NCG030564 - Industrial Fabricators South Plant

Energy, Mineral
and Land Resources
ENVIRONMENTAL QUALITY
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
ROY COOPER
Governor
MICHAEL S REGAN
Secretary
IL IAM E. TOBY VINSON, JR.
Interim Director
DEQ WATER RESOURCES `
401 & BUF` ER PERMITTING �� t
January 22, 2018 %��
0 0/ -
Industrial Fabricators, Incorporated 7016 1370 0000 2595 8457
Attention: Roger Bingham, President
4328 South York Highway
Gastonia, North Carolina 28052
Bingham Properties LLC 7016 1370 0000 2595 8464
Attention: Roger Bingham, Manager and Patricia Bingham, Registered Agent and Manager
323 Dover Road
Kings Mountain, North Carolina 28086-8697
Subject: NOTICE OF DEFICIENCY
NOD -2018 -PC -0005
General Permit Number NCG030000
Certificate of Coverage Number NCG030564
Industrial Fabricators South Plant
Industrial Fabricators, Incorporated
Gaston County, North Carolina
Dear Sir and Madam,
Enclosed is a copy of the Compliance Evaluation Inspection (CEI) report for the compliance
inspection conducted on January 11, 2018 at your facility located at 5053 S York Highway,
Gastonia, North Carolina. This inspection was conducted by Holliday Keen.
This inspection was conducted as a routine inspection to evaluate compliance with
Certificate of Coverage number NCG030564 issued to Industrial Fabricators, Inc. for this site on
November 16, 2017. This permit covers on site activities including the manufacturing of metal
products.
The enclosed report should be self-explanatory. Please note the comments located in the
summary portion of the inspection report. As noted by the inspector, the Stormwater Pollution
prevention plan has not been created for this site which is a violation of permit condition Part II
Section A stating that "The permittee shall develop and implement a Stormwater Pollution
Prevention Plan (SPPP)." Additionally, Analytical and Qualitative Monitoring have not been
conducted or recorded in the SPPP. This is a violation of permit conditions Part II Section B and
Part II Section D respectively. It was also noted on site that this site has not determined all
State of North Carolina I Environmental Quality I Energy, Mineral and Land Resources
Mooresville Regional Office 1 610 East Center Ave Ste 301 1 Mooresville, NC 28115
704 663 1699 T

Industrial Fabricators, Incorporated
January 22, 2018
Page 2
applicable outfalls which is a violation of Part II Section A.1(c) of the general permit. Please review
the violations as listed below and see the attached addendum for information about your permit.
1) Stormwater Pollution Prevention Plan (SPPP)
A Stormwater Pollution Prevention Plan (SPPP) has been developed, recorded, and properly
implemented.
Yes ❑ No
2) Qualitative Monitoring
Qualitative monitoring has been conducted and recorded in accordance with permit requirements.
Yes ❑ No ® NA ❑
3) Analytical Monitoring
Analytical monitoring has been conducted and recorded in accordance with permit requirements.
Yes ❑ No ® NA ❑
4) Permit and Outfalls
The permittee has not evaluated the stormwater outfalls for illicit discharges annually as required by
the permit.
Required Response
Thank you for your attention to this matter. This office requires that the violations as
described above be properly resolved. Unresolved violations may lead to the issuance of a Notice
of Violation and/or assessments of civil penalties. Please provide a written response detailing the
measures taken to bring your facility into compliance. Your response should document the initiation
of the analytical and qualitative monitoring at the subject facility in accordance with the terms and
conditions of the permit. This response should be received no later than 30 days from the date
of this letter.
If you have any questions or require any additional information, please contact Holliday
Keen at [phone] or [e-mail] or me at [phone].
Sincerely,
3�'i --� K--
Zahid S. Khan, CPM, CPESC, CPSWQ
Regional Engineer
Land Quality Section
Mooresville Regional Office
HK/cys
Enclosures: Inspection Report

