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HomeMy WebLinkAboutNCS000289_COMPLIANCE_20091117STORMWATER-DIVISION"CODINGGSHEET--- - PERMIT NO. DOC TYPE ❑ FINAL PERMIT ❑ MONITORING INFO ❑ APPLICATION kCOMPLIANCE ❑ OTHER DOC DATE ❑ a ooq l I I -) YYYYM M DD North Carolina Beverly Eaves Perdue Governor Mrs. Brenda Jones Shenandoah Wood Preservers 301 E. 16" St. Scotland Neck, NC 27874 Dear Mrs. Jones: NC®ENR Department of Environment and Natural Resources Division of Water Quality Coleen H. Sullins Director November 11, 2009 Subject: Stormwater Compliance Evaluation Inspection Permit No. NCS000289 Shenandoah Wood Preservers Scotland Neck Halifax County Dee Freeman Secretary On September 30, 2009 your help as I performed a stormwater inspection was greatly appreciated. Your facility was in compliance. Please see the attached inspection checklist. There are some adjustments to your program as a result of this inspection, as highlighted below: Change in the Wood Preserving Process In December 2008, shortly before the renewal of your permit, a new process was put into practice that replaced the MCA process. Please provide to the Central Office, attention Brian Lowther, a description of the new process and an MSDS sheet for the chemical(s) involved. This will call for revisions in at least three paragraphs of the Stormwater Pollution Prevention Plan (SP3). Outfall Designations The permit gives responsibility for determining the stormwater discharge points from a property to the permittee (or their consulting firm). Three locations were so identified at the start of your program several years ago. During this inspection a discussion of sampling resulted in a close examination of the sample points, and it was determined that Outfalls 002 and 003 that were once thought to discharge from the perimeter ditch actually receive water into the perimeter ditch from small watersheds. The perimeter channel carries stormwater around three sides of the facility, and discharges only at Outfall 001. Consequently, sampling and visual inspections are required only at Outfall 001. Revisions will be needed in your site map, the wording of the SP3, and the contract you have with the laboratory because of this change. Sampling Details Analytical testing was not accomplished in the first half of 2009, explained at follows. In the first six months of the renewed permit, the laboratory doing the testing went out of business. One NorthCarolina JVahtra!!!f North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone (919) 7914200 Customer Service Internet: www.ncwaterquality.org 1628 Mail Service Center Raleigh, NC 27699-1628 FAX (919) 788-7159 877-623-6748 _ An Equal Opportunity/Affirmative Action Employer — 50 % Recycled/10% Post Consumer Paper a Shenandoah_ Wood.Preservers„Septa•er 30, 2009 Page 2 of 2 v l J yl'.htrScri:Y . In the time to contract with another laboratory and receive a bottle kit, the rains for the period of the year ending 4une'3Aca'me to an end. Visual inspections had been done. About a week ago sampling for the other semi-annual round had been accomplished. Secondary Containment Drain Issue Following the DWQ inspection in 2007, a drain with a padlock had been placed on the containment drain for diesel fuel. At this inspection, the padlock was located on the top of the wall and the handle of the valve had been significantly bent and mutilated. The valve was closed, but no longer functional. Please make repairs. If you have any comments or questions about this inspection, please call me at 919-791-4200. Sincerely, Myrl A. Nisely Environmental Chemist Raleigh Regional Office cc: S WP/RRO file Brian Lowther, Stormwater Permitting Unit Central Files 0 • Permit: NCS000289 SOC: County: Halifax Region: Raleigh Compliance Inspection Report Effective: 03/01/09 Expiration: 02/28/14 Owner: Shenandoah Wood Preservers In Effective: Expiration: Facility: Shenandoah Wood Preservers In 301 E 16th St Contact Person: Brenda H Jones Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 09/30/2009 Primary Inspector: Myrl Nisely Secondary Inspector(s): Title: President Entry Time: 01:15 PM Reason for Inspection: Routine Permit Inspection Type: Stormwater Discharge, Individual Facility Status: ■ Compliant ❑ Not Compliant Question Areas: 0 Storm Water (See attachment summary) Certification: Scotland Neck NC 27874 Phone: 252-826-4151 Exit Time: 03:00 PM Phone: Phone: 919-791-4200 Inspection Type: Compliance Evaluation Page: 1 Permit: NCS000289 Owner - Facility: Shenandoah Wood Preservers In Inspection Date: 09/30/2009 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? ❑ Cl ❑ # 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? 