NCG030677_NOV_20200717

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ROY COOPER - ,
Governor
MICHAEL S.REGAN �
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Secretor
BRIAN WRENN NORTH CAROLINA
Director Environmental Quality
July 17, 2020
CERTIFIED MAIL: 7012 3050 0001 9398 7492
RETURN RECEIPT REQUESTED
Southeastern Tool and Die
Attn: Michael Fidanza, HR/EHS Manager
105 Taylor Street
Aberdeen, NC 28315
Subject: NOTICE OF VIOLATION (NOV-2020-PC-0318)
NPDES Stormwater General Permit NCG030000
Southeastern Tool and Die
Certificate of Coverage NCG030677
Moore County
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Dear Mr. Fidanza:
On June 30, 2020, Mike Lawyer, Environmental Program Consultant with the Fayetteville Regional Office of the Division
of Energy, Mineral and Land Resources(DEMLR), conducted a site inspection for the Southeastern Tool and Die facility
located at 105 Taylor Street in Aberdeen, Moore County, North Carolina. A copy of the Compliance Inspection Report is
enclosed for your review. Your time and assistance provided during the inspection is greatly appreciated. The site visit
and file review revealed that the subject facility is covered by NPDES Stormwater General Permit NCG030000 under
Certificate of Coverage NCG030677. Permit coverage authorizes the discharge of stormwater from the facility to receiving
waters designated as Aberdeen Creek, a class C water in the Lumber River Basin. F
As a result of the site inspection, the following permit conditions violations are noted:
1) Stormwater Pollution Prevention Plan (SPPP)
A Stormwater Pollution Prevention Plan (SPPP) has not been developed, recorded, or properly implemented.
2) Qualitative Monitoring
Qualitative monitoring has not been conducted and recorded in accordance with permit requirements.
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3)Analytical Monitoring
Analytical monitoring has not been conducted and recorded in accordance with permit requirements. r.
Other Observations
Please refer to the enclosed Compliance Inspection Report for additional comments and observations made during the
inspection.
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Requested Response
You are asked to respond to this office, in writing, within 30 calendar days from receipt of this notice. Your written
response should include a reasonable explanation as to why the aforementioned violations have occurred as well as a
Plan of Action to prevent these violations from recurring.
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��� North Carolina Department of Environmental Quality 10[vision of Energy;Mineral and Land Resources
Fayetteville Regional Office 1 225 Green Street,Suite 714( Fayetteville,North Carolina 28301
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Action Items
Immediately develop and implement a site-specific Stormwater Pollution Prevention Plan. Conduct and record stormwater
discharge outfall monitoring per the schedule and conditions of NPDES Stormwater General Permit NCG030000.
Thank you for your attention to this matter. This office requires that the violations, as noted above and detailed in
the enclosed Compliance Inspection Report, be properly resolved.These violations and any future violations are
subject to a civil penalty assessment of up to$25,000 per day for each violation. Should you have any questions
regarding these matters, please contact Mike Lawyer at(910) 433-3394 or via e-mail at [e-mail].
Sincerely,
�imothyy L. La nty, PE
Regional Engineer
DEMLR
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Enclosure: Compliance Inspection Report
ec: William E. (Toby)Vinson, Jr., PE, CPESC, CPM, Section Chief, Program Operations—DEMLR F
Annette Lucas, PE, Stormwater Program Supervisor— DEMLR, Stormwater Program
Alaina Morman, Environmental Specialist—DEMLR, Stormwater Program
cc: FRO— DEMLR, Stormwater Files
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Compliance Inspection Report
Permit:NCG030677 Effective: 11/01/18 Expiration: 05/31/21 Owner: Southeastern Tool and Die
SOC: Effective: Expiration: Facility: Southeastern Tool and Die
County: Moore 105 Taylor St
Region: Fayetteville
Aberdeen NC 28315
Contact Person:Michael Fidanza Title: HR/EHS Manager Phone:[phone] k
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Directions to Facility:
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System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
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On-Site Representative(s):
On-site representative Michael Fidanza 910-944-7677
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Related Permits:
Inspection Date: 06/30/2020 Entry Time 12:50PM^�--� Exit Time: 02:20PM I
Primary Inspector:Mike Lawyer `%v Phone: [phone]
Secondary Inspector(s):
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Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Metal Fabrication Stormwater Discharge COC i
Facility Status: ❑ Compliant E Not Compliant
Question Areas:
Storm Water
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(See attachment summary)
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Permit: NCG030677 Owner-Facility:Southeastern Tool and Die
Inspection Date: 06/30/2020 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Inspection conducted to evaluate facility's compliance with the conditions of NPDES Stormwater General Permit
NCG030000. Met with Michael Fidanza, HR/EHS Manager. Made observations of site conditions including outside storage
areas of materials, equipment, scrap metal dumpsters, etc. as well as various storm drains leading to single discharge
outfall at the rear of the facility.At the time of inspection,there were no ASTs, containers, etc. of liquid materials/products
requiring secondary containment.According to Mr. Fidanza, there is no onsite vehicle or equipment maintenance where
more than 55 gallons of motor oil and/or hydraulic oil is used per month.After site observations, discussions about facility
operations and stormwater permit conditions were held. Facility operations include custom metal fabrication as well as tool
and die manufacturing. Per Mr. Fidanza, metal finishing operations such as iodizing, painting and stripping occur at another
facility located at the other end of the road (225 Taylor Street)where there are no stormwater drains or discharge outfalls.
Regarding the facility's Stormwater Pollution Prevention Plan and stormwater monitoring records for the current permit
period, Mr. Fidanza was unable to provide for review at the time of inspection and requested additional time to try to locate !
as the previous HR/EHS Managers had left the company.A deadline to provide the records via e-mail by July 10, 2020 was
agreed upon, however no such records could be located/provided. Mr.Fidanza was informed that a Notice of Violation would (=
be issued for failure to develop and implement a Stormwater Pollution Prevention Plan and failure to conduct/record
Analytical and Qualitative Monitoring per the conditions of the NCG030000 stormwater permit.
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Permit: NCG030677 Owner-Facility:Southeastern Tool and Die
Inspection Date: 06/30/2020 Inspection Type:Compliance Evaluation Reason for Visit: Routine
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iPrevention Plan Stormwater Pollution Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan? ❑ 0 ❑ ❑
#Does the Plan include a General Location (USGS)map? ❑ ❑ ❑
#Does the Plan include a"Narrative Description of Practices"? ❑ ❑ ❑ 0
#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? ❑ ❑ 0 ❑
#Does the Plan include a BMP summary? ❑ ❑ ❑ 0
#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: Facility personnel could not provide a Stormwater Pollution Prevention Plan for review at the tim(
of inspection and was unable to locate and provide a copy via e-mail to the inspector by the
agreed upon deadline of July 10, 2020.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ❑ N ❑ ❑
Comment: Monitoring records for 2018 and 2019 could not be provided for review.
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? ❑ 0 ❑ ❑
#Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ E ❑
Comment: Monitoring records for 2018 and 2019 could not be provided for review.
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? E ❑ ❑ ❑
#If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ 0 ❑
#Has the facility evaluated all illicit(non stormwater)discharges? ❑ ❑ ❑
Comment:
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