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HomeMy WebLinkAboutNCG210015_COMPLETE FILE - HISTORICAL_20160307a(A" IL STORMWATER DIVISION CODING SHEET NCG PERMITS PERMIT NO. /v DOC TYPE. ❑ HISTORICAL FILE ❑ MONITORING REPORTS DOC DATE ❑ YYYYMMDD �-� PAT MCCRORY CJ! L \LffDONALD R. VAN DER VAART Secretary March 7, 2016 GLENN WATKINS—PRESIDENT GRANVILLE PALLET COMPANY, INC. 3566 Hwy 15 OXFORD, NORTH CAROLINA 27565 Subject: Multimedia Compliance Inspection Granville Pallet Company, Inc. Granville County Dear Permittee: Department of Environment and Natural Resources staff from the Raleigh Regional Office conducted a multimedia compliance inspection of Granville Pallet Company, Inc. on December 9, 2015 for permits and programs administered by the following Divisions: Division of Air Division of Energy, Division of Water Division of Waste Quality Mineral, and Land Resources . Management Resources We appreciate your cooperation during the inspection and 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 and any associated response actions or necessary corrective measures are detailed in the inspection letters/reports attached to this transmittal sheet. If a Division report is not attached, you may assume compliance with that particular Division's rules and regulations at the time of inspection. If you have any questions regarding this multimedia inspection or the results of each program inspection, please contact the Raleigh Regional Office at (919) 791-4200 and ask to speak with the appropriate Division staff. Thank you for your cooperation. encl: Air Quality Inspection Report Stormwater Inspection Report cc: DAQ RRO Files DEMLR RRO Files DWR RRO Files DWM RRO Files State of North Carolina I Environmental Quality I Air Quality Raleigh Regional Office 1 3800 Barrett Drive J Raleigh, NC 27609 919 7914200 T 1 919 8812261 F NORTH CAROLINA DIVISION OF Raleigh Regional Office, , AIR QUALITY Granville Pallet Company, Inc. NC Facility ID 3900086 . Inspection Report County/FIPS: Granville/077 Date: 12/10/2015 Facility Data Permit Data Granville Pallet Company, Inc. Permit, 06978,/ R07 3566 Highway 15 South Issued 4/22/2015 Oxford, NC . 27565 Expires 3/31/2023 Latc'36d 11.9830m `Long: 78d38.7260m Classification' Small SIC: 2448 / Wood Pallets And Skids Permit Status Active NAILS: 32192 / Wood Container and Pallet Manufacturing Current Permit Application(s) None Program Applicability. SIP Contact Data Facility Contact Authorized Contact Technical Contact Glenn Watkins Glenn Watkins Glenn Watkins President President ., . President . (919)528-2347 (919)528-2347 (919)528-2347 Compliance Data Comments: Inspection Date `12/09/2015 Inspector's Name Maureen Conner spector's Signature, Operating Status Operating Compliance Code Compliance - inspection Action Code '' FCE Date of Signature: On -Site Inspection Result Compliance t2-t0-w15 Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PMIO * HAP 2014 256.00 --- 0.0000 0.0000 0.0000 ., : 12.20 2009 92.65 -- --- --- --- 4.42 * Highest HAP Emitted inpounds) Five Year Violation History: Date Letter Tvae Rule Violated Violation Resolution Date 08/13/2015 NOV 2D .1900 Open Burning 09/09/2015 Performed Stack Tests since last FCE: None Date Test Results Test Methods) Source(s) Tested (I) DIRECTIONS TO FACILITY: From the RRO take Highway 50 to Creedmoor.. Go 6.1 miles north on Highway 15 from the NC50/56 and US 15 intersection in Creedmoor. The facility is on the right located approximately 100 yards back from the road. The entrance is a paved road and the facility is at the end of this paved road. I Page 2 of 3 (II) . FACILITY DESCRIPTION: Granville Pallet Company Inc. manufactures new wooden pallets utilizing two assembly lines. Standard safety personal protective equipment should be used. (III) SAFETY: As with all facility visits, standard safety gear (steel -toed shoes, hard hat, safety glasses and hearing protection) is to be worn. (M INSPECTION SUMMARY: On December 9, 2015, 1, Maureen Conner of DAQ, Cory Larsen of DWQ and Ray Williams of DWM arrived at'dianville Pallet to conduct an air quality- inspection as part of a multimedia inspect . ion that had been pre -arranged with the facility. We met with Jamie who manages the Safety/Storm Water records and Paul who manages Air records. The facilitywas operating both saw lines during the inspection. No fugitive dust was observed and all VE was less than 20 1A. opacity:;: (V) PERMITTED EMISSION SOURCES: ... ... . ........ - ...................... ......... Emission i Emission Source Control Control System Operating/Opacity Sol Des . criptimi System jDJFC ' D escription 1Wood Sawing Line,No. ...l ..... ....... E.'S_'r1­u­.- Jcutoffsaw ..... ............... C F—TS-ol _b ES Old double arbor saw gang s ad notche F ES _01e chamfer machine ;F -Eso i f blockcuttingsaw ...... . ..... ..... F1ES Olg single head p6pup saw Woad Sawing Line No 2.'! saw ES-02e multiheadblock saw simple cyclone (120 inches in diameter) Yes/Zi cyclone (144 inches (VI) SPECIFIC CONDITIONS AND LIMITATIONS: A.I., The Peimitt6e shall c'o'niply with Title 15ANCAC, Subchapter 2D.0202, 2D.0512, 2D.0521, 2D.0535, 2D .0540 and 2D .0611. Appeared to be in . compliance. A.2 . 2D.0202 hmission Inventory Requirement. The company is required that within 90-days of their pernjit�r expiration, . and if the . y are requesting renewal, they must submit an emission inventory. Appeared to be in compliance since their permit is up for renewal.. A.3 2D.0512 Particulates from Wood Products Finishing Plants. Requires quires a minimum of dust collection for operations, which work with wood. Appeared to be in compliance. All of the wood working equipment appeared to be attached to the two cyclones. Cyclone CD-1 fills 1 truck a day. Cyclone CD-2 fills 2 trucks a week A.4% 2D .0521 Control of Visible Emission. VE from the permitted items at the facility shall not exceed 20% opacity. Appears to be in compliance. YE was 0% opacity from all of the sources. Page 3 of 3 A.5 213.0535 Excess Emission Reporting and Malfunctions. When particulate, visible, sulfur dioxide, volatile organic compounds, odorous and /or visible emissions exceed environmental regulations for more than 4 hours, the NCDAQ must be notified. Appeared to be in compliance. The facility stated that they had not operated in an upset state. A.6 2D .0546 Particulates from Fugitive Non -Process Dust Emission Sources. The purpose ,of this rule is to control fugitive non -process dust emissions from such items as haul roads, stock piles, parking lots and yards. This is a complaint driven stipulation. Appeared to be in compliance. No visible emissions were observed The facility has not received any complaints either. A.7 2D .0611 Cyclone Requirements. Establish inspection, maintenance and recordkeeping requirements for the cyclones at the facility. Appeared to be in compliance. The company is keeping both digital and paper record The cyclones. are inspected quarterly, with the last one conducted 812012015. During that inspection a hole was noted and repaired that day. (VH) PERMIT EXEMPT EMISSION SOURCES: There are no exempt emission sources listed in the current exempted list for this facility. A pallet treatment kiln was discovered during this inspection. The facility permit is open for renewal at the time of this inspection and it will be determined in the permit review process as to whether the equipment is exempt from permitting. (VIM 112r: This facility is not subject to the 112r rule. (IX) COMPLIANCE HISTORY — There are no -past compliance issues. (X) STACK TEST REVIEW: No stack tests performed in the past 5 years. (XI) EMISSION INVENTORY: The change in emissions between 2009 and 