11 ❑ ❑ # 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)? E ❑ ❑ ❑ # 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: A process modification to Copper Carbonate Tebuconazole and away from Micronized Copper Quaternary has been made since the revised permit was issued. Please notify the Central Office permit writers of this and include an MSDS sheet for the new material. The Stormwater Plan has been updated since the above change, but there are sentences on pages 1,4, and 7 that need to also reflect the change. On page 4 we discussed adding a comment on the diesel containment drain that a valve with a lock has been added. See the comment in the cover letter concerning this lock. Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ■ ❑ ❑ ❑ Comment: Have been reviewing the site quarterly. New recording form should make ranking of observations easier and more reliable. 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: In the first half of 2009, the laboratory doing the testing ceased operation. It took a period to establish with a new lab and receive sample bottles. There was no rain large enough after that to sample before the end of June. Permit and Outfalls Yes No NA NE Page: 3 4. Permit: NCS000289 Owner - Facility: Shenandoah Wood Preservers In Inspection Date: 09/30/2009 Inspection Type: Compliance Evaluation Reason for Visit: Routine # 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: A closer look at outfalls 002 and 003 during this inspection showed that what might at first look like discharge ditches are in reality run-on conveyances. Discussion with the employee who gathers the samples revealed that discharges have never been observed at those two locations. For that matter, run-on has not been observed. Therefore, the entire perimeter ditch comes to outfall 001, the only location to be sampled. Please make these changes in the Plan, and notify the lab as well. Page: 4 01. ,rw � Michael F. Easley, Governor N Brenda Jones Shenandoah We 301 E 16th Street Scotland Neck, 1 Dear Mrs. Jones: Preservers, Inc. 27874 A. William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Coleen K Sullins, Director Division of Water Quality November 24, 2008 Subject: Draft NPDES Stormwater Permit Permit No. NCS000289 Shenandoah Wood Preserver, Inc, Halifax County Enclosed with this letter is a copy of the draft stormwater permit for your facility. Please review the draft very carefully to lensure thorough understanding of the conditions and requirements it contains. The draft permit contains the following significant changes from this facility's current permit: 1. The analytical monitoring for COD and TSS was maintained for the sampling requirements in this permit. Addition monitoring will include BOD5 and Cu. BOD5 and COD has been included because our regional offices have found some timber treating sites have high le ,els of these pollutants in surface waters along the properties of timber facilities. BOD5 and COD have be en added to this permit. pH has been added to the analytical monitoring requirements. 2. All analytical monitoring has been set to semi-annually during a representative storm event as defined in Part II Section B. The permittee must also document the total precipitation for each event. If no discharge occurs during the sampling period, the permittee must submit a monitoring report indicating "No Flow" within 30 days of the end of the six-month sampling period. Additionally, samples must be taken a minimum of 60 days apart, as specified in Table 2. 