NCG210078_Email RE Outfall Updates_20231025

Cook, Brittany
From: Mertins, Andrea <[e-mail]>
Sent: Wednesday, October 25, 2023 2:43 PM
To: Cook, Brittany
Subject: FW: [External] NCG210078 COC/Outfall Update
Attachments: NCG210078_Insp Rpt_20230921.pdf; Compliance Evaluation Inspection Sept 2023.pdf
Follow Up Flag: Follow up
Flag Status: Flagged
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Hi Brittany,
Per our call—
Outfall 001: 36.498871, -77.422991
Outfall 002: 36.498565, -77.420918
Outfall 003: 36.499155, -77.418780
Outfall 004: 36.499859, -77.417209
Outfall 001 was relocated onto WF property and Outfalls 002-004 have slight coordinate updates based on a site visit.
Let me know if you need anything else.
Thanks,
Andrea Mertins, EIT
Environmental Engineer
♦ � � c 50 International Drive, Suite 150, Greenville, SC 29615
C 512.318.9793 amertins(c�trccompanies.com
Linkedln Twitter Blog TRCcompanies.com
From: Mertins, Andrea
Sent: Friday, October 20, 2023 8:45 AM
To: Cook, Brittany<[e-mail]>; Georgoulias, Bethany<[e-mail]>
Subject: FW: [External] NCG210078 COC/Outfall Update
Brittany and Bethany,
The report that West Fraser received with cover letter also attached.There are some admin errors on the cover letter,
but the report details are correct.
Please let me know if there's a time we can talk next week regarding updates to the facility's coverage.
1

I'd like to submit any documentation necessary sooner rather than later so that we can get their SWPPP and SPCC
updated by the end of the year.
Thank you,
Andrea Mertins, EIT
Environmental Engineer
� amok c 50 International Drive, Suite 150, Greenville, SC 29615
C 512.318.9793 amertins6a�trccompanies.com
Linkedln I Twitter Bloq TRCcompanies.com
From: Mertins, Andrea <[e-mail]>
Sent:Tuesday, October 17, 2023 2:32 PM
To: Cook, Brittany<[e-mail]>
Cc: [e-mail]
Subject: RE: [External] NCG210078 COC/Outfall Update
Hi Brittany,
Thad Valentine conducted a site inspection on 9/21, report attached.There are notes about which of the seven outfalls
require technical updates (location, etc.) and which no longer require coverage.
Will a new COC need to be submitted?
Thank you,
Andrea Mertins, EIT
Environmental Engineer
50 International Drive, Suite 150, Greenville, SC 29615
C 512.318.9793 amertins(cDtrccompanies.com
Linkedln I Twitter I Blog I TRCcompanies.com
0 TIRC
ff
From: Cook, Brittany<[e-mail]>
Sent:Thursday, August 17, 2023 9:04 AM
To: Mertins,Andrea <[e-mail]>
Cc:Valentine,Thad<[e-mail]>
Subject: RE: [External] NCG210078 COC/Outfall Update
contentThis is an External email. Do not click links or open attachments unless you validate the sender and know the
hoverALWAYS over • • and confirm
Good morning Andrea,
2

How significant are the industrial process changes?The reason I ask is to ensure your site still qualifies for coverage
under General Permit NCG210000.
I am looping in Thad Valentine with the Raleigh Regional Office. He would be a good contact to discuss a site visit.
Mrs. Brittany Cook
NPDES Stormwater General Permit Coordinator
Stormwater Program, Division of Energy, Mineral,and Land Resources
N.C. Department of Environmental Quality
Phone: [phone]
Email: [e-mail]
From: Mertins, Andrea <[e-mail]>
Sent:Thursday, August 17, 2023 9:56 AM
To: Cook, Brittany<[e-mail]>
Subject: RE: [External] NCG210078 COC/Outfall Update
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Good morning Brittany,
I'd like to begin the process of updating the outfalls and request a site visit for 4400 NC Hwy 186 Seaboard, NC. (Permit
No. #NCG210078).
During my site visit at the facility,we determined that some industrial activities have changed as well as some changes
to the drainage areas and corresponding outfalls.
The current permit reflects 7 outfalls, 3 of which are being sampled and are in Tier status. For the update,we will need
to relocate 2 outfalls, remove an outfall, and potentially add a representative outfall status.
Do you have availability for a call in the coming week?
Thank you,
Andrea Mertins, EIT
Environmental Engineer
� � c 50 International Drive, Suite 150, Greenville, SC 29615
-- C 512.318.9793 amertins(c�trccompanies.com
FXLinkedln Twitter Bloq TRCcompanies.com
From: Georgoulias, Bethany<[e-mail]>
Sent: Friday,July 7, 2023 6:21 AM
To: Mertins,Andrea <[e-mail]>
Cc: Cook, Brittany<[e-mail]>
Subject: RE: [External] NCG210078 COC/Outfall Update
3

