the plant control room, where a copy of the current permit was also seen tacked onto the wall. All required records appeared complete and up-to-date. Overall, the facility appeared to be maintained well from an air quality standpoint. Further details follow. (IV) PERMITTED EMISSION SOURCES: Emission Emission Source Control Control System Source (D Description I System 1D Description Drum Mix Asphalt Plant (350 tons per hour maximum capacity, 280 tons per hour permitted production rate) Natural gas / No. 2 fuel oil / liquid petroleum gas- Cyclone (112 inch diameter), ES I-1 fired, 350 tons / hr (280 tons / hr permitted CD -I, CD-2 in series with a bagfilter (NSPS) production rate), drum mix type asphalt plant (11,581 square feet of filter 110 10.5 mmBtu / hour maximum heat input rate) area) All equipment was observed onshe and in operation. The facility also has a recycled asphalt plant (RAP) (hat was formerly permitted. The RAP was removed from the permit in revision R15 as its emissions from this source are considered fugitive and thus not requiring a permit. (V) SPECIFIC PERMIT CONDITIONS: A. 1. Permittee shall comply with Title 15A NCAC, Subchapter 2D .0202, 2D .0506, 2D .0516, 2D .0521, 2D .0524 (40 C F R 60, Subpart 1), 2D .0535, 2D .0540, 2D .061 I, 2D .I806 and 2Q .0315. Appeared to be in compliance — see below. A.2. PERMIT RENEWAL AND EMISSION INVENTORY REOUIREMENT - At least 90 days before this permit's expiration date, the Permittee shall request a renewal and submit the air pollution emission inventory report for the 2015 calendar year in accordance with 15A NCAC 2D .0202. Appeared to be in compliance — I reminded Mr. Marsh of this condition. A.3. PARTICULATE CONTROL REQUIREMENT - As required by 15A NCAC 2D .0506 "Particulates from Hot Mix Asphalt Plants," 9200314 Inapdc(iun 1(tpnr( 1'ngc 13 a. PM emissions resulting from the operation of a HMA plant shall not exceed allowable emission rates. b. VE from stacks or vents at a HMA plant shall be < 20% opacity when averaged over a six -minute period. c. Fugitive dust emissions shall be controlled as required by 15A NCAC 2D .0540, d. Fugitive emissions for sources at a HMA plant not covered elsewhere under this Rule shall not > 20% opacity averaged over six minutes. e. All HMA batch plants shall be equipped with a scavenger process dust control system for the drying, conveying, classifying, and mixing equipment. The scavenger process dust control system shall exhaust through a stock or vent and shall be operated and maintained in such a manner as to comply with the allowable particulate emission rate and opacity limit of this Rule. Appeared to be in compliance — The facility appeared to be operating properly with VE < 20% observed from the baghouse emission stuck and fugitive sources. A.4. SULFUR DIOXIDE CONTROL REQUIREMENT - As required by I SA NCAC 2D .0516, sulfur dioxide emissions from the combustion sources shall not exceed 2.3 pounds per million Btu heat input Appeared to be in compliance — The facility is currently operating with natural gas as its sole fuel source. Mr. Marsh Indicated that the facility had not used fuel oil for a number of years, but wishes to retain the fuel oil option In the permit in case of need. A.S. VISIBLE EMISSIONS CONTROL REQUIREMENT - As required by 15A NCAC 2D .0521, visible emissions from the emission sources, manufactured after July 1, 1971, shall not be > 20% opacity when averaged over a six -minute period. Appeared to be in compliance— I observed about 15% VE coming from the baghouse stack during the facility tour. A.6. 15A NCAC 2D .0524 "NEW SOURCE PERFORMANCE STANDARDS (NSPS)" - For ID No. ESl-1, die Perriduce shall comply with all applicable provisions contained in NSPS as promulgated in 40 CFR 60, Subpart 1, including Subpart A "General Provisions." a. NSPS Emissions Limitations - the Permittec shall not discharge or cause the discharge into the atmosphere from any affected source any gases which: I. Contain particulate matter in excess of 90 mg/dscm (0.04 gn'dscf); or ii. Exhibit 20 percent opacity, or greater. b. Recordkeeping Requirement - Asa result of the June 5.6, 2013 compliance test, the asphalt production shall not exceed 280 tons per hour. For each day of operation, the Permittee shall maintain records showing the total production in tons, the hours of operation, and the highest targeted hourly production rate for that day. Appeared to be in compliance — Recordkeeping is maintained in a logbook. All records were observed including the (tours of operation, which began in March 2014, after the previous inspection when they were found deficient. The most recent entries were on November 18, which logged 1,641 tons asphalt produced and 8.75 hr operation for that day, and a cumulative production of 143,037 tons asphalt for 2015. A.7. NOTIFICATION REQUIREMENT - As required by 15A NCAC 2D .0535, the Permittee of a source of excess emissions that last > 4 hr. and results from a malfunction, a breakdown of process or control equipment or any other abnormal conditions, shall notify DAQ by the next business day. Appeared to be in compliance — Mr. Marsh indicated that no such incidents have occurred; 1 reminded him of this stipulation. A.S. FUGITIVE DUST CONTROL REQUIREMENT - As required by 15A NCAC 2D .0540, the Permittee shall not cause or allow fugitive dust emissions to cause or contribute to substantive complaints or excess visible emissions beyond the property boundary. Appeared to be in compliance — no fugitive emissions were observed during the inspection; the site was still largely wet from the previous day's rain. No dust complaints have been riled against the facility. A.9. CYCLONE REQUIREMENTS - As required by I5A NCAC 2D .0611, particulate matter emissions shall be controlled as described in the permitted equipment list. a. Inspection and Maintenance Requirements - the Permittee shall perform an annual inspection of the cyclone system as well as periodic inspections and maintenance (1&M) as recommended by the manufacturer. i. the Permiuee shall perform an monthly inspection of the cyclone system. In addition, the Permittee shall perform periodic I&M as recommended by the manufacturer. b. Recordkeeping Requirements - The results of all inspections and any variance from the manufacturer's recommendations shall be investigated with corrections made and dates of actions recorded in a logbook. Records of 0200114 insp:crion Rcptnt 11itgc14 all maintenance activities shall be recorded in the logbook. The cyclone logbook be kept on -site and made available to DAQ personnel upon request. Appeared to be in compliance - the facility logbook was reviewed and found complete with monthly checks and occasional repairs recorded. The most recent cyclone Inspection was conducted on November 2, 2015. A.10. FABRIC FILTER REQUIREMENTS - As required by 15A NCAC 2D .0611, particulate matter emissions shall be controlled as described in the permitted equipment list. a. Inspection and Maintenance Requirements - the Permiuee shall perform, at a minimum, a monthly internal inspection of each bagftlter system as well as periodic 1&M as recommended by the equipment manufacturer. b. Recordkeening Requirements - The results of all inspections and any variance from manufacturer's recommendations shall be investigated with corrections made and dates of actions recorded in a