NCS000522_COMPLIANCE_20130716

STORMWATER DIVISION CODING SHEET
PERMIT NO.
W's- wo %Ajg 5Z2
DOC TYPE
❑FINAL PERMIT
0 MONITORING INFO
❑ APPLICATION
COMPLIANCE
❑ OTHER
DOC DATE
❑ 2UI��-1 � �P
YYYYMMDD

��c�ect Qale�tatloa, Qac.
July 12, 2013
Ms. Allocco
NCDENR
Mooresville Regional Office
610 East Center Ave., Suite 301
Mooresville, NC 28115
704-66-1699
RECE',VED
DIVISION OF WATER QUALITY
JUL 16 2013
I jOORESV� LLE I�I»O,GwiF1L OFFICE
RE: Notice of Violation/Compliance Evaluation Inspection
Tracking Number: NOV-2013-PC-0219
3f Chimica Americas, Inc; 4330 Chesapeake Dr, Charlotte, NC
NPDES Stormwater Permit NCS0005222J
Dear Ms. Allocco:
On behalf of 3F Chimica America's Inc. (3FCA), Project Integration, Inc. (PI) is submitting this
letter in response to findings of the inspection conducted February 22, 2013 by Mr. Andrew
Martin of Charlotte -Mecklenburg Storm Water Services (CMS WS). Each finding is listed in
an abbreviated format with subsequent response.
Additionally, please note that all findings listed in the original inspection report were
addressed in a February 27, 2013 Storm Water Permit Renewal Application. A copy of the
February 27, 2013 renewal document is included as Attachment A, and is referenced where
appropriate.
1. The SPPP is missing several elements required by the NPDES permit as noted in the
attached report:
a. General Location (USGS) Map - The USGS map was located in the front
pocket of the SPPP three ring binder.
b. Feasible Alternatives to current practices - see Best Management Practices,
Attachment A.
c. Employee Training Records - Training records for annual storm water
training will be documented going forward and will be incorporated into
new hire training.
d. Stormwater facility inspection program - The SPPP contains monthly facility
inspections logs (SPPP -Appendix Cl), Facility Inspection Report/ Benchmark
Tier Review Report (SPPP-App C2), and Non-Stormwater Discharge
Assessment and Certification (SPPP -App C3). These inspections logs and
have been adapted/modified by 3FCA' to the format contained in the
February 27, 2013 renewal (Renewal Application -Attachment A).
2. Analytical Sampling/Discharge Monitoring Reports (DMR's) -
a. Analytical Sampling was conducted January 11, 2012, October 15, 2012 and
January 23, 2013. Absent DMR's will be submitted under separate cover and
maintained with facility records.
1097 Hghway 101 South, Suite D16 Greer, SC 29651
P.O. Box 1414 Greer, SC 29652-1414
Phone - 864.334.5085 Fax [phone]
sales®pintegration.com

( .. q: �':

Page 2
3. Permit and Outfalls -
a. New Outfall - the new outfall 003 has been added to the facility's SPPP Site
Map (Attachment A - Renewal Package).
b. Update the SPPP - 3FCA has contracted with PI to update the facility's
SPPP/SPCC plan. The updated SPPP/SPCC will be completed prior to the
September 14, 2013 follow-up evaluation.
c. Illicit Discharge - The facility maintains several potable water/sink and
drinking fountains that are connected to a common sanitary sewer
connection. On the date of the inspection, there was a small break in the line
that led to leaking into the storm water conveyance system located adjacent to
the north warehouses. The line was promptly repaired following the
February 22, 2013 inspection.
We appreciate your review of this Ietter and do not hesitate to contact us with any questions.
Sincerely,
Jason W. Davis
Project Manager
Attachments: Attachment A -February 27, 2013 Storm Water Permit Renewal Package
1097 Highway 101 South, Suite D16 Geer, South Carolina 29651
Phone - 864.334.5085 Fax [phone]
[e-mail]

Page 3
Attachment A
February 27, 2013 Storm Water Permit Renewal Package
1097 Highway 101 South, Suite D16 Greer, South Carolina 29651
Phone - 864.334.5085 Fax [phone]
[e-mail]

February 27, 2013
Mr. Brian Lowther
NCDENR
Division of Water Quality, Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
RE: 3f Chimica Americas
Charlotte, North Carolina Facility
Storm Water Permit Renewal Application
Dear Mr. Lowther:
RECEIED
DMISInQN OF ALTER
QUALITY
JUL 16 2013
3 tl j n .:- +"tQi�, l
MDaRFSVfL! I"tF�ltjOFFlCE
Permit Number NC5000522 expires February 28, 2013. 3f Chimica is submitting this
application to request renewal of the facility storm water permit. The permit was originally
issued to US Polymers, however, US Polymers changed the name of the company to 3f
Chimica Americas.
Included in this document is the following requested information:
• Current site map -
• Summary of facility sampling -
• Summary of visual monitoring -
• Summary Best Management Practices -
• Significant facility changes -
• Certification of SWPPP-
Attachment A
Attachment B
Attachment C
Included in text of letter
Included in text of letter
Attachment D
3f Chimica Americas implements a number of best management practices (BMPs) at the
Charlotte facility. These BMPs include the following:
1. Covered storage - 3f Chimica has covered storage of used totes. This storage area
manages the totes in a storm water free area.
2. Secondary containment draining practices - 3f Chimica has three (3) secondary
containment areas. Each of the areas is maintained as normally closed. When the
containment area contains storm water 3f Chimica visually inspects the storm water
and then measures the pH of the storm water prior to releasing the water to the storm
drain.
3. A further best management practice implemented by 3f Chimica relates to the release
of the secondary containment and other industrial area storm water. The facility
maintains the holding pit drain in the closed position during normal operations. This
holding pit catches all the water from the secondary containment areas as well as
most of the rest of the industrial area. 3f Chimica collects the storm water in the
1097 Highway 101 South, Suite DI Greer, SC 29651
P.O. Box 1414 Greer, SC 29652-1414
Phone - 864.334.5095 Fax 864,334.5143
[e-mail]

