NCG500318_Inspection_20180802

NORTH CAROLINA
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MICHAEL S. REGAL
Secr�rary
LINDA CULPEPPER
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2 August 2018
CERTIFIED MAIL #: 70161370 0000 25961136
RETURN RECEIPT REQUESTED
Mr. Johnny Drummond, Plant Manager
Ipex USA, LLC
10100 Rodney Street
Pineville, North Carolina 28134
Subject: Notice of Violation
Compliance Evaluation Inspection
Ipex USA, LLC
NPDES General Permit No. NCG500318
Mecklenburg County
Tracking #: NOV-2018-PC-0303
Dear Mr. Drummond:
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the subject facility on
July 24, 2018, by Mr. Wes Bell of this Office. Please inform the staff that oversee the facility's environmental affairs of our
findings by forwarding a copy of the enclosed report.
This report is being issued as a Notice of Violation (NOV) due to the following:
- Unpermitted discharge of contact cooling water (extrusion process) into the storm water drainage system and receiving
stream;
- Failure to obtain Division approval of chemical additives used in the cooling towers and chiller water systems;
- Failure to collect representative samples including flow of the effluent discharges;
- Effluent total residual chlorine limit exceedance during the June 2017 sampling event.
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North Carolina Department of Environmental Quality I Division of Water Resources
610 East Center Avenue I Suite 3011 Mooresville, North Carolina 28115
704.663.1699

Mr. Johnny Drummond
Page Two
2 August 2018
All above -noted findings are violations of the subject NPDES Permit No. NCG500318 and North Carolina General Statute
(G.S.) 143-215.1 as detailed in the Permit/Summary, Record Keeping, Effluent Sampling, and Flow Measurement Sections
of the attached report. Please be advised that G.S. 143-215.6A provides for a civil penalty assessment of not more than twenty-
five thousand dollars ($25,000.00), or twenty-five thousand dollars ($25,000.00) per day when the violation is of a continuing
nature, against any person who violates or fails to act in accordance with the terms, conditions, or requirements of any permit
issued pursuant to G.S. 143-215.1. Penalties may also be assessed for any damage to surface waters of the State that may result
from the violations.
It is requested that a written response be submitted to this Office by August 24, 2018, detailing the actions taken to address
the violations and all efforts to prevent the recurrence of any future violations. The response should also include how the facility
will address the industrial air compressor condensate discharges. In responding, please address your comments to the attention
of Mr. Wes Bell. The Biocide/Chemical Treatment Worksheet — Form 101 should be completed for each chemical additive and
submitted to the Division's Aquatic Toxicity Unit (address listed on the form) by September 7, 2018.
Should you have any questions concerning this letter, please do not hesitate to contact Mr. Bell at [phone], or via
email at wes.bell(u,ncdenr.og_v.
Sincerely,
Do�cu�Signed by:
A14CC681 AF27425...
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Enclosure:
Inspection Report
cc: Rusty Rozzelle, MCWQP (via email)

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN I 2 15 I 3 I NCG500318 111 12 I 18/07/24 I17 18 I S i 19 LG] i 201 I
211111 1 1 1 1 1 111 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 111 1 1 1 1 1 166
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved-------------------
67 1.0 70 71 I„ I 72 n 73 �74 751 I I I 1 1 1 I80
u
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES oermit Number)
09:30AM 18/07/24
15/12/29
Ipex Industrial Incorporated
10100 Rodney St
Exit Time/Date
Permit Expiration Date
Pineville NC 28134
11:45AM 18/07/24
20/07/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Brad Hintz/Engineering Manager/704-889-2431 ext 50229/7048892390
Darrell Bishop/Maintenance Manager/704-889-2431 /7048892390
Tony Sain/& Coordinator E HS/704-889-2431 ext 50204/7048892390
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Johnny Drummond,10100 Rodney St Pineville NC 28134/Plant
Manager/704-889-2431/7048892390 No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenance Records/Reports
Self-Monitoring Program Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters
Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
EDoby: 8/1/2018
Wes Bell �� B MRO WQ//704-663-1699 Ext.2192/
A:e.D90CC3437...
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
W. Corey Basinger MRO WQ//704-235-2194/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
DocuSigned by:
8/2/2018
A14CC681 AF27425...
Page#