logbook. Records of all maintenance activities shall be recorded in the logbook. The logbook shall be kept on -site and made available to DAQ personnel upon request. Appeared to be in compliance - the facility logbook was reviewed and found complete with monthly checks and occasional repairs such as bag changings recorded. The most recent baghouse-related entry was a replacement of two bags on November 17, 2015. A.1 I. CONTROL AND PROHIBITION OF ODOROUS EMISSIONS -As required by 15A NCAC 2D .1806, the Permittee shall not cause or contribute to objectionable odors beyond the facility's boundary. Appeared to be in compliance - No odors were detected outside the property boundary during the inspection, although mild - moderate asphalt odors were detected near the equipment. DAQ has received multiple odor complaints to which investigations were made on the following dates: March 25, 2015, June 6, 2013, March 2011, December 2009, April 2008, and October 2004. None were round substantiated. A.12. LIMITATION TO AVOID 15A NCAC 20.0501 - Pursuant to 15A NCAC 2Q .0315 "Synthetic Minor Facilities," to avoid the applicability of I SA NCAC 2Q .0501 "Purpose of Section and Requirement for a Permit," as requested by the Permittee, facility -wide emissions shall be less than the following: Pollutant Emission Limit ,(Tons per consecutive 12-month period) S.T..O- .. 100...- ._...__. -- CO 1 100 a. Operations Restrictions - the following restrictions shall apply: i. The sulfur content of the No. 2 fuel oil shall be limited to 0.5%sulfur by weight. ii. The amount of asphalt produced shall not exceed 1,500,000 tons per consecutive 12-month period. b. Recordkeening Requirements i. The Permittee shall record monthly and total annually the following: A. The total amount of asphalt produced (in tons). ii. Fuel supplier certification shall be kept on -site and made available to DAQ personnel upon request. c. Reporting Requirements -Within 30 days after each calendar year, the Permittee shall submit the following: i. data listed below; these should include monthly and 12 month totals for the previous 12-month period. A. Tons of asphalt produced; B. CO and S0: emissions. Appeared to be in compliance - Mr. Marsh indicated that the facility only burns natural gas. The onsite production records were reviewed and found to appear complete and up-to-date with the 14,099 tons asphalt produced In October 2015. The most recently submitted annual report was received at the RRO on April 1, 2015. In 2014, 150,744 tons of asphalt were produced CO emissions were 10.13 tons and SOr emissions were 0.008 tons. (VI) GENERAL PERMIT CONDITIONS: B.2. RECORDS RETENTION REQUIREMENT - Any records required by the conditions of this permit shall be kept on site for at least 2 yrs. and made available to DAQ personnel for inspection upon request. Appeared to be in compliance - All required records were reviewed onsite and found to be complete and up-to-date. 9200114 1nspdction Itcport Pugc 15 B.14. PERMIT RETENTION REOUIREMENT - The Permittee shall retain a current copy of the air permit at the site. The Permittee must make available to personnel of the DAQ, upon request, the current copy of the air permit for the site. Appeared to be in compliance- The facility copy of the current air permit Is posted Inside the Control House. B.15. CLEAN AIR ACT SECTION 112(r) REOUIREMENTS -Pursuant to 15A NCAC 2D .2100 "Risk Management Program," if the Permittee is required to develop and register a risk management plan pursuant to Section 112(r) of the Federal Clean Air Act, then the Permittee is required to register this plan with the USEPA in accordance with 40 CFR Part 68. Not Applicable - The facility is not subject to the 112(r) program. Gelder had submitted an RMP In 1999 for Its propane which is held onsite above its threshold quantity, but withdrew it upon discovery that the propane is exempted as fuel. B.16. PREVENTION OF ACCIDENTAL RELEASES - GENERAL DUTY - Pursuant to Title I Part A Section 112(r)(1) of the Clean Air Act "Hazardous Air Pollutants - Prevention of Accidental Releases - Purpose and General Duty," although an RMP may not be required, if the Permittee produces, processes, handles, or stores any amount of a listed hazardous substance, the Permittee has a general duty to take such steps as are necessary to prevent the accidental release of such substance and to minimize the consequences of any release. Appeared to be in compliance - (from previous inspection) Included with the prior submitted RMP was a propane safety information packet, which had contained: 1) copies of propane MSDS from two vendors; 2) copied pages from a NPGA (National Propane Gas Association) section titled "How to Handle Gas Leak and/or Odor Service Calls", which Includes leak reporting guidelines; and 3) a sheet titled "Emergency Procedure for a Propane Leak". (VII) INSIGNIFICANT / EXEMPT SOURCES Source Exemption Source of Source of - Regulation TAPS? Title V Pollutants? Ilan - 30,000 gallon asphaltic cement storage 1102 (c)(1)(D)(i) Yes Yes tank. �oQ IS-3 - 1.5 mmBtu/hour LPG -fired hot oil heater. 2Q .0102 (c)(2)(B)(u) Yes �� Yes IS-2 - 30,000 gallon LPG storage tank.- 2Q .0102 (c)(1)(D)(i) Yes _r Yes I{~� IS-4 - 10,000 gallon diesel storage tank.-_-___..-F2Q .0102 (c)(1)(D)(i) Yes Yes IS-5a - liquid asphalt storage tanks (3,000 �''-Q•0102(c)(I)(D)(i) Yes Yes gallons). - - _._..__ - - -_ �_ .. _ . I IS-6a - hot storage asphalt silos. �2Q .0102 (c)(_xE)(i) Yes I Yes IS-7 - five cold feed bins. �2Q .0102 (c)(2xE)(i) �No I Yes IS-51a - liquid asphalt storage tanks (10,000—�— 12Q.0102(cHl)(D)(i) Yes Yes gallons). I I__-- IS-5c - liquid asphalt storage tanks (20,01 .0102 (c)(I)(D)(i) I Yes Yes gallons). 12Q IS-Sd - liquid asphalt storage tanks (30,000 {� Yes Yes gallons). '2Q.0102(c)(I)(D)(i) __,._..��- _ IS-6b - hot storage asphalt silos. 2Q .0102 (c)(2)(E)(i) Yes Yes IS-6c - hot storage asphalt silos. i26 .6102 (c)(2)(E)(i) Yes Yes IS-F-5 - cold aggregate handling conveyor 0102 IS-F-6 -cold aggregate handling conveyor .2Q .O102 (c)(2)(E)(i) I No Yes .._.. -.___....__-...--a-__..._... .__ _ ._... _ _... .... IS-FJ -cold aggregate handling conveyor �2Q .0102 (c)(2)(E)(i) ....._. __.._.. ' No .. ..._.._ .__....._._ ( Yes IS-F-B • cold aggregate scalper 2Q .0102 (c)(2)(E)(i) v20(1114 InspeCIiun ILcp.11t 11ago 16 Most sources were verified and observed in operation during the inspection. According to Mr. Marsh, IS-Sb or IS-Sd are probably no longer onsite. IS-5c should be listed as 15,000 gallons and not 20,000 gallons. (Vlll) SOURCE TEST REVIEW: In its air compliance history, Gelder has record of two source testings: • July 10, 1996 (original test) — the asphalt plant was tested for compliance with NSPS Subpart 1. The opacity average during the testing was 7.3% (limit 20%) and the measured particulate emission rate was less than one third of the emission limit. • June 6, 2013 — This source testing was at DAQ request for compliance with current permit stipulations A.3 (Particulate Control from Hot Mix Asphalt Plants) and A.6 (NSPS Subpart 1). The request was triggered by a series of VE emissions observations from the Asphalt Plant's stack over the past three inspections. Compliance was demonstrated. (IX) COMPLIANCE HISTORY: Gelder & Associates has the following compliance history: • April 15, 2015 — an NOD was issued for unpermilted fuel type