Page 2
holding pit and visually inspects as well as checks the pH of the storm water prior to
releasing the storm water off the property.
4. The facility completes weekly good housekeeping inspections. These inspections
review each of the facility areas and look for potential issues related to process and
environmental issues. The facility uses a checklist and documents each review.
This covers some of the main BMPs implemented at the facility.
The facility is also making one significant change to the facility storm water pollution
prevention plan (SWPPP). The facility is eliminating the existing Outfall 3 at the rear of the
facility. The outfall does not cover an industrial area in normal operations and the discharge
is more effectively described as sheet flow instead of a point source. The facility is also
adding an outfall. This outfall will cover the rear parking and raw material unloading area.
This outfall will be identified as Outfall 3, replacing the exiting Outfall 3. There are no other
significant changes. The facility still processes the same materials and produces the same
products.
Additionally, as noted above, this document includes four (4) attachments that provide the
remainder of the information needed to submit a complete storm water permit renewal
application.
Please call me at [phone] if you have any questions or need any further information.
Thank you for your assistance in the renewal process.
Sincerely,
I !Awl AWA
nv 400
David L. Kirby
Project Manager
Attachments: Attachment A -Facility Site Map
Attachment B - Summary of Test Results
Attachment C - Summary of Visual Monitoring
Attachment D - SWPPP Certification
1097 Highway 101 South, Suite D16 Greer, South Carolina 29651
Phone - 864.334.5085 Fax [phone]
[e-mail]

Page 3
Attachment A
Facility Site Map
1097 Highway 101 South, Suite D16 Greer, South Carolina 29651
Phone - 864.334.5085 Fax [phone]
sales@pintegration. corn

r ♦
�MWLY DOW
• ' • y+EEi, r,
. r♦y( • 'S
mom
p 711aM�` - tME�� r To" LCACM
•
� . " 14RW L'Nutm TM*S
WM OKI
• O O '
O
}
ASS .' : IMF
/�� .O1YU11C�
��' ♦ PAVFJAEN,�
1�tGMb
. FWW • ♦
aLffol #I - OF1xE� AY0N1Es "
T.
� PAAr�ENS

Page 4
Attachment B
Summary of Test Results
1097 Highway 101 South, Suite D16 Greer, South Carolina 29651
Phone - 864.334,5085 Fax [phone]
[e-mail]

Cf .2!:3f chimica
3F Chimica
Charlotte, NC
Facility Sampling Summary
I I
mg/L t I
I, mg/Kg
Outfall
No.
Sample Date
Total
Rainfall
(inches)
TSS (PQL)
HEM (PQL)
pH
Acrylamide
1
10/15/2012
N/A
40(10)
43(4.5)
6.50
1.268
2
10/15/2012
N/A
23(10)
13(4.9)
6.00
<0.025
-1 W
1-2 W,
1 11 2012
1,1/11/2012
',21 (13)
(6 7)
"WKV17 9N,
ND,!�(4-7)
(4.'6)
tR ft-V
0'
6 0(
I T
25.
25.
25:
J... 172
24, O}
6.00.'.
-�OMS
1
1/26/2012
0.38
4.8(1.0)
ND (4.8)
6 .90
<0-025
2
1/26/2012
0.38
63(1.7)
N D (4.6)
3.40
<0,025
3
1/26/2012
0.38
73(1.8)
ND (4-8)
5.70
<0.025
-1
AO/25 2 1
-t - ...
'-A/25/2 I
3P 44
.,o
dRA3G4�w
.40
-'15 O(5,O)
., -4- � - '4- -
-4, Rw , E
"12V(3-.' 1)
�9 !;-'ND'(4 8)
" -, t
Ii2� 01'(4 6)
t6:00�
- 114w�;;
6 bil)
0037
.252
.i
0
,
1
2/22/2010
0.53
18(3.3)
ND (4.2)
5.80
0,054
2
2/22/2010
0.53
50(5.0)
5.2(4.4)
5.85
<0.025
3
2/22/2010
0.53
61(5.0
ND (4.3)
5.48
<0.025
*-�:8/31/2009
ikww
,.,',8/517/2009
tj,,110 (5,0)
'a
-'(4 7)
!D
fN
-Z" �Arlw.. 11 "POW
kA i-n4i , 'W"
-17 (13)
- i,
D
1
1/28/2009
0.21
5.1(1.3)
540 (5.0)
6.50
0,211
2
1/28/2009
0.21
8.7(1.4)
ND (4.5)
6.50
ND
3
1/28/2009
0.21
25(3.3)
ND (4.5)
6.50
ND
V�--,�
8
0'9/16/2008
lw
W
IWIVV�, n
.7'�`3�j
�1233 (�11,,-.00)
ii.4,ND­(4A)
Di (4`5)
6.41�,
i,5'12,?
015
tw
!V.',A!
'91.1672008
Z3
::
ND- 5)
5 45j
TSS - Total Suspended Solids
HEM - Hexane Extractable Material {Oil & Grease)
PQL- Practical Quantification Limit
All sampling performed by Shealy Environmental Services, Inc.