2004 is a credited to change in the amount produced in the different years at the plant. (XH) CONCLUSIONS/RECOMMENDATIONS: At the time of this inspection, Granville Pallet Company Inc. was in compliance with all the requirements of their air quality permit. The facility should be inspected again in two years. Water Resources ENVIRONMENTAL QUALITY MR. GLENN WATKINS — PRESIDENT GRANVILLE PALLET COMPANY, INC. 3566 Hwy 15 OXFORD, NORTH CAROLINA 27565 PAT MCCRORY Gommor DONALD R. VAN DER VAART Secretary . j S. JAY ZIMMERMAN February 19, 2016 Subject: NPDES Stormwater Compliance Evaluation Inspection COC Number NCG210015 Granville Pallet Company, Inc. NCG210000 General Permit for Lumber and Wood Products Granville County Dear Mr. Watkins, Staff from the Department of Environmental Quality (DEQ) conducted a stormwater compliance inspection on December 9, 2015 for permit no. NCG210015 as part of a multimedia inspection of the subject facility. We appreciate the assistance provided by Mr. Jaime Rodriguez and other plant.personnel during the inspection. Please reference the attached inspection report checklist and summary in addition to the comments provided below. The facility was operating the day of the inspection and appeared well -maintained. An effective stormwater management program has been implemented, however, a number of items do require your attention to achieve full compliance as follows: The stormwater pollution prevention plan (SPPP) was complete based on the presence of all essential elements. Please be sure to conduct and document annual stormwater training for all relevant employees covering spill response and cleanup, preventative maintenance activities, and facility operations with potential to contaminate stormwater runoff. Please make certain to monitor all identified outfalls (SDO#I, SDO#2, and SDO#3) for qualitative parameters on a semi-annual basis going forward, and if operations, change or are modified in such a way that results in exposure of raw or waste wood materials for greater than 7 days, all outfalls will require analytical monitoring twice per year as well. Please provide a written acknowledgement of the above items within 30 days of reeeipt of this letter. Your response should include measures taken to address the above compliance items and/or a schedule for their completion. If you have any questions regarding these matters, please contact me at cory.larsen(ancdenr.aov or 919-791-4200. . Division of Water Resources, Raleigh Regional Office, Water Quality Operations Section www.ncwaterquality.org 1628 Mail Service Center, Raleigh, NC 27699-1628 Phone: (919) 791-4200 Location: 3800 Barrett Drive, Raleigh, NC 27609 Fax: (919) 788-7159 February 19, 2016 Page 2 of 2 r Compliance Inspection Report Permit: NCG210015 Effective: 08/01/13 Expiration: 07/31/18 Owner: Granville Pallet Co Inc SOC: Effective: Expiration: Facility: Granville Pallet Co Incorporated County: Granville 3566 Hwy 15 Region: Raleigh Oxford NC 27565 Contact Person: Glenn Watkins Title: Phone: 919-528-2347 Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s)i OnSlte Representative(s): Related Permits: Inspection Date: 12/09/2015 Primary Inspector: Cory Larsen Secondary Inspector(s): Certification: Phone: Entry Time: 09:45AM Exit Time: 11:15PM - Phone: 919-807-6300 Reason for Inspection: -Other Inspection Type: Compliance Evaluation Permit Inspection Type: Timber Products Stormwater Discharge COC Facility Status: Compliant ❑ Not Compliant Question Areas:. Storm Water (See attachment summary) Page: 1 Permit: NGG210015 Owner - Facility: Granville Pallet Cc Inc Inspection Data: 12109/2015 Inspection Type : Compliance Evaluation Reason for Visit: Other Inspection Summary: - A multi -media program compliance inspection was conducted by staff from the Division of Water Resources, Air Quality, and Waste