and recordkeeping. • March 19, 2015 — an NOD was issued for a late annual report. • December 8, 2011 — an NOD was issued due to a late permit renewal package. • April 27, 2010 — an NOV was issued for a B.6 violation due to high emissions from the bagfilter stack. • March 6, 2006 — an NOV was issued to this facility for failure to submit an updated Risk Management Plan. • May 30, 2003 — an NOV/NRE was issued for another late quarterly report. • October 23, 2002 — an NOV was issued for a late quarterly report. (X) CONCLUSIONSIRECOMMENDATIONS, At the time of the inspection, Gelder & Associates Inc. appeared to be in compliance with its permitting requirements with two deficiencies noted. It is recommended that the facility be re -inspected in one year. STORMWATER DISCHARGE OUTFALL (SDO) ANNUAL SUMMARY DATA MONITORING REPORT (DMR) Annual Report for Year 2014 (Renewal Permit Expiring 9/30/2019) Revised 9/172014 General Permit No. NCG160000 Certificate of CoverageNo.NCG160036 This monitoring report summary is due to the DEMLR Regional Office no later than November 1 of each year. Facility Name: Gelder & Associates, Inc. County: Wake Phone Number: (9� 772-6895 Total no. of SDOs monitored 1 Part A. Outfall No.001 (use multiple sheets for multiple outfalls) Is this outfall currently in Tier 2 (monitored monthly)? Was this outfall ever in Tier 2 (monitored monthly) during the past year? If this outfall was in Tier 2 last year, why was monthly monitoring discontinued? Enough consecutive samples below benchmarks to decrease frequency ❑ Received approval from DEMLR to reduce monitoring frequency ❑ Other Outfall 001 Total Rainfall, inches 00530 TSS, mg/L Benchmark N/A 501100 Date Sample Collected, mo/dd/yr = M 10/15/2014 1.5 14 Yes ❑ No X ❑ Yes ❑ No X ❑ 1E ! P` I Ifi 7 s 3 2014 NC DENR Raleigh Regional Office Page I I I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations." Signature Date o� Mail Annual DMR Summary Reports to: 3800 Barrett Drive Raleigh, NC 27609 (919)791-4200 Page � 2 STORMWATER DISCHARGE OUTFALL (SDO) ANNUAL SUMMARY DATA MONITORING REPORT (DMR) ORI G1 NA t Calendar Year 2013 General Permit No. NCG160000 Certificate of Coverage (COC) No. NCG 160036 Facility Name: Gelder & Associates Inc. County: Wake Phone Number: (919 ) 772-6895 Total no. of SDOs monitored Outfall No. 001 Is this outfall currently in Tier 2 (monitored monthly)? Yes ❑ No Was this outfall ever in Tier 2 (monitored monthly) during the past year? Yes ❑ No If this outfall was in Tier 2 last year, why was monthly monitoring discontinued? Enough consecutive samples below benchmarks to decrease frequency ❑ Received approval from DWQ to reduce monitoring frequency ❑ Other ❑ 00530 00400 00556 Total Total Petroleum Rainfall, TSS, mg/I pH, S.U. Hydrocarbons, inches mg/1 Benchmark 'N/A 100 6.0-9.0 15 Date Sample Y Collected = mm/dd/yy, _ 03/12/13 0.6 16.0 7.0 <5.0 09/20/13 0.18 30.3 6.3 <5.0 SW U-264-Generic-25May2010 I certify, under penalty of law, that this document.and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations." Signature Date /0 3 /1 DWO Regional Office Contact Inform2 e j 2090 US Highway 70 Swannanoa, NC 28778 (828)296-4500 , 3800 Barrett Drive Raleigh, NC 27609' (919)791-4200 585 Waughtown Street Winston-Salem, NC 27107 (336) 771-5000 , Mail Annual DMR'Summary Reports to 225 Green Street Systel Building Suite 714 Fayetteville, NC 28301-5043 (910)433-3300 943 Washington Square Mall Washington, NC 27889 (252)946-6481 161E Mail Service Center Raleigh, NC 27699-1617 (919)807-6300 610 East Center Avenue/Suite 301 Mooresville, NC 28115 (704)663-1699 127 Cardinal Drive Extension Wilmington, NC 28405-2845 (910) 796-7215 To preserve prolecl and enhance f North Carolinas valer 11_i �g�gv SW 1_1-264-Generic-25May2010 STORMWATER DISCHARGE OUTFALL (SDO) ANNUAL SUMMARY DATA MONITORING REPORT (DMR) Calendar Year 2011 O v General PermifNo. NCG160000 Certificate•of Coverage (COC) No. NCG1160036 This monitoring report summary of the calendar year is due to the DWQ Regional Office no later than March I" of the following year. Facility Name: `Gelder & Associates. Inc. County: Wake Phone Number: Total no. of SDOs monitored 1 Outfall No. 001 Is this outfall currently in Tier 2 (monitored monthly)? Was this outfall ever in Tier 2 (monitored monthly) during the past year? If this outfall was in Tier 2 last year, why was "monthly monitoring discontinued? Enough consecutive samples below benchmarks to decrease frequency ❑ Received approval from DWQ to reduce monitoring frequency ❑ Other ❑ 9' Yes ❑ No ®.� -i r� `Lj OCT 202011 IVC DEVF; Balogh R40nai Office 11 1 11.11 11 . ••••. ��k-i�� "f-Fa�^3�j* 3'�.�, t' r y M1{{ � �� ia` w ; ui..U♦, r «;«3�ikF«pa �s :�,- "t 'd :s:V� _ SW U-264-Generic-25May2010 "I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware_ that there are significant penalties for submitting false information, including the possibijity of fines and imprisonment for knowing violations." Signature Date H oil "•' Mail Annual DMR Summary Reports to: DWQ Regional Office Contact Information• 2090 US Highway 70 Swannanoa, NC 28778 (828)296-4500 3800 Barrett Drive Raleigh, NC 27609 (919)791-4200 585.Waughtown Street Winston-Salem, NC 27107, (336) 771-5000 - 225 Green Street Systel Building Suite 714 Fayetteville, NC 28301-5043 (910) 433-3300 943 Washington Square Mall Washington, NC 27889 (252)946-6481 . 1617 Mail Service Center Raleigh, NC 27699-1617 (919)801-6300 { 610 East Center Avenue/Suite 301 Mooresville, NC 28115 (704)663-1699 127 Cardinal Drive Extension Wilmington, NC 28405-2845 (910) 796-7215 "To preserve, protect and enhance North Carolina's svatec.." SW U-264-Generic-25May2010 STORMWATER DISCHARGE OUTFALL (SDO) ANNUAL SUMMARY DATA MONITORING REPORT (DMR) Calendar Year 2011 General Permit No. NCG160000 Certificate of Coverage (COC) No. NCG 160036 This monitoring report summary of the caleendar year is due to the DWQ Regional Office no later than March 15` of the following year. Facility Name: Gelder & Associates Inc. County: Wake Phone Number: (919 ) 772-6895 Total no. of SDOs monitored Outfall No. 001 Is this outfall currently in Tier 2 (monitored monthly)? Was this outfall ever in Tier 2 (monitored monthly) during the past year? If this. outfall was in Tier 2 last year, why was monthly monitoring discontinued? Enough consecutive samples below benchmarks to decrease frequency ❑ Received approval from DWQ to reduce monitoring frequency ❑ Other ❑ Benchmark Date Sample Collected, mm/dd/yy 03/01 /11 r Yes ❑: No Yes ❑ No V � �Cj202411 R�conai'G�L� 00530" 00400 00556. Total is Total Rainfall, TSS m /I " 9 s u ". „Petroleum t ` inches i =Hydrocarbons,, m /I .., NIA 100. 0090. 15 1.0 28.3 3.0 0.25 163 121 Invalid -- <5.0 27 <5.0 SW U-264-Generic-25May2010 STORMWATER DISCHARGE OUTFALL (SDO) ANNUAL SUMMARY DATA MONITORING REPORT (DMR) Calendar Year 2011 General Permit No. NCG160000 s. Certificate of Coverage (COC) No. NCG 160036 'p ,�/Vc This monitoring reportsummary of the calendar year is due to the DWQ Regional Office no later than March 1s` of the following year. Facility Name: Gelder & Associates. Inc. County: Wake Phone Number: 919 ) 772-6895 Total no. of SDOs monitored 1 Outfall No. 001 Is this outfall currently in Tier 2 (monitored monthly)? Yes ❑ No Was this outfall ever in Tier 2 (monitored monthly) during the past year? Yes ❑ No If this outfall was in Tier 2 last year, why v:as monthly monitoring discontinued? Enough consecutive samples below benchmarks to decrease frequency ❑ Received approval from DWQ to reduce monitoring frequency ❑ Other ❑ 00530 „.">... .00400s t-E00556 y Total Rainfall inches' :. , ',°, TSS mgll— z s Exv,''F, ]� _ r upp s u N, � _ r}'"'aTOtalri it�`^.3'auyi u Petroleums Mydrocarbons;� `„ y..m llrf .', g tiro a r Y".z� tat xs �T.