Page 5
Attachment C
Summary of Visual Monitoring
1097 Highway 101 South, Suite D16 Greer, South Carolina 29651
Phone - 864.334.5085 Fax [phone]
[e-mail]

( 3f,chimica
3F Chimica
Charlotte, NC
Facility Visual Monitoring Summary
Outfall
No.
Inspection
Date
Color
Odor
Clari
Foam
Oil
Scum
Comments
Inspected
By:
1
1/16/2013
OK
OK
OK
None
None
None
None
Ian Trossell
2
1/16/2013
OK
OK
OK
None
None
None
None
Ian Trossell
3
1/16/2013
OK
None
None
None
Ian Trossell
1 -
12/14/2012
_OK
� '.OK
OK"
_OK
OK.}
_None
'Noe
None
None
None
Ian Trmsell
2
12/14/201,2
OK
OK
OK
None
None
None
None
lan Trossell
A.
12/14/2012
`OK
OK
`B.OK
None.`
None
None
; :None
Ian Trossell

Page 6
Attachment D
SWPPP Certification
1097 Highway 101 South, Suite D16 Greer, South Carolina 29651
Phone - 864.334.5085 Fax [phone]
[e-mail]

Permit Coverage Permit Number
tF Yi`re,, Renewal Application Form NCS000522
� r National Pollutant Discharge Elimination System
Stormwater Discharge Permit
1
i'he following is the information currently in our database for your facility. Please review this information carefully and make all
corrections/additions as necessary in the space provided to the right of the current information.
Owner Affiliation_ Information
*Reissued Permit will be mailed to the owner address
Owner / Organization Name: US Polymers 3F Chimica Amertcas
Owner Contact:
. Roberto Loniolo Ian Trassell
Mailing Address:
4330 Chesapeake Dr
Charlotte, NC 28216
Phone Number:
Fax Number:
E-mail address:
Facility/Perm,It Contact Information
Facility Narne:
U S Polymers
Facility Physical Address:
4330 Chesapeake Dr
Charlotte, NC 28216
Facility Contact:
Mailing Address:
Phone Number:
Fax Number:
E-mail address:
f
_.schame Information
Receiving Stream
Stewart Creek
Stream Class:
C
Basin:
Catawba River Basin
Sub -Basin:
03-08-34
Number of Outfalls:
ImnairesLW_aters/TMDL
Does this facility discharge to waters listed as impaired or waters with a finalized TMDL? ❑ Yes W No C3 Don't Know
( for information on these waters refer to http://h2o.enrstate.ncus/sulimpaire(tWaters TMDL/ )
C+>1W.VdI;ffil•:]L1 rWl
I certify that I am familiar with the information contained in the application and that to the best of my knowledge and belief such
information is true, complete and accurate.
Signature _ Date a.4.�/ .CIS vl�,
Print or type name of person signing above Title
Stormwater Permitting Unit
,ase return this completed renewal application form to: Attn: Brian Lowther
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

STORMWATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
North Carolina Division of Water Quality - Stormwater Permitting Unit
Facility Name. U S Polymers
Permit Number: NCS000S22
Location Address: 4330 Chesapeake Dr
Charlotte, NC 28216
County: Mecklenburg
"I certify, under penalty of law, that the Stormwater Pollution Prevention Plan (SPPP) document and all attachments were developed and
implemented under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather
and evaluate the information required by the SPPP. Based on my inquiry of the person or persons who manage the system, or those persons
directly responsible for gathering the information, the information gathered Is, to the best of my knowledge and belief, true, accurate and
complete."
And
"1 certify that the SPPP has been developed, signed and retained at the named facility location, and the SPPP has been fully implemented at
this facility location in accordance with the terms and conditions of the Stormwater discharge permit"
And
"[ am aware that there are significant penalties for falsifying information, including the possihility of fines and imprisonment for knowing
violations."
Sign (according to permit signatory requirements) and return this Certification. DO NOT SEND
STORMWATER POLLUTION PREVENTION PLAN WITH THIS CERTIFICATION.
Signature f t%r Date 2-C)
Print or type name of person signing above Title
SPPP Certification 5109

SUPPLEMENTAL INFORMATION REQUIRED FOR RENEWAL OF INDIVIDUAL
NPDES STORMWATER PERMIT
Two copies of each of the following shall accompany this submittal in order for the application
to be considered complete:
(Do not submit the site Stormwater Pollution Prevention Plan)
Initials
1, A current Site Map from the Stormwater Pollution Prevention Plan. The location of
industrial activities (including storage of materials, disposal areas, process areas and
loading and unloading areas), drainage structures, drainage areas for each outfan,
building locations and impervious surfaces should be clearly noted.
!L 2. A summary of Analytical Monitoring results during the term of the existing permit
(if your pernit required analytical sampling). Do not submit individual lab reports.
The summary can consist of a table including such items as outfall number,
parameters sampled, lab results, date sampled, and storm event data. H
3. A summary of the Visual Monitoring results. Do not submit individual monitoring
reports. The summary can consist of a table including such items as outfall number,
parameters surveyed, observations, and date monitoring conducted.
4. A summary of the Best Management Practices utilized at the permitted facility.
Summary should consist of a short narrative description of each BMP's in place at
the facility. If the implementation of any BMP's is planned, please include
information on these BMP's.
5. A short narrative describing any significant changes in industrial activities at the
permitted facility. Significant changes could include the addition or deletion of
work processes, changes in material handling practices, changes in material storage
practices, and/or changes in the raw materials used by the facility.
6. Certification of the development and implementation of a Stormwater Pollution
Prevention Plan for the permitted facility (Sign and return attached form).
If the final year analytical monitoring of the existing permit term has not been completed
prior to filing the renewal submittal, then the last years monitoring results should be submitted
within 30 days of receipt of the laboratory reports. (i.e. do not withhold renewal submittal
waiting on lab results)

NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Roberto Loniolo
US Polymers
4330 Chesapeake Dr
Charlotte, NC 28216
Dear Permtttee:
Division of Water Quality
Charles Wakild, PE
Director
July 6, 2012
RECEIVED
DIVISION OF WATER QUALITY
JUL 1 " 2012
::UJ: _v i •.1i1
MOORESVILLE REGIONAL OFFICE
Subject: NPDES Stormwater Permit Coverage Renewal
U S Polymers
Permit Number NCS000522
Mecklenburg County
Dee Freeman
Secretary
Your facility is currently covered for stormwater discharge under NPDES Permit NCS000522. This permit
expires on 2/28/2013. To assure consideration for continued coverage under your individual permit, you
must apply to the Division of Water Quality (DWQ) for renewal of your permit. Enclosed you will find an
individual permit Renewal Application Form, Supplemental Information request, and Stormwater Pollution
Prevention Plan Certification for your facility.
Filing the application form along with the requested supplemental information will constitute your
application for renewal of this permit. Until your permit renewal is completed and you receive a new permit,
please continue to comply with all conditions and monitoring requirements in your expired NPDES
stormwater permit.
The application and supplement must be completed and returned to DWQ by September 1. 2012, Failure to
request renewal within this time period will result in delay of your permit renewal and may result in a civil
assessment. Discharge of stormwater from your facility without coverage under a valid stormwater NPDES
permit would constitute a violation of NCGS 143-215.1 and could result in assessments of civil penalties of up
to $25,000 per day.
If you have any questions regarding permit renewal procedures please contact Brian Lowther of the
Stormwater Permitting Unit at (919)-807-6368 or [e-mail].
Sincerely,
Bradley Bennett, Supervisor
Stormwater Permitting Unit
Cc: Central Files
SPU Files
Mooresville Regional Office
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Rateigh, North Carolina 27604
Phone. 91M07-63001 FAX:[phone] Internet: www.nmaterquality.org
One
NorthiCarolina
Naturally
An Equal Opportunity 1 Affirmalive Action Employer

■ Permit Coverage Permit Number
p4WArfo
p� Renewal Application Form NCS000522
a t National Pollutant Discharge Elimination System
The following is the information currently in our database for your facility. Please review this information carefully and make all
corrections/additions as necessary in the space provided to the right of the current information.
Owner Affiliation Information
*Reissued Permit will be mailed to the owner address
Owner / Organization Name:
US Polymers
Owner Contact:
. Roberto Loniolo
Mailing Address:
4330 Chesapeake Dr
Charlotte, NC 28216
Phone Number:
FaxNumber:
------•-------------•---_____...-��._.--•-----..-._-----�
E-mail address:
Facil4ty/PerMit Contact Information
Facility Name:
U S Polymers
Facility Physical Address:
4330 Chesapeake Dr
Charlotte, NC 28216
Facility Contact:
Mailing Address:
Phone Number:
Fax Number:
E-mail address:
Discharge Information
Receiving Stream
Stewart Creek
Stream Class:
C
Basin:
Catawba River Basin
Sub -Basin:
03-08-34
Number of Outfalls:
IMIjaired Waters jTMDL
Does this facility discharge to waters listed as impaired or waters with a finalized TMDL? ❑ Yes ❑ No ❑ Don't Know
( for information on these waters refer to http://h2o.enr.state.nc.uslsullmpairec Waters TMDL/ )
CERTIFICATION
I certify that I am familiar with the information contained in the application and that to the best of my knowledge and belief such
information is true, complete and accurate.
Signature
Print or type name of person signing above
Date
Title
Stormwater Permitting Unit
Please return this completed renewal application form to: Attn: Brian Lowther
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

North Carolina Division of Water Quality - Stormwater Permitting Unit
Facility Name: U S Polymers
Permit Number: NCS000522
Location Address: 4330 Chesapeake Dr
Charlotte, NC 28216
County: Mecldenburg
"I certify, under penalty of law, that the Stormwater Pollution Prevention Plan (SPPP) document and all attachments were developed and
implemented under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather
and evaluate the information required by the SPPP. Based on my inquiry of the person or persons who manage the system, or those persons
directly responsible for gathering the information, the information gathered is, to the best of my knowledge and belief, true, accurate and
complete."
And
"I certify that the SPPP has been developed, signed and retained at the named facility location, and the SPPP has been fully implemented at
this facility location in accordance with the terms and conditions of the stormwater discharge permit."
And
"I am aware that there are significant penalties for falsifying information, including the possibility of fines and imprisonment for knowing
violations."
Sign (accarding to permit signatory irequlrementsy and return this Certification DO NOT SEND'
STORMWATER POLLUTION IPREVENTI0N;PLAN WITH,THIS„CERTIFICATION i' „r
I',Lil L 1L1i1�III;I��J;i :',! C rl � L1i�II �I'�11�i116�. I�i6i��i��i l i i ll� �. '.ilil.il6i���l��.�iig �C1�!, �.il.li� lil!�Ill �i . l�al,llililii'K. I�4�ui i:l�lslfala
Signature
Print or type name of person signing above
Date
Title
SPPP Certification 5/09

omn,
ACDENR FILE
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Pat McCrory Thomas A. Reeder John E. Skvarla, III
Governor Acting Director Secretary
June 14, 2013
Leigh Guinn, General Manager
3F Chimica .
10930 Darracott Road
Aberdeen, MS 39730
Subject; Notice of Violation
Compliance Evaluation Inspection
Tracking Number: NOV-2013-PC-0219
3F Chimica
4330 Chesapeake Drive, Charlotte NC 28216
NPDES Individual Stormwater Permit NCS000522
Mecklenburg County
Dear Mr. Guinn:
On February 22, 2013, Andrew Martin; from Charlotte -Mecklenburg Stormwater Services (CMSWS), conducted a site
inspection of the 3F Chimica facility located at 4330 Chesapeake Drive in Charlotte, Mecklenburg County, North Carolina.
The site drains to Stewart Creek, Class C waters located in the Catawba River Basin. The site visit and file review
revealed that the subject facility is covered by NPDES Individual Stormwater permit NCS000522.
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 ll Section H. The following observations and/or permit condition violations
were noted during the CMSWS inspection (please 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
The SPPP is missing several elements required by the NPDES stormwater permit as noted in the attached report.
2} Qualitative Monitorin
Qualitative monitoring has been conducted and recorded in accordance with permit requirements.
Yes ® No ❑
3) Analytical Monitoring
Yes ® No ❑ NA ❑
Analytical Monitoring was conducted as required; however discharge monitoring reports (DMRs) for 2012 were not
submitted. Outfall 003 was not sampled during the October 2012 monitoring event. Please complete and submit the
DMRs as directed on the form.
4) Permit and Outfalls
The permittee's coverage under the individual stormwater permit expired on February 28, 2012; renewal was shortly after
the inspection date. A new outfall was found during the inspection; please update the SPPP and commence monitoring for
the outfall. An illicit discharge was noted entering the on -site stormwater system. If not already removed this discharge
must cease.
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] Fax: [phone] Customer Service: 1-877-623-6748
Internet: http://portal.nodenr,org/webtwq
No Carolina
��ttur!luu�y
An Equal Opportunity 1 Affirmative Action Employer — 50% Recycledlt 0% Post Consumer paper