NPDES yr/mo/day Inspection Type (Cont.)
NCG500318 111 121 18/07/24 1 17 18 JCJ
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
PERMIT SECTION cont'd:
The Permittee failed to obtain prior approval from the Division for the usage of the following chemical
additives in the extrusion and molding cooling tower and chilled water systems: Vaporene 9402, Metro
270, K Brom T, Metro 252, and Vaporene 8402. Please be advised that the permittee must obtain
approval from the Division prior to the use of any chemical additive in the permittee's systems covered
under this permit [Permit Condition Reference: Part I, A(1) Effluent Limitations and Monitoring
Requirements for Non -Contact Cooling Water, Cooling Tower and Boiler Blowdown, Air Compressor
Condensate and similar wastewaters].
The chiller water system for the extrusion process comes in direct contact with the PVC pipe. This
contact cooling water is discharged into the storm drainage system during the annual pit cleaning.
Please be advised that the NCG500318 NPDES Permit does not cover contact cooling water
discharges and therefore, is an unpermitted discharge of wastewater and a violation of North Carolina
General Statute (NCGS) 143-215.1. All contact cooling water discharges to the stormwater drainage
system and/or receiving stream must be immediately ceased.
There are two separate locations that the condensate from the industrial air compressors is
discharged. The condensate (at both locations) is treated by an oil/water separator and approximately
70 -100 gallons is discharged at each location. The condensate discharges are currently being
collected in 300 gallon tote bins that will be disposed by a contracted company. The condensate may
be discharged into storm water drainage system/receiving stream under the coverage of this permit.
The oil/water separators must be properly operated and maintained at all times and the facility must
comply with all permit effluent limitations and monitoring requirements. In addition, an updated site
map with all discharge locations including the storm water drainage system and receiving stream must
be submitted to the Division if the condensate discharges are to be included for permit coverage.
Page#

Permit: NCG500318 Owner -Facility: Ipex Industrial Incorporated
Yes No NA NE
Are records kept and maintained as required by the permit?
0
Inspection Date: 07/24/2018 Inspection Type: Compliance Evaluation
❑
❑
Is all required information readily available, complete and current?
0
❑
❑
❑
Permit
Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
❑
❑
0
❑
application?
0
❑
Is the chain -of -custody complete?
0
Is the facility as described in the permit?
❑
❑
0
❑
# Are there any special conditions for the permit?
❑
❑
0
❑
Is access to the plant site restricted to the general public?
0
❑
❑
❑
Is the inspector granted access to all areas for inspection?
0
❑
❑
❑
Comment: The last compliance evaluation inspection was performed at the facility
on 1/12/16 by DWR
Name of person performing analyses
staff.
Transported COCs
See "Summarv" Section for additional comments.
Are DMRs complete: do they include all permit parameters?
Record Keeping
Yes No NA NE
Are records kept and maintained as required by the permit?
0
❑
❑
❑
Is all required information readily available, complete and current?
0
❑
❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
❑
❑
❑
0
Are analytical results consistent with data reported on DMRs?
❑
❑
0
❑
Is the chain -of -custody complete?
0
❑
❑
❑
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
❑
❑
0
❑
Has the facility submitted its annual compliance report to users and DWQ?
❑
❑
0
❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator
❑
❑
❑
on each shift?
Is the ORC visitation log available and current?
❑
❑
0
❑
Is the ORC certified at grade equal to or higher than the facility classification?
❑
❑
0
❑
Is the backup operator certified at one grade less or greater than the facility classification?
❑
❑
0
❑
Is a copy of the current NPDES permit available on site?
❑
❑
❑
Facility has copy of previous year's Annual Report on file for review?
❑
❑
❑
Comment: The records reviewed during the inspection were organized and well maintained. The 2018
(May) and 2017 (November and June) effluent monitoring data was reviewed during the
inspection. The facility exceeded the total residual chlorine (TRC) permit limit during the
June 2017 sampling event (121 ug/L TRC result reported).
Page# 3

