HomeMy WebLinkAboutNCS000049_COMPLIANCE_20171127STORMINATER-DIVISION CODING -SHEET---
PERMIT NO.
�s DODD
DOC TYPE
❑FINAL PERMIT
❑ MONITORING INFO
❑ APPLICATION
COMPLIANCE
❑ OTHER
DOC DATE
❑ 2al'1 I l 21
YYYYMMDD
FMA
NCDENR
Ntl C__ oouR Kw or
Ennrwnnn —N.4VI k�Xh
Division of Energy, Mineral & Land Resources
Land Quality Section/Stormwater Permitting
National Pollutant Discharge Elimination System
FOR AGENCY USE ONLY
Date Received
Year Month
Dey
PERMIT NAME/OWNERSHIP CHANGE FORMR►EGEIVED
FEB 14 2018
I. Please enter the permit number for which the change is requested. CENT 2AL FILES
NPDES Permit (or) Certifica
N S 10 10 10 10 4 9 N C G
II. Permit status prior to requested change.
a. Permit issued to (company name): IGM Resins Charlotte, Inc.
b. Person legally responsible for permit: Scott C Massey
First MI Last
j�
Plant Manager
I E V`' F E) RECDMD Title
201T 3300 Westinghouse Blvd.
��B �atia NOV 2 7 u Permit Holder Mailing Address
Charlotte NC 28273
,. /AL FILES DENR•IAND QtJAi.1TY City State Zip
�WR SECTION Mg WATER PERMITTING (704 ) 588-2500 (704 ) 945-8721
Phone Fax
c. Facility name (discharge): IGM Resins Charlotte, Inc.
d. Facility address: 3300 Westinghouse Blvd.
Address
Charlotte NC 28273
City State Zip
e. Facility contact person: Gerald W. Walker (704 ) 945-8702
First / Ml / Last
Phone
III. Please provide the following for the requested change (revised permit).
a. Request for change is a result of: ❑ Change in ownership of the facility
❑■ Name change of the facility or owner
If other please explain:
b. Permit issued to (company name):
c. Person legally responsible for permit:
d. Facility name (discharge)
e. Facility address:
f. Facility contact person:
IGM Resins USA Inc.
Scott
C Massey
First
MI Last
Plant Manager
Title
3300 Westinghouse Blvd.
Permit Holder Mailing Address
Charlotte
NC 28273
City
State Zip
_(7.04 ) 945-8738
s.massey(aigmresins.com
Phone
E-mail Address
IGM Resins USA Inc
3300 Westinghouse Blvd.
Address
Charlotte
NC 28273
City
State Zip
Gerald
W Walker
First
MI Last
(704 ) 945-8702
cimalker(caigmresins.com
Phone
E-mail Address
IV. Permit contact information (if different from the person legally responsible for the permit) mP 6,1
Revised Jan. 27, 2014 j 'd>"
41V
NODES PERMIT NAME/OWNERSHIP CHANGE FORM
Page 2 of 2
Permit contact: Gerald W Walker
First MI Last
Environmental Health and Safety Manager
Title
3300 Westinghouse Blvd.
Mailing Address
Charlotte, NC 28273
City State Zip
(704 ) 945-8702 g.walker@igmresins.com
Phone E-mail Address
V. Will the permitted facility continue to conduct the same industrial activities conducted prior
to this ownership or name change?
M Yes
❑ No (please explain)
VI Required Items: THIS APPLICATION WILL BE RETURNED UNPROCESSED IF ITEMS
ARE INCOMPLETE OR MISSING:
❑ This completed application is required for both name change and/or ownership change
requests.
❑ Legal documentation of the transfer of ownership (such as relevant pages of a contract deed,
or a bill of sale) is required for an ownership change request. Articles of incorporation are
not sufficient for an ownership change.
.....................................................................................................................
The certifications below must be completed and signed by both the permit holder prior to the change, and
the new applicant in the case of an ownership change request. For a name change request, the signed
Applicant's Certification is sufficient.
PERMITTEE CERTIFICATION (Permit holder prior to ownership change):
I, , attest that this application for a name/ownership change has been reviewed and is accurate and
complete to the best of my knowledge. I understand that if all required parts of this application are not
completed and that if all required supporting information is not included, this application package will be
returned as incomplete.
Signature
APPLICANT CERTIFICATION
Date
I, Ms"a" , attest that this application for a name/ownership change has been reviewed and is accurate and
complete to the best of my knowledge. I understand that if all required parts of this application are not
completed and that if all required supporting information is not included, this application package will be
returned as incomplete.
Sj,4,M,f-t� xg�
Signat Date
PLEASE SEND THE COMPLETE APPLICATION PACKAGE TO:
Division of Energy, Mineral and Land Resources
Stormwater Permitting Program
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
Revised Jan. 27, 2014
NCDENR
North Carolina Department of Environment and. Natural Resources
Division of Water Quality
Beverly Eaves Perdue - Coleen H. Sullins Dee Freeman
Governor Director Secretary
July 7, 2010
Mr, Bill Shaw
Cognis Corporation
3300 Westinghouse Blvd.
Charlotte, NC 28273
Subject: Permit NCS000049
Cognis Corporation
Mecklenburg County
Dear. Mr. Shaw:
Your letter to Bradley Bennett concerning an additional outfall to NCS000049 was received by the
Division of Water Quality (Division) on June 1, 2010. The letter requests guidance regarding proposed
Outfall #005.
From the information provided and comments by Heather Sorensen of Mecklenburg County after her site
visit, we recommend proposed outfall #005 be added to the Stormwater Pollution Prevention Plana e.`o start
monitoring at that outfall. Based on Heather Sorenson's site visit the perimeter Swale that drains to Outfall
#004 is a perennial and intermediate stream. Outfall #005 should be included as an. outfall because all outfalls
should be indentified before the discharge joins with a surface water. Therefore, in addition to adding Outfall
#005, please discontinue identifying Outfall #004 as an outfall. Please make sure no other outfalls e:. ist that
drain directly to this stream and should be identified as new outfall. Your permit will not need to be mortified
because it refers to all stormwater discharge outfalls on the site but please.update your Stormwater Pollution
Prevention Plan of the necessary changes.