r
Leigh Guinn, 3F Chimica
NOV-20137PC-0219, Page 2
June 14;.2013 , -- d
5) City of Charlotte'Stormwater Ordinance Review:
A summary of the review completed for compliance with the City of Charlotte Stormwater Ordinance is contained in the
Summary section of the enclosed report.
Thank you for the assistance and cooperation during the inspection. As noted above and in the enclosed report, permit
and City of Charlotte Stormwater Ordinance violations were noted during the inspection. It is requested that a written
response be submitted to this Office by July 15, 2013, addressing these violations. In responding to the violations, please
address your comments to the attention of Ms. Allocco at the letterhead address.
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.
A follow-up evaluation will be conducted by CMSWS after September 14, 2013, to ensure compliance with the facility's
Stormwater Permit and/or compliance with the City of Charlotte Stormwater Ordinance.
If you have any questions, comments, or need assistance understanding any aspect of your permit, please do not hesitate
to contact Andrew Martin with CMSWS at [phone] or Ms. Marcia Allocco of the Division of Water Quality at (704)
235-2204.
Sincerely,
for Michael L. Parker
Regional Supervisor
Surface Water Protection Section
Mooresville Regional Office
cc: NPS-ACO Unit
Rusty Rozzelle, MCWQP
Craig Miller, City of Charlotte
Ian Trossell, 3F Chimica, 4330 Chesapeake Drive, Charlotte, NC 28216
Water Quality Central Files
Mooresville Regional Office
Location, 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] Fax: [phone] Customer Servlce: 1-877-623-6748
Internet: http:i/portal.nedenr.orgAmeb/wq
An Equal Opportunity 4 Affirmative Action Employer- 30% Recycle l O% Post Consumer paper
Noe• Carolina
/

` Ile ti
Leigh Guinn, 3F Chirnica
NOV-2013-PC-0219, Page 3
June 14, 2013
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 reggired 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 (NO]) 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 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 approval.
• There are currently 19 active general permits. Permit conditions vary accordingly; however, most of the
permits have the following condition requirements (you must read your entire permit to ensure full
compliance):
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
Mooresville Regional Office
Location: 610 East Center Ave., suite 301 Mooresville, NC 28115
Phone: [phone] Fax: [phone] Customer Service: 1-877-623-6748
Internet: http://portal.nodenr.org/weblwq
No Carolina
An Equal opportunity 1 Affirmative Action Employer — 30% Recycled110% Post Consumer paper

Leigh Guinn, 3F Chimica
NOV-2013-PC-0219, Page 4
June 14, 2013
c 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 5tormwater 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.
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] Fax: [phone] Customer Service:1-877.623-6748
Intemet: http:1/por1al.ncdenr.oVwebtwq
An Equal Opportun'dy 1 Affirmative Action Employer — 30% Recycled110% Post Consumer paper

Permit: NCS000522
SOC:
County: Mecklenburg
Region: Mooresville
Compliance Inspection Report
Effective: 03/01/08 Expiration: 02/28/13 Owner: US Polymers
Effective: Expiration: Facility: U S Polymers
4330 Chesapeake Dr
Contact Person: Roberto Loniolo
Directions to Facility:
-System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Title:
Certification:
Charlotte NC 28216
Phone:
Phone:
Inspection Date: 02/22/2013 Entry Time: 09:09 AM Exit Time: 11:31 AM
Primary Inspector: Water Quality Program Meckenburg County Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: Q Compliant ■ Not Compliant
Question Areas:
0 Storm Water
(See attachment summary)
Inspection Type: Compliance Evaluation
Page: 1

Permit: NCS000522 • Owner -Facility: US Polymers
Inspection late: 02/22/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Facility Description:
The 3F Chimica facility is engaged in producing waste water treatment products and is located on a 12.9-acre parcel. The
site is owned by BASF but is leased by 3F Chimica. All process activities occur inside and under cover.
Industrial Operations/City of Charlotte Stormwater Ordinance Review:
Illicit discharges/connections —
At the time of inspection a white PVC pipe was observed leaking into the storm drain system near the main office area.
The PVC pipe is tied into the sanitary sewer system and is connected to an interior sink. This is an illicit discharge. It is
not approved under the stormwater permit or the City of Charlotte Stormwater Ordinance and should be removed.
Aboveground storage tank(s) —
The facility has acrylamide, surfactants, and solvents stored at the facility in 12,700 gallon tanks. There are four solvent
tanks in use, two surfactant tanks, and one acrylamide tank in use. The solvent tanks are under cover within secondary
containment. The other storage tanks are uncovered within secondary containment.
Underground storage tank(s) — The permittee has three 10,000-gallon diesel and one 4,000-gallon gasoline underground
storage tanks on site.
Outdoor material storage —
The permittee stores empty totes outside at multiple locations around the property. A large amount of totes are stored
outside in two locations that contain reject and waste product. The totes are not properly labeled with their contents.
There is a stormwater draw -down pipe with a locked valve located at the tote loading/unloading area at the facility that
acts as secondary containment for the totes stored in this area.
t-oading/unloading area(s)-
A loadingfunlo'ading area at the facility has a sump pump which discharges rainwater from the area into the storm drain
system. This sump is manually controlled, but has no locking mechanism. The water is visually inspected and a pH
reading is performed before the pump is tumed on, logs of the inspection are kept on site.
Floor drains —
Floor drains inside the facility are all sealed. Product or water that spills into these drains are pumped into large plastic
totes for disposal.
Waste storage/disposal areas (dumpsters, scrap metal bins, etc.) —
A scrap metal bin is located on site and exposed to stormwater. It is recommended that the bin be covered to minimize
the potential for stormwater pollution.
Additional Observations —
A polymer spill was observed in front of the rear bay door at the tote warehouse. The spill occurred within the secondary
containment area. The spill should be cleaned up.
A sanitary sewer lift station was observed onsite at the rest area. Only one pump is functional and is not being inspected
as frequently as required by North Carolina Administrative Code (15ANCAC 2T .0403), which states that pump stations
that are not connected to a telemetry system (Le, remote alarm system) shall be inspected every day (i.e. 365 days per
year). Pump stations that are connected to a telemetry system shall be inspected at least once per week.
Page: 2

