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HomeMy WebLinkAboutNCGNE1151_COMPLETE FILE - HISTORICAL_20160719STORMWATER DIVISION CODING SHEET NCG PERMITS PERMIT NO. NCGNE I I DOC TYPE L9 HISTORICAL FILE DOC DATE ❑ 6 V1 �lJ � I q YYYYMMDD Environmental Quality July 19, 2016 Mr. Ronald Cox, Owner and Plant Manager Wood Products Inc 507 North Harrington Street Raleigh, NC 27603 Dear Permittee: PAT MCCRORY Governor DONALD R. VAN DER VAART Secretary Subject: Multimedia Compliance Inspection Wood Products Inc Wake County Department of Environment Quality (DEQ) staff conducted a multimedia compliance inspection of Wood Products Tnc. on June 30. 2016 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 EMLR 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@ncdem.goy). Thank you for your cooperation. cc: DAQ RRO Files DEMLR (DWR) RRO Stormwater Files Department of Environmental Quality, Raleigh Regional Office http://(Ieq.ne.gov/ 1628 Mail Service Center, Raleigh, NC 27699-1628 Phone: (919) 791-4200 Location: 3800 Barrett Drive, Raleigh, NC 27609 Fax: (919) 571-4718 cy LrD -) ry PAT MCCRORY Govemor DONALD R. VAN DER VAART Secretary Environmental Quality July 19, 2016 Mr. Ronald Cox, Owner and Plant Manager Wood Products Inc 507 North Harrington Street Raleigh, NC 27603 Subject: Notice of Regulatory Requirements NPDES No Exposure Certification for Exclusion NCGNE0000 Wood Products Inc Wake County Dear Mr. Cox: Staff from the Department of Environmental Quality (DEQ) conducted a compliance inspection on June 30, 2016 of the subject facility as part of a multimedia program inspection. We appreciate your assistance during the inspection. Based on the information you provided on your process and products and Standard Industrial Classification (SIC) code 2499, along with the fact that no exposure of industrial activities to precipitation, your facility is deemed eligible for the no exposure exclusion In accordance with North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission and the Federal Water Pollution Control Act, all owners and operators of stormwater point source discharges associated with establishments primarily engaged in activities classified as Lumber and Wood Products, Except Furniture (SIC 24), are required to obtain an NPDES permit to cover stormwater discharges from their sites or an NPDES No Exposure Certification for Exclusion. Enclosed with this Notice, please find a National Pollutant Discharge Elimination System application for No Exposure Certification for Exclusion NCGNE0000. Your application should be completed and submitted to: Stormwater Permitting Program Division of Energy, Mineral, and Land Resources 1612 Mail Service Center Raleigh, North Carolina 27699-1612 Please provide a written response to this Notice within 30 days of receipt of this letter. Your response should include documentation of your submittal to the Stormwater Permitting Program or a schedule for completion and submittal of the NOI. Note that failure to comply with the Raleigh Regional Office1628 Mail Service Center, Raleigh, North Carolina 27699-1628 Phone: 919-791-4200 / FAX: 919-571-4718 / Internet: http://portal.ncdenr.org/web/Ir/ An Equal Opportunity \ Affirmative Action Employer — 50% Recycled \ 10% Post Consumer Paper July 19, 2016 pnge 2 of 2 requirements of this Notice may result in compliance and enforcement action including the assessment of civil penalties. We appreciate your attention and prompt response to this matter. If you have any questions please contact Cheng Zhang at cheng.zhangpncdenr.gov or 919-791-4259. Sincerely, Cheng Zhang Environmental Senior Specialist Raleigh Regional Office NC Dept. of Environmental Quality Encl: NPDES Application for Exclusion from a Stormwater Permit based on No Exposure cc: RRO/SWP Files Stormwater Permitting Unit DAQ RRO Files Division of Energy, Mineral and Land Resources Land Quality Section National Pollutant Discharge Elimination System NO EXPOSURE CERTIFICATION for Exclusion Energy. Mineral NCGNE0000 and Lund Resources ENVIRONMENTAL QUALITY FOR AGENCY USE ONLY Date Received Year I Month I De Certificate of Covem e National Pollutant Discharge Elimination System application for exclusion from a Stormwater Permit based on NO EXPOSURE: Submission of this No Exposure Certification constitutes notification that your facility does not require a permit for stormwater discharges associated with industrial activity in the State of North Carolina because it qualifies for a no exposure exclusion. A condition of no exposure at an industrial facility means all industrial materials and activities are protected by a storm resistant shelter (with some exceptions) to prevent exposure to rain, snow, snowmelt, and/or runoff. For permitted facilities in North Carolina, DEMLR must approve your application for No Exposure Certification before this exclusion is effective. Until you are issued a No Exposure Certification