Management on December 9, 2015 to evaluate compliance with NPDES stormwater and air quality permits issued to the facility. The stormwater inspection results for NCG210015 are presented below. The stormwater pollution prevention plan (SPPP) was reviewed and appeared to be complete and being implemented. Employees responsible for stormwater management were eager to understand and meet all regulatory requirements. , Employee stormwater training covering spill response and cleanup, preventative maintenance activities, and facility operations with . potential to contaminate stormwater runoff should be conducted at least annually and documented going forward., - The facility conducts quarterly qualitative monitoring at SDO 1 and SDO 2 but has not been monitoring SDO 3 (as - illustrated on the SPPP site plan). As the facility is currently operated, there is no exposure of sawdust, wood chips or mulch piles for 7 days or greater, and as a result, analytical monitoring isn't' required. Division staff instructed the... stormwater manager.to monitor all identified outfalls for qualitative parameters on a semi-annual basis going forward. If operations change to expose raw wood materials for greater than 7 days, all outfalls will require analytical monitoring twice . per year as well. No bulk liquid storage was observed requiring secondary containment. Most of the operations are under roof and the site appeared well kept and was operating at the time of inspection. Page: 2 Permit: NCG210015 Owner- Facility: Granville Pallet Ca Inc Inspection Data: 12/09/2015 Inspection Type : Compliance Evaluation Stormwater Pollution Prevention Plan 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? # 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 Training? # 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 is limited but more will be implemented. Qualitative Monitoring Has the facility conducted its Qualitative Monitoring semi-annually? Comment: conducted quarterly A 1 and 2. none at 3 currently - will monitor in future. Analytical Monitoring Has the facility conducted its Analytical monitoring? # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? Comment: Not applicable due to no exposure of raw wood materials for greater than 7d. Permit and Outfalls # Is a copy of the Permit and the Certificate of Coverage available at the site? # 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? Comment: Reason for Visit: Other Yes No NA NE ®❑ ❑ ❑ U NUNNI ■❑❑❑ ❑ ❑ ® ❑ ®❑❑❑ ❑❑U.❑ ®❑ ❑ ❑ ■❑❑❑ E ❑ ❑ ❑ ■❑❑❑ E.❑ ❑11 ■❑Ell] E ❑ ❑ ❑ �o❑❑ Yes No NA NE ■❑❑❑ Yes No NA NE ❑ ❑ 0.❑ ❑❑■❑ Yes No NA NE ® ❑ ❑ ❑ ❑ ❑ ❑ ❑❑0❑ e❑❑❑ Page: 3 �V1 WaterResources ENVIRONMENTAL QUALITY MR. GLENN WATKINS —PRESIDENT GRANVILLE PALLET COMPANY, INC. 3566 Hwy 15 OXFORD, NORTH CAROLINA 27565 PAT MCCRORY Governor DONALD R. VAN DER VAART Secretary S. JAY ZIMMERMAN February 19, 2016 Subject: NPDES Stormwater Compliance Evaluation Inspection COC Number NCG210015 Granville Pallet Company, Inc. NCG210000 General Permit for Lumber and Wood Products Granville County Dear Mr. Watkins, Staff from the Department of Environmental Quality (DEQ) conducted a stormwater compliance inspection on December 9, 2015 for permit no. NCG210015 as part of a multimedia inspection of the subject facility. We appreciate the assistance provided by Mr. Jaime Rodriguez and other plant personnel during the inspection. Please reference the attached inspection report checklist and summary in addition to the comments provided below. The facility was operating the day of the inspection and appeared well -maintained. An effective stormwater management program has been implemented, however, a number of items do require your attention to achieve full compliance'as follows: The stormwater pollution prevention plan (SPPP) was complete based on the presence of all essential elements. Please be sure to conduct and document annual stormwater training for all relevant employees covering spill response and cleanup, preventative maintenance activities, and facility operations with potential to contaminate stormwater runoff. 