Permit: NCS000522 Owner - Facility: US Polymers
Inspection Date: 02/22/2013 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?
# Has the facility evaluated feasible alternatives to current practices?
# Does the facility provide all necessary secondary containment?
# Does the Plan include a 8MP 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 facility has a SPPP but as noted in this section required elements are
missing. The SPPP has not been updated to reflect a company name change and
personnel changes at the facility and has not been updated since 2008. Secondary
containment is provided, however the permittee should verify that the secondary
containment is large enough to contain the amount of liquid stored in the areas next to
the warehouse. The facility was unable to produce records of employee training. The
permittee did not provide documentation showing that semi-annual stormwater
inspections were performed. There was no general location map in the SPPP.
Qualitative Monitoring
Has the facility conducted its Qualitative Monitoring semi-annually?
Comment:
Analytical Monitoring
Has the facility conducted its Analytical monitoring?
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
Yes No NA NE
■ ❑ ❑ ❑
Yes No NA NE
011110
❑ ❑ ■ ❑
Page: 3

Permit: NCS000522 Owner -Facility: US Polymers
Inspection Date: 02/2212013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Comment: Analytical Monitoring was conducted as required; however 2012 discharge
monitoring reports (DMRs) were not submitted for the monitoring. Outfall 003 was not
sampled during the October 2012 monitoring event. Please submit the DMRs for
analytical monitoring performed in 2012.
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?
011011
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ■ ❑
# Has the facility evaluated all illicit (non stormwater) discharges?
Comment: The stormwater system at the site consists of a series of drop inlets that
drain to three outfalls on the property. Some of the
inlets are equipped with valves to contain spills. No issues observed at the outfalls.
Outfall 003 currently drains a grassy field with no industrial activity occurring on it. A
new outfall was found near Chesapeake Drive, which connects to the City of Charlotte
Municipal Stormwater System. The drainage area for this outfall does contain industrial
activities. It is recommended that Outfall 003 be moved to the new location at the
street. The permittee was unable to provide documentation showing that
non-stormwater discharge evaluations were conducted as required.
Page: 4

a I
chimica
RU$
Ms. Marcia Allocco
Division of Water Quality
Mooresville Regional Office
610 East Center Ave Suite 301
Mooresville, NC 28115
CC: Chris Elmore
RE: Stormwater Permit Number NCS000522
Dear Ms. Allocco,
_1'd
VS1, Joef5Y
July 15, 2008
JUL 17 2008
NC DENR MRO
M-Surface Water Protection
This is a response to the Notice of Deficiency report dated June 23,
2008. After the June 16th inspection, several areas of concern were noted by
Chris Elmore and Ron Eubanks of the Charlotte -Mecklenburg Storm Water
Services. The following letter identifies the corrective actions taken to address
these issues/concerns.
The first area of concern was an offloading area adjacent to the
production area. This area Is used for secondary containment for offloading
incoming shipments to the site. In the event of rainfall in the area, storm water
does collect in this area and needs to be released to access the offloading
controls. Per the recommendations contained In the notice, the sump pump
that is in this containment area has been locked at the control switch located
Inside the production area of the site.
The second area of concern was located outside the Warehouse
receiving area where reusable 275 gallon totes are stored. There are 2
release points in this dock area. One releases from a drain on the front part of
the dock area, and the other releases from an area closer to the rear of that
portion of the dock. They release to a common ouff all line that drains to the
loading\unloading dock of the Warehouse. Per the recommendations
contained in the notice, both of the manual- release valves for this area have
been locked.
In response to the concerns noted above, the site Release Log has
been updated to include additional information and is located in the
Warehouse Shipping Office. The keys for the locks noted above are in the
control of Operations Shift Leaders or the Production Team Leader. The log
requires proper authorization by the Production Team Leader before releases
are allowed.
The scrap metal bin that was noted in the inspection has since been
removed from the site and is no longer an issue.
4330 Chesapeake Drive
Charlotte, NC 28216
704-394-8518

0 a
chnica
S
j 4141 �
olymofs
'P
Another area of concern that was found in the inspection was 2 interior
sinks and a drinking water fountain in the Warehouse that were reported to
drain to the storm water system. Information obtained after the inspection
found that the above discharge sources were in fact routed to the sanitary
sewer system as required by the NPDES permit.
The eyewash/safety shower mentioned in the statement concerning
illicit discharges, has been corrected and has been directed to a catch basin
per the inspectors' suggestions.
Regarding the notations concerning the Stormwater Pollution
Prevention Plan (SPPP) and the Qualitative and Analytical monitoring, the
completion and implementation of the SPPP is ongoing and will be completed
within the period allotted in the permit. The monitoring Is also ongoing and
will be completed by the date indicated in the permit. The discrepancy
regarding the number of outfalls will be resolved and will fall Into compliance
with the SPPP.
Please do not hesitate to contact me with any questions you may have
concerning this response or the actions taken.
z
y,
Darren Miller
Production Team Leader
U.S. Polymers
Charlotte Site
4330 Chesapeake Drive
Charlotte, NC 28216
704-394-8518

