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Home My WebLink AboutNCG050442_Compliance Eval Inspection_20180723Energy, Mineral and Land Resources ENVIRONMENTAL QUALITY July 23, 2018 Lumberton Cellulose, LLC Attn: Charles P. Oxendine, General Manager 1000 Noir Street Lumberton, NC 28358 Subject: COMPLIANCE EVALUATION INSPECTION NPDES Stormwater Permit NCS000374 Lumberton Cellulose, LLC Robeson County Dear Mr. Oxendine: ROY COOPER Governor MICHAEL S. REGAN Secretary WILLIAM E. (TOBY) VINSON, JR. Interim Director On July 12, 2018, a site inspection was conducted for the Lumberton Cellulose, LLC facility located at 1000 Noir Street, Lumberton, Robeson County, North Carolina. A copy of the Compliance Inspection Report is enclosed for your review. Mr. Grant Oxendine, Environmental, Health & Safety Manager, was also present during the inspection and his time and assistance is greatly appreciated. The site visit and file review revealed that the subject facility is covered by NPDES Stormwater Permit NCS000374. Permit coverage authorizes the discharge of stormwater from the facility to receiving waters designated as the Lumber River, a Class C;Sw stream in the Lumber River Basin. As a result of the inspection, the facility was found to be in compliance with the conditions of NPDES Stormwater Permit NCS000374. 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 Permit are subject to a civil penalty assessment of up to $25,000 per day for each violation. If you or your staff have any questions, comments, or needs assistance with understanding any aspect of your permit, please contact me at (910) 433-3394 or by e-mail at mike.lawyer@ncdenr.gov. Sincerely, Michael Lawyer, CPSWQ Environmental Program Consultant DEMLR Enclosure (Compliance Inspection Report) Attachments (NOI for NCG050000, Rescission Request Form) ec: Grant Oxendine, Environmental, Health & Safety Manager — Lumberton Cellulose, LLC Bradley Bennett, Environmental. Engineer — DEMLR, Stormwater Program cc: FRO — DEMLR, Stormwater Files State of North Carolina I Environmental Quality I Energy, Mineral and Land Resources Fayetteville Regional Office 1 225 Green Street, Suite 714 1 Fayetteville, NC 28301 910-433-3300 Compliance Inspection Report Permit: NCS000374 Effective: 09/01/10 Expiration: 08/31/15 Owner : Lumberton Cellulose LLC SOC: Effective: Expiration: Facility: Lumberton Cellulose LLC County: Robeson 1000 Noir St Region: Fayetteville Lumberton NC 28358 Contact Person: Charles P Oxendine Title: General Manager Phone: 910-737-3231 Directions to Facility: System Classifications: Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): On -site representative Grant Oxendine 910-737-3283 Related Permits: Inspection Date: 07/12/2018 Entry Time: 01:OOPM Primary Inspector: Mike Lawyer/A�t Secondary Inspector(s): Reason for Inspection: Routine Permit Inspection Type: Stormwater Discharge, Individual Facility Status: Compliant ❑ Not Compliant Question Areas: Storm Water (See attachment summary) Exit Time: 03:30PM Phone: 910-433-3300 Ext,7� 33,74 Inspection Type: Compliance Evaluation Page: Permit: NCS000374 Owner - Facility: Lumberton Cellulose LLC Inspection Date: 07/12/2018 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: Compliance inspection conducted as part of the individual permit renewal process. Met with Grant Oxendine, Environmental, Health & Safety Manager. Discussed plant operations/industrial activities both past and present. A portion of the facility used to function as a pulp mill, which required coverage under an individual stormwater permit. According to Mr. Oxendine, the pulp mill operations ended in 2003. Currently, the facility receives by-product cotton fiber from other facilities, cleans and bleaches the cotton, then returns the cotton in wrapped bales back to the customer. Caustic and hydrogen peroxide solutions are used in the bleaching process, which is all conducted indoors. Mr. Oxendine relayed information about a leak from the facility's underground piping associated with their AST for #2 fuel oil, which can be used in their boiler as a backup heat source. The leak was discovered on March 29, 2018 and reported to staff with the UST Section. Per Mr. Oxendine, approximately 2,900 gallons total was estimated to leak out with some of the product getting into the perimeter drainage ditch, but none leaving the property. An environmental cleanup contractor was notified and hired to respond and conduct assessment and recovery, which is being finalized. Facility's Stormwater Pollution Prevention Plan (SPPP) is very detailed and well organized containing all permit -required components. The SPPP is reviewed and updated annually as required and contains various forms for documenting employee training, non-stormwater certification, spills, etc. Facility has identified and conducted monitoring for nine outfalls. Monitoring records from 2013 to 2017 were reviewed. Several exceedances of the benchmark value for TSS at outfalls 2, 6 and 7 and a few for pH primarily at outfall 2 from 2011 to 2014 were noted, however records from 2016 and 2017 showed no exceedances. After the records review, toured the plant site and operations. Made observations of the area where the #2 fuel oil leak occurred, secondary containment areas, stormwater discharge outfalls and associated drainage areas. Majority of the drainage areas consist solely of roof runoff and areas with no industrial activities. Exposure of products/materials to stormwater consists of two open top dumpsters, one for scrap metal and the other for waste cotton, some used pallets, some metal ductwork and empty totes all of which are within the drainage area to outfall 2. Although previous versions of the individual permit contained information designating representative outfalls, the currentlexpired permit does not. Discussed with Mr. Oxendine the current process for requesting and documenting representative outfall status and provided him with a copy of the Representative Outfall Status (ROS) Request Form. Also discussed the possibility of the facility being covered under a general permit instead of the individual permit as well as actions that could be taken for the facility to qualify for the No Exposure Certification. Based on the facility ceasing the pulp mill operations and its current industrial activity of processing cotton fiber along with the most recent monitoring results and limited exposure risks, inspector feels that coverage under Stormwater General Permit NCG050000 would be appropriate. A copy of the NOI for obtaining coverage under the NCG050000 permit as well as a copy of the Rescission Request Form to rescind the individual permit will be sent along with the compliance inspection report. Page: 2 Permit: NCS000374 Owner - Facility: Lumberton Cellulose LLC Inspection Date: 07/12/2018 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? E ❑ ❑ ❑ # 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? 0 ❑ ❑ ❑ # Does the Plan include a list of significant spills occurring during the past 3 years?- ❑ ❑ ❑ # Has the facility evaluated feasible alternatives to current practices? 0 ❑ ❑ ❑ # Does the facility provide all necessary secondary containment? ❑ ❑ ❑ # Does the Plan include a BMP summary? 0 ❑ ❑ ❑ # 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? ❑ ❑ ❑ # 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? 0 ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? ❑ ❑ ❑ Comment: Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? E ❑ ❑ ❑ 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: 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? ❑ ❑ 0 ❑ # Has the facility evaluated all illicit (non stormwater) discharges? 0 ❑ 1111 Comment: Page: 3