Industrial Fabricators, Incorporated
January 22, 2018
Page 3
ADDENDUM
The National Pollutant Discharge Elimination System (NPDES) program was established under the
federal Clean Water Act and then delegated to the Division of Water Quality for implementation in
North Carolina. The NPDES permitting program for stormwater discharges was established in
1990. Phase I focuses on site and operations planning to reduce pollutant sources.
Through the NPDES permitting program industrial facilities that fall into one of the subject ten
categories are required to obtain permit coverage under a general permit or an individual permit,
depending upon the facilities SIC code and the industrial activity occurring at the facility. There are
currently 19 active general stormwater permits in North Carolina. One condition that is applicable
to both the general permits and individual stormwater permits is the requirement to develop and
implement site-specific comprehensive Stormwater Pollution Prevention plans (SPPP). These plans
are required to include a comprehensive evaluation of the site and operations to reduce pollutant
sources and prevent pollutant discharge.
Copies of the general permits and accompanying documents can be accessed from the following
webpage: http://portal.ncdenr.org/web/wq/ws/su/npdessw#General_Permits_NPDES. Permit text,
technical bulletins, discharge monitoring forms, and a Notice of Intent [which is the application for
coverage under a NPDES General Stormwater Permit] can be found on this website.
The following items are a subset of permit requirements and are listed to assist you and help bring
your attention to certain permitting issues, process and condition requirements of your permit.
Please see the above mentioned website to obtain a copy of the permit so you may fully comply
with all the conditions therein: Failure to properly comply with conditions of the permit, like
those bulleted below, is a violation(s) of the permit and subject to civil penalty assessment(s) of
up to $25,000.00 per day.
• Industrial facilities that fall into one of the subject ten categories are required to obtain
permit coverage under a general NPDES stormwater permit or an individual NPDES
stormwater permit
• All persons desiring to have facilities covered by a General Permit must register with the
Division of Water Quality (DWQ) by filing of a Notice of Intent (NOI) and Applicable Fees.
• This Notice of Intent (NOI) must be submitted and a Certificate of Coverage issued prior to
any discharge of stormwater associated with the industrial activity, process wastewater,
and/or mine dewatering.
• Once the Notice of Intent is received, DWQ will review and determine whether a Certificate
of Coverage (COC) may be issued. If this Certificate of Coverage is issued the facility is j
covered by the General Permit. That is, the permittee is authorized to discharge stormwater,
process wastewater, and/or mine dewatering pursuant to the type of General Permit until the
permit expires or is modified or revoked.
• Any other point -source discharge to surface waters of the state is prohibited unless it is an
allowable non-stormwater discharge or is covered by another permit, authorization, or i
approval. ,
• its. Permit conditions vary accordingly; however,
There are currently 19 active general perm
most of the permits have the following condition requirements (you must read your entire
permit to'ensure full compliance):

Industrial Fabricators, Incorporated
a
January 22, 2018
Page 4
o Development and compliance with the Stormwater Pollution Prevention Plan
o Collection, reporting, and recording of Analytical Monitoring
o Collection, reporting, and recording of Qualitative Monitoring
o Collection, reporting, and recording of Vehicle Maintenance Monitoring (if
applicable)
o Records — Visual monitoring shall be documented and records maintained at the
facility along with the Stormwater Pollution Prevention Plan. Copies of the
analytical monitoring results shall also be maintained on site. The Permittee shall
retain records of all monitoring information, including all calibration and
maintenance records and all original strip -chart recordings for continuous monitoring
instrumentation, and copies of all reports required by this general permit for a period
of at least 5 years from the date of the sample measurement, report, or application.
o Expiration — The permittee is not authorized to discharge after the expiration date of
the general permit. In order to receive automatic authorization to discharge beyond
the expiration date, the permittee shall submit forms and fees as are required by the
agency authorized to issue permits no later than 180 -days prior to the expiration date.
Any permittee that has not requested renewal at least 180 days prior to expiration, or
any permittee that does not have a permit after the expiration and has not requested
renewal at, least 180 days prior to expiration, will be subject to enforcement. Failure
to renew your permit is a violation.
o Transfer — The Certificate of Coverage (COC) issued pursuant to this general permit
is not transferable to any person expect after notice to and approval by the Director.
The Director may require modification or revocation and reissuance of the
Certificate of Coverage to change the name and incorporate such other requirements
as may be necessary under the Clean Water Act. The Permit is NOT transferable.
o Name Change, Closure, or Facility Ownership change — Permittee is required to
notify the Division in writing in the event the permitted facility is sold or closed.
The Division of Water Quality views changes of name or ownership as a
modification that requires the Director's approval and reissuance of the permit.
Name and ownership changes require you to complete a Name/Ownership Change
Form from the Division and mail it back to the Division of Water Quality along with
all appropriate information.
o Proper Operation and Maintenance is a requirement of the permit.