Permit: NCG500318 Owner -Facility: Ipex Industrial Incorporated
Inspection Date: 07/24/2018 Inspection Type: Compliance Evaluation
Yes No NA NE
Is composite sampling flow proportional?
❑
Laboratory
Yes No NA NE
Are field parameters performed by certified personnel or laboratory?
0
❑
❑
❑
Are all other parameters(excluding field parameters) performed by a certified lab?
0
❑
❑
❑
# Is the facility using a contract lab?
0
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
❑
❑
0
❑
Celsius)?
Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
❑
❑
0
❑
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
❑
❑
0
❑
Comment: All effluent sampling and analyses (including on-site field analyses) are performed by Pace
Analytical Services, Inc.
Effluent Sampling
Yes No NA NE
Is composite sampling flow proportional?
❑
❑
0
❑
Is sample collected below all treatment units?
❑
❑
0
❑
Is proper volume collected?
0
❑
❑
❑
Is the tubing clean?
❑
❑
0
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
❑
❑
0
❑
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
❑
0
❑
❑
representative)?
Comment: The subiect aeneral Dermit reauires effluent arab samples
The facility typically discharges only during the annual dumping of the cooling tower and
chiller pits for the extrusion and molding processes. The semi-annual sampling was
performed during a forced discharge (small volume) at the cooling tower. No sampling has
been performed during the annual dumping of the pits. In addition, no sampling has been
performed on the chiller pit wastewater. Please be advised that the Permit requires the
collection of representative samples and measurements [Permit Condition Reference: Part
II, Section D (1) Representative Samplingl.
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and ❑ ❑ 0 ❑
sampling location)?
Comment: The effluent is discharged/pumped into a storm water drainage system.
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ❑ 0 ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Page# 4

Permit: NCG500318
Inspection Date: 07/24/2018
Operations & Maintenance
Owner -Facility: Ipex Industrial Incorporated
Inspection Type: Compliance Evaluation
Yes No NA NE
Comment: Significant accumulations of the powder used in the extrusion, compounding,
etc.
Is right of way to the outfall properly maintained?
❑
processes were observed throughout the outside storage areas, driveways,
etc. The facility
❑
Are the receiving water free of foam other than trace amounts and other debris?
staff should initiate the appropriate corrective actions to prevent this material from entering
❑
❑
surface waters via storm water drainage system.
If effluent (diffuser pipes are required) are they operating properly?
❑
❑
Flow Measurement - Effluent
Yes No NA NE
# Is flow meter used for reporting?
❑ ❑
0
❑
Is flow meter calibrated annually?
❑ ❑
0
❑
Is the flow meter operational?
❑ ❑
0
❑
(If units are separated) Does the chart recorder match the flow meter?
❑ ❑
0
❑
Comment: The flow from the annual dumDina of the chiller and coolina tower pits (extrusion and
molding processes) had not been determined. The flow must be measured/determined as
required by the Permit [Permit Condition Reference: Part 1, A(1) Effluent Limitations and
Monitoring Requirements for Non -Contact Cooling Water, Cooling Tower and Boiler
Blowdown, Air Compressor Condensate and similar wastewatersl.
Effluent Pipe
Yes No NA NE
Is right of way to the outfall properly maintained?
❑
❑
0
❑
Are the receiving water free of foam other than trace amounts and other debris?
❑
❑
❑
0
If effluent (diffuser pipes are required) are they operating properly?
❑
❑
0
❑
Comment: No discharges were observed at the time of the inspection.
Page# 5