NCS000049_IGM Resins Inspection Report_20230530

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
DOUGLAS R. ANSEL
Interim Director
IGM Resins USA Inc
Attn: Bryan Hug, Plant Manager
3300 Westinghouse Boulevard
Charlotte, North Carolina 28273
NORTH CAROLINA
Environmental Quality
May 30, 2023
Subject: COMPLIANCE EVALUATION INSPECTION
NPDES Stormwater Permit NCS000049
IGM Resins USA Inc.
Mecklenburg County
Dear Permittee:
On May 25, 2023, a site inspection was conducted for the IGM Resins USA Inc. facility located at 3300
Westinghouse Boulevard, Charlotte, Mecklenburg County, North Carolina. A copy of the Compliance
Inspection Report is enclosed for your review. Mr. Matthew Murray was present -during the inspection and his
time and assistance is greatly appreciated. The site visit and file review revealed that the subject facility is
covered by NPDES Stormwater Permit NCS000049. Permit coverage authorizes the discharge of stormwater
from the facility to receiving waters designated as Steele Creek, class C waters in the Catawba River Basin.
As a result of the inspection, the facility was found to be noncompliant with the conditions of the
NCS000049 permit. Please refer to the enclosed Compliance Inspection Report for additional comments and
observations made during the inspection.
Please be advised that violations of the NPDES Stormwater General Permit are subject to a civil
penalty assessment of up to $25,000 per day for each violation. If you or your staff have any questions,
comments, or need assistance with understanding any aspect of your permit, please contact Jerry Eplin at
[phone] or via e-mail at [e-mail].
Sincerely,
v
Zahid S. Khan, CPM, CPESC, CPSWQ
Regional Engineer
Land Quality Section
JWE
Enclosure: Compliance Inspection Report
c: Matthew Murray, EHS Manager, IGM Resins USA Inc., 3300 Westinghouse Blvd, Charlotte, NC 28273
DEMLR NPDES Stormwater Permit Laserfiche File
9 e0if -ftle North Carolina Department of Environmental Quality Division of Energy, Mineral, and Land Resources
A
ftE_ Mooresville Regional Office 1610 East Center Avenue, Suite 301 Mooresville, North Carolina 28115
704-663-1699

Compliance Inspection Report
Permit: NCS000049 Effective: 11/06/18 Expiration: 10/31/21 Owner: Igm Resins USA Inc
SOC: Effective: Expiration: Facility: IGM Resins USA, Inc.
County: Mecklenburg 3300 Westinghouse Blvd
Region: Mooresville
Charlotte NC 28273
Contact Person: Gerald Walker Title: Phone: [phone]
Directions to Facility:
System Classifications: SWNC,
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 05/24/2023
Primary Inspector: Jerry W Eplin
Secondary Inspector(s):
Entry Time 09:30AM
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ❑ Compliant 0 Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Certification:
Phone:
Exit Time: 12:05PM
Phone: [phone]
Inspection Type: Compliance Evaluation
Page 1 of 4

Permit: NCS000049 Owner - Facility: Igm Resins USA Inc
Inspection Date: 05/24/2023 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On May 24, 2023, the referenced facility was inspected by Jerry Eplin and Rebecca Edwards from the Mooresville Regional
Office of DEMLR. Matthew Murray, EHS Manager, was available for the inpsection.
The inspection revealed the following:
1) The facility has an SWPPP and it has been implemented.
2) The last review date for the SWPPP was 11/22/2022, however, the list of Stormwater Pollution Prevention Team
members in Section 1.4 of the SWPPP do not appear to have been fully updated at that time. It was recommended that the
facility update the SWPPP and DEMLR records to include the correct contacts related to stormwater.
3) The facility utilizes a third party to conduct Qualitative and Analytical Monitoring. These records were up to date.
4) It was noted that the Qualitative Monitoring records do not include "Erosion and Deposition" and "Other". It was
recommended that the third party's monitoring be modified to include these parameters.
5) The most recent documented illicit (non-stormwater) discharge evaluation was dated 10/11/2019. Reportedly other
evaluations have been completed but signed documentation was not available.
6) Most of the outfalls were observed during the inspection. Outfall 4A was not observable due to overgrowth. It was
recommended that the outfall be maintained so as to be accessible at all times.
7) Training records for the facility were up to date.
8) The SWPPP lists a comprehensive stormwater inspection program. Mr. Murray indicated that the comprehensive
inspection is completed by a third party. However, no documentation was avialable related to the comprehenisve inspection
program other than Qualitative Monitoring records. It was recommended that records related to the comprehensive
inspection program be improved.
COMPLIANCE ISSUES:
1) Illicit (non-stormwater) discharge evaluations are required on an annual basis. The facility should complete the evaluation
as soon as possible and repeat the evaluations on an annual basis.
Page 2 of 4

Permit: NCS000049 Owner - Facility: Igm Resins USA Inc
Inspection Date: 05/24/2023 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?
0 ❑ ❑ ❑
# Does the Plan include a General Location (USGS) map?
0 ❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
0 ❑ ❑ ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
N ❑ ❑ ❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
0 ❑ ❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
0 ❑ ❑ ❑
# 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)?
0 ❑ ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
0 ❑ ❑ ❑
# Does the facility provide and document Employee Training?
0 ❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
0 ❑ ❑ ❑
# Is the Plan reviewed and updated annually?
N ❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
0 ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
0 ❑ ❑ ❑
Comment: Facility inspection program listed in SWPPP is conducted by a third party.
No documentation
of completion was available, other than the Qualitiative Monitoring records.
Additionally,
contact names in the SWPPP need to be updated.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring? N ❑ ❑ ❑
Comment: A third party conducts qualitative monitoring. Recommended that the third party inlcude
"Erosion and Deposition" and "Other" as part of the qualitative monitoring, as these are not
curentlV shown on the monitoring forms that are being utilized.
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? ❑ ❑ 0 ❑
Comment:
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? ❑ 0 ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ E ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ❑ E ❑ ❑
Comment: Outfall 4A was not observable due to overgrowth of weeds. Recommended that the outfall be
maintained in an accessible manner at all times. Additionally, the last signed illicit
(non-stormwater) discharge evaluation was dated 10/11/2019. Reportedly other illicit
discharge evaluations have been completed, but signed documentation was not available.
Page 3 of 4

Permit: NCS000049 Owner - Facility:lgm Resins USA Inc
Inspection Date: 05/24/2023 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Page 4 of 4