N
Permit: NCG030564
SOC:
County: Gaston
Region: Mooresville
Compliance Inspection Report
Effective: 11/16/17 Expiration: 10/31/18 Owner: Industrial Fabricators
Effective: Expiration: Facility: Industnal Fabricators/South Plant
5053 S York Highwy
Contact Person: Roger Bingham
Directions to Facility:
On corner of South York Highwy and Community Drive
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Title: President
Certification:
Gastonia NC 28052
Phone: [phone]
Phone:
Inspection Date: 01/11/2018 Entry Time: 02 OOPM Exit Time: 03 OOPM
Primary Inspector: Holliday Keen Phone:
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Metal Fabrication Stormwater Discharge COC
Facility Status: ❑ Compliant 0 Not Compliant
Question Areas:
0 Storm Water
(See attachment summary)
Page 1

. d ,
Permit: NCG030564 Owner -Facility. Industrial Fabricators
Inspection Date: 01/11/2018 Inspection Type : Compliance Evaluation Reason for Visit. Routine
Inspection Summary
During this inspection I met with Jack Herndon and discussed site conditions and permit requirements I noted that a
Stormwater Pollution Prevention Plan (SPPP) has not been created, site outfalls have not been determined, and analytical
and qualitative monitoring have not been completed.
Please create and implement a SWPPP and a follow up inspection will be conducted to assess site compliance
If you have any questions, please contact our office at 704-663-1699 or by email at Holliday Keen@NCDENR gov
Page 2

Permit: NCG030564 Owner - Facility Industrial Fabricators
Inspection Date: 01/11/2018 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?
❑
0 ❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
❑
® ❑ ❑
# Does the Plan Include a detailed site map including outfall locations and drainage areas?
❑
0 ❑ ❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
❑
N ❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
❑
® ❑ ❑
# Does the facility provide all necessary secondary containment?
❑
® ❑ ❑
# Does the Plan include a BMP summary?
❑
Is ❑ ❑
# Does the Plan Include a Spill Prevention and Response Plan (SPRP)?
❑
Is ❑ ❑
# Does the Plan Include a Preventative Maintenance and Good Housekeeping Plan?
❑
® ❑ ❑
# Does the facility provide and document Employee Training?
❑
E9 1:1 ❑
# Does the Plan include a list of Responsible Party(s)?
❑
19 1:1 ❑
# Is the Plan reviewed and updated annually?
❑
IM 1:1 ❑
# Does the Plan include a Stormwater Facility Inspection Program?
❑
In 1:1 ❑
Has the Stormwater Pollution Prevention Plan been implemented?
❑
® ❑ ❑
Comment A Stormwater Pollution Prevention Plan has not been created for this facility
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ❑ ® ❑ ❑
Comment- Qualitative Monitoring has not been conducted
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? ❑ ® ❑ ❑
# Has the facility conducted Its Analytical monitoring from Vehicle Maintenance areas? ❑ ® ❑ ❑
Comment Analytical Monitoring has not been conducted
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? ❑ ❑ 0 ❑
# Has the facility evaluated all Illicit (non stormwater) discharges? ❑ ® ❑ ❑
Comment. All site outfalls have not yet been determined
Page 3