NCS000084_COMPLIANCE_20100506

�STORMWATER DIVI-S1ON CODING-SH'EET
PERMIT NO.
/lc- SDpo6�
DOC TYPE
❑ FINAL PERMIT
❑ MONITORING INFO
❑ APPLICATION
A COMPLIANCE
❑ OTHER
DOC DATE
❑ D toy bt
YYYYMM DD

V
olmv , iTonnt
Sevedy Eaves Perdue, Govemor
Mr. Jeff W. Grizzle
South Atlantic Services, Inc.
P.O. Box 1886
Wilmington, NC 28402
Dear Mr. Grizzle,
AWA
TX�s /�
NCDENR
Department of Environment and
May 6, 2010
Natural Resources
Subject: NPDES Compliance Inspection
South Atlantic Services Incorporated
NPDES Permit No. NCS000084
New Hanover County
Dee Freeman, Secretary
An inspection of the South Atlantic Services Incorporated facility located on Hwy 421 in Wilmington was conducted on May 3, 2010.
This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in
NPDES Permit No. NCS000084. Please read the enclosed inspection report to address the areas of concern addressed in the
inspection report. Attached is a copy of a Notice of Intent (application form) for securing a NPDES General Permit for the
boiler/cooling tower blowdown discharge from this facility. Should you have any questions or concerns, please do not hesitate to
contact me at 910-796-7343 or at my email address [e-mail].
Sincerely,
Linda Willis
Environmental Engineer I
Division of Water Quality
Surface Water Protection Section
Cc: Wilmington Regional Office — NCS000084 New Hanover (w/att)
DWQ Central Files, Surface Water Protection Section (w/att except NOI)
1601 Mail SeRice Center, Raleigh, North Carolina 27694-1601
Phone: [phone] FAX: 919-7i�-3060) Intemet: w1Aw.ensr.state,.nc.us!ENRI
North Carolina
Natmeally
An Equal O porfunity / Atrimkl` ve Action Ernploy�-r - tiu %, RKydec, Fost Can_ ur Hr Paper

Permit: NCS000084
SOC:
County: New Hanover
Region: Wilmington
Compliance Inspection Report
Effective: 08/01/05 Expiration: 07/31/10 Owner. South Atlantic Services Inc
Effective: Expiration: Facility: South Atlantic Services Incorporated
3527 US Hwy 421
Contact Person: Jeff W Grizzle
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Wilmington NC 2a401
Title: Phone: [phone]
Certification: Phone:
Inspection Date: 05/0312010 Entry Time: 01:00 PM Exit Time: 02:30 PM
Primary Inspector: Linda Willis yyip,Y V f ,1U1» Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas:
M Storm Water
(See attachment summary)
Inspection Type: Compliance Evaluation
Page: 1

Permit: NCS000084 owner - Faclflty: South Atlantic Services Inc
Inspection Date: 05/03/2010 Inspection Type- Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
You should update the SWP3 to include the area to the west of the railroad tracks. The area where the railcars offload
sodium sulfate for bagging and storage should have BMPs and good housekeeping practices implemented immediately to
eliminate as much exposure of spilled/fugitive product as possible. Although this area drains to an infiltration basin, this
material is soluble in water. If it has the potential to enter the groundwater table, it may pose groundwater quafity issues.
There is a cooling tower/boiler blowdown discharge to an outfall located on the north side of the property. Please apply
for a NPDES General Permit for non contact cooling tower/boiler blowdown discharge (NCG500000). A copy of the notice
of intent (application) is attached to this inspection report.
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? ■ ❑ Q ❑
# Were all outfalls observed during the inspection? ■ ❑ ❑
# 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: This permit is up for renewal. It expires July 31, 2010. Central Office staff,
Robert Patterson, made a site visit with RO for permit renewal purposes. Division staff
met with Jeff Grizzle and Walter Kennedy. A site inspection of all processing areas and
outdoor storage areas was conducted. Every outfall from the site was observed. No
evidence of illicit: discharge or unnatural characteristics in the receiving stream were
seen. The area of the plant west of the railroad spur was not on the plans for the
SWP3..This area is newly developed and is a bagging area for sodium sulfate which
comes in by rail. The offloading area has a significant amount of fugitive material on the
ground. This material poses exposure issues for stormwater. The stormwater runoff
from this area travels to a nearby stormdrain to the north and is conveyed to an earthen
Swale (dry pond) where the stormwater is allowed to infiltrate.
Page: 2