If you have any questions or comments'concerning this permit, contact Brian Lowther at (919) 807-6368
or brian.lowther-Rnedenngo_v.
Sincerely,
Brian Lowther
Environmental Engineer
Stormwater Permitting Unit
cc: Mooresville Regional Office, Water Quality Section
Stormwater permitting Unit.
Central Files
Heather Sorensen, Mecklenburg County
Wetlands and Stormwater Branch
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St, Raleigh, North Caro4na 27604
Phone: 919-807-63001 FAX: 919-807.6494 I Customer Service:1-877-62M748
Internet: www.ncwaterqualq.org
An Equal Opportunity 4 Affirmative Action Employer
Nne
orthCarolina
Natura!!ff
4F
AAA
WDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
June 14, 2010
Mr, Bill Shaw
Cognis Corp ration k
P 7 4
Charlot 8241
Subject: Permit NCS000049
Cognis Corporation
- Mecklenburg -County -
Dear Mr. Shaw:
Dee Freeman
Secretary
Your letter to Bradley Bennett concerning an additional outfall to NCS000049 was received by the
Division of Water Quality (Division) on June 1, 2010, The letter requests guidance regarding proposed
Outfall #005.
From the information provided and continents by Heather Sorensen of Mecklenburg County after her site
visit, we recommend proposed outfall #005 be added to the Stormwater Pollution Prevention Plan and to start
monitoring at that outfall. Based on Heather Sorenson's site visit the perimeter swale that drains to Outfall
#004 is a perennial and intermediate stream. Outfall #005 should be included as an outfall because all outfalls
should be indentified before the discharge joins with a surface water. Therefore, in addition to adding Outfall.
#005, please discontinue identifying Outfall #004 as an outfall. Please make sure no other outfalls exist that
drain directly to this stream and should be identified as new outfall. Your permit will not need to be modified
because it refers to all stormwater discharge outfalls on the site but please update your Stormwater Pollution
Prevention Plan of the necessary changes.
If you have any questions or comments concerning this permit, contact Brian Lowther at (919) 807-6368
or brian.lowther@nederingov.
Sincerely,
Brian Lowther
Environmental Engineer
Stormwater Permitting Unit
cc: Mooresville Regional Office, Water Quality Section
Stormwater Permitting Unit
Central Files
Heather Sorensen, Mecklenburg County
Wetlands and Slormwater Branch �1, 1
1617 Mail Service Center, Raleigh, North Carolina 27699.1617 Noe
Carofina
Location: 512 N. Salisbury St, Raleigh, North Carolina 27604 �th����`f��
Phone: 919.807.63001 FAX: 919-807.64941 Customer Service: 1-877.623.6748
Internet: www.ncwaterquality.org
An Equal Opportunity 1 Affirmative Action Employer
A*AA
NCDENR
North Carolina Department of Environment and Natural
Division of Water Quality
Beverly Eaves Perdue Coleen H, Sullins
Governor Director
June 14, 2010
Mr. Bill Shaw
Cognis Corporation
PO Box 7044
Charlotte, NC 28241
Resources
Subject: Permit NCS000049
Cognis Corporation
Mecklenburg County
Dear Mr. Shaw:
Dee Freeman
Secretary
Your letter to Bradley Bennett concerning an additional outfall to NCS000049 was received by the
Division of Water Quality (Division) on June 1, 2010. The letter requests guidance regarding proposed
Outfall 4005.
;-Iom the information provided and comments by Heather Sorensen of Mecklenburg County after her site
visit, we recommend proposed outfall #005 be added to the Stormwater Pollution Prevention Plan and to start
rn(; ;Atoring at that outfall. Based on Heather Sorenson's site visit the perimeter swale that drains to Outfall
#004 is a perennial and intermediate stream. OutfalI #005 should be included as an outfall because all outfalls
should be indentified before the discharge joins with a surface water: Therefore, in addition to adding Outfall .
#005, please discontinue identifying Outfall #004 as an outfall. Please make sure no other outfalls exist that
drain directly to this stream and should be identified as new outfall. Your permit will not need to be modified
because it refers to all stormwater discharge outfalls on the site but please update your Stormwater Pollution
Prevention Plan of the necessary changes. •
If you have any questions or comments concerning this permit, contact Brian Lowther at (919) 807-6368
or bri.an.lowtherAncdenr.aov.
Sincerely,
�— C.
Brian Lowther
Environmental Engineer
Stormwater Permitting Unit
cc: K,resville Regional Office, Water Quality Section
Sto.'.nwater Permitting Unit
Central Files
Heather Sorensen, Mecklenburg County
Wetlands and Stormwater Branch One 1 1617 Mail Service Center, Raleigh, North Carolina 27699.1617 North(Carolina
Location: 5.8 7 Salisbury St. Raleigh, North Carolina 27604 ,� q������r�
Phone: 919.1307.63001 FAX:919.607.64941Customer Service. 1-677.623-6748 ✓/1/ `
Internet: www.ncwaterquality.org
An Equal Opportunity\ Affirmative Action Employer
f�-
May 24, 2010
Mr. Bradley Bennett
Stormwater and General Permits Unit
1617 Mail Sevice Center
Raleigh, NC 27699-1617
RE. NPDES Permit NCS000049 — Cognis Corporation
Dear Mr. Bennett:
nisl
Cognis Corporation
3300 Westinghouse Blvd,
Charlotte, NC 28273
USA
Phone 704/588-2500
www.cognis-us.com
Cognis Corporation in Charlotte, NC has been advised that it should add an additional outfall to
the storm water permit referenced above. An excerpt from the letter issued by Robert Krebs of
the Mooresville Regional office is shown below.
In addition, Cognis Corporation shall add a newly identified storm drain outfall, S W#005, located at the
storm drain outfall, which serves the train tracks, and discharges into the swale along the northern side
of the property. This outfall must be added since the swale may contain stormwater from the adjacent
property (CIBA Corporation) and the "swale" may be a channelized stream (as depicted on the
Mecklenburg County GIS website). As noted in NCS000049 Part III, Section D - Monitoring and
Records, Item l - Representative Sampling, "All samples shall be taken before the discharge joins or is
diluted by any other waste stream, body of water, or substance".