✓':'` ` fad JsL �-e�'-� E:y,`a=+* 3* a„. t n �, ` �s Benchmark N/A .. 100 .' . 60, 9 0 15 Date Sample' Collected s mmldd/YYJ m` � „ R + { ON 03/01/11 1.0 28.3 7.21 Invalid 04/27/11 3.0 -- -- <5.0 09/21/11 0.25 163 7.27 <5.0 SW U-264-Generic-25May2010 I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of ,fines and imprisonment for knowing violations." Signature Date Mail Annual DMR Summary Reports to: DWQ Regional Office Contact Information: 2090 US Highway 70 225 Green Street I 610 East Center Avenue/Suite�301 Swannanoa, NC 28778 Systel Building Suite 714 Mooresville, NC 28115 (828) 296-4500 Fayetteville, NC 28301-5043 (704) 663-1699 (910) 433-3300 3800 Barrett Drive 943 Washington Square Mall IVCardinal Drive Extension Raleigh, NC 27609 Washington, NC 27889 Wilmington, NC 28405-2845 (919) 791-4200 (252) 946-6481 (910) 796-7215 WINSTON`SAkEWREGIONAItOFFICE CEN?PRALtOFFI,_CE `+ 85 Waughtown Street 1617 Mail Service Center a„To preserve pivtecta` Winston-Salem, NC 27107 Raleigh, NC 27699-1617 i andenh' 771-5000_ (91� 807-6300 cCarolinasvraier SWU-264 G'e6eric'25May20f0 14 /vC6 i 0036 U-j 0, L C.� V"--,f STORMWATER POLLUTION PREVENTION PLAN GELDER & ASSOCIATES, INC. October 1999 Prepared for: Gelder & Associates, Inc. 3901 Gelder Drive Raleigh, North Carolina 27603 Prepared by: Applied Water Technology 621 Hutton Street, Suite 107 Raleigh, North Carolina 27606 (919)836-8688 Gelder & Associates' SPPP October 1999 Page 2 DISCLAIMER This Stormwater Pollution Prevention Plan was developed for Gelder & Associates, Inc.to use at their Raleigh, North Carolina facility. Modifications to the plan, other than those to accommodate changes in normal plant operations required by the execution of this SPPP, or reuse for other facilities or operations for which this document was not originally intended are not recommended. Any such modification or reuse without written verification or adaptation by AWT, as appropriate, for the specific purpose intended will be at Gelder & Associates' sole risk and without liability or legal exposure to AWT from all claims, damages, losses, and expenses including attorneys' fees arising out of or resulting therefrom. Any such verification or adaptation will entitle AWT to further compensation at rates to be agreed upon by Gelder & Associates, Inc. and AWT. Gelder & Associates' SPPP October 1999 Page 3 Certification 1, George Marsh (Vice President), certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. 1 am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. Name and Official Title George Marsh, Vice President Signature Date Signed Area Code and Telephone No. (919) 772-6995 Gelder & Associates' SPPP October 1999 Page 4 TABLE OF CONTENTS SECTION PAGE 1. POLLUTION PREVENTION TEAM 6 11. FACILITY MAPS 8 III. SITE ASSESSMENT 12 1. Chemical Inventory 12 2. Potential Pollutant Evaluation 12 3. Existing Management Practices 17 4. Existing Monitoring Data 18 5. Spill Incidents 18 6. Non-Stormwater Discharge Certification 20 IV. BEST MANAGEMENT PRACTICES 21 V. PERSONNEL AWARENESS AND TRAINING 27 1. Introduction 27 2. Spill Prevention Measures 27 3. Housekeeping 28 4. Preventative Maintenance 28 5. Specific Personnel Duties 29 6. Outside Contractors 30 7. Facility Inspections 30 8 Stormwater Sampling 31 Vl. STORM WATER POLLUTION PREVENTION PLAN EVALUATION 34 1. Semi -Annual Site Compliance Evaluation 34 2. SPPP Revisions 34 3. Record Keeping and Internal Reporting 35 4. EPCRA, Section 313 Chemicals 35 (continued next page) TABLE OF CONTENTS (continued) TABLES Table I Significant Material Areas Table 2 Chemical and Material Inventory Table 3 Exposed Significant Materials Table 4 Significant Spills and Leaks Table 5 Pollutant Source Summary Table 6 Best Management Practice Summary Table 7 Best Management Practice Implementation Table 8 Employee Training FIGURES Gelder & Associates' SPPP October 1999 Page 5 to 15 16 19 24 25 26 33 Figure I Pollution Prevention Team Organization Chart 7 Figure 2 Pre-BMP Site Map 9 Figure 3 Facility Location Map I I Figure 4 Example Stormwater Systems Evaluation Form 32 Gelder & Associates' SPPP October1999 Page 6 I. POLLUTION PREVENTION TEAM Leader George Marsh, Vice President Signatory authority Hazard Communication Training Members Inez Underwood , Treasurer Coordinate SPPP & BMP implementation Coordinate employee training Retain all records Emergency response director Coordinate and submit documentation of required stormwater sampling Safety/spill response coordinator Responsible for annual site compliance evaluation & SPPP revisions Ensure reports/forms are submitted to leader Larry Martin, Plant and Shop Manager Oversee facility inspections Note process changes Responsible for spill training Performs facility inspections Shift Workers Responsible for general good housekeeping and clean-up of routine spills Group Activities Targeting stormwater management options Gelder & Associates' SPPP October 1999 Page 7 Figure 1 Pollution Prevention Team Organization Chart Vice President George Marsh Treasurer Inez Underwood Plant and Shop Manager Larry Martin Shift Workers Gelder & Associates' SPPP October 1999 Page 8 II. FACILITY MAPS The pre-BMP site map located in the map pocket identifies the representative stormwater outfall, drainage areas, and locations of significant materials at the facility prior to implementation of any Best Management Practices (BMPs). The significant material areas indicated on the pre-BMP site map are listed in Table 1. The facility pre-BMP site map presented in Figure 2 shows the site location for all stormwater discharges. The significant material areas listed are located on the pre-BMP site map in Figure 2. Gelder & Associates' SPPP October 1999 Page 9 Figure 2 Pre-BMP Site Map (See Map Pocket) Area 1 Area 2 Area 3 Area 4 Area 5 Gelder & Associates' SPPP October 1999 Page 10 Table 1 Significant Material Areas* Diesel fueling station: 3-diesel oil tanks within secondary containment (2-6,000 gallons and 1-3,000 gallons) 2 propane tanks (1,000 and 500 gallons) 2 empty liquid asphalt (partially underground) Truck washing area Storage structure for steam cleaner soap Truck parking area Accumulation of miscellaneous scrap metal debris 7,500 gallon tanker of CRS 1 tacking Uncovered dumpster Pond #2 Maintenance shop area 400 gallon hydraulic oil tank, 400 gallon motor oil tank, 200 gallon gear oil tank, and 125 gallon underground waste oil tank Asphalt release station 10,000 gallon diesel fuel tank within secondary containment 30,000 gallon propane tank 30,000 gallon liquid asphalt tank 750 gallon heat transfer oil station Large accumulated piles of sand and stones and reclaimed asphalt Laboratory building Pond #I Water truck filling area * The significant material areas listed are located on the pre-BMP site map. II1. SITE ASSESSMENT 1. Chemical Inventory Gelder & Associates' SPPP October 1999 Page 12 A review and inventory of the facility raw material information, supplied by Gelder & Associates, was performed and is summarized in Table 2. The table outlines the purpose/use, quantity used and stored on -site, and the likelihood of stormwater contact for each material. Chemical Inventory materials that are exposed to stormwater contact are further described in Table 3. 