NCG030622_NOD_20170929

Energy, Mineral &
Land Resources
ENVIRONMENTAL DUALITY
September 20, 2017
CERTIFIED MAIL #70171450 0001 1945 0649
RETURN RECEIPT REQUESTED
Attn: Dale Greenwood
SPEED Metal Fabrication, Inc.
2400 Shore Street
Archdale, NC 27263
Subject: NOTICE OF DEFICIENCY
NOD-2017-PC-0233
ROY COOPER
Governor
MICHAEL S. REGAN
secretory
TRACY DAVIS
Director
RtCEJED
SEP292017
L?ENR,LMID QUALITY
ORMK/ATER PERMITTING
Permit No. NCG 030622
SPEED Metal Fabrication (formerly IV-S Metal Stamping, Inc.
Randolph County
Dear Mr. Greenwood:
On September 20, 2017 Glen White, Environmental Specialist with the North Carolina
Department of Environmental Quality — Division of Waste Management (NCDEQ — DEMLR)
conducted an unannounced compliance inspection with you at the facility located at 2400 Shore
Street in Archdale.
This facility holds General Stormwater Permit NCG030622 to discharge stormwater from
industrial activity associated with Metal Fabrication [SIC 341 under the National Pollutant
Discharge Elimination System (NPDES). The permit became effective October 1, 2014 and
expires on September 30, 2019. A copy of the current permit is required to be maintained with
the Stormwater Pollution Prevention Plan (SPPP) documents.
This facility was required to develop and maintain a Stormwater Pollution Prevention Plan
(SPPP) in accordance with Part II, Section A of the permit. All qualitative and analytical
monitoring records are required to be maintained with the SPPP for a minimum of five (5) years.
The following observations and deficiencies were noted during the NCDEQ inspection and
subsequent file review:
Stormwater Pollution Prevention Plan:
General Permit NCG 030000, Part II Section A requires the permittee to develop and
implement a Stormwater Pollution Prevention Plan (SPPP) that incorporates items 1
through 9 of this section of the permit. This facility was found to be deficient in that it
State of North Carolina ' Environmental Quality Energy, Mineral and Land Resources
WinstoirSalem Regional Office i 450 Hanes Mill Road. Suite 300 1 Winston-Salem. NC 27103

did not appear to have provided a Stormwater Pollution Prevention Plan (SPPP) and
does not have a plan being prepared. The facility has not updated the responsible parties
information, name%wnership of the facility.
4ualitative & Analytical Monitoring:
General Permit NCG 030000, Part II Section B & D require the permittee to conduct
semi-annual qualitative and analytical monitoring at the facilities outfalls. This facility
was found to be deficient in that it has conducted no monitoring.
No Exposure Exclusion:
It appears that this facility may qualify for No Exposure Exclusion to the full industrial
stormwater permit. This is only an observation, not a requirement. If the facility or
property owners were to clean up the area behind the facility and remove all metal, wood
and plastic waste materials and totes, the facility could apply for No Exposure Exclusion
under current operating procedures.
Your Required Response:
Accordingly, you are directed to respond to this letter in writing within 30 calendar days of
receipt of this Notice. Your response should outline how the violations will be addressed and
should be sent to this office at the letterhead address and include the following:
Stormwater Pollution Prevention Plan:
• Provide a Stormwater Pollution Prevention Plan (SPPP) and all nine (9) of the required
components unless the facility plans to qualify for No Exposure Exclusion to the full
permit within 30 days from the date of registered receipt of this letter.
• Provide qualitative and analytical monitoring at all outfalls on a semi-annual basis unless
the facility plans to qualify for No Exposure Exclusion to the full permit within 30 days
of receipt of this letter.
• If No Exposure Exclusion is requested, the site must be cleaned up as discussed prior to
inspection to determine if exclusion can be granted.
Thank you for your attention to this matter. This Office is considering sending a
recommendation for enforcement to the Director of the DEMLR (Division of Energy, Minerals,
& Land Resources) regarding these issues and any future/continued violations that may be
encountered. This office requires that the violations, as detailed above, be abated
immediately and properly resolved. Environmental damage and/or failure to secure proper
authorizations have been documented on the subject tract as stated above. Your efforts to
undertake activities to bring the subject site back into compliance is not an admission, rather it is
an action that must be taken in order to begin to resolve ongoing environmental issues.
State ref North Carolina Environmental Quality 1 'Energy, Mineral and Land Resources
Winston-Salem Regional Office 1 450 Nane:� Mill Road, Suit. 300 1 Winston-Salem, NC 27103
336 i76 9800