Currently, Cognis has four permitted outfalls which discharge directly into Steele Creek. The
proposed fifth outfall discharges into a swale which wraps around our facility and combines with
storm water that is discharged at existing Outfall #004. Previous analytical and visual data from
Outfall #004 includes the water discharged from the proposed fifth outfall. The proposed
addition collects water from roof drains and some surface areas along the rail spur.
In the photo shown below, the perimeter swale is shown in black and terminates at Outfall #004
which is currently permitted and tested, and which discharges directly to Steele Creek. The
proposed fifth outfall is shown in red; water from adjacent property comes in at the blue arrow.
f-..JU'
N ! 1 2010
Bill Shaw — Safety & Environmental Manager Ph: 704-94"702 Fax: 704-945-8721 Cognis Corporation — 3300 Westinghouse Blvd., Charlotte, NC 28273 bill.shaw(Moognis.com
Mr. Bennett
May 24, 2010
Cognis is requesting guidance from your office regarding proposed outfall #005. If you agree
with the assessment, will you please advise us on how to proceed with modifying the permit?
Respectfully yours,
Bill Shaw
Safety & Environmental Manager
Enclosures:
NOCV Letter from Robert Krebs
Aerial Photo of Storm Water Drainage Areas at Cognis Corporation
Bill Shaw — Safety & Environmental Manager Ph: 704-945-8702 Fax: 704-94"721 Cognis Corporation — 3300 Westinghouse Blvd., Charlotte, NC 28273 bill.shaw@oognis,com
=A
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
September 11, 2009
Mr. Bill Shaw
Cognis Corporation
PO Box 7044
Charlotte, NC 28241
Subject: Notice of Continuing Violation
Tracking Number: ,NOV-2009-PC-0490
.Follow-up Compliance Evaluation. Inspection
l Cognis Corporation
Stormwater Permit Number NCS000049
Mecklenburg County, NC
Dear Mr. Shaw: -
Enclosed is a copy of the Follow-up Compliance Evaluation Inspection (CEI) report for the inspection
conducted,at-the,§ubject,facility,on September. 1,:•2009;;_by,Heather Sorensen of Charlotte -Mecklenburg
Storm Water Services. (CMSWS).,-=This inspectionmwas conducted as -part of a cooperative -working
agreement tbetween.Mecklenburg •County and the -Division oflWater Quality. In addition, the inspection
was conducted on behalf of the City of Charlotte in compliance,with the. City's NPDES Permit,
NCS000240, Part II Section H. Thank you for your assistance and cooperation during the inspection.
.. The follow-up inspection found that.Cognis Corporation, Inc. has implemented most of the corrective
actions as stated in the subject facility's response letter dated July 10, 2009, and this Office commends
your efforts to comply with the requirements of your Stormwater permit. The completed corrective
actions include:
• Updating the Stormwater Pollution Prevention Plan,
• Removing discharge pipes, from pilot plant, ,
• Removing and replacing contaminated soil from around the trash compactor,
• Removing oil from around the filter cake dumpster pump,
• Removing steam condensate and other non-stormwater lines from stormwater down spouts on
the Process Building,
• Removing unknown product from Sugar Creek Tank Farm roadway,
• Removing, testing, -and disposing of contaminated soil -near the' South -Tank Farm; and.' -
Removing, testing,.and- disposing.of contaminated soil.nearthe,North,Wall.-Process Building..
Mooresville Regional office
location: 610 East Center Ave., Suite 301 Mooresvole, NC 28115
Phone: (704) 663-16991 Fax: (704) 663-M k Customer Service: "77-623.6748
Internet www rt waterquaGty.org,
Art Equal Opportunity 4 Affirrnative Action Employer— 50% Recycled110% Past Consumer paper
One
NCarolina
atura!!if
Mr. Bill Shaw, Cognis Corporation
Continuing NOV-2009-PC-0490, Page 2
September 11, 2009
However, Cognis Corporation is not in compliance with the City of Charlotte Storm Water Ordinance.
As a result, this inspection is being issued as a Notice of Continuing Violation. To come' into
compliance, Cognis Corporation shall conduct proper clean-up and disposal of any spilled oils'or other
materials, and all impacted soils as noted in the Industrial Operations/City of Charlotte Stormwater
Ordinance Review of the enclosed report. Analytical confirmation sampling using EPA Method 9071 for
Oil and Grease to below the reportable concentration of 250 ppm shall be conducted for any petroleum
impacted soils. As part of the written response, the facility shall provide an expected date of completion
for this project to this Office.
In addition, Cognis Corporation shall add a newly identified storm drain outfall, SW#005, located at the
storm drain outfall, which serves the train tracks, and discharges into the swale along the northern side
of the property. This outfall must be added since the swale may contain stormwater from the adjacent
property (CIBA Corporation) and the "swale" may a channelized stream (as depicted on the
Mecklenburg County G1S website):`;As noted in NCS000049 Part III, Section D - Monitoring and
Records, Item I - Representative Sampling, "All samples shall be taken before the discharge joins or is
diluted by any other waste stream, body of water, or substance".
It is requested that a written response be submitted to this Office by October 9, 2009, in response to
the above noted issues as detailed in the enclosed report. When responding, please address your
comments to the attention of Ms. Allocco at the letterhead address:
The subject facility will have 90 days from the letterhead date to come into compliance with the above -
noted violation.: A`follow-up evaluation will be conducted by CMSWS after the expected completion
'date for the removal, of contaminated soils to ensure compliance with the,dclility s' Stormwater Permit
and/or compliance with the' City of Charlotte Stormwater Ordinancc.
The enclosed report should be self-explanatory; however should you have any questions concerning this
report or have any questions regarding your permit, please do not hesitate to contact -Ms. Marcia Allocco
of this Office'at (704) 663-1699.