and your NPDES permit is rescinded, your facility must continue to abide by the terms and conditions of the current permit. Industrial materials or activities include, but are not limited to: material handling equipment or activities, industrial machinery, raw materials, intermediate products, by-products, final products, or waste products. Material handling activities include the storage, loading and unloading, transportation, or conveyance of any raw material, intermediate product, final product or waste product. A storm resistant shelter is not required for the following industrial materials and activities: drums, barrels, tanks, and similar containers that are tightly sealed, provided those containers are not deteriorated and do not leak. "Sealed" means banded or otherwise secured and with locked or non -operational taps or valves; adequately maintained vehicles used in material handling; and final products, other than products that would be mobilized in stormwater discharges (e.g., rock salt). A No Exposure Certification must be provided for each facility qualifying for the no exposure exclusion. In addition, the exclusion from NPDES permitting is available on a facility -wide basis only —not for individual outfalls. If any industrial activities or materials are, or will be, exposed to precipitation, the facility is not eligible for the no exposure exclusion. By signing and submitting this No Exposure Certification form, you certify that a condition of no exposure exists at this facility or site and are obligated to comply with the terms and conditions of 40 CFR 122.26(g). If approved, your conditional no -exposure exclusion must be self re -certified at least annually. Please see information here: For questions, please contact the DEMLR Regional Office for your area. (See page 6) (Please print or type) 1) Mailing address of owner/operator (address to which all certification correspondence will be mailed): Name Contact Street Address City State ZIP Code Telephone No. Fax: Page 1 of 7 SWU-NCGNE Last revised 1/25/2016 NCGNE0000 No Exposure Certification 2) Location of facility producing discharge: Facility Name Facility Contact Street Address City County Telephone No. 3) Physical location information: State ZIP Code Fax: Please provide a narrative description of how to get to the facility (use street names, state road numbers, and distance and direction from a roadway intersection). (A copy of a map with the facility clearly located on it should be included with the certification application.) 4) Is the facility located on Native American Lands? ❑ Yes ❑ No 5) Is this a Federal facility? ❑ Yes ❑ No 6) Latitude Longitude (deg., min., seconds) 7) This NPDES No Exposure Exclusion application applies to which of the following: ❑ New or Proposed Facility ❑ Existing Date operation is to begin Date operation began ❑ Renewal of existing No Exposure Certification Certification No.: NCGNE 8) Was this facility or site ever covered under an NPDES Stormwater Permit? ❑ Yes ❑ No If yes, what is the NPDES Permit Number? 9) Standard Industrial Classification: Provide the 4 digit Standard Industrial Classification Code (SIC Code) that describes the primary industrial activity at this facility SIC Code: 10) Provide a brief description of the types of industrial activities and products produced at this facility: 11) Does this facility have any Non -Discharge permits (ex: recycle permits)? ❑ No ❑ Yes If yes, list the permit numbers for all current Non -Discharge permits for this facility: Page 2 of 7 SWU-NCGNE Last revised 1/25/2016 NCGNE0000 No Exposure Certification Exposure Checklists (12. - 14.) 12) Are any of the following materials or activities exposed to precipitation, now or in the foreseeable future? (Please check either "Yes" or "No.") If you answer "Yes" to any of these items, you are not eligible for the no exposure exclusion. a. Using, storing, or cleaning industrial machinery or equipment, and areas where ❑ Yes ❑ No ❑ N/A residuals from using, storing or cleaning industrial machinery or equipment remain and are exposed to stormwater b. Materials or residuals on the ground or in stormwater inlets from spills/leaks ❑ Yes ❑ No ❑ N/A c. Materials or products from past industrial activity ❑ Yes ❑ No ❑ N/A d. Material handling equipment (except adequately maintained vehicles) ❑ Yes ❑ No ❑ N/A e. Materials or products during loading/unloading or transporting activities ❑ Yes ❑ No 0 N/A f. Materials or products stored outdoors (except final products intended for outside ❑ Yes ❑ No ❑ N/A use [e.g., new cars] where exposure to stormwater does not result in the discharge of pollutants) g. Materials contained in open, deteriorated or leaking storage drums, barrels, tanks, ❑ Yes ❑ No ❑ N/A and similar containers h. Materials or products handled/stored on roads or railways owned or maintained by ❑ Yes ❑ No ❑ N/A the discharger L Waste material (except waste in covered, non -leaking containers [e.g., dumpsters]) ❑ Yes ❑ No ❑ N/A j. Application or disposal of process wastewater (unless otherwise permitted) ❑ Yes ❑ No ❑ N/A k. Particulate matter or visible deposits of residuals from roof stacks and/or vents not ❑ Yes ❑ No ❑ N/A otherwise regulated (i.e., under an air quality control permit) and evident in the stormwater outflow I. Empty containers that previously contained materials that are not properly stored ❑ Yes ❑ No ❑ N/A (i.e., not closed and stored upside down to prevent precipitation accumulation) m. For any exterior ASTs, as well as drums, barrels, tanks, and similar containers ❑ Yes ❑ No ❑ N/A stored outside, has the facility had any releases in the past three (3) years? 