This is an EXTERNAL email. Do not click links or open attachments unless you validate the sender and know
the content
ALWAYS hover over the link to preview the actual URL/site and confirm its legitimacy.
Good morning,Andrea,
Our General Permits coordinator, Brittany Cook, is the best contact for this. However,to verify outfall updates,the next
course is to request a site visit from a DEQ regional office inspector. There is a form to request Representative Outfall
Status on our website, as well (which always prompts a site visit to verify). That info/links to the form are below:
Request Representative Outfall Status (New Requests)
• Attach the completed Representative Outfall Status (ROS) Request Form to
the Stormwater Upload Form.
• Mail one hard copy of the form and supporting documents directly to the appropriate
Regional Office.
I hope this information helps!
Best regards,
Bethany Georgoulias (she/her)
Environmental Engineer, Stormwater Program
DEMLR Laserfiche Administrator
Division of Energy, Mineral,and Land Resources
N.C. Department of Environmental Quality
919 707 3641 office
[e-mail]
512 N. Salisbury Street, Raleigh, NC 27604 (location)
1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing)
Website: http://deq.nc.gov/about/divisions/energy-mineral-land-resources/stormwater
From: Mertins, Andrea <[e-mail]>
Sent:Thursday,July 6, 2023 3:27 PM
To: Georgoulias, Bethany<[e-mail]>
Subject: [External] NCG210078 COC/Outfall Update
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Hi Bethany,
I am updating the SWPPP for West Fraser—Seaboard Mill at 4400 NC Hwy 186 Seaboard, NC. (Permit No. #NCG210078).
During my site visit at the facility,we determined that some industrial activities have changed as well as some changes
to the drainage areas and corresponding outfalls.
4

The current permit reflects 7 outfalls, 3 of which are being sampled and are in Tier status. For the update,we will need
to relocate 2 outfalls, remove 2 outfalls, and potentially add a representative outfall status.
Would you be willing to have a call to discuss?We would like to get approval from the state to update these items
before the SWPPP is completed.
Thank you in advance,
Andrea Mertins, EIT
Environmental Engineer
50 International Drive, Suite 150, Greenville, SC 29615
C 512.318.9793 amertins(a�trccompanies.com
r< Linkedln Twitter Bloq TRCcompanies.com
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.
5

Compliance Inspection Report
Permit:NCG210078 Effective: 06/01/23 Expiration: 05/31/28 Owner: West Fraser Inc
SOC: Effective: Expiration: Facility: Seaboard Lumber Mill
County: Northampton 4400 NC Hwy 186
Region: Raleigh
Seaboard NC 27876
Contact Person:Christine Jenkins-Jordan Title: Phone: [phone]
Directions to Facility:
System Classifications: SWNC,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 09/21/2023 Entry Time 10:30AM Exit Time: 12:45PM
Primary Inspector:Thaddeus W Valentine Phone:
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Timber Products Stormwater Discharge COC
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 4