Sincerely,
for Robert B. Krebs, Regional Supervisor
Surfacd Water Protection Section
Mooresville Regional,Office
cc: Shelton Sullivan, NPS-ACO Unit ,
Rusty,Rozzelle, Mecklenburg County
Craig Miller, City of Charlotte
Brian Lowther, Stormwater Permitting
Compliance Inspection Report
Permit: NCS000049 Effective: 02/01/09 Expiration: 01/31/14 Owner Cognis Corporation
SOC: Effective: Expiration: Facility: Cognis Corporation
CountMecklenburg 3300 Westinghouse; Blvd
y
Region: �Mooresville •. f _ - i; j
,'�. .1:� _ �r'.E_. .�'F'S- F .. .� ''n.lii. �..rl:':.�3` .. :J� .`.iCi :1�i=
1 :? '� i:• r"t�1'=:f' ]rn., y_ ;f.. e. i :=n. i�CharlotteNC28241 Mir.
Contact'PePson:-' Randa[I Bruce Rhoades r Title: ' ' ' Phone: 704-945-8726 -
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):. ,.
On -Site Representative(s)-
Related Permits:
Inspection Date: 09/0112009 Entry Time: 09:00 AM Exit Time: 10:00 AM
Primary Inspector: Water Quality Program Meckenburg.County ' ' . -Phone: 704-336-5449
7.
Secondary Inspector(s):
Reason for, Inspection:..Follow-up.; • . Inspection Type: Gampliance•Evaluation
' 'i
Permit Inspection Type: Storrn;vater Discharge, Iridividual• ,
Facility Status: ❑ Compliant ■ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page: 1
Permit: NCS000049 Owner - Facility: Cognis Corporation
Inspection Date: 09/01/2009 Inspection Type: Compliance Evaluation Reason for,Visit: Follow-up.
Inspection Summary:
Facility Description:
The Cogriis facility reacts and blends raw chemicals to produce defoamers, synthetic lubricants, and paint elements and
operates 24 hours a day, seven days a week. The facility handles hazardous and non -hazardous materials and has an
onsite pre-treatment wastewater facility which discharges to Charlotte -Mecklenburg Utilities sewer system under CMU
Pre-treatment permit#0500. Areas identified to have a significant potential to contribute stormwater pollution are routed to
the on -site pre-treatment facility. No vehicle maintenance or washing occurs on -site.
Compliance History:
Mecklenburg County Water Quality Program (MCWQP) conducted a compliance evaluation on March 11, 2005. The
facility was in compliance at,this,time, On March 15, 2005, approximately 12,000 gallons of treated wastewater spilled due
to a pump failure. On July 10, 2008, approximately 500 gallons of wastewater overflowed from an equalization tank. '
Mecklenburg County Water Quality Program responded. On August 26, 2008, approximately 1,000 gallons of oil
overflowed from a wastewater trench due to flooding from Tropical Storm Fay. MCWQP responded and the Division of
Water Quality was notified (incident # 200802263),
Charlotte -Mecklenburg Storm Water Services (CMSWS) conducted an industrial storm water inspection on April 9, 2009.
The Division of Water Quality issued a Notice of Violation as a result of the inspection.
Industrial Operations/City of Charlotte Stormwater Ordinance Review'
Train Unloading Area --
Materials are unloaded from trains in an area where a storm drain inlet is located.. Spill containment structures are in
place in these areas. During the September 1, 2009, follow-up inspection, facility staff explained that a marival.ini6it
shut-off valve system has been ordered and will be installed.
Swale to Storm Drain Outfall #004 —
During the: April 4, 2009;,i6spec'ti6n; a brown liquid and a white gel substance were observed at the end of a stormwater
pipe that drains into a swale and discharges to Storm Drain Outfall #004. �During.the September 1, 2009, follow-up
inspection, minor amounts of a white gel substance was observed in the area of the outfall.
The facility shall add this point of discharge, into the swale, as a storm drain outfall to be monitored.
Dike in front of Aeration Tank #3 —
During the April 4, 2009, inspection, petroleum stained soil and dead grass were observed along the earthen edge of the
wastewater tank farm. Petroleum stained gravel throughout the wastewater tank farm was also observed, Staff
commented this was due to the previous oil spill in 2008,
The facility shall properly remove and dispose of all impacted gravel and soils and conduct oil and grease sampling for
less than 250 ppm. These areas shall be restored to their original conditions. The facility shall provide a date of
completion for this project.
Page: 2
Permit: NCS000049 Owner - Facility: Cognis Corporation .
Inspection Date: 0910t/20091". * Inspection Type: Compliance Evaluation
Reason for Visit:, Follow-up
Stormwater Pollution Prevention Plan _
Yes, No NA
NE..,.- .. !
Does the site.have a Stormwater, Pollution_ Prevention.Plan?..
■
.Q rn
`
# Does the.Plan,inciude a General -Location (USGS) map?_
■,10
. Q
n,
#Does the Plan include a "Narrative Description of Practices"?
000
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■
n n
n
# Does the Plan.include a list of significant spills occurring during the past 3 years?
■
❑ 0
Q
# Has the facility evaluated feasible alternatives to current practices?
■
n C3
n
# Does the facility provide all necessary secondary containment?
■
n n
n
# Does the Plan include a BMP summary?
■
n n
n
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■
❑ Q
❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
■
n ❑
n
# Does the facility provide and document Employee Training?
■
n n
E!
# Does the.Plan •include a list of Responsible Party(s)? . E Q' Q n
# Is the Plan reviewed and updatedr annually? " ` r ■ S n'
# Does the Plan include a Stormwater Facility Inspection Program? ■ n 'f_i n
Has the Stormwater Pollution Prevention Planbeen implemented? ' ■ n n n
Comment: Employee training was conducted and documented on 9-19-2006,
9-29-2006, 11-2-2006, 12-4-2007, 12-6-2007, 12-11-2007, 10-24-2008, 10-27-2008,
and 11-10-2008.
The Stormwater Pollution Prevention Plan was reviewed and updated in March 2009
and on June 2009.
Stormwater Facility Inspections were conducted on 11-17-2004, 5-14-2004, 5-19-2005,
9-14-2005, 6-30-2006, 11-28-2006, 6-6-2007, 11-30-2007, 6-9-2008, 11-10-2008, and
6-1 V2009.
Qualitative Monitoring
Yes
No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
■
❑
❑
n
Comment: Qualitative Monitoring was conducted on 6-14-2004, 11-12-2004,
6-6-2005, 11-28-2005, 6-2-2006, 11-7-2006, 6-2-2007, 11-15-2007, 6-13-2008,
11-13-2008, and 6-11-2009.