2. Please make certain to monitor all identified outfalls (SDO#l, SDO#2, and SDO#3) for qualitative parameters on a semi-annual basis going forward, and if operations change or are modified in such a way that results in exposure of raw or waste wood materials for greater than 7 days, all outfalls will require analytical monitoring twice per year as well. Please provide a written acknowledgement of the above items within 30 days of receipt of this letter. Your response should include measures taken to address the above compliance items and/or a schedule for their completion. If you have any questions regarding these matters, please contact me at cory.larsen@ncdenr.gov or 919-791-4200. Division of Water Resources, Raleigh Regional Office, Water Quality Operations Section www.ncwaterquality.org 1628 Mail Service Center, Raleigh, NC 27699-1628 Phone: (919) 791-4200 Location: 3800 Barren Drive, Raleigh, NC 27609 - Fax: (919) 788-7159 February 19, 2016 Page 2 of 2 r Sincerely, Cory rsen, E Environmental Engineer Raleigh Regional Office Encl: Compliance Inspection Report cc: RRO/SWP Files Compliance Inspection Report Permit: NCG210015 Effective: 08/01/13 Expiration: 07/31/18 Owner: Granville Pallet Cc Inc SOC: Effective: Expiration: Facility: Granville Pallet Co Incorporated County: Granville 3566 Hwy 15 Region: Raleigh Oxford NC 27565 Contact Person: Glenn Watkins Title: Phone: 919-528-2347 Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 12/09/2015 Primary Inspector: Cory Larsen Secondary Inspector(s): Certification: Phone: Entry Time: 09:45AM Exit Time: 11:15PM Phone: 919-807-6300 Reason for Inspection: Other Inspection Type: Compliance Evaluation Permit Inspection Type: Timber Products Slormwater Discharge COC Facility Status: Compliant ❑ Not Compliant Question Areas:. Storm Water (See attachment summary) Page: 1 Peonit: NCG210015 Owner -Facility: Granville Pallet Co Inc Inspection Date: 12/09/2015 Inspection Type : Compliance Evaluation Reason for Visit: Other Inspection Summary: A multi -media program compliance inspection was conducted by staff from the Division of Water Resources, Air Quality, and Waste Management on December 9, 2015 to evaluate compliance with NPDES stormwater and air quality permits issued to the facility. The stormwater inspection results for NCG210015 are presented below. The stormwater pollution prevention plan (SPPP) was reviewed and appeared to be complete and being implemented. Employees responsible for stormwater management were eager to understand and meet all regulatory requirements. Employee stormwater training covering spill response and cleanup, preventative maintenance activities, and facility operations with potential to contaminate stormwater runoff should be conducted at least annually and documented going forward. The facility conducts quarterly qualitative monitoring at SDO 1 and SDO 2 but has not been monitoring SDO 3 (as illustrated on the SPPP site plan). As the facility is currently operated, there is no exposure of sawdust, wood chips or mulch piles for 7 days or greater, and as a result, analytical monitoring isn't' required. Division staff instructed the stormwater manager to monitor all identified outfalls for qualitative parameters on a semi-annual basis going forward. If operations change to expose raw wood materials for greater than 7 days, all outfalls will require analytical monitoring twice per year as well. No bulk liquid storage was observed requiring secondary containment. Most of the operations are under roof and the site appeared melt kept enrt dms nnorefinn at fhp time of