Permit: NCG210078 Owner-Facility:West Fraser Inc
Inspection Date: 09/21/2023 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
I meet on site with Christine Jenkins-Jordan (EHS)and Kevin DeBerry(General Manager.We walked the site and identified
some issues and made a call for the requested moving of sample point SDO1 from within Carolina Bark facility boundary
back to the SW corner of the West Frazer facility.
Outfall #1 is approved to move from the outfall location at the culvert outlet on Bluejay Trail to the culvert pipe across the
ditch located on the NW corner of the Carolina Bark facility and adjacent to the Scale Yard entrance lot(it is recommended
that a sample be taken from the head of the ditch just North of where the two facilities property lines join to get an idea of
what runs off the West Frazer facility before co-mingling with Carolina Bark runoff). The sample data for this outfalls shows
ultra high readings for COD. I am requesting an assesment of the cause of these high readings and a plan for reducing
count.
SDO-#2 outlets from the facility through a plastic corrugated pipe next to the train track. I recommend that the sample be
taken right at the mouth of the discharge pipe if not slightly inside the pipe opening. I would also request that there is an
assesment of the cause of the very high COD readings.
SDO-#3 outlets from tht facility through a plastic corrugated pipe next to the train track.) recommend this sample be taken
at the very end of the pipe as well to be sure the sample is run off from teh facility only. COD is not being tested at this
outfall and should be according to the requirements of the permit.
SDO-#4 outlets as a ditch just inside the tree line below the maintenance shop. This outfall has not been sampled in the
past and should be. The additional sample requiremenst for vehicle maintenance should be added to the other sample
requirements.
Outfall-#5 was not found. The area where the sample outlet should be is a flat grassy area with no discernable concentrated
flow (not sampled)
Outfall-#6 is a grass lined ditch that runs along the fenceline on the NE side of the facility.It appeared the ditch was runoff
conveyance for the office trailer area with a unknown 15inch RCP pipe at the upper end (not sampled)
Outfall-#7 This outfall is shown on the map at the NE edge of the parking lot. After thoroughly searching that area, no outfall
was found. (not sampled)
All the sample points should be tested for all the required protocols. SDO-1 should include COD and SDO-3 &SDO-4 for
vehicle maintenance along with the other required samples.
The SP3 is missing a number of key elements:
The site map should include all areas (accordingto to there activities) including the maintenance area, drum storgae area,
OWS location with materail storage areas, disposal areas, processing areas,drainage areas etc.. Include drainage flow
direction for all areas and outfall areas with latitude and longitude positions along with all other required features stated in the
permit.
Provide a narative description of processes to include storage and loading and unloading practices, outdoor process areas,
waste disposal processes along with the list of potential pollutants expected to be present in the discharge point for each
outfall
Include additional information in the BMP summery that list all structural and non-structual practices for the facility and
especially the vehicle maintenance area
The secondary containment plan should include not only tanks, but should list all materials that should be stored in
secondary containment. That includes drums and containers of pollutants when full, empty and in use, but not being used.
All drums should be in secondary containment unless activily being used. Any drums in use should be kept under cover.
Page 2 of 4

Permit: NCG210078 Owner-Facility:West Fraser Inc
Inspection Date: 09/21/2023 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Any dumpsters or containers exposed to stormwater should be covered and maintained in structurally sound non-leaking
containers
A list of significant spills should be provided and if no significant spills occur, list"No Spills"for each year. All leaks and
spills should be documented and provide where, when, how it occur and how it was fixed when. The matersil cleaned up
should be stored for disposal and that should be noted as to how it was stored where and when was it disposed of by who.
Detailed tracking is paramount.
Training of personnel that have responsibilities for any of the facility operations is required which includes spill response and
preventive maintenance and good housekeeping of the fscility operations. This should focus on any areas, machinary or
processes that could create a spill or cause a pollutant to be released into the stormwater. They should all be trained and
they should sign off on their training. Provide training that covere all those areas.
Inspections of the site should occur at least twice yearly and be documented. More frequent inspections are recommended
and should cover any and all areas that have the potential for spills, leaks or releases. The maintenance shop should always
be included in that inspection and should include inspections for leaks under equipment, containers and materials stationed
outside. The shop itself should be part of the inspection and should look for open containers or drums with the potential to
spill or leak or be punctured and any spills should be cleaned up immediately and stored properly for disposal.
Page 3 of 4

Permit: NCG210078 Owner-Facility:West Fraser Inc
Inspection Date: 09/21/2023 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? ❑ ❑ ❑
#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? 0 ❑ ❑ ❑
#Does the Plan include a list of Responsible Party(s)? 0 ❑ ❑ ❑
# Is the Plan reviewed and updated annually? 0 ❑ ❑ ❑
#Does the Plan include a Stormwater Facility Inspection Program? 0 ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented? 0 ❑ ❑ ❑
Comment: The facility has an SP3 plan but it needs to be updated with any changes and include any
missing documents or documents that don't fully provide the permit requirements. Additional
comments in summery
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring? 0 ❑ ❑ ❑
Comment: Provided for all outfalls being sampled. Outfall (SDO)#4 is being added with additional
samples for vehicle maintenance
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: All analytical documentation was provided with very high COD readings for outfalls 2 & 3.
Outfall #4 has not been sampled in the past and it is located iust below the maintenance shop.
Outfall #4 should be added to the outfalls sampling regiment. Additional comments in summery
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: We viewed all outfalls that could be found. Outfall #5 and #7 could not be located. Outfalls
should be clearly marked with durable signage.
Page 4 of 4