Analytical Monitoring
Yes
No
NA
NE
Has the facility conducted its Analytical monitoring?
■
n
n
Q
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
❑
n
■
n
Page: 3
Permit: NCS000049 Owner - Facility: Cognis Corporation
Inspection Date;-09/0112009 inspection Type: Compliance Evaluation Reason for Visit: Follow-up
Comment: Analytical Monitoring was conducted on 11-12-2004, 2-14-2005, and
6-6-2005.
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? ■ ❑ - n ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ Q ■ ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ■ ❑ ❑ ❑
Comment:
Page: 4
LEGEND
Property Line
Drainage
Area to
Outfall
arml Stormwater
Outfail
Aerial Photo taken
from Mecklenburg
Coumy, North
Carolina Polaris
Property Ownership
Land Records
Information System.
Photograph Dated
2002.
FIGURE 3
AERIAL PHOTO WITH STQRMWATER DRAINAGE AREAS A 4UTFALLS
Cognis Corporation A =• • FE-
Charlotte, North Carolina Hamm: 49501acrid.ppt
47*h
M==Iv
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
September 11, 2009
Mr. Bill Shaw
Cognis Corporation
PO Box 7044
Charlotte, NC 28241
Subject: Notice of Continuing Violation
Tracking Number: NOV-2009-PC-0490
Follow-up Compliance Evaluation Inspection
Cognis Corporation
Stormwater Permit Number NCS000049
Mecklenburg County, NC
Dear Mr. Shaw:
Enclosed is a copy of the Follow-up Compliance. Evaluation Inspection (CEI) report for the inspection
conducted at the subject facility on September 1, 2009, by Heather Sorensen of Charlotte -Mecklenburg
Storm Water Services (CMSWS). This inspection was conducted as part of a cooperative working
agreement between Mecklenburg County and the Division of Water Quality. In addition, the inspection
was conducted on behalf of the City of Charlotte in compliance with the City's NPDES Permit,
NCS000240, Part II Section H. Thank you for your assistance and cooperation during the inspection.
The follow-up inspection found that Cognis Corporation, Inc. has implemented most of the corrective
actions as stated in the subject facility's response letter dated July 10, 2009, and this Office commends
your efforts to comply with the requirements of your Stormwater permit. The completed corrective
actions include:
• Updating the Stormwater Pollution Prevention Plan,
• Removing discharge pipes from pilot plant,
• Removing and replacing contaminated soil from around the trash compactor,
• Removing oil from around the filter cake dumpster pump,
• Removing steam condensate and other non-stormwater lines from stormwater down spouts on
' the Process Building,
• Removing unknown product from Sugar Creek Tank Farm roadway,
• Removing, testing, and disposing of contaminated soil near the South Tank Fame, and
• Removing, testing, and disposing of contaminated soil near the North Wall Process Building.
Mooresville Regional office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 One
Phone: (704) 663-1699 ti Fax: (704) UM040 ti Customer Service:1-877.623.6748 NoI 7 CaTo�ina
Internet: wvnv.ncwaterquality.org ,iv%'tl./f'!]'1111
Mr. Bill Shaw, Cognis Corporation
Continuing NOV-2009-PC-0490, Page 2
September 11, 2009
However, Cognis Corporation is not in compliance with the City of Charlotte Storm Water Ordinance.
As a result, this inspection is being issued as a Notice of Continuing Violation. To come into
compliance, Cognis Corporation shall conduct proper clean-up and disposal of any spilled oils or other
materials, and all impacted soils as noted in the Industrial Operations/City of Charlotte Stormwater
Ordinance Review of the enclosed report. Analytical confirmation sampling using EPA Method 9071 for
Oil and Grease to below the reportable concentration of 250 ppm shall be conducted for any petroleum
impacted soils. As part of the written response, the facility shall provide an expected date of completion
for this project to this Office.
In addition, Cognis Corporation shall add a newly identified storm drain outfall, SW#005, located at the
storm drain outfall, which serves the train tracks, and discharges into the swale along the northern side
of the property. This outfall must be added since the swale may contain storrnwater from the adjacent
property (CIBA Corporation) and the "swale" may be a channelized stream (as depicted on the
Mecklenburg County GIS website). As noted in NCS000049 Part III, Section D - Monitoring and
Records, Item 1 - Representative Sampling, "All samples shall be taken before the discharge joins or is
diluted by any other waste stream, body of water, or substance".
It is requested that a written response be submitted to this Office by October 9, 2009, in response to
the above noted issues as detailed in the enclosed report. When responding, please address your
comments to the attention of Ms. Allocco at the letterhead address.
r The subject facility will have 90 days from the letterhead date to come into compliance with the above -
noted violation. A follow-up evaluation will be conducted by CMSWS after the expected completion
date for the removal of contaminated soils to ensure compliance with the facility's Stormwater Permit
and/or compliance with the City of Charlotte Stormwater Ordinance.
The enclosed report should be self-explanatory; however should you have any questions concerning this
report or have any questions regarding your permit, please do not hesitate to contact Ms. Marcia Allocco
of this Office at (704) 663-1699.
�t Sincerely,
for Robert B. Krebs, Regional Supervisor
Surface Water Protection Section
Mooresville Regional Office FED
F �, ram,
rn ,' a
cc: Shelton Sullivan, NPS-ACO Unit``
�L:�.I
Rusty Rozzelle, Mecklenburg County
Craig Miller, City of Charlotte
Brian Lowther, Stormwater Permitting CD
";
Compliance Inspection Report
Permit: NCS000049 Effective: 02/01/09 Expiration: 01/31/14 Owner: Cognis Corporation
SOC: Effective: Expiration: Facility: Cognis Corporation
County: Mecklenburg 3300 Westinghouse Blvd
Region: Mooresville
Charlotte NC 28241
Contact Person: Randall Bruce Rhoades Title: Phone: 704-945-8726
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Certification:
Inspection Date: 09/01/2009 Entry Time: 09:00 AM
Primary Inspector: Water Quality Program Meckenburg County
Secondary Inspector(s):
Reason for Inspection: Fallow -up
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: 0 Compliant ■ Not Compliant
Question Areas:
■ Storm Water
(See attachment summary)
Phone:
Exit Time: 10:00 AM
Phone: 704-336-5449
Inspection Type: Compliance Evaluation
Page: 1
Permit: NCS000049 Owner -Facility: Cognis Corporation
Inspection Date: 09/01/2009 Inspection Type, Compliance Evaluation Reason far Visit: Follow-up
Inspection Summary:
Facility Description:
The Cognis facility reacts and blends raw chemicals to produce defoamers, synthetic lubricants, and paint elements and
operates 24 hours a day, seven days a week. The facility handles hazardous and non -hazardous materials and has an
onsite pre-treatment wastewater facility which discharges to Charlotte -Mecklenburg Utilities sewer system under CMU
Pre-treatment Permit #0500. Areas identified to have a significant potential to contribute stormwater pollution are routed to
the on -site pre-treatment facility. No vehicle maintenance or washing occurs on -site.