Pursuant to G.S. 143-215.6A, these violations and any future violations -are subject to a civil
penalty assessment of up to a maximum of $25,000.00 per day for each violation. Your
above -mentioned response to this correspondence, the degree and extent of harm to the
environment and the duration and gravity of the violation(s) will be considered in any civil
penalty assessment process that may occur. Should you have any questions regarding these
matters, please contact Glen White at [phone].
Sincerely,
Matthew E. Gantt, P.E.
Regional Engineer
Land Quality Section
Winston-Salem Regional Office
Enclosures: Inspection Report
Name/Ownership Change Form
No Exposure Exclusion Application
cc: DEMLR — WSRO
DEMLR — Stormwater Permitting Unit
State of North. Carohna I Environmental Quality I Energy, Mineral and Land k:es", Arces
Winston-Salem Regional Office 1450 Hanes Mill Road, SWW WO I Winston-Salem. NC 27103

Permit: NCG030622
SOC:
County: Randolph
Region: Winston-Salem
Contact Person: Jerri Smith
Compliance Inspection Report
Effective: 12/12/12 Expiration: 10/31/17 Owner: Jerri Smith
Effective: Expiration: Facility: IV-S Metal Stamping Inc
2400 Shore St
Title:
High Point NC 27263
Phone: [phone]
Directions to Facility:
From 1-85 take Hwy 311 N toward High Point. Take left on Fairfield Rd. Take left on Shore St - Bldg located on comer of Shore St &
Corporation Dr
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 09/20/2017 EntryTime: 10:OOAM Exit Time: 11:OOAM
Primary Inspector: Glen White Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Metal Fabrication Stormwater Discharge COC
Facility Status: Compliant Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page: 1

Permit: NCG030622 Owner -Facility: Jerri Smith
Inspection Date: 09/20/2017 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Environmental Specialist, Glen White, visited the facility on 9/20/2017 and met with Dale Greenwood. The facility was
formerly IV-S Metal Stamping, Inc. and the permit continues to be covered under that name. Annual Stormwater fees have
been paid and are current but no Name/Ownership has been submitted to update the permit. This form will need to be
submitted to NCDEQ to verify the new owner information.
The interior of the process area inside of the building has a floor drain system that drains to the city sanitary sewer system
No production is conducted outside of the facility. This is a metal stamping facility that produces parts from sheet metal.
All lubricants used in the process are non hazardous, water based solutions.
1. The new owner, SPEED Metal Fabrication will need to provide Name/Ownership information for the permit. A copy of
the required form is included with this letter.
2. The facility appears to qualify for No Exposure Exclusion to the industrial stormwater permit. Complete and submit the
attached Notice of Intent (NO[) for if exclusion is preferred.
3. If No Exposure cannot be granted, the facility will need to provide a Stormwater Pollution Prevention Plan (SPPP) and
conduct semi-annual monitoring as the permit required.
4. Clean-up the grounds on the rear side of the facility. All metal, plastic and wood waste materials stored in this area as
well as empty totes, need to be removed before No Exposure Exclusion can be granted.
Page: 2

Permit: NCG030622 Owner - Facility: Jerri Smith
Inspection Date: 09/20/2017 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?
❑ ®El ❑
# 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?
❑ 0 ❑ ❑
# Does the facility provide all necessary secondary containment?
❑ N ❑ ❑
# 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?
❑ N ❑ ❑
# 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?
❑N ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
❑ 0 (l ❑
Comment: SPEED Metal Fabricators took ownership on June 1- 2017 from IV-S Metal Stamping, Inc. Fees
are current for the facility but there is no Stormwater Pollution Prevention Plan and the ownership
information has not been updated.
Qualitative Monitorinq Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ❑ N ❑ ❑
Comment: No monitoring has been performed.
Analytical Monitoring
Has the facility conducted its Analytical monitoring?
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
Yes No NA NE
❑❑0❑
Comment: Analytical Monitoring is not required since the facility conducts no vehicle maintenance and all
production completed inside the facility with no exposures to stormwater or outfalls. Facility
actually appears togualifiy for a No Exposure Exclusion to the Industrial Stormwater Permit for
Metal Fabrication facilities.
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?
Page: 3

Permit: NCG030622 Owner -Facility: Jerri Smith
Inspection Date: 09/20/2017 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Comment: Inspector walked the site with Mr. Greenwood. The back of the facility has scrap metal, wood
waste materials and a couple of empty totes that need to be hauled off. All of the waste metals,
wood and totes will need to be hauled offsite and the area cleaned up before a No Exposure
Exclusion to the stormwater rules can be granted.
Page: 4