ROY COOPER
ELIZABETH S.BISER
Serraa"
WILLIAM E.TOBY VINSON.jR Nor?c n ao uNn
mrene,D1111, ar
envrronmea LINA
May 19, 2023
West Frazer, Inc.
ATTN: Christine Jenkins-Jordan
4400 NC Hwy 186
Seaboard, NC 27876
Subject: COMPLIANCE EVALUATION INSPECTION
West Frazer, Inc.
Seaboard Facility, Certificate of Coverage-NCG210078
Person County
Ms. Jenkins-Jordan:
On September 21, 2023 a site inspection was conducted for the West Frazer facility located at 4400 NC
Hwy 186, Northampton County, North Carolina.A copy of the Compliance Inspection Report is enclosed
for your review. The site visit and file review revealed that the subject facility is covered by NPDES
Generall Stormwater Permit-NCG210078. Permit coverage authorizes the discharge of stormwater from
the facility to receiving waters designated as Ivy Creek a Class C;NSW waterbody in the Chowan River
Basin.
As a result of the inspection, the facility was found to be in compliance with the conditions of the
NCG210078 General 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 has any
questions,comments, or needs assistance with understanding any aspect of your permit, please contact
me at(919) 791-4200 or by e-mail at Thad valentineamcdenr eoy.
Sincerely,
Thad Valentine
Environmental Senior Specialist
�E�J 4oth Ce,nGtmnl r0uetitdE kAQVAAtt ' o(E myy M' land LronJR vmces
UfeahRegi 1pffce116J.EMaIS vlaGcxer350 MB ttDTve QI 'ghNorthCa Pa2]60a
419 7n14200

Compliance Inspection Report
Permit:NCG210078 Motive: 06/01/23 Expiration: 05/31/28 Owner: Weat Fraserinc
SOC: Effective: Expiration: Facility: Seaboard Lumber Mill
County:Northampton 4400 NC Huy 186
Region: Raleigh
Seaboard NC 27876
Contact Person:Christine Jenkins-Jordan Title: Phone:[phone]
Directions to Facility:
System Classifications: SWNC,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 09121Q023 Entry Time 10:30AM Exit Time: 12:45PM
Primary Inspector:Thaddeus W Valentine Phone:
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Timber Products Stormwater Discharge COC
Facility Status: 0 Compliant [] Not Compliant
Question Areas:
Sterm Water
(See attachment summary)
Page 1 of 4

permit: NCO210078 Owner-Facility:west Fraser Inc
Inspection Date: 0912112023 Inspection Tpe:Compiianpe Evaluation Reason for Visit Rourre
Inspection Summary:
I meet on site with Christine Jenkins-Jordan (EHS)and Kevin DeBerry(General Manager.We walked the site and identified
some issues and made a call for the requested moving of sample point SDO1 from within Carolina Bark facility boundary
back to the SW corner of the West Frazer facility.
Ouffall 91 is approved to move from the outfall location at the culvert outlet on Bluejay Trail to the culvert pipe across the
ditch located on the NW corner of the Carolina Bark facility and adjacent to the Scale Yard entrance lot(it is recommended
that a sample be taken from the head of the ditch just North of where the two facilities property lines join to get an idea of
what runs off the West Frazer facility before oo-mingling with Carolina Bark runoff).The sample data for this oulf u s shows
ultra high readings for COD. I am requesting an assesment of the cause of these high readings and a plan for reducing
count.
SDO-#2 outlets from the facility through a plastic corrugated pipe next to the Vain track. I recommend that the sample be
taken right at the mouth of the discharge pipe if not slightly inside the pipe opening. I would also request that there is an
assesmenl of the cause of the very high COD readings.
S0043 outlets from tht facility through a plastic corrugated pipe next to the train track.l recommend this sample be taken
at the very end of the pipe as well to be sure the sample is run off from ten facility only. COD is not being tested at this
outfall and should be according to the requirements of the permit.
SDO-#4 outlets as a ditch just inside the tree line below the maintenance shop.This outfall has not been sampled in the
past and should be.The additional sample requiremenst for vehicle maintenance should be added to the other sample
requirements.
Outfallat5 was not found. The area where the sample outlet should be is a flat grassy area with no discernable concentrated
flow(not sampled)
Ouffall-#6 is a grass lined ditch that runs along the fenceline on the NE side of the facility.It appeared the ditch was runoff
conveyance for the office trailer area with a unknown 15inch RCP pipe at the upper end(not sampled)
Outfall-#7 This outfall is shown on the map at the NE edge of the parking lot.After thoroughly searching that area, no outfall
was found. (not sampled)
All the sample points should be tested for all the required protocols. SDO-1 should include COD and SDO-3&SDO-4 for
vehicle maintenance along with the other required samples.
The SP3 is missing a number of key elements:
The site map should include all areas(accordingto to there activities)including the maintenance area,drum storgae area,
OWS location with metered storage areas,disposal areas, processing areas,drainage areas etc.. Include drainage now
direction for all areas and outfall areas with latitude and longitude positions along with all other required features stated in the
permit.
Provide a narative description of processes to include storage and loading and unloading practices, outdoor process areas,
waste disposal processes along with the list of potential pollutants expected to be present in the discharge point for each
ouffall
Include additional information in the BMP summery that list all structural and non-structual practices for the facility and
especially the vehicle maintenance area
The secondary containment plan should include not only tanks, but should list all materials that should be stored in
secondary containment. That includes drums and containers of pollutants when full,empty and in use, but not being used.
All drums should be in secondary containment unless activity being used.Any drums in use should be kept under cover.
Page 2 of 4