2. Potential Pollutant Evaluation The potential for stormwater contact with pollutants exists at locations around the facility. A visual inspection of the facility by Applied Water Technology (AWT) on September 2, 1999 and October 7, 1999 revealed the following potential pollutant areas: Area 1 A fueling station is located in this area and contains two 6,000 gallon and one 3,000 gallon diesel fuel. These three tanks have secondary containment. There is the potential for oil and grease buildup from trucks used in this area for filling or emptying of the tanks. Two propane tanks, 1,000 gallons and 500 gallons, are also located in this area. Since propane is a gas there is no potential for stormwater contamination. Two liquid asphalt tanks, empty and partially underground, are located in this area. There is minimal potential for stormwater contact with these tanks or residues from these tanks. Truck washing is performed on a concrete pad located between the propane tanks and diesel oil tanks in this area. A storage structure that contains the 55 gallon barrels of steam cleaner is located between the washpad and diesel oil tanks in this area. Runoff from Area 1 flows south into the pond (pond #2) on the southwest side of the property. The pond ultimately discharges into Middle Creek. Gelder & Associates' SPPP October 1999 Page 13 Area 2 Truck parking and accumulated piles of miscellaneous metal debris are located in this area. There is the potential for oil and grease buildup from trucks with leaks to accumulate on the ground in this area. An uncovered dumpster filled with miscellaneous debris from the office and shop area. The potential also exists for stormwater to contact residues from the debris in the dumpster and accumulated piles in this area. A 7,500 gallon tanker of tacking solution is located in this area. Runoff from Area 2 flows south into the pond (pond #2) on the southwest side of the property. This pond ultimately discharges into Middle Creek. Area 3 A maintenance shop and asphalt release station is located in this area. A 400 gallon hydraulic oil tank, 400 gallon motor oil tank, 200 gallon gear oil tank, and 55 gallon drums of numerous products such as aluminum brite are stored inside the maintenance shop. A 125 gallon underground waste oil tank located on the southern side of the maintenance shop collects the sanitary wastes and waste liquids to be disposed of from the facility. Noble oil periodically empties the waste oil tank. The asphalt release station is used to rinse out excess buildup from the trucks. At most, two 55 gallon barrels of release agent are located at this station. Trucks park in this area while excess residues are being removed at the asphalt release station or while being serviced at the maintenance shop. There is the potential for oil and grease buildup from trucks with leaks to accumulate on the ground in this area. Runoff from Area 3 flows south/southwest into the pond (pond #2) on the southwest side of the property. The pond ultimately discharges into Middle Creek. Area 4 This area includes the actual asphalt plant operation facility. A 10,000 gallon diesel oil tank, 30,000 gallon propane tank, 30,000 liquid asphalt tank, and a 750 gallon heat transfer oil station in this area. The diesel fuel tank has secondary containment. Since propane is a gas there is no potential for stormwater contamination. There is minimal Gelder & Associates' SPPP October 1999 Page 14 potential for stormwater contamination from the liquid asphalt tank. The liquid asphalt solidifies quickly when released from the tank. Large sand and aggregates are piles are located in this area. Trucks park in this area while being filled with the asphalt mixture. There is potential for oil and grease buildup on the ground from trucks with leaks. Runoff from Area 4 flows south and collects in a ditch, along the south side of the asphalt plant operations, and flows west into the pond (pond #2) on the southwest side of the property. The pond ultimately discharges into Middle Creek. Area 5 The laboratory is located in a renovated house between the asphalt plant operations area and the pond on the south southeast side of the facility. A propane tank used for space heat is located in this area. Trucks park on the path on the west side of pond #1 and are filled with water from the pond. There is the potential for oil and grease buildup from trucks with leaks to accumulate on the ground in this area. Runoff from Area 5 flows south into the south southeast pond (pond #1) and then flows west through a pipe into the pond (pond #2) on the southwest side of the property. Gelder & Associates' SPPP October 1999 Page 15 Table 2 Chemical and Material Inventory Material Purpose/ Use(gallons) Quantity Purchased/Stored Contact with Stormwater Hydraulic Oil Vehicle Upkeep 400 No Motor Oil Vehicle Upkeep 400 No Propane Space Heat Space Heat Process Heat 1,000 500 30,000 Yes Gear Oil Vehicle Upkeep 200 No Diesel Fuel Vehicle Fuel Vehicle Fuel Vehicle Fuel Process Fuel 6,000 6,000 3,000 10,000 Yes Hot Oil Tank Process Heat 750 Yes Liquid Asphalt Asphalt 30,000 Yes Asphalt Release Agent R-6690 Cleaner 160 Yes Aluminum Brite Cleaner 55-110 No Antifreeze Vehicle Upkeep 55 No Steam Cleaner Soap 55 No CRS 1 Tacking/bonding agent 7,500 Yes Gelder & Associates' SPPP October 1999 Page 16 Table 3 Exposed Significant Materials Method of Existing Practice of Description of Storage (e.g. Material Exposed Quantity Location (as pile, drum, Management (e.g. Significant Period of Exposed indicated on tank) pile covered, drum Material Exposure (Units) site map) sealed) Propane gas 2 yrs All Area 1,4 tank None Diesel fuel 10 yrs All Area 1, tank Secondary 3 yrs Area 4 containment H draulic oil 12 yrs All Area 3 tank Inside building Motor oil 12 yrs All Area 3 tank Inside building Gear oil 12 yrs. All Area 3 tank Inside building Hot oil 3 yrs All Area 4 tank None Liquid Asphalt 3 yrs All Area I, tank None 23 yrs. Area 4 Waste oil 12 yrs. None Area 3 tank Underground CRSI tacking/ Exchanged All Area tanker None bonding agent periodically Asphalt release Exchanged All Area 3 barrels None agent periodically Dumpster 46 yrs All Area 2 dumpster None contents Gelder & Associates' SPPP October 1999 Page 17 3. Existing Management Practices There are numerous areas at the facilities that already employ measures that reduce stormwater contact with significant materials and activities. These areas are as follows: Area 1 The three diesel oil tanks have secondary containment provided to contain any spills while loading or unloading the tanks. The steam cleaner soap is located inside a storage structure to reduce the potential for stormwater contact. Area 3 The hydraulic oil, motor oil, and gear oil tanks are kept in the maintenance shop, which eliminates the potential for stormwater contact. Area 4 The diesel fuel tank has secondary containment provided to contain any spills while loading or unloading. A baghouse is being used to collect airborne particles generated as a result of material handling operations. Gelder & Associates' SPPP October 1999 Page 18 4. Existing Monitoring Data There is no existing stormwater monitoring data available. All stormwater monitoring data will be collected in the future under the requirements of the general stormwater permit. A rain gauge has been installed and will be used to monitor precipitation. 