Michael F. Easley, Governor , 0�
William G. Ross Jr., Secretary
North Carolina De ent nvir Natural Resources
C(aulen . lins, Director
ivisWater
Quality
June 23, 2008
Mr. Darren Miller, Production Manager
US Polymers
4330 Chesapeake Drive
Charlotte, NC 28216
Subject: Notice of Deficiency
Compliance Evaluation Inspection
US Polymers
Stormwater Permit Number NCS000522
Mecklenburg County, NC
Dear Darren Miller:
Enclosed is a copy of the Compliance Evaluation Inspection (CEI) report for the
inspection conducted at the subject facility on June 16, 2008, by Christopher Elmore and Ron
Eubanks of Charlotte -Mecklenburg Storm Water Services. 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 11 Section H. Thank you for your
assistance and cooperation during the inspection.
The inspection found that US Polymers has drafted a Stormwater Pollution Prevention
Plan as required by NCS000522 but a number of deficiencies were noted as detailed in the
Industrial Operations/City of Charlotte Stormwater Ordinance Review, Stormwater
Pollution Prevention Plan, and Permit and Outfalls sections of the attached report.
With regard to the illicit discharges plumbing connections cannot discharge to the storm
water system or to the surface of the ground. The connections at this facility must be evaluated
and any illicit connections found must be corrected.
It is requested that a written response be submitted to this Office by July 21, 2008,
addressing the above -noted violations 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 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. Allocco of this Office at [phone].
ATA
HCDENR
Mooresville Regional Office Division of Water Quality Phone [phone]
Internet: wuw.ncwateryualitv.ors; 610 East Center Ave, Suite 301 Mooresville, NC 28115 Fax [phone]
An Equal OpportunitylAffirrrative Action Employer — 50% Recycled110% Post Consumer Paper
o e
NCarolina
Naiura!!y
Customer Service
1-877-623-6748

Mr. Darren Miller, US Polymers
Compliance Evaluation Inspection, Page 2
June 23, 2008
Sincerely,
for Robert B. Krebs
Regional Supervisor
Surface Water Protection Section
Mooresville Regional Office
Enclosure
cc: NPS-ACO Unit
Rusty Rozzelle, Mecklenburg County
Craig Miller, City of Charlotte

Permit: NCS000522
SOC:
County: Mecklenburg
Region: Mooresville
Compliance Inspection Report
Effective: 03/01/08 Expiration: 02/28/13 Owner: US Polymers
Effective: Expiration: Facility: U S Polymers
4330 Chesapeake Dr
Contact Person: Robert Rebello
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Title:
Certification
Charlotte NC 28216
Phone:
Phone:
Inspection Date: 04/28/2008 Entry Time: 01:00 PM Exit Time: 03:25 PM
Primary Inspector: Water Quality Program Mecklenburg County Phone:
Secondary Inspector(s):
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ❑ Compliant ■ Not Compliant
Question Areas:
0 Storm Water
(See attachment summary)
Inspection Type: Compliance Evaluation
Page: 1

Permit: NCS000522 Owner— Facility: US Polymers — US Polymers
Inspection Date: 04/28/08 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Facility Description:
The US Polymers facility produces wastewater treatment products and is located on a 12.9-acre parcel. The site is still
owned by BASF but is leased by US Polymers. All process activities occur inside and under cover.
Compliance History:
This site has had a significant history of discharge incidents with associated issuances of Notices of Violation under
BASF ownership. US Polymers is a new responsible party for this site and none of the previous incidents occurred
while US Polymers was responsible for the site's Clean Water Act compliance as required under permit NCS000522.
Industrial Operations/City of Charlotte Stormwater Ordinance Review:
Chemical Storage -
The permittee stores acrylamide, surfactants, and solvents at the facility in 12,700-gallon tanks. There are four solvent
tanks in use, two surfactant tanks, and one acrylamide tank in use. The solvent tanks are under cover with secondary
containment. The other storage tanks are uncovered with secondary containment.
Loading/Unloading Area -
There is a loading/unloading area at the facility which has a sump pump that discharges rainwater from the area into
the storm sewer system. This sump is manually controlled, but has no locking mechanism.
The sump pump in the loading/unloading area must be fitted with a lock on its manual controls to prevent unauthorized
releases from this area. This area is functioning like a secondary containment area, which means accumulated
stormwater must be evaluated for contamination before it is released. A log of these releases must be kept along with
the information noted from the evaluations of the stormwater.
Hazardous Materials Storage -
There is a hazardous materials shed on the facility ground which is still controlled by BASF. This shed is a covered
storage building and no water quality problems with the structure were found at the time of inspection.
Tote Storage -
The permittee stores empty totes outside and all totes observed stored outside at the time of inspection were empty.
There is a stormwater draw -down pipe with a valve located at the tote loading/unloading area at the facility. This valve
did not have a locking mechanism at the time of inspection.
The draw -down pipe with the valve leading from the tote storage area must be kept closed and be fitted with a locking
mechanism. This area is functioning like a secondary containment area, which means accumulated stormwater must
be evaluated for contamination before it is released. A log of these releases must be kept along with the information
noted from the evaluations of the stormwater.
Scrap Metal Bin -
There is a scrap metal bin located at the facility which should be covered to exclude stormwater.
Page: 2

Permit: NCS000522 Owner - Facility: US Polymers - US Polymers
Inspection Date: 0412B108 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Industrial OperationslCitV of Charlotte Stormwater Ordinance Review (cont.):
Illicit Discharges -
At the time of inspection two interior sinks and a drinking water fountain were reported to drain to the stormwater
system, in addition, an emergency eyewash was found to discharge outside.
All sinks, wash areas, drinking water fountains, eyewashes, and any other sources of illicit discharges must be brought
into compliance with the NPDES permit and City of Charlotte Stormwater Ordinance.
Page: 3