Compliance History:
Mecklenburg County Water Quality Program (MCWQP) conducted a compliance evaluation on March 11, 2005. The
facility was in compliance at this time. On March 15, 2005, approximately 12,000 gallons of treated wastewater spilled due
to a pump failure. On July 10, 2008, approximately 500 gallons of wastewater overflowed from an equalization tank.
Mecklenburg County Water Quality Program responded. On August 26, 2008, approximately 1,000 gallons of oil
overflowed from a wastewater trench due to flooding from Tropical Storm Fay. MCWQP responded and the Division of
Water Quality was notified (Incident # 200802263).
Charlotte -Mecklenburg Storm Water Services. (CMSWS) conducted an industrial storm water inspection on April 9, 2009,
The Division of Water Quality issued a Noticeiof Violation as a result of the inspection.
Industrial Operations/City of Charlotte Stormwater Ordinance Review:
Train Unloading Area —
Materials are unloaded from trains in an area where a storm drain inlet is located. Spill containment structures are in
place in these areas. During the September 1, 2009, follow-up inspection, facility staff explained that a manual inlet
shut-off valve system has been ordered and will be installed.
Swale to Storm Drain Outfall #004 —
During the April 4, 2009, inspection, a brown liquid and a white gel substance were observed at the end of a stormwater
pipe that drains into a swale and discharges to Storm Drain Outfall #004. During the September 1, 2009, follow-up
inspection, minor amounts of a white gel substance was observed in the area of the outfall.
The facility shall add this point of discharge, into the swale, as a storm drain outfall to be monitored.
Dike in front of Aeration Tank #3 —
During the April 4, 2009, inspection, petroleum stained soil and dead grass were observed along the earthen edge of the
wastewater tank farm. Petroleum stained gravel throughout the wastewater tank farm was also observed. Staff
commented this was due to the previous oil spill in 2008.
The facility shall properly remove and dispose of all impacted gravel and sails and conduct oil and grease sampling for
less than 250 ppm. These areas shall be restored to their original conditions. The facility shall provide a date of
completion for this project.
Page: 2
Permit: NCS000049 Owner - Facility: Cognis Corporation
Inspection Date: 09/01/2009 Inspection Type: Compliance Evaluation
Reason for Visit: Follow-up
Stormwater Pollution Prevention Plan
Yes
No
NA
NE
Does the site have a Stormwater Pollution Prevention Plan?
■
n
❑
n
# Does the Plan include a General Location (USGS) map?
■
n
n
n
# Does the Plan include a "Narrative Description of Practices"?
■
n
n
n
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■
n
n
# Does the Plan include a list of significant spills occurring during the past 3 years?
■
n
El
Q
# Has the facility evaluated feasible alternatives to current practices?
■ n
n
n
# Does the facility provide all necessary secondary containment?
■ n
Cl
n
# Does the Plan include a BMP summary?
■ n
n
n
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■
# Dees the Plan include a Preventative Maintenance and Good Housekeeping Plan?
■
n
n
n
# Does the facility provide and document Employee Training?
■
n
n
n
# Does the Plan include a list of Responsible Party(s)?
■
n
n
n
# Is the Plan reviewed and updated annually?
■
n
❑
n
# Does the Plan include a Stormwater Facility Inspection Program?
■
n
❑
n
Has the Stormwater Pollution Prevention Plan been implemented?
■
n
n
n
Comment: Employee training was conducted and documented on 9-19-2006,
9-29-2006, 11-2-2006, 12-4-2007, 12-6-2007, 12-11-2007, 10-24-2008, 10-27-2008,
and 11-10-2008.
The Stormwater Pollution Prevention Plan was reviewed and updated in March 2009
and on June 2009.
Stormwater Facility Inspections were conducted on 11-17-2004, 5-14-2004, 5-19-2005,
9-14-2005, 6-30-2006, 11-28-2006, 6-8-2007, 11-30-2007, 6-9-2008, 11-10-2008, and
6-11-2009.
Qualitative Monitoring Yes No NA Nc
Has the facility conducted its Qualitative Monitoring semi-annually? ■ n n ❑
Comment: Qualitative Monitoring was conducted on 6-14-2004, 11-12-2004,
6-6-2005, 11-28-2005, 6-2-2006, 11-7-2006, 6-2-2007, 11-15-2007, 6-13-2008,
11-13-2008, and 6-11-2009.
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? ❑ ❑ ■
Page: 3
Permit: NGS000049 Owner - Facility: Cognis Corporation
Inspection Date: 09/01/2009 Inspection Type: Compliance Evaluation
Reason for Visit: Follow-up
Comment: Analytical Monitoring was conducted on 11-12-2004, 2-14-2005, and
6-6-2005.
Permit and Outfalls
Yes
No
NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site?
■
❑
n n
# Were all outfalls observed during the inspection?
■
n
00
# If the facility has representative outfall status, is it properly documented by the Division?
n
n
■ o
# Has the facility evaluated all illicit (non stormwater) discharges?
■
n
00
Comment:
Page: 4
���
NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Division of Water Quality
Coleen H. Sullins
Director
June 12, 2009
CT Corporation System, Registered Agent 7007 1490 0004 4510 2329
Cognis Corporation
150 Fayetteville Street, Box 1011
Raleigh, North Carolina 27601
SUBJECT: Notice of Violation NOV-2009-PC-0490
Compliance Evaluation Inspection for Stormwater Permit NCS000049
Cognis Corporation
Mecklenburg County, NC
Dear Registered Agent:
Dee Freeman
Secretary
Please forward this letter and the attached Notice of Violation dated June 3, 2009. The document was
undeliverable as addressed and the US Postal Service was unable to forward after being sent to the
permit contact listed in the compliance database for the Division of Water Quality at PO Box 7044,
Charlotte, NC 28241.