inspection Page: 2 Permit: NCG210015 Owner - Facility: Granville Pallet Cc Inc Inspection Date: 12/09/2015 Inspection Type : Compliance Evaluation Reason for Visit- Other Stormwater Pollution Prevention Plan - Yes No NA NE Does the site have a Stormwater Pollution Prevention Plan? ■ ❑ 1-111 # Does the Plan include a General Location (USGS) map? 1-1El # Does the Plan include a "Narrative Description of Practices"? ® El ❑ ❑ # 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? ❑ ❑ M ❑ # Has the facility evaluated feasible alternatives to current practices? M El 1:1.0 # Does the facility provide all necessary secondary containment? El Q ■ ❑ # Does the Plan include a BMP summary? ■ Q # Does the Plan include a Spill Prevention and Response Plan'(SPRP)? - 13.0 El # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? - -1:1 El ❑ # Does the facility provide and document Employee Training? ❑ ❑ ❑ # Does the Plan include a list of Responsible Party(s)? ■ ❑ ❑ ❑ # Is the Plan reviewed and updated annually? ■ ❑ ❑ 1-1 # Does the Plan include a Stormwater Facility Inspection Program? ■ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? ❑ ❑ El Comment: Employee training is limited but more will be implemented Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? 0 0Q ❑ Comment: conducted quarterly @ 1 and 2. none at 3 currently - will monitor in future Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? ❑ ❑ ■ ❑ # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ Q M ❑ Comment: Not applicable due to no exposure of raw wood materials for greater than 7d Permit and Outfalls - Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? ■ ❑ Q ❑ # Were all outfalls observed during the inspection? -0 ❑ ❑ ❑ # If the facility has representative outfall status, is it properly documented by the Division? . ❑ ❑ # Has the facility evaluated all illicit (non stormwater) discharges? 0 ❑ ❑ ❑ Comment: Page: 3 Penult: hC�G ZIOOIS Owner -Facility: &n, AWVI.L£ Inspection Date: I (1(i I j Inspection Typo: Compliance Evaluation 1't'lutl— 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? B/❑ ❑ ❑ # Does the Plan include a "Narrative Description of Practices"? VO ❑ ❑ # Does the Plan include a detailed site map including outfall locations and drainage areas? O/ ❑ ❑ ❑ # Does the Plan include a list of significant spills occurring during the past 3 years? ❑ ❑ 9 ❑ # Has the facility evaluated feasible alternatives to current practices? 9 ❑ ❑ # Does the facility provide all necessary secondary containment? - ❑ ❑ ,❑ ,/ 6d ❑ # Does the Plan include a BMP summary? BID ❑ ❑ # Does the Plan include a Spill Prevention and Response Plan (SPRP)? ❑ ❑ # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ,J/,❑ 6 ❑ ❑ It Does the facility provide and document Employee Training? /.rti+.+fv ,Lx- {� ,-d,"/❑ 913 ❑ ❑ # Does the Plan include a list of Responsible Party(s)? ll'j' 4"'^"'r-` h1" ❑ ❑ ❑ # Is the Plan reviewed and updated annually? @�❑ ❑ ❑ A4 # Does the Plan include a Stormwater Facility Inspection Program? 0/6 n ❑ Has the Stormwater Pollution Prevention Plan been implemented? V❑ ❑ ❑ Comment: Qualitative Monitoring YesNo NA NE Has the facility conducted its Qualitative Monitoring semi-annually? Q,.,.r1�L(6^-may ./ !�J ❑ ❑ ❑ Comment: Soo ! 2 r 3� ( A v Yos No NA NE Analytical Monitoring _ rNA Has the facility conducted its Analytical monitoring? Z-A,% l /Z,&Q- # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? may( ❑ ❑ t`1 ❑ Comment: •sue P i c e, > 7d Permit and Outfalls # Is a copy of the Permit and the Certificate of Coverage available at the site? Yes /No NA NE 0 ❑ ❑ ❑ # Were all outfalls observed during the inspection? — d❑ El 0 # If the facility has representative outfall status, is it properly documented bylphne `Division? 