13) Above Ground Storage Tanks (ASTs): If you answer "No" to any of the following items, you are not eligible for the no exposure exclusion. a. Are exterior ASTs or piping free of rust, damaged or weathered coating, pits, or ❑ Yes ❑ No ❑ N/A deterioration, or evidence of leaks? b. Is secondary containment provided for all exterior ASTs? If so, is it free of any ❑ Yes ❑ No ❑ N/A cracks, holes, or evidence of leaks, and are drain valves maintained locked shut? Page 3 of 7 SWU-NCGNE Last revised 1/25/2016 NCGNE0000 No Exposure Certification 14) Secondary Containment: If you answer "No" to any of the following items, you are not eligible for the no exposure exclusion. a. Is secondary containment provided for single above ground storage containers (including drums, barrels, etc.) with a capacity of more than 660-gallons? b. Is secondary containment provided for above ground storage containers stored in close proximity to each other with a combined capacity of more than 1,320- gallons? c. Is secondary containment provided for Title III Section 313 Superfund Amendments and Reauthorization Act (SARA) water Priority chemicals*? d. Is secondary containment provided for hazardous substances** designated in 40 CFR §116? e. Are release valves on all secondary containment structures locked? 15) Hazardous Waste: a. Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility? b. Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous waste generated per month) of hazardous waste? c. Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste generated per month) of hazardous waste? If you answered yes to questions b. or c., please provide the following information: Type(s) of waste: _ How is material stored: Where is material stored: How many disposal shipments per year: Name of transport / disposal vendor: _ Vendor address: Footnotes to Questions 14) c. & d. ❑ Yes ❑ No ❑ N/A ❑ Yes ❑ No ❑ N/A ❑ Yes ❑ No ❑ N/A ❑ Yes ❑ No ❑ N/A ❑ Yes ❑ No ❑ N/A ❑ Yes ❑ No ❑ N/A ❑ Yes ❑ No ❑ N/A ❑ Yes ❑ No ❑ N/A *Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require secondary containment. However, some exceptions may be made for de minims amounts of certain substances, and/or other qualifiers, as described in the exemptions from reporting requirements of Title III SARA 313 in 40 CFR §372.38. **Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require secondary containment. However, some exceptions may be made for amounts less than the Reportable Quantities of the hazardous substances listed in 40 CFR §117.3. Page 4 of 7 SWU-NCGNE Last revised 1/25/2016 NCGNE0000 No Exposure Certification 16) Other information: If you answer "Yes" to any of the following items, you might not be eligible for the no exposure exclusion. A more in-depth evaluation of the site circumstances may be required. a. Does your facility store used, recycled, or otherwise reclaimed pallets outside? ❑ Yes ❑ No ❑ N/A b. Does your facility have coal piles on site? c. Does your facility store other fuel sources outside in piles, such as wood chips, sawdust, etc.? d. Does your facility have air emissions associated with its industrial activity (e.g., degreasing operations, plating, painting and metal finishing)? If so, describe the industrial activity: e. If you answered yes to d., are those emissions permitted by an Air Quality Permit? Please specify: f. Please list any other environmental program permits (federal, state, etc.) not specified earlier in this application (such as Hazardous Waste Permits, etc.): Permit: Program: Permit: Program: Permit: Program: Permit: Program: Permit: Program: Permit: Program: Permit: Program: ❑ Yes ❑ No ❑ N/A ❑ Yes ❑ No ❑ N/A ❑ Yes ❑ No ❑ N/A ❑ Yes ❑ No ❑ N/A Page 5 of 7 SWU-NCGNE Last revised 1/25/2016 NCGNE0000 No Exposure Certification 17) Certification: I certify under penalty of law that I have read and understand the eligibility requirements for claiming a condition of "no exposure' and obtaining an exclusion from NPDES stormwater permitting. I certify under penalty of law that there are no discharges of stormwater contaminated by exposure to industrial activities or materials from the industrial facility or site identified in this document (except as