Permit NCG210076 owner-Facility:West Fraser Inc
Inspection Date: 09/2112023 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? ❑ ❑ ❑
#Does the Plan include a"Narrative Description of Practices"? 11Q ❑
#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? MQ ❑
#Does me facility provide all necessary secondary containment? ■ 11 ❑
is Does the Plan include a BMP summary? M13Q
#Does the Plan include a Spill Prevention and Response Plan (SPRP)?
#Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? 11 0
#Does the facility provide and document Employee Training? Q Q
11
#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? . Q11
Has the Stormwater Pollution Prevention Plan been implemented?
Comment: The facility has an SP3 plan but it needs to be updated with any changes and include an
missing documents or documents that don't fully provide the permit requirements. Additional
comments in summery
Qualitative Monitoring
Yes No NA NE
Has the facility conducted its Qualitative Monitoring? ■ ❑ ❑ ❑
Comment: Provided for all outfalls being sampled Outfall (SDO)#4 is being added with additional
samples for vehicle maintenance
Analytical Monitoring
Yes No NA NE
Has the facility conducted its Analytical monitoring? ■ 000
#Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? Q
11
Comment: All analytical documentation was provided with very high COD readings for outfalls 2& 3
Outfall#4 has not been sampled in the oast and it is located 'ust below the maintenance hop
Outfall#4 should be added to the outfalls sampling regiment Additional comments in summery
Permit and Outfalls
Yes No NA NE
#Is a copy of the Permit and the Certificate of Coverage available at the swe? 0 1111
#Were all outfalls observed during the inspection? 0 ❑ ❑ ❑
#If the facility has representative cutfali status.is it properly documented by the Division? ❑ 11011
#Has the facility evaluated all illicit(non stormwater)discharges? ❑ 0011
Comment: We viewed all ouffalls that could be found. Outfall#5 and#7 could not be located Outfalls
should be clearly marked with durable signage
Page 4 of 4

Permit: NCG210078 Owner-Facility:West Fraser Inc
Inspection Date: 09/212023 Inspectors Type:Compliance Evaluahcn Reason for Visit: Rovurs
Any clumpsters or containers exposed to stormwater should be covered and maintained in structurally sound non-leaking
containers
A list of significant spills should be provided and if no significant spills occur,list"No Spills'for each year.All leaks and
spills should be documented and provide where,when,how it occur and how it was fixed when.The matersil cleaned up
should be stored for disposal and that should be noted as to how it was stored where and when was it disposed of by who.
Detailed trecking is paramount.
Training of personnel that have responsibilities for any of the facility operations is required which includes spill response and
preventive maintenance and good housekeeping of the facility operations.This should focus on any areas, machinery or
processes that could create a spill or cause a pollutant to be released into the stormwater.They should all be trained and
they should sign off on their training. Provide training that covere all those areas.
Inspections of the site should occur at least twice yearly and be documented. More frequent inspections are recommended
and should cover any and all areas Mat have the potential for spills, leaks or releases.The maintenance shop should always
be included in that inspection and should include inspections for leaks under equipment, containers and materials stationed
outside.The shop itself should be part of the inspection and should look for open containers or drums with the potential to
spill or leak or be punctured and any spills should be cleaned up immediately and stored properly for disposal.
Page 3 of 4