5. Spill Incidents As required by regulation, an audit of all spills and leaks was completed for the past 3 years. No spills have occurred at this facility in the three years prior to issuance of Gelder & Associates' general stormwater permit as defined in Table 4. Gelder & Associates' SPPP October 1999 Page 19 Table 4 Significant Spills and Leaks Gelder & Associates' SPPP October 1999 Page 20 6. Non-Stormwater Discharge Certification Gelder & Associates, Inc. personnel have inspected the facility floor drain piping and confirmed that all non-stormwater discharges are collected in an underground waste oil tank and is periodically emptied by Noble Oil. Plant Manager Certification I, George Marsh (Vice President), certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. Name and Official Title George Marsh, Vice President Date Signed Area Code and Telephone No. (919) 772-6895 Gelder & Associates' SPPP October 1999 Page 21 IV. BEST MANAGEMENT PRACTICES Best Management Practices (BMPs) address potential pollutant areas that were identified during the facility site assessment. The BMPs are designed to help reduce the potential for stormwater pollution. Recommended BMPs for the previously identified areas are as follows: Area 1 There is obvious oil and grease accumulated on the ground in this area. The soil in this area that has been contacted by oil and grease should be removed and disposed of properly. Berms and ditches should be provided to divert runoff from this area to reduce the amount of stormwater contacting the pollutants in this area. Periodic inspections of the containment structures in this area should be conducted for evidence of corrosion. It is recommended that the wash water be collected and piped into the underground waste oil tank and disposed of properly. Area 2 A cleaning schedule should be established to periodically clean up debris and place into an appropriately segregated storage area. It is recommended that the dumpster in this area be covered to protect the waste materials inside from exposure to stormwater. Drip pans should be placed under the trucks parked in this area to collect any oil drippage. Area 3 The hydraulic oil, motor oil, and gear oil tanks should continue to be kept inside the maintenance shop. Periodic inspections of the tanks should be conducted for evidence of corrosion. The asphalt release station area should be located on a concrete surface and berms or ditches constructed to direct flow into a collection tank to be disposed of properly. Gelder & Associates' SPPP October 1999 Page 22 Area 4 Periodic inspections of the tanks and containment structure should be conducted for evidence of corrosion. Berms and ditches should be provided to divert runoff around the piles of sand and aggregates in this area to reduce the amount of stormwater contacting the pollutants in this area. The hot oil transfer station should be covered to reduce the potential for stormwater contact with any residuals on the equipment. General Best Management Practices for the site in general will include regular comprehensive facility inspections, maintaining an updated material inventory, and ensuring that current MSDSs are readily available. All employees shall be trained in spill response and good housekeeping practices. Adequate supplies of materials for dry clean up of spills and leaks should be kept readily available to all areas. Additional BMP's These additional BMPs could be implemented to further reduce or eliminate the potential for stormwater contact. Some of these additional BMPs were recommended for site specific pollutant areas; however, utilization of these BMPs facility wide could further reduce the potential for stormwater contact. Material storage, handling, and processing • Cover material storage and handling areas with an awning, tarp or roof. Practice good stockpiling practices such as: storing materials on concrete or asphalt pads; surrounding stockpiles with diversion dikes or curbs; and revegetating areas used for stockpiling in order to slow runoff. • Use curbing, diking or channelization around material storage, handling and processing areas to divert runon around areas where it can come into contact with materials stored or spilled on the ground. • Utilize secondary containment measures such as dikes or berms around asphalt storage tanks and fuel oil tanks. • Use dust collection systems (i.e. baghouses) to collect airborne particles generated as a result of material handling operations or aggregate drying. Gelder & Associates' SPPP October 1999 Page 23 • Properly dispose of waste materials from dust collection systems and other operations. • Remove spilled material and dust from paved portions of the facility by shoveling or sweeping on a regular basis. • Utilize catch basins to collect potentially contaminated stormwater. • Implement spill plans to prevent contact of runoff with spills of significant materials. • Clean material handling equipment and vehicles to remove accumulated dust and residue. • Use a detention pond or sedimentation basin to reduce suspended solids. • Use an oil/water separator to reduce oil/grease. Erosion and sediment control: • Trap sediment at downgradient locations and outlets serving unstabilized areas. This may include filter fabric fences, gravel outlet protection, sediment traps, vegetated or riprap swales, vegetated strips, diversion structures, catch -basin filters, retention/detention basins or equivalent. • Runoff containing oil and grease may include the use of absorbent booms or sand filters in front of outlet structures or other equivalent measures. Gelder & Associates' SPPP October 1999 Page 24 Table 5 Pollutant Source Summary Stormwater Pollutant Sources Existing Management Description of New BMP Options Practices Area 1 • Diesel tanks have • Perform periodic inspections of • 6000 gal diesel oil tank secondary containment tanks and containment structures. • 6000 gal diesel oil tank structure provided. • Provide berms & ditches to • 3000 gal diesel oil tank • Steam cleaner/soap kept divert runoff from these areas. • 1000 gal propane tank inside a covered storage • Clean up and dispose of oily • 500 gal propane tank structure. soils. • Truck washing area • Divert and collect washpad • Storage structure of steam runoff to underground waste oil cleaner/soap tank and dispose of properly. Area 2 • None • Periodic inspections and cleaning • Truck parking area. of area. • Uncovered dumpster. • Clean up and dispose of oily • Storage piles (miscellaneous soils. debris) • Cover dumpster. • 7,500 gallon tanker of • Place drip pans under trucks tacking/bondingtacking/bonding agent. while parked. Area 3 • Hydraulic oil, motor oil, • Periodic inspections of tanks. • Maintenance shop area and gear oil tank are • Provide berms & ditches to • Asphalt release station inside maintenance divert runoff around asphalt building. release station. • Concrete area and redirect flow into collection tank and dispose of properly. • Place 55 gallon barrels of asphalt release agent inside or provide cover. Area 4 Diesel tank has • Periodic inspections of tanks and • 10,000 gal diesel oil tank secondary containment containment structure • 30,000 gal propane tank structure provided. • Provide berms & ditches to • 30,000 gal liquid asphalt • Baghouse used to divert runoff around tanks and tank collect airborne piles of sand and aggregates. • 750 gal heat transfer oil particles from material . Cover hot oil transfer station. station handling operations • Large piles of sand and aggregates Gelder & Associates' SPPP October 1999 Page 25 Table 6 Best Management Practice Summary BMP's Brief Description of Activities Good Housekeeping • Sweep area regularly • Pick up all trash and dispose of in proper container Preventive Maintenance • Comprehensive semi-annual facility inspections. • Regular equipment maintenance. Inspections • Comprehensive monthly facility inspections. • Semiannual stormwater system inspections. Spill Prevention Response • Keep absorbent materials on hand. Sediment and Erosion Control • Provide maintenance to preserve vegetative cover on unpaved areas. Management of Runoff Provide berms & ditches to divert runoff from areas. (Areas I, 2, and 4). Additional BMP's (Activity and • Provide berms & ditches to divert runoff from areas.(Areas Site Specific) 1, 2, and 4) • Remove and dispose of oily soils.(Areas I and 2) • Place drip pans under trucks.(Area 2) • Cover dumpster.(Area 2) • Concrete area and redirect flow into collection tank and dispose of properly.(Area 3) • Divert and collect washpad runoff to underground waste oil tank and dispose of properly (Area 1) • Cover hot oil transfer station (Area 4) • Place barrels inside or provide cover Area 3) Gelder & Associates' SPPP October 1999 Page 26 Table 7 Best Management Practice Implementation Scheduled Person BMP's Description of Action(s) Required for Completion Responsible Implementation Dates for Action Good I . Sweep regularly. Housekeeping 2. Pickup trash and dispose of properly. Preventive I. Comprehensive monthly facility inspections. Maintenance 2. Regular equipment maintenance. Inspections 1. Comprehensive semi-annual facility inspections. 2. Regular equipment maintenance. Spill Prevention l . Keep absorbent materials on hand. and Response Sediment and 1. Provide maintenance to preserve vegetative Erosion Control cover on unpaved areas. Management of Provide berms & ditches to divert runoff from Runoff areas. (Areas I, 2, and 4). Additional • Provide berms & ditches to divert runoff BMP's (Activity from areas.(Areas 1, 2, and 4) and Site Specific) . Divert and collect washpad runoff to underground waste oil tank and dispose of properly (Area 1) • Remove and dispose of oily soils.(Areas I and 2) • Place drip pans under trucks.(Area 2) • Cover dumpster.(Area 2) • Collect runoff in waste oil tank(Area 3) • Cover hot oil transfer station (Area 4) • Place barrels inside or provide cover Area 3 Gelder & Associates' SPPP October 1999 Page 27 V. PERSONNEL AWARENESS AND TRAINING 1. Introduction If any pollution prevention program is to succeed, all of the people involved must be properly oriented, trained, and motivated. Personnel working in potential spill areas shall be acquainted with the following basic issues: 1. Proper precautions to prevent spills, 2. Good housekeeping, 3. Preventative maintenance, 4. Specific duties of designated personnel, 5. Material Safety Data Sheets, 6. Emergency response procedures, and 7. Facility inspection procedures. 2. Spill Prevention Measures A. The facility shall schedule and conduct stormwater pollution prevention briefings for their operating personnel to assure adequate understanding of pollution prevention for the entire facility. Such briefings will highlight and describe known spill events or failures, malfunctioning components, and recently developed precautionary measures. B. Facility personnel shall be trained in initial emergency response for chemical and petroleum spills. The training shall familiarize personnel with emergency procedures, emergency equipment, and emergency systems. Personnel shall be sufficiently well trained and informed about procedures and equipment to make immediate decisions. Gelder & Associates' SPPP October 1999 Page 28 C. The facility shall always have designated personnel available who are accountable for spill prevention and response. D. Operators of powered industrial equipment such as forklift trucks and other such equipment shall be trained in their proper operation. E. Warehousing rules will be comprehensive and will follow good practices. Care shall be taken to assure that materials and chemicals are stored properly. Reactive chemicals shall not be stored in the same area with combustible materials. F. Contractors or other temporary personnel using the facilities shall be informed about the facility's provisions for stormwater pollution prevention and directed to dispose of hazardous materials and other chemicals and wastes properly. G. All personnel training shall be documented and records retained in the personnel files. 3. Housekeeping Good housekeeping principles should be practiced throughout the facility. All employees should be trained on the location and use of housekeeping materials, spill response materials, and personal protective equipment. Keeping the facility clean and orderly will help facilitate identification of spills, leaks, and general maintenance problems. Therefore, a "clean as you go" attitude should be encouraged. All employees should be on the lookout for potential spills and conditions that could lead to direct contact of stormwater with significant materials. 4. Preventative Maintenance A preventative maintenance program used in conjunction with facility inspections is the heart of any pollution prevention plan. Equipment repairs shall be initiated when defects and flaws are revealed during an inspection and before failure occurs. Additionally, Gelder & Associates' SPPP October 1999 Page 29 normal equipment maintenance schedules will be implemented according to equipment manufacturer's recommendations. With proper scheduling, preventative maintenance operations can be carried out without disrupting facility operations. Maintenance items such as repairs to leaking valves and cleaning and painting of rusting piping or vessels shall be regularly performed. A vessel of proper size shall be provided to catch and contain any such material that could spill on the floor or ground. The contained material shall be properly disposed in accordance with normal and approved facility disposal procedures for the material in question. These requirements and procedures shall also apply to outside contractors working on -site. 5. Specific Personnel Duties Specific personnel shall be responsible for emergency response procedures. All personnel are responsible for the following duties: 1. Identifying spills, leaks, or potential problem areas, 2. First response and initial containment of spills, if possible, and 3. Reporting all problems to the shift supervisor. The Shift Supervisors are responsible for the following duties: 1. Notifying the Safety Coordinator of all incidents, 2. Ensuring that all personnel are properly trained in emergency response, and 3. Ensuring that all spills are adequately cleaned up. The Safety Coordinator shall be responsible for the following duties: Ensuring that all Shift Supervisors are adequately trained to supervise emergency response, 2. Reporting all significant incidents to the Emergency Response Director, 3. Verifying that any spills have been adequately cleaned up, and The Emergency Response Director shall be responsible for the following duties: I. Reporting significant spills to regulatory authorities, and 2. Maintaining incident reports. Emergency phone numbers are as follows: Police Department Fire Department N.C. DENR 6. Outside Contractors Gelder & Associates' SPPP October 1999 Page 30 911 911 (800) 662-7956 (24 hours) (919) 733-5083 (days) Contractors or other temporary personnel using the facilities shall be informed about the facility's provisions for stormwater pollution prevention and directed to dispose of significant materials and other chemicals and wastes properly. Handling and hazardous awareness training must be provided to outside contractors and all training must be documented. 