In the attached Notice of Violation this Office asserts that violations of North Carolina General Statue
(G.S.) 143-215.1 and the associated stormwater permit NCS000049 were noted during the inspection
performed by Charlotte -Mecklenburg Storm Water Services personnel on April 9, 2009. Therefore, this
Office requires a response regarding the inspection report by July 10, 2009. Please see the enclosed
inspection report for further details regarding the violations and the requested response.
If you have any questions, please contact Marcia Allocco or myself at (704) 663-1699.
Sincerely,
Robert B. Krebs, Regional Supervisor
Surface Water Protection
Division of Water Quality
Cc: DWQ Central Files
B. Lowther, Stormwater Permitting Unit
Shelton Sullivan, NPS-ACOU
Rusty Rozzelle, MCWQP
Craig Miller, City of Charlotte Stormwater
Bill Shaw, Cognis Corporation
Mooresville Regional Office
Location: 610 East Center Avenue, Suite 301, Mooresville, NC 28115
Phone: j704) 663-16991 Fax (704) 663-6040
Phone: 919-807-63001 FAX: 919-607-64941 Customer Service 1-877-623-6748 One
Internet: www.ricwaterqual4 org NorthCarofiina
An Equal Opportunity ti Affirmative Action Empoyer - 50 n Recycled110% Post Consumer paper Naturally
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
June 3, 2009
CERTIFIED MAIL 7007 1490 0004 4510 0035
RETURN RECEIPT REQUESTED
Mr. Bill Shaw
Cognis Corporation -
PO Box 7044
Charlotte, NC 28241
Subject: Notice of Violation
Tracking Number: NOV-2009-PC-0490
Compliance Evaluation Inspection
Cognis Corporation
Stormwater Permit Number COC NCS000049
Mecklenburg County, NC
Dear Mr. Shaw:
Enclosed is a copy of the Compliance Evaluation Inspection (CEI) report for the
inspection conducted at the subject facility on April 9, 2009, by Ms. Heather Sorensen and Mr.
John McCulloch of Charlotte -Mecklenburg Storm Water Services (CMSWS). This inspection
was conducted as part of a cooperative working agreement between Mecklenburg County and the
Division of Water Quality. In addition, the inspection was conducted on behalf of the City of
Charlotte in compliance with the City's NPDES Permit, NCS000240, Part II Section H. Thank
you for your assistance and cooperation during the inspection.
This report is being issued as a Notice of Violation (NOV) due to the permittee's failure
to prevent the discharge of chemical products to the storm drain system in violation of the subject
Stormwater Permit and North Carolina General Statute (G.S.) 143-215.1, as detailed in the
Industrial Operations/City of Charlotte Stormwater Ordinance Review and Permit and
Outfalls sections of the enclosed report. Pursuant to G.S. 143-215.6A, a civil penalty of not
more than twenty-five thousand dollars ($25,000.00) may be assessed 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.
In addition, to comply with the City of Charlotte Stormwater Ordinance the facility shall
conduct proper clean up and disposal of any spilled oils or other materials and all impacted soils.
Mooresville Regional Office
Location: 610 East CenterAve., Suite 301 Mooresville, NC 28115 One
Phone: (704) 663-16991 Fax: (704) 663-60401 Customer Service:1-877-623-6748 NorthCarolina
Internet: www.ncwaterquality,org �li�lll"1����
An Equal Opportunity 1 AffrmaUve Aclien Employer— 50% Recycled110% Post.Consumer paper Y
Mr. B. Shaw, Cognis Corporation
NOV-2009-PC-0490, Page 2
June 3, 2009
Analytical confirmation sampling using EPA Method 9071 for Oil and Grease to below the
reportable concentration of 250 ppm shall be conducted for any petroleum -impacted soils. Any
materials discharged to the storm drain system shall be cleaned up and disposed of properly. Any
illicit connections to the storm drain system or ground shall be permanently removed.
It is requested that a written response be submitted to this Office by July 6, 2009,
addressing the above -noted violations and the issues noted in the Stormwater Pollution
Prevention Plan section in the enclosed report. In responding to the violations, please address
your comments to the attention of Ms. Marcia Allocco at the letterhead address.
The subject facility will have 90 days from the letterhead date to come into compliance
with the above -noted violations. A follow-up evaluation will be conducted by CMSWS after
August 30, 2009 (90 days from letterhead date) to ensure compliance with the facility's
Stormwater Permit and/or compliance with the City of Charlotte Stormwater Ordinance.
The enclosed report should be self-explanatory; however should you have any questions
concerning this report or have any;questions regarding your permit, please do not hesitate to
contact Ms. Marcia Allocco of this Office at (704) 663-1699.
Sincerely,
for Robert B. Krebs
Regional Supervisor
Surface Water Protection Section
Mooresville Regional Office
Enclosure
cc: S. Sullivan, NPS-ACO Unit
B. Lowther, Stormwater Permitting Unit
Rusty Rozzelle, Mecklenburg County
Craig Miller, City of Charlotte
°gyp (5- Cs�
P7
0
Compliance Inspection Report
Permit: NCS000049 Effective: 02/01/09 Expiration:-01/31/14 Owner: Cognis Corporation
SOC: Effective: Expiration: Facility: Cognis Corporation
County: Mecklenburg 3300 Westinghouse Blvd
Region: Mooresville
Charlotte NC 28241
Contact Person: Randall Bruce Rhoades Title: Phone: 704-945-8726
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Relates! Permits:
Certification: Phone:
Inspection Date: 04/0912009 Entry Time: 09:00 AM Exit Time: 01:00 PM
Primary Inspector: Water Quality Program Meckenburg County Phone: 704-336-5449
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: Q Compliant ■ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page: 1
S"
1114
Permit: NCS000049 Owner— Facility: Cognis Corporation
Inspection Date: 04/09/09 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Facility Description:
The Cognis facility reacts and blends raw chemicals to produce defoamers, synthetic lubricants, and paint elements
and operates 24 hours a day, seven days a week. The facility handles hazardous and non -hazardous materials and
has an onsite pre-treatment wastewater facility which discharges to Charlotte -Mecklenburg Utilities sewer system
under CMU Pre-treatment Permit #0500. Areas identified to have a significant potential to contribute stormwater
pollution are routed to the on -site pre-treatment facility. No vehicle maintenance or washing occurs on -site.
