NCS000594_Inspection Report_20240306

Compliance Inspection Report
Permit:NCS000594 Effective: 02/01/19 Expiration: 01/31/24 Owner: Sepro Development Company III LLC
SOC: Effective: Expiration: Facility: Sepro Research &Technology Campus
County: Nash 16013 Watson Seed Farm Rd
Region: Raleigh
Whitakers NC 278919114
Contact Person:Ben Willis Title: Phone: [phone]
Directions to Facility:
System Classifications: SWNC,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 03/06/2024 Entry Time 11:20AM Exit Time: 12:55PM
Primary Inspector:Thaddeus W Valentine Phone:
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 4

Permit: NCS000594 Owner-Facility:Sepro Development Company III LLC
Inspection Date: 03/06/2024 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
I meet with Sam Mason Director of Manufacturing and Joe Armstrong Director of Research, Regulatory and Innovation and
they provided the documents and showed me around the facility and the following is what I found.
During the site visit I noted that chemicals, including Acetic Acid are being stored in an open shelter that has a high
exposure to stormwater. It was raining moderately during the inspection and the rain was easily reaching the stored
chemicals and the floor around the chemicals was wet from the rain as seen in the photos taken.
We viewed the areas inside where more of the chemicals were stored in poly tanks, woven sacks and drums.
There is a good amount of chemicals stored indoors next to doors and rollup doors were the chemicals can easily run
outdoors if there is a spill. Additionally the base of the building at the floor is not made to contain liquids.
There is a room where chemical samples are stored in an abundance of small containers that have no type of containment
protection.
There are used containers outside in the form of poly tanks, drums and aluminum containers that should be stored inside
There are wood pallets used to receive and haul chemicals stored outside that should be stored inside.
There is a diesel fuel tank and dispenser outside that does have a double walled tank but no shelter or containment for the
dispenser
There is a pipe inlet downhill from the open shelter chemical storage area that discharges in a field next to an onsite pond
with no type of protection or standard operating procedure for what to do if a chemical spill reaches it.
There is a roll-off container that is not covered and should be. When ever there is nothing actively being placed in the roll-off
container, it should be covered.
Documentation:
The site map needs to be reviewed and upgraded to include all the required information required by the permit
Provide a spill list that documents all spills, reportable or not, for the last (3)years
A study of the economic and technical feasibility of altering the facilities ongoing practices for managing, storing, handling
and transporting materials that are exposed to stormwater should be undertaken each year.
The large quantities of chemicals stored on site should be located within secondary containment or otherwise kept in
accordance with your permit***********
The secondary containment areas located outside have a secured valve to release accumulated water, but there is not
documentation of who or when stormwater was released from the containment area or how it was determined there were no
issues with the water being released.
The BMP summery couldn't be found and is required.A list of site structural and non structural BMP's should be kept on
site that is a written record of each BMP and of any changes made to BMP's and the rational for those changes.The BMP
summery should be reviewed and updated annually.
Preventive maintenance and good housekeeping program (PMGHP) is not addressed in the SP3. There is a single sentence
under PMGHP that talks about inspection of areas. There must be a healthy PMGHP put together and the facility
employees should be trained yearly.
Procedures should be developed for all duties on site that have the potential to contaminate stormwater such as: Draining
Page 2 of 4

Permit: NCS000594 Owner-Facility:Sepro Development Company III LLC
Inspection Date: 03/06/2024 Inspection Type:Compliance Evaluation Reason for Visit: Routine
secondary containment located outside. Who is qualified to drain secondary containment and the steps for doing that if
water is clean or contaminated, Cleaning out secondary containment inside and when its cleaned (if not daily) how its
cleaned-what's done with the cleaning materials and chemicals that are cleaned out Loading, unloading, staging and
moving chemicals around the site.
The employees have not been trained on stormwater management strategies. This includes:
Secondary containment requirements and records
Spill prevention and response procedures for all areas of the facility
Preventive maintenance and good housekeeping that is site specific
Facility inspections that identifies all areas of the site that should be inspected and what for
Sample procedures if staff take the samples
The inspection program is not site specific and doesn't include all areas of the site that should be inspected, nor what they
are inspecting for. Some areas should be inspected for spills, some for leaks and some areas should be inspected to be
sure materials are not being stored where they are not supposed to be. The roll-off should be inspected to insure it doesn't
have rust holes, drains or that the door is sealed properly.
The stormwater pollution prevention plan should be reviewed and dated each year
Page 3 of 4

Permit: NCS000594 Owner-Facility:Sepro Development Company III LLC
Inspection Date: 03/06/2024 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"? ❑ ❑ ❑
#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 SP#was available, but was incomplete. Additional comments in summery
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring? 0 ❑ ❑ ❑
Comment:
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: Les
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? ❑ ❑ ❑
# 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: The outfall was observed
Page 4 of 4