7. Facility Inspections Facility personnel shall perform regular inspections of the facility. The inspections shall cover the following areas: I. Storage areas, 2. Waste accumulation, 3. Log entries, and 4. Security. Stormwater system inspections shall be performed semiannually in April and September and any time a stormwater problem is identified. An example stormwater systems evaluation form is provided in Figure 4. All stormwater inspections shall include: 1. Potential spill areas, 2. Existing spills and leaks, 3. Potential new stormwater pollution contact sources, 4. Inspection of containers, tanks, and drums for signs of deterioration, 5. Inspection of existing BMPs, Gelder & Associates' SPPP October 1999 Page 31 6. Recommendation of new BMPs, 7. Identification of sediment and erosion problem areas, 8. Visual monitoring for color, foam, outfall staining, visible sheens and dry weather flow, and 9. A summary and narrative description of findings. All inspection records shall be maintained in the facility files with the SPPP. 8. Stormwater Sampling Stormwater sampling will be performed according to the terms of the general permit and the Stormwater Discharge Sampling Plan prepared by Applied Water Technology for Gelder & Associates, Inc. Sampling procedures, analytical parameters, and standard reporting forms are presented in the Sampling Plan. All samples shall be analyzed in accordance with the terms of the permit and analytical results shall be submitted to the Director of DENR on standard forms no later than January 31 for the previous year in which sampling was required to be performed. Gelder & Associates' SPPP October 1999 Page 32 Figure 4 Example Stormwater Systems Evaluation Form Inspectors Name and Title: Inspectors Signature: Check One: Routine Evaluation Non -Routine Evaluation (Reason: Describe the Following: I. Potential spill areas 2. Existing spills and leaks 3. Potential new stormwater pollution contact sources 4. Identification of sediment and erosion problem areas 5. Recommendation of new BMPs 6. Visual monitoring for color, foam, outfall staining, visible sheens and dry weather flow Condition and Practice Satisfactory? YES NO I. Signs of deterioration of containers, tanks, and drums 2. Existing BMPs Comments or Recommendations: This evaluation form must be accompanied by a narrative summary including description of findings and recommendations. Gelder & Associates' SPPP October 1999 Page 33 Table 8 Employee Training Training Schedule for Topics Description of Training Training Attendees Spill Prevention Specific duties of personnel, April/October All shifts and Response emergency response procedures and equipment, emergency notification protocol, contingency lannin Good Location and use of materials and April/October All shifts Housekeeping equipment, importance of clean and orderly facility, reporting potential pollutant sources Material General management practices April/October All shifts Management (BMP's), pollution potential Practices awareness Hazard Labeling, MSDSs April/October All employees Communication with potential chemical contact Preventative Spill prevention, preventative April/October All shifts Maintenance maintenance in conjunction with monthly inspections Inspections Purpose and content of regular facility April/October Facility inspections, stormwater systems inspectors evaluations, required forms and reporting Outside Stormwater pollution prevention, April/October Outside Contractors proper disposal of significant contractors materials, handling and hazard awareness Stormwater Awareness reminder program April/October All employees Pollution Prevention Awareness Gelder & Associates' SPPP October 1999 Page 34 V1. STORMWATER POLLUTION PREVENTION PLAN EVALUATION 1. Semi -Annual Site Compliance Evaluation The facility site assessment and best management practices must be regularly updated through semi-annual site compliance evaluations. Semi-annual evaluations should be documented and a copy of the report placed in the facility files with the SPPP. Semi- annual site compliance evaluations shall include the following: • Inspect stormwater drainage areas for evidence of pollutants entering the drainage system. • Evaluate the effectiveness of Best Management Practices (BMPs). • Observe any structural measures, sediment controls, or other stormwater BMPs to ensure proper operation. • Prepare a summary report of inspection results, including the date and inspector's name, signature, and recommended follow-up actions. 2. SPPP Revisions This Stormwater Pollution Prevention Plan shall be reviewed and/or amended within two weeks of: -Revision of applicable regulations. -Changes in facility design, construction, operations, or maintenance which materially affect the potential for stormwater contact of significant materials. -Identification of an SPPP deficiency or recommendation of follow-up measures during annual site compliance evaluation inspections. -Notification from the State that the plan does not meet a minimum requirement of the permit. The plan shall be reviewed at least once every year and shall be amended if such review indicates that the plan does not reflect current operations or physical facility features or is deficient in any way. Gelder & Associates' SPPP October 1999 Page 35 3. Record Keeping and Internal Reporting Records of all facility inspections and training should be kept in the facility files with the SPPP for a period of five years. All documentation should include the name and signature of the reporter and the date of the incident or inspection. Spill and incident reports should also include a description of the incident, weather conditions, cause, and any resulting environmental problems. The following records should be maintained with the SPPP: I. Facility inspections, 2. Spill reports, 3. Site evaluations, 4. Employee training, 5. Stormwater sampling, 6. Facility and equipment maintenance, 7. Sampling data, and 8. BMP implementation. 4. EPCRA, Section 313 Chemicals If the facility is subject to reporting under EPCRA, Section 313 for water priority chemicals, the SPPP must be reviewed and certified by a Registered Professional Engineer and recertified every 3 years or after the plan is significantly changed. This certification that the plan was prepared in accordance with good engineering practices does not relieve the facility owner or operator of responsibility to prepare and implement the plan.