allowed under 40 CFR 122.26(g)(2)). I understand that 1 am obligated to submit a no exposure certification form once every five (5) Years to the North Carolina Division of Water Quality and, if requested, to the operator of the local municipal separate storm sewer system (MS4) into which the facility discharges (where applicable). I understand that I must allow the North Carolina Division of Water Quality, or MS4 operator where the discharge is into the local MS4, to perform inspections to confirm the condition of no exposure and to make such inspection reports publicly available upon request. In the event that the site no longer qualifies for a No Exposure Exclusion, I understand that I must obtain coverage under an NPDES permit prior to any point source discharge of stormwater from the facility. Additionally, 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 gathered and evaluated 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. I certify that I am familiar with the information contained in this` application and that to the best of my knowledge and belief such information is true, complete, and accurate. Printed Name of Person Signing: Title: (Signature of Applicant) (Date Signed) Please note: This application for the No Exposure Exclusion is subject to approval by the NCDENR Regional Office prior to issuance. The Regional Office may inspect your facility for compliance with no exposure conditions prior to that approval. The Regional Office may also inspect your facility at any time in the future for compliance with the No Exposure Exclusion. North Carolina General Statute 143.215.6 B(i) provides that: Any person who knowingly makes any false statement, representation, or certification in any application, record, report, plan, or other document filed or required to be maintained under this Article or a rule implementing this Article; or who knowingly makes a false statement of a material fact in a rulemaking proceeding or contested case under this Article; or who falsifies, tampers with, or knowingly renders inaccurate any recording or monitoring device or method required to be operated or maintained under this Article or rules of the [Environmental Management] Commission implementing this Article shall be guilty of a Class 2 misdemeanor which may include a fine not to exceed ten thousand dollars ($10,000). There is currently no fee for a No Exposure Exclusion. Page 6 of 7 SWU-NCGNE Last revised 1/2512016 NCGNEO00O No Exposure Certification Final Checklist This application should include the following items: ❑ This completed application and all supporting documentation. ❑ A map with the location of the facility clearly marked. ❑ If the site currently has an NPDES Stormwater Permit, be sure to indicate the permit number in Question 8. Mail the entire package to: Stormwater Permitting Unit Program Division of Energy, Mineral and Land Resources 1612 Mail Service Center Raleigh, North Carolina 27699-1612 Note The submission of this document does not guarantee the issuance of a No Exposure Exclusion. For questions, please contact the DEMLR Regional Office for your area. DEMLR Regional Office Contact Information: Asheville Office ...... (828) 296-4500 Fayetteville Office ... (910) 433-3300 Mooresville Office ... (704) 663-1699 Raleigh Office ........ (919) 791-4200 Washington Office ...(252) 946-6481 Wilmington Office ... (910) 796-7215 Winston-Salem ...... (336) 771-5000 Central Office .........(919) 807-6300 Page 7 of 7 SWU-NCGNE Last revised 1125/2018 NORTH CAROLINA DIVISION OF Raleigh Regional Office AIR QUALITY Wood Products Inc NC Facility ID 9200402 Inspection Report County/FIPS: Wake/183 Date: 06/30/2016 Facility Data Permit Data Wood Products Inc Permit 04245 / R07 507 North Harrington Street Issued 3/26/2012 Raleigh, NC 27603 Expires 2/28/2017 Lat: 35d 47.2380m Long: 78d 38.6830m Classification Small SIC: 2499 / Wood Products, Nee Permit Status Active NAICS: 32192 / Wood Container and Pallet Manufacturing Current Permit Application(s) None Program Applicability SIP Contact Data Facility Contact Authorized Contact Technical Contact Ronald Cox Ronald Cox Ronald Cox Owner and Plant Owner and Plant Owner and Plant Manager Manager Manager (919) 834-2075 (919)834-2075 (919) 834-2075 Compliance Data Comments: In Compliance. Mr. Cox stated that he was informed by the landlord that he needed to relocate the facility by the end of November 2016, because the Inspection Date 06/30/2016 building will be torn down for redevelopment. Inspector's Name Cheng Zhang Operating Status Operating Inspector's Signature: Q rtnA f Compliance Code Compliance - inspection Action Code FCE Date of Signature: On -Site Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP SO2 NOX VOC CO PMIO * HAP 2010 0.3100 --- --- 0.4800 --- 795.58 2006 0.8100 --- 0.3400 --- --- 281.46 * Highest HAP Emitted inpounds) Five Year Violation History: None Date Letter Type Rule Violated