Compliance History:
Mecklenburg County Water Quality Program (MCWQP) conducted a compliance evaluation on March 11, 2005. The
facility was in compliance at this time. On Match 15, 2005, approximately 12,000 gallons of treated wastewater spilled
due to a pump failure. On July 10, 2008, approximately 500 gallons of wastewater overflowed from an equalization
tank. Mecklenburg County Water Quality Program responded. On August 26, 2008, approximately 1,000 gallons of oil
overflowed from a wastewater trench due to flooding from Tropical Storm Fay. MCWQP responded and the Division of
Water Quality was notified (Incident # 200802263).
Industrial Operations/City of Charlotte Stormwater Ordinance Review:
Train Unloading Area —
Materials are unloaded from trains in an area where a storm drain inlet is located. Spill containment structures are in
place in these areas. The permittee should consider installing spill control measures around the storm drain inlet.
Pilot Plant —
A one -inch pipe was observed plumbed to the concrete ground outside the building. Staff commented that the pipe
was not in use. The permittee should permanently remove the connection to prevent potential releases to the storm
drain system.
Trash Compactor —
The trash compactor is located outside in a concreted, bermed area and is exposed to stormwater. A sump pump is
located within the berm that pumps any stormwater or wastewater from the compactor to the on -site wastewater
treatment facility. Dark staining of the soil around the outside of the containment area was apparent. The permittee
shall remove all impacted soils.
Filter Cake Dumpster_Pump —
The pump is located on concrete and stormwater from this area is sent to the on -site wastewater treatment facility. The
pump was covered. Standing oil was observed on the concrete surface around the base of the pump. The permittee
shall remove all spilled oil and should maintain the pump to prevent future discharges.
Dike in front of Aeration Tank #3 —
Petroleum stained soil and dead grass were observed along the earthen edge of the wastewater tank farm. Petroleum
stained gravel throughout the wastewater tank farm was also observed. Staff commented this was due to the previous
oil spill in 2008. The permittee shall properly remove and dispose of all impacted gravel and soils and conduct oil and
grease sampling for less than 250 ppm. These areas shall be restored to their original conditions.
Process Building Down Spouts —
Steam condensate lines and other lines were observed plumbed into down spouts that discharge to the storm drain
system. The permittee shall remove all illicit connections to the storm drain system.
Sugar Creek Tank Farm Roadway —
Puddles of bright green liquid were observed along the Sugar Creek Tank Farm roadway. The permittee shall properly
remove all products and impacted soils. The area shall be restored to its original conditions.
Page: 2
Permit: NCS000049 Owner— Facility: Cognis Corportion
Inspection Date: 04/09/09 inspection Type: Compliance Evaluation Reason for Visit: Routine
South Tank Farm —
An area of approximately ten square feet of dead grass was observed outside the concrete containment wall of the
South Tank Farm. Facility personnel explained that wastewater spilled from the tank. The permittee shall properly
remove and dispose of all impacted soils, and conduct oil and grease sampling for less than 250 ppm. This area shall
be restored to its original condition.
North wall of Process Building —
An area of stained soil was observed under the stairwell of the north wall of the Process Building. Facility personnel
explained that the staining might be from overspray when spraying down the floor inside the building. The permittee
shall properly remove and dispose of all impacted soils, and conduct oil and grease sampling for less than 250 ppm.
This area shall be restored to its original condition.
Page: 3
Permit: NCS000049 Owner -Facility: Cognis Corporation
Inspection Date: 04109/2009 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?
■
❑
❑
❑
# 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?
I
■
❑
❑
❑
# 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?
■
❑
❑
❑
# 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: The SPPP general location map was missing a notation on whether the
receiving water is impaired or located in a watershed for which a TMDL has been
established and the site map was missing the percentage of each drainage area that is
impervious, the impervious surfaces on site, and the site topography. Feasible
alternatives to current practices are not included in the SPPP. An area of liquid
materials were stored outside in multiple aboveground storage containers in close
proximity to each other with a total combined capacity of a1,320 gallons. Facility
personnel explained that the storage area for these containers is under construction and
the containers should be moved into the new containment area by the beginning of May
2009. Employee training was conducted and documented for 2006, 2007, and 2008.The
SPPP was reviewed and updated in March 2009; no other reviews/updates were
documented. Stormwater Facility inspections were conducted semi-annually in 2004,
2005, 2006, 2007, and 2008,
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ■ ❑ ❑ ❑
Comment: Qualitative Monitoring was conducted on 6-14-2004, 11-12-2004,
6-6-2005, 11-28-2005, 6-2-2006, 11-7-2006, 6-2-2007, 11-15-2007, 6-13-2008, and
11-13-2008.
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? ■ ❑ ❑ ❑
Page: 4
Permit: NC5000049 owner -Facility: Cognis Corporation
Inspection Date: 04/09/2009 Inspection Type: Compliance Evaluation Reason for Visit: Routine
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ a ❑
Comment: Analytical Monitoring was conducted on 11-12-2004, 2-14-2005 and
6-6-2005.
Permit and Outfalls Yes No NA Na
# Is a copy of the Permit and the Certificate of Coverage available at the site? ■ ❑ ❑ ❑
# Were all outfalls observed during the inspection? 0 ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ■ ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ■ ❑ ❑ ❑
Comment: Swale to Storm Drain Outfall #004 —
During the inspection, a brown liquid and a white gel -like substance was observed at
the end of a storm drain pipe that drains into a swale that discharges to Storm Drain
Outfall #004. The facility shall properly remove and dispose of the materials. The
facility should investigate the source of the release and take steps to prevent future
discharges to the storm drain system.
9
Page: 5