3. Benchmarkslfor analytical monitoring have been added to this draft permit. Exceedances of benchmark values require the permittee to increase monitoring, increase management actions, increase record keeping, and%or install stormwater Best Management Practices (BMPs) in a tiered program. If the sampling results are above a benchmark value, or outside of the benchmark range, for any parameter at any outfall thlen the facility shall follow the Tier 1 guidelines which require a facility inspection within two weeks and implementation of a mitigation plan within two months. If during the term of this permit, the samplinglresults are above the benchmark values, or outside of the benchmark range, for any specific parameter at a specific discharge outfall two times in a row (consecutive), then the facility shall follow the Tier 2 guidelilnes which require a repetition of the steps listed for Tier 1 and also immediately institute monthly monitoring for all parameters at every outfall where a sampling result exceeded the benchmark value for two consecutive samples. 4. You are required to collect all of the analytical and qualitative monitoring samples during representative storm events ias defined in Part II Section B. Qualitative monitoring is required regardless of representative outfall status. NoithCarolina North Carolina Division of Niater Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone (919) 807-6300 Customer Service Internet: h2oanrstate.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX (919) 807-6494 1-877-623-6748 Equal Opportunity/Affirmative Action Employer -50% Recycled110% Post Consumer Paper W. Brenda Jones 11 Georgia-Pacific Treated Lut11-c`k.L.1. Permit No. NCS000289 5. You are responsible for all monitoring until the renewal permit is issued. See Footnote 1 of Tables 1, 4, and 5. 6. The flow reporting requirement has been removed per DWQ revised strategy. (The total rainfall parameter is in this permit, however.) 7. Vehicle maintenance monitoring has been revised to semi-annually in order to coincide with analytical and qualitative monitoring. This requirement appears in all Individual Stormwater permits, however it only applies to facilities that do vehicle maintenance. If the facility begins vehicle maintenance during the permitted timeframe then the requirements shall apply. 1. Additional guidance is provided about the Site Plan requirements. The site map must now identify if the receiving stream is impaired and if it has a TMDL established. It must also describe potential pollutants in each outfall. The map requirements are stated more explicitly. And, the site plan must contain a list of significant shI�ills that have occurred in the past three years and also must certify that the outfalls have been inspectE d to ensure that they do not contain non-stormwater discharges. Additional information is provided in Part II Section A. 2. Additional requirements for the Stormwater Management Plan have been specified in Part II Section A. More details regarding secondary containment are provided. 3. Additional requirements for the Stormwater Pollution Prevention Plan have been specified in Part II Section A. The plan must also be updated annually to include a list of significant spills and to certify that the outfalls jo not contain non-stormwater discharges. 4. The facility must now implement a semi-annual Facility Inspection Program of the site's stormwater management controls as specified in Part II Section A. 5. Information fegarding the No Exposure Exclusion has been added to this draft permit. If industrial materials and activities are not exposed to precipitation or runoff as described in 40 CFR §122.26(g), the facility may qualify for a No Exposure Exclusion from NPDES stormwater discharge permit requirements. Additional information is provided in Part I Section A. Please submit any comments to me no later than thirty (30) days following your receipt of the, draft. Comments should be sent to the address listed at the bottom of this page. If no adverse comments are received from the public or from you, this permit will likely be issued in about two months. If you have any questions or comments concerning this draft permit, contact Brian Lowther at (919) 807-6368 or brian.lowther Pncmail.net Sincerely, Brian Lowther Environmental Engineer Stormwater Permitting Unit cc: Raleigh Regional Office Stormwater Permitting Unit Attachments: Draft 0 0� W ArF9 6 ®® 00 Michael F. Easley, Governor Y William G. Ross,.lr., Secretary Cl r" North Carolina Department of Environment and Natural Resources --I O Y Alan W. Klimek, P.E., Director Division of Water Quality April 20, 2007 E Ms. Brenda Jones, Secretary -Treasurer Nge Shenandoah Wood Preservers 301 E. 16`h St. Scotland