NCG030235_NOV_20190205

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Interim Director
NORTH CAROLINA
Environmental Quality
February 5, 2019
CERTIFIED MAIL: 7017 2620 0000 9759 0348
RETURN RECEIPT REQUESTED
Saft America Inc.
Attn: Michael McGuire, EHS Manager
313 Crescent Street NE
Valdese, North Carolina 28690
Subject: NOTICE OF VIOLATION (NOV-2019-PC-0058)
NPDES Stormwater General Permit NCG030235
SaftAmerica Incorporated, Certificate of Coverage NCG030235
Burke County, North Carolina
Dear Mr. McGuire:
On January 29, 2019, Isaiah Reed from the Asheville Regional Office of the Division of
Energy, Mineral and Land Resources (DEMLR), conducted a site inspection for the Saft
America facility located at 313 Crescent Street NE, Burke County, North Carolina. A copy of
the Compliance Inspection Report is enclosed for your review. You were present during the
inspection and your time and assistance is greatly appreciated. The site visit and file review
revealed that the subject facility is covered by NPDES Stormwater General Permit
NCG030000 under Certificate of Coverage NCGNCG03023S. Permit coverage authorizes the
discharge of stormwater from the facility to receiving waters designated as an unnamed
tributary of McGalliard Creek, a Class (WS-IV;CA) waterbody in the Catawba River Basin.
As a result of the site inspection, the following permit conditions violation(s) are noted:
1) Stormwater Pollution Prevention Plan (SPPP)
A Stormwater Pollution Prevention Plan (SPPP) has not been updated, or properly
implemented.
D _E Q�� North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
Asheville Regional Office 12090 U.S. Highway 70 1 Swannanoa, North Carolina 28778
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^^^W"�V' 828.296.4500

Notice of Violations
Saft America Inc.
Page 2 of 2
2) Inspection Observations
a) It was noted during the inspection, that two of the outfalls were discharging
stormwater which was slightly foamy.
b) It was noted during the inspection that the lock on one of the secondary
containments was inadequate to prevent accidental discharge from the
structure.
c) It was noted during the inspection that a 1259 gallon tank of Sodium Hydroxide
did not appear to be in secondary containment.
Requested Response:
You are asked to respond to this office, in writing, within 30 calendar days from receipt of
this notice. Your written response should include a reasonable explanation as to why the
aforementioned violation(s) has/have occurred as well as a Plan of Action to prevent
this/these violation(s) from recurring.
Thank you for your attention to this matter. This office requires that the violations, as
detailed above, be properly resolved. These violations and any future violations are
subject to a civil penalty assessment of up to $25,000 per day for each violation.
Should you have any questions regarding these matters, please contact Isaiah Reed or
myself at [phone].
Sincerely,
Stanley E. Aiken Gn
Regional Engineer
Land Quality Section
Enclosure:
Inspection Report
ec: Alaina Morman, Environmental Specialist Alaina.monnannn.ncdenr.gov
Stanley E. Aiken- Regional Engineer [e-mail]

Compliance Inspection Report
Permit: NCG030235 Effective: 11/01/18 Expiration: 05/31/21 Owner: Saft Americalnc
SOC: Effective: Expiration: Facility: Saft America Incorporated
County: Burke Crescent St
Region: Asheville
Valdese INC 28690
Contact Person: Beth Anderson Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 01/29/2019
Primary Inspector: Isaiah L Reed
Secondary Inspector(s):
Certification:
Phone:
Entry Time: 01:OOPM Exit Time: 02:15PM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Metal Fabrication Stormwater Discharge COC
Facility Status: Compliant Not Compliant
Question Areas:
Storm water
(See attachment summary)
Page: 1

Permit: NCG030235 Owner- Facility: Saft America Inc
Inspection Date: 01/29/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary
On January 29, 2019 this facility was inspected for compliance. I met with Michael McGuire and Eric Sims on site. During
the inspection, the following items were noted:
1) The Stormwater Pollution Prevention Plan (SPPP) has not been updated, or properly implemented. The permittee is
directed to immediately review, revise and implement the SWPPP on site.
2) It was noted during the inspection, that two of the outfalls were discharging stormwater which was slightly foamy. The
permittee is directed to evaluate and classify the nature and extent of the issue, and beginning a plan to address it.
3) It was noted during the inspection that the lock on one of the secondary containments was inadequate to prevent
accidental discharge from the structure. The permittee is directed to pursue other means of locking the valve on the
secondary containment drain.
4) It was noted during the inspection that a 1259 gallon tank of Sodium Hydroxide did not appear to be in secondary
containment. The permittee is directed to evaluate and classify the nature of the container and confirm whether secondary
containment is part of the vessel and if it is found that the vessel does not have secondary containment, the permittee shall
immediately begin designing and installing a secondary containment structure sufficient to contain the vessel.
If you have any questions, please contact this office at [phone]
Page: 2

Permit: NCG030235 Owner- Facility: Saft America Inc
Inspection Data: 01/29/2019 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?
❑ 0 ❑ ❑
# 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?
❑ E ❑ ❑
# Does the Plan include a BMP summary?
❑ N ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
❑ E ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
❑ 0 ❑ ❑
# Does the facility provide and document Employee Training?
❑ E ❑ ❑
# 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?
❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
❑ ❑ ❑
Comment: SWPPP has not been maintained on site
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? N ❑ ❑ ❑
Comment:
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? E ❑ 1113
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ ❑
Comment:
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? ❑ 1:10 ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ❑ E ❑ ❑
Comment:
Page: 3