Permit: NCS000522 Owner -Facility: US Poiymers
Inspection pate: 04/28/2008 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?
■
❑
n
n
# Does the Plan include a General Location (USGS) map?
In
■
o
n
# Does the Plan include a "Narrative Description of Practices"?
■
n
11
❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
❑
■
Q
❑
# Does the Plan inctude 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?
■
n
n
n
# Does the Plan include a BMP summary?
■
❑
❑
❑
#•Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■
❑
Q
❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
■
❑
❑
❑
# Does the facility provide and document Employee Training?
■
❑
Q
❑
# Does the Plan include a list of Responsible Party(s)?
■
n
❑
❑
# Is the Plan reviewed and updated annually?
n
❑
■
❑
# Does the Plan include a Stormwater Facility Inspection Program?
■
❑
❑
❑
Has the Stormwater Pollution Prevention Plan been implemented?
n
■
n
n
Comment: At the time of inspection the permittee presented a draft Stormwater
Pollution Prevention Plan (SPPP). The permittee has a period of 12 months from the
issuance of the permit to complete and implement the SPPP. The draft plan did not
include all of the elements required by the permit. The elements provided were in need
of review and completion. The draft SPPP had not been completed or implemented as
of the site inspection.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? n ■ Cl n
Comment: The permittee is required to perform qualitative monitoring by the permit.
This monitoring must be performed at the frequency required by the permit at the
designated industrial outfalls and does not have a 12-month grace period as the
development of a SPPP.
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? n ■ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? n ❑ ■ n
Page. 4

Permit: NCS000622 Owner - Facility: US Polymers
Inspection Date: 04/28/2008 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Comment: The permittee is required by the permit to perform analytical monitoring.
This monitoring must be performed at the frequency required by the permit at the
designated industrial outfalls and does not have a 12-month grace period as the
development of a SPPP. If the facility falls within the monitoring requirements for
on -site vehicle maintenance (Part li, Section D of the permit) then the permittee must
perform this monitoring at the designated industrial outfalls at the frequency required by
the permit. This monitoring requirement covers all vehicle maintenance performed on
site not just maintenance of on -road or passenger vehicles.
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? ■ Cl ❑ ❑
# 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: The draft Stormwater Pollution Prevention Plan (SPPP) indicated that there
are three designated stormwater outfalls at the site. Facility personnel indicated that
there is one designated outfall at the site. The CMSWS inspectors observed this outfall
and noted no current impacts. This discrepancy regarding the number of industrial
stormwater outfalls at the site must be resolved. The permittee must conduct an
evaluation of illicit discharges as required by the permit.
Page: 5

o•eas�
The Chemical Company
December 20, 2007
RE CMakEIVED
D EC 2 1 2007
Division of Water Quality D-,
Robert B. Krebs, Regional Supervisor
Surface Water Protection
Division of Water Quality
North Carolina Department of Environment and Natural Resources
610 East Center Ave. Suite 301
Mooresville, NC 28115
Subject: BASF Corporation
4330 Chesapeake Drive
Mecklenburg County
Tracking No.: NOV-2007-DV-0312
Dear Mr. Krebs,
This letter serves as BASF Corporation's response to North Carolina Department of
Environmental and Natural Resources Division of Water Quality's (DWQ) November 28,
2007 Notice of . Violation concerning an alleged storm water permit violation at 4330
Chesapeake Drive, Charlotte, NC (Site). BASF has a strong commitment to protecting the
environment and takes seriously any events that could compromise its standing in the
community. However, BASF has no knowledge or information of any evidence that
supports DWQ's allegation.
By way of background, BASF previously carried on manufacturing operations at the Site.
BASF ceased manufacturing operations in 2002 and decommissioned the equipment in
2003. Since that time, BASF has maintained only laboratory and office operations at the
Site as it has sought to sell the property. In October of this year, BASF entered into an
agreement with US Polymers (USP) under which USP agreed to lease the bulk of the Site
for up to 2 years and then purchase it from BASF. While the presence of USP has led to
increased activity at the Site, as of the date of the inspection (October 29, 2007), no
manufacturing activities were being performed at the property. The primary activities
carried out on this date involved removal of old equipment and installation of new
equipment.
On the day of the Site inspection, Andrew Martin and Chris Elmore of the Mecklenburg
County Water Quality Program (MCWQP) were accompanied by personnel from BASF
and USP. While the inspection revealed blue stains in three areas, (on the pavement near
the loading dock and dumpster, on the pavement near the maintenance building, and at
the bottom of a drain near the maintenance building) no evidence was found that links
these stains to an off -site release. The parties then followed the path of the Site storm
drain system that leads to small creek at the end of Pompano Drive. There was no
indication of any blue discoloration observed in the last storm drain on the Site or in the

Rob erVB!Krdbs!Rdgi6na"I_Supervisor
DecOmber-19;, 200T i
Page°,2c z--JJ v?
1..
creek. Moreover, the MCWQP representatives tested the water in the creek and found no
color present,in any of the samples and normal values for conductivity, pH, temperature,
dissolved oxygen. If an off -site release were to have occurred, for which BASF has no
knowledge or information, it would'have been an isolated incident that would not be
expected to reoccur in the future.
As part of a separate initiative, BASF has implemented two (2) measures that are
designed to prevent issues such as that alleged by DWQ from occurring due to any
activities by BASF at the Site
• The Site containment system was upgraded by installing two (2) manual valves to
control the release of water to the storm drain system.
• A catch basin that had previously been used for the sanitary waste water system
was converted to use by the storm water system. This allows storm water to be
collected and water quality monitored before it is released to the storm drain
system.
It should also be mentioned that in addition to these items, US Polymers has significantly
reduced their construction activities. Moreover, BASF Intends to provide training
concerning the importance of environmental protection and this specific issue to all
employees and contractors at the site (US Polymers and BASF Corporation).
BASF trusts this response addresses any issues raised by DWQ's November 28th letter.
If I can be of further assistance, please contact me at the phone number or e-mail address
listed below.
Sincerely,
BASF Corporation
ike Scarp 2(ti
Business Manager
[phone]
[e-mail]
cc: Rusty Rozelle, MCWQP
BASF Corporation
4330 Chesapeake Drive
Charlotte, NC 28216