Neck, NC 27874 Subject: Stormwater Compliance Evaluation Inspection Permit No. NCS000289 Shenandoah Wood Preservers Scotland Neck, NC Halifax County Dear Ms. Jones: The inspection I carried out with your help on April 18, 2007 showed the facility to be in compliance with the above stormwater permit. Thank you for the tour and in-depth discussion we had. Please see the attached inspection checklist and comments. Highlighted points are these: 1. The Stormwater Pollution Prevention Plan did not show documented evidence that it had been reviewed and updated in the last year, mostly because you expect to do so when the new permit arrives (see 5. below). There were recent documents included, though, that showed that the plan is in use and is being followed. Carefully update each section to be sure names, phone numbers and similar topics are current. Please make notations on the site map showing where samples are taken. These can simply be added by ballpoint. 3. In the future, document more fully the stormwater training employees receive. A page with their signatures verifying attendance, the name and initials of the trainer, the date and topics covered can be inserted into the manual The drainpipe that empties the secondary containment structure around the diesel fuel tank had no valve. Please place a valve on this drain,'witi h either a handle that can be removed until needed, or can be locked with a padlock. The containment should be drained only by authorized, trained personnel who know to look for an oil/water interface. 5. An application for renewal of this permit had been submitted in February 2006, but a draft has not yet been issued by DWQ. You stated that at this time a new preserving process is being added to the plant, known as Wolman AG. Please write a letter to the permit writer who is reviewing your permit, Ms. Aisha Lau, providing the details of this process, so that consideration of any possible impact of the new chemicals can be included in the new permit. The number and kinds of chemicals, MSDS sheets for each, and an estimate of volumes likely to be consumed annually should be included in this submittal. No,,,Kmolina nkrrally North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone (919) 791-4200 Customer Service Internet: www.ncwamruu'dity ore 1628 Mail Service Center Raleigh, NC 27699-1628 FAX (919) 788-7159 1-877-623-6748 An Equal Opportunity/Affirmative Action Employer-50% Recycled110% Post Consumer Paper Shenandoah Wood Preservers CEI, April 2007 Page 2 of 2 •® ®® Please either drop me a note at the address in the tooter, or an email when Item 4. has been accomplished. If you have any comments or questions about this inspection, please call me at 919-791-4200. ®,k_py�TT:Rk�a6�� cc: SWP/RRO file Central Files Sincerely, 'Y G. yL Myrl A. Nisely Environmental Chemist myrl.nisely@ncmai1.net 0® ®o Compliance Inspection Report Permit: NCS000289 Effective: 08/31/01 Expiration: 08/31/06 Owner: Shenandoah Wood Preservers In Sac: Effective: Expiration: Facility: Shenandoah Wood Preservers In County: Halifax 301 E 16th St Region: Raleigh -p p Scotland Neck NC 27874 Contact Person: Feenk—FaithfGl Phone: 252-826-4151 Directions to Facility: Q Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 04/1812007 Entry Time: 10:30 AM Primary Inspector: Myrl Nisely Secondary Inspector(s): Reason for Inspection: Routine Permit Inspection Type: Stormwater Discharge, Individual Facility Status: ■ Compliant ❑ Not Compliant Question Areas: Storm Water r_ U Ut (See ) Exit Time: 11:55 AM Phone: 919-791-4200 Inspection Type: Compliance Evaluation Page: 1 •0 0® Permit: NCS000289 Owner -Facility: Shenandoah Wood Preservers In Inspection Date: 04/18/2007 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? ■ ❑ ❑ ❑ # Does the Plan include a BMP summary? ■ ❑ ❑ ❑ # Does the Plan include a Spill Prevention and Response Plan (SPRP)? ■ ❑ ❑ ❑ # Does the Planinclude 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: Request that sampling location for each outfall be noted on site map. Can be added with ballpoint. There was an ineffective valve on the fuel tank secondary containment structure. Replace it with a good valve and a lock. The containment is to be drained by authorized personnel only. Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ■ ❑ ❑ ❑ Comment: 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: Permit and Outfalls Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? ■ ❑ 110 # Were all outfalls observed during the inspection? ■ ❑ ❑ ❑ # If the facility has representative outfall status, is it properly documented by the Division? Cl ❑ ■ ❑ # Has the facility evaluated all illicit (non stormwater) discharges? ■ ❑ ❑ ❑ Page: 3 ®® 0® Permit: NCS000289 Owner -Facility: Shenandoah Wood Preservers In Inspection Date: 04/18/2007 Inspection Type: Compliance Evaluation Reason for Visit: Routine Comment: Application for permit renewal was submitted on time in 2006. Facility is now adding a new process called Wolman AG, in addition to maintaining the ACQ process. Please submit to Aisha Lau details of the chemicals this entails (seven components), MSDS sheets for each, and an estimate of the quantity likely to be used each year. If any of these new materials will be in bulk storage outside the buildings, address plans for secondary containment in your writeup, as well. Page: 4 #0 0® Compliance Inspection Report Permit: NCG020131 Effective: 01/19/05 Expiration: 12/31/09 Owner: M J Price Price Borrow Pit SOC: Effective: Expiration: Facility: M J Price Price Borrow Pit County: Halifax Hwy 903 Region: Raleigh Littleton NC 27850 Contact Person: M J Price Phone: 919-537-0244 Directions to Facility: Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 04113/2007 Entry Time: 01:10 PM Exit Time: 01:20 PM Primary Inspector: Myrl Nisely Phone:919-791-4200 Secondary lnspector(s): Reason for Inspection: Routine Inspection Type: Stormwater Permit Inspection Type: Mining Activities Stormwater Discharge COC Facility Status: ■ Compliant f1 Not Compliant Question Areas: 0 Storm Water (See attachment summary) Page: 1 Permit: NCG020131 Owner - Facility: M J Price Price Borrow Pit Inspection Date: 04/13/2007 Inspection Type: Stormwater Reason for Visit: Routine Inspection Summary: Recon on this Borrow Pit showed that the "dish" hollowed out from earlier activity simply would hold all stormwater received. There has been no soil removed from the pit in several years. This site is idle, and there is no environmental threat. Permit could be rescinded, unless permittee wants to keep it just to have it available for future activities. Myrl Nisely Page: 2 Questions for General Permit Inspections r 252-5"37-O24q �t�cu�41n-ti,y 9 Date: ��� 3lb� Permit No. NCG020131 Facility: MJ Price Borrow Pit Time ln: (',(6 Qtj Departure Time: a0 Inspector(s): Myrl Nisely YES NO NA -NE 1. Is a copy of the Permit and the Certificate of Coverage available at the site? ❑ ❑ ❑ ❑ 2. Does the Plan include a General Location (USGS) map? ❑ ❑ ❑ ❑ 3. Does the Plan include a "Narrative Description of Practices"? ❑ ❑ ❑ ❑ 4. Does the Plan include a detailed site map including outfall locations? ❑ ❑ ❑ ❑ 5. Does the Plan include a list of significant spills in the past 3 years? ❑ ❑ ❑ ❑ 6. Has the facility evaluated all illicit (non stormwater) discharges to the storm sewer system? ❑ ❑ ❑ ❑ 7. Has the facility evaluated feasible alternatives to current practices? ❑ ❑ ❑ ❑ 8. Does the facility provide all necessary secondary containment? ❑ ❑ ❑ ❑ 9. Does the Plan include a BMP summary? ❑ ❑ ❑ ❑ 10. Does the Plan include a Spill Prevention and Response Plan (SPRP)? ❑ ❑ ❑ ❑ It. Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ❑ ❑ ❑ ❑ 12. Does the facility provide and document Employee Training? ❑ ❑ ❑ ❑ 13. Does the Plan include a list of Responsible Party(s)? ❑ ❑ ❑ ❑ 14. Is the Plan reviewed and/or updated annually? ❑ ❑ ❑ ❑ 15. Does the Plan include a Stormwater Facility Inspection Program? ❑ ❑ ❑ ❑ 16. Has the Plan been implemented? ❑ ❑ ❑ ❑ 17. Has the facility conducted its Qualitative Monitoring semi-annually? ❑ ❑ ❑ ❑ 18. Has the facility conducted its Quantitative (Analytical) monitoring? ❑ ❑ ❑ ❑ 19. Does the facility have Vehicle Maintenance activities on site (uses more than 55 gallons of new motor oil per month)? ❑ ❑ ❑ ❑ 19a. Has the facility conducted its Annual Quantitative (Analytical) monitoring at outfalls, receiving runoff from Vehicle Maintenance areas? ❑ ❑ ❑ ❑ 20. Were all outfalls observed during the inspection? ❑ ❑ ❑ ❑ 21. If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ❑ ❑ Comments: 6 Q- J �`� al Recommendations: Requirements: �j03, 031 Q ®� ..