Violation Resolution Date Performed Stack Tests since last FCE: None Date Test Results Test Methods) Source(s) Tested (1) DIRECTIONS: From PRO, (left) Six Forks Road, (right) Old Wake Forest Road, South Capital Blvd., t'eace Street Exit, (right) Peace Street, (left) West Street, (left) Harrington Street. Second building on right is Wood Products Inc. (11) FACILITY DESCRIPTION: Wood Products, Inc. manufactures wood cabinetry products. The facility was clean and appeared to have no safety problems. No trip hazards or unsafe obstructions were noted inside the facility. Safety Note: Hearing protection, safety glasses, and safety shoes should be worn while inspecting this facility. (111) INSPECTION SUMMARY: On June 30, 2016, I (Cheng Zhang) met with Ronald Cox, owner and plant manager for Wood Products, Inc. to conduct a compliance inspection of the facility. We first reviewed the permit and then took a tour of the facility. At the time of the inspection, there were several workers using different pieces of woodworking equipment that attached to the woodwaste collection system. Mr. Cox stated that he was informed by the landlord that he needed to relocate the facility by the end of November 2016, because the building will be torn down for redevelopment. Overall, the facility seemed to be running well from an air quality standpoint. The woodwaste collection system was operating with 0% opacity. No depositions were observed on the property or any adjacent properties. Annual inspections were logged into a logbook and kept onsite. (IV) PERMITTED EMISSION SOURCES: 1. A simple cyclone (86 inches in diameter, ID No. C-1) installed on a wood waste collection system (ID No. WC-1) (V) SPECIFIC PERMIT CONDITIONS: A.1 Applicable Regulations: The Permittee shall comply with 15A NCAC 2D .0202, 2D .0512, 2D .0521, 2D .0535, 2D .0540, 2D .0611 and 2D .1806. In compliance. At the time of the inspection, this facility appeared to be in compliance with all permit conditions. A.2. Permit renewal and Emission Inventory Requirement -At least 90 days prior to the expiration date of this permit, the Permittee shall submit the air pollution emission inventory report in accordance with 15A NCAC 2D .0202, pursuant to N.C. General Statute 143 215.65. In compliance — Mr. Cox was reminded of this condition. A.3 Particulate Emission Limitations: Pursuant to 15A NCAC 2D .0512, particulate matter emissions from the affected emission sources listed in the permit shall not exceed allowable emission rates which are determined based on process throughput rates using the equations provided in the permit. In compliance. All woodworking equipment is hooked to a woodwaste collection system. Other than the simple cyclone, the facility also has two internal woodwaste collection systems that collect finer saw dust, these systems do not emit to the air. AA 2D .0521 Control of Visible Emissions: Visible emissions from the facility emission sources, established after July 1, 1971, shall not be more than 20 percent opacity. In compliance. No visible emissions were observed during the inspection. A.5 2D .0535 Notification Requirements: Facility is required to notify the Division of Air Quality if excess emissions are released for more than four (4) hours. In compliance. Mr. Cox stated that there had been no excess emissions due to a malfunction. A.6 2D .0540 Fugitive Dust: The facility shall not allow fugitive dust to extend beyond the property's boundary. In compliance. No fugitive dust was observed during the inspection. No complaints concerning fugitive dust have been received by the RRO. A.7 2D .0611 Cyclone Requirements. Facility cyclones shall be inspected at least once during each 12-month period and the results ofthe inspections shall be recorded in a logbook In compliance. Maintenance is performed on an "as needed" basis as well as an annual internal inspection of the system. Records are kept in a logbook. Most recent annual inspection was conducted on December 12, 2015. A.S 2D. 1806 Control and Prohibition of Odorous Emissions: The permittee shall employ suitable measures to control odorous emissions from all emission sources. In compliance. No odorous emissions were detected outside of the facility's boundaries. The RRO has not received any complaints concerning odor at this facility. (VI) COMPLIANCE HISTORY: The facility has not history of violations with the PRO. (VII) EXEMPT EMISSION SOURCES: No new exempt sources were found. (V Ill) SOURCE TEST HISTORY: There are no stack tests required by the facility's air permit and no testing has been required according to DAQ source test database. (a) 112(r) APPLICABILITY: There is no indication that chemicals are stored in threshold volumes. (X) CONCLUSIONSIRECOMMENDATIONS: At the time of the inspection, this facility appeared to be in compliance with all permitted requirements. It is recommended that the facility be reinspected in two (2) years.