NCS000235_Inspection Report_20211130

Compliance Inspection Report
Permit: NCS000235 Effective: 11/01/10 Expiration: 10/31/15 Owner: Southern Resin Inc
SOC: Effective: Expiration: Facility: Southern Resin Incorporated
County: Davidson 3440 Denton Rd
Region: Winston-Salem
Thomasville NC 27360
Contact Person: Brandon Conrad Title: Quality/Safety Manager Phone: [phone]
Directions to Facility:
System Classifications: SWNC,
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 11/30/2021
Primary Inspector: Levi Hiatt
Secondary Inspector(s):
Entry Time 10:30AM
Reason for Inspection: Follow-up
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Certification:
Phone:
Exit Time: 01:30PM
Phone: [phone]
Inspection Type: Compliance Evaluation
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Permit: NCS000235 Owner - Facility: Southern Resin Inc
Inspection Date: 11/30/2021 Inspection Type: Compliance Evaluation Reason for Visit: Follow-up
Inspection Summary:
Documents pertaining to the Individual Industrial Stormwater Permit were reviewed for this facility as a follow-up to the
previous inspection in response to a spill that had occurred on site. Upon reviewing the documents, several issues were
found that need to be addressed:
A general USGS Map or detailed site map was not found in the SWPPP, and the list of responsible parties was out of date
The most recent spill was not included in the SWPPP. This spill, as well as any other spills that have occurred during the
past 3 years, need to be listed and summarized in the SWPPP.
Page 11 of the SWPPP states that rubber mats are used to cover drains during the loading/unloading of polymer. These
mats should be supplemented with compost sock wattles that completely surround the drain. Also, please specify what is
to be done with any leaked materials captured in the buckets during loading/unloading.
The Spill Prevention and Response plan should be included in the SWPPP. This plan should state the specific actions to be
taken by employees in the event of a spill, and list who to contact in the event of a spill.
The capacities of each storage tank should be listed with the approximate amount of chemical contained. The volume of
secondary containment, if applicable, should also be listed for each tank.
The BMPs for this facility are sporadically listed, and not summarized in one place. BMPs can be structural (diversions,
ponds, valves, wattles, etc.) and non-structural (inspections, good housekeeping operations). Please list all the BMPs in one
section of the SWPPP, even though they may be referenced in other sections.
The Preventative Maintenance and Good Housekeeping Plan should include a table showing the inspections that were
discussed in this section of the SWPPP. This table should include at a minimum, the area that was inspected, the date of
the inspection prior to the most recent inspection, the date of the most recent inspection, the date of the next inspection, as
well as a summary of the inspection, including any issues that have been or need to be resolved. This will also satisfy
Section II.A.8 of the permit.
The Employee Training documents should include labeled pictures, specifically for the Spill Prevention and Response, Best
Practices, and Housekeeping sections. These pictures will supplement the current training documents and better
demonstrate what specific actions need to be taken or specific areas of concern.
The BMPs listed in section 3.8 (should be labeled II.A.2a) needs to also include the stormwater diversions and settling
ponds.
The SWPPP does not appear to have been reviewed since 2017. However, previous plan review documentation is excellent.
The sections of the SWPPP should be labeled to match the permit (i.e. section 2.1 should be labeled I I.A.1.a, section 6.1
should be labeled II.A.7). Ensure that the new permit is followed when making this change.
Please attend to the above issues as soon as possible. A follow-up inspection will occur after 120 days of receipt of this
inspection report. Please contact this office with any questions concerning this report.
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Permit: NCS000235 Owner - Facility: Southern Resin Inc
Inspection Date: 11/30/2021 Inspection Type: Compliance Evaluation Reason for Visit: Follow-up
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?
Yes No NA NE
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Comment: There were multiple issues with the SWPPP and the Employee Traininq documents. Please see
the Summary above for details.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ❑ ❑ ❑
Comment: This was not evaluated at this time.
Analytical Monitoring
Has the facility conducted its Analytical monitoring?
Yes No NA NE
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# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ 0 ❑
Comment: Sampling results were not provided for the second sampling periods of 2017 and 2020.
The parameter Formaldehyde was also not tested for during 2021. Testing for this parameter is
required by the permit.
Furthermore, this facility should be in Tier 3 Monitoring for Formaldehyde and Nitrate and
Nitrite, and Tier I for COD and Zinc. Please begin the required responses for these Tiers
immediately as specified in the permit.
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? ❑ ❑ 0 ❑
Comment:
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