0 0 `� ❑ # Has the facility evaluated all illicit (non stormwater) discharges? O/✓r �6 lb ` m ❑ ❑ ❑ %Wu/ p rt,t,u Comment: 71L6,�yy`��/ Chad E. Abbott Professional Engineer, PE #036242 3080 Blackley Road Oxford, NC 27565 Phone: (919) 625-7368 June 24, 2011 Cheng Zhang NCDENR-DWQ Raleigh Regional Office 3800 Barrett Drive Raleigh, NC 27609 JUL - 12911 Raleigh ��E.rir�OWCL: Re: Notice of Violation and Stormwater Compliance Evaluation Inspection Case No. NOV-201 1 -PC-0334 Certificate of Coverage No. NCG210015 Granville Pallet Company Granville County Dear Mr. Zhang: On behalf of my client, Granville Pallet Company, I would like to inform your office that I am in receipt of the Notice of Violation and have been retained to provide professional services for all applicable scopes listed in the violation letter. In accordance with our phone conversation on June 22, 2011, 1 will be addressing the following items with supplemental information to be provided to your office for review: o A SWPPP will be prepared in accordance with the provisions under North Carolina General Permit #210000 specifically for the operations and runoff conditions at the Granville Pallet Facility. o Documentation of Monitoring in accordance with the provisions under North Carolina General Permit #210000 will be provided. As discussed, significant rainfall events have been ephemeral at best since the receipt of this letter. However, if a significant rainfall event does occur prior to the requested monitoring date of June 30, monitoring will occur. Otherwise monitoring will be conducted as required thereafter and records kept in accordance with the provisions of the approved SWPPP. o I have advised the owner to begin monitoring and keeping records of the vehicle maintenance activities and consumption of oil at the facility. A description of these activities and provisions for keeping records will also been provided in the approved SWPPP. I look forward to discussing these matters further with your office and providing efficient and timely solutions to the items noted in your letter dated June 6, 2011. If you have any further questions or concerns, please feel free to contact me at (919) 625-7368. Sincerely, 04� — ✓ Chad E. Abbott, PE W11,111CUNNUMMAY North Carolina Beverly Eaves Perdue Governor WDENR Department of Environment and Division of Water Quality Coleen H. Sullins Director June 6, 2011 CERTIFIED MAIL 70081300000011314719 RETURN RECEIPT REQUESTED Mr. Glenn Watkins Granville Pallet Company Inc. 3566 Highway 15 Oxford, NC 27565 Natural Resources Subject: Notice of Violation and Stormwater Compliance Evaluation Inspection Case No. NOV-2011-PC-0334 Certificate of Coverage No. NCG210015 Granville Pallet Company Inc. Granville County Dear Mr. Watkins: Dee Freeman Secretary On May 25, 2011, Cheng Zhang of the Raleigh Regional Office (RRO) conducted a Stormwater Compliance Evaluation Inspection at Granville Pallet Company Inc. The assistance provided by Mr. Keith Tunstall, the Production Manager, was greatly appreciated. The inspection report is attached. Findings during the inspection were as follows: Certificate of Coverage (COC) No. NCG21015 of NPDES general permit NCG210000 was issued to Granville Pallet Company Inc., to discharge stormwater runoff to an unnamed tributary to Johnson Creek, a class C NSW stream, in the Tar - Pamlico River Basin. 2. Granville Pallet Company Inc. was found to have violated Part II Section A of the General Permit for failure to develop and implement a Stormwater Pollution Prevention Plan (SPPP). The facility must develop a SPPP within 90 days of receipt of this notice. 3. Granville Pallet Company Inc. was found to have violated Part II Section B and Section C of the General Permit for failure to conduct analytical and qualitative monitoring. The facility must start to conduct both analytical and qualitative monitoring at all identifiable stormwater discharge outfalls (SDOs). The first qualitative and analytical monitoring must be conducted no later than June 30, 2011. North Carolina Division of Water Quality 1628 Mail Service Center Raleigh, NC 27699-1628 Phone (919) 791-4200 Customer Service Internet: www.ncwaterquality.org Location: 3800 Barren Drive Raleigh, NC 27609 Fax (919) 788-7159 1-877-623-6748 An Equal Opportunity/Af linnative Action Employer— 50% Recycled/10% Post Consumer Paper Granville Pallet Company Inc. Permit No. NCG? Ii10015' ` Compliance Evaluation Inspection 4. V, 4. The facility conducts vehicle maintenance on site. Please record the monthly usage of new motor oil. If the monthly usage is more than 55 gallons, the facility must conduct analytical monitoring for on -site vehicle maintenance. The SDO connecting to a nearby pond was observed during the inspection, it was well maintained and in good condition. Please address Items 2 and 3 above and respond in writing to RRO 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.gov). i Sincerely, s� S. Daniel Smith, Supervisor Surface Water Protection Raleigh Regional Office Enclosure: Compliance Evaluation Inspection Forth cc: Central Files %RRO SWP files: Keith Tunstall, Granville Pallet Company Permit: NCG210015 SOC: County: Granville Region: Raleigh Compliance Inspection Report Effective: 08/01/08 Expiration: 07/31/13 Owner: Granville Pallet Cc Inc Effective: Expiration: Facility: Granville Pallet Co Incorporated 3566 Hwy 15 Contact Person: Glenn Watkins Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 05/25/2011 Primary Inspector: Chang Zhang Secondary Inspector(s): Title: Entry Time: 10:20 AM Oxford NC 27565 Phone: 919-528-2347 Certification: Exit Time: 11:30 AM Phone: Phone: 919-791-4200 Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Timber Products Stormwater Discharge COC Facility Status: Cl Compliant ® Not Compliant Question Areas: E Storm Water (See attachment summary) Page: 1 Permit: NCG210015 Owner - Facility: Granville Pallet Co Inc Inspection Date: 05/25/2011 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? ❑ ■ ❑ ❑ # Does the facility provide all necessary secondary containment? ❑ ■ ❑ ❑ If 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 Training? ❑ ■ ❑ ❑ # 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: The facility has not developed and implemented a SPPP. Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ❑ ■ ❑ ❑ Comment: No qualitative monitoring has been conducted. 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: No qualitative monitoring has been conducted. The facility claimed it used less than 55 gallons of new motor oil every month. Permit and Outfalls - Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? ■ ❑ ❑ ❑ # 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? ❑ ■ ❑ ❑ Comment: Non stormwater discharge will be evaluated when the SPPP is developed Page: 3 I k 'ON 133HS I :3WVN ONimvNa I 'ON 1.03robdj Nod Im1111 me 11 /-- I - -- -� ­_ � I � I ,- - , I I --- --- -q%%Okl I � \ I , �', - 1 --:5'- -�-_ ��,, 1 , . � ,� � � I / '1/ ,_� - - ­_ --- I - _�' 1 11 " \ \ \ - \\ � 1\ "I-- -_ _� � I I j 1 1 - I , " - - ­ - - - - , I ! i i ,-I- _� I I I � / ", � --- 1- 1- I --- I I - -1 I 'I- ­ -- - ­__/ 1, I __ , � - - - I , , - __ - ,-,, - - I_— - I -_ -_ I - ­ - - I , I I " --- - .- i I - - , , - ,� I / I I " . � I - _ I I " , I --- ­­:�/ ,� / -- - / � - I I , / - ,�_ - - - �, "I , � 11 \ -, I _� � I " , -, � ___ - I I " � .1 - -_ _ - -1 --- - � -_ , I i \ , � '_ 11 - - -_ , - - , �_, I - - .. -_ I \ - 1��_, - - - ___ - ,----, - ---,-,I- � � I " I �� -1 _� -,-- - ___ , __ --- - I/ I _ I , I I I I � , , , - __ --/, "' _ " / ' / -------- - __�__ ' ' ___ __ / -\- , � I � I I ­ _ I ­- I/ 1 I � " ,,- , , - ,, � ___� I - - - `_� - �, - --- - -,-- - - --- �_�7.__ _ --11 " , , - I _­ - -- I - -_ ! 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