INDUSTRIAL STORM WATER INSPECTION FORM
FACILITY: CA 5
COC#:
CONTACT NAME: WR � � �(�nrt�
DATE:
LOCATION ADDRESS:
CONTACT PHONE NUMBER:
CONTACT MAILING ADDRESS:
DIRECTIONS:
COUNTY:
ROUTINE COMPLIANCE IINSPECTION
COMPLAINT INVESTIGATION
RECISSION REQUEST
OTHER -EXPLAIN
INIUMINN
1. Is a copy of the signed and certified SWPPP at the facility?
YES
NO
N/A
COMMENTS
2. Does the facility's SWPPP address the minimum BMP
requirements?
3. Are amendments to the SWPPP clearly documented?
4. Is the current SWPPP corn lete?
I= i
1. Were the vehicle/equipment maintenance areas inspected?
YES
NO
N/A
2. Are vehicle/machinery leaks and drips properly mans ed?
3. Is vehicle/equipment washing done in a designated area so that
wash water can be properly managed?
4. Was the vehicle fueling area inspected?
5. Are vehicle maintenance activities kept indoors?
f
6: Were the vehicle/equipment storage areas inspected?
7. Are current BMPs in vehicle/e ui ment/fuelin areas ade uate?
YES
NO
N/A
1. Are containers for temporary storage of wastes labeled?
/
2. Are waste materials recycled?
3. Are hazardous wastes pi-operly properlyhandled and disposed of?
4. Is processed debris removed re ulaidy?
/
5. Is there secondary containment for liquid wastes?
/
6. Are current waste mana ement BMPs ade uatO
1. Are there appropriate BMPs for outdoor storage of raw
materials, products, and byproducts?
YES
NO
N/A
2. Are containers for chemical substances labeled?
3. Is there secondary containment for I quid storage?
4. Are current BMPs in material storage areas adequate?
Logged by:
Form SWU-265-032502
Inspected by:

IM- = ,-_
YES
NO
NIA
COMMENTS
1. Are there procedures for spill response and cleanup?
/
2. Are appropriate spill containment and cleanup materials kept
on -site and in convenient locations?
3. Are used absorbent materials disposed of in a timely manner?
/
4. Are currents ill BMPs ade uate?
12YES
NO
NIA
1. Are unpaved outdoor areas protected from water/wind erosion?
i
2. Are drainage ditches or the areas around the outfalls free of
erosion?
3- Do im lemented BMPs a ear effective in controllin erosion?
i. Have.all illicit water dischar cs been clirrinated or ermined?
YES
NO
NIA
2. Are BMPs for authorized non -storm water discharges properly
i m lemented?
S. Are current BMPs adequate for management of authorized non -
storm water discharges?
1. Are wastewater treatment facilities properly maintained?
YES
NO
NIA
2. Has monitorin been done?
1- Were there any stream impacts?
YES
NO
NIA
2. Were field parameters taken for pH or DO?
3. Were there any stream standard violations?
4. Were there excessive solids in the stream?
/
5. Were pictures taken?
6. Were samples taken?
0
1. Industry in substantial -compliance.
2. Minor deficiencies noted.
3. Major deficiencies or discharges noted and require prompt correction. Revisit scheduled for
4. Critical deficiencies or discharges noted and require immediate correction. Revisit scheduled for
5. Rescission is appropriate.
6. Rescission is not apnropriate-
Logged by_ Inspected by:
Form 5WU-265-032502

UNITED STATES POSTAL SERVICE f t age 88 Fees Paid
uSPS
Permit No. G10
• 5en r Please print your name, address, and.ZiP+4 in ti is box •
State of North Carotins umP, T
Dept of Fsvisonm�'t &Natural Reno
D2� Cardinal pnve won
y�filmingtnn, NC 7_ o
Attu: Patti O
0
V
Z
Michael F. Easley. Governor
William G. Ross Jr., Secretary
Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
I ce Inspection Report
1{1{l fill A'tili$ill 11t1�1,1:11�5111 JI��� ices Incorporated
} NPDES Permit No. NCS000084
New Hanover County
Dear Mr. Grizzle:
The North Carolina Division of Water Quality conducted a recent inspection of the South Atlantic
Services Inc Wastewater Treatment Facility on February 17, 2005. ' This inspection was conducted
to verify that the facility is operating in compliance with the conditions and limitations specified in
NPDES Permit No. NCS000084.
A summary of the findings and comments noted during this inspection is provided in Section D on
Page 2 of the attached copy of the complete inspection report entitled "Water Compliance Inspection
Report".
If you have any questions concerning this report, please contact me at [phone] Ext. 218 in.
the Wilmington Regional Office.
Sincerely,
Thomas F_ Moore
Environmental Chemist I
Attachments
Cc: �IminO#o`n Regional'Office — Yellow Eile�
f Maureen Crawford (DWQ / NPDES Permit Unit — Raleigh)
127 Cardinal Drive Extension, Wilmington, North Carolina 28405
Phone: [phone] Fax: [phone] Intemei: h2o.enr.state.nc.us
An Equal Opportunity/Affirmative Action Employer — 50% Recycled110% Post Consumer Paper
None
rthCarolina
)Vatmrally

United States Environmental Protection Agency
Form
EPA Washington, D.C. 20450
OMB No. 0057
No. 2040-
ater 1 n 1nS eC !O R
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 U 2 U 31 NCS000084 1 fi 121 05/02/17 1 17
18U 19U 20I �--+
Remarks
211 1 1 1 1 I 1 1 I 1 1 1 1 1 1 1 1 1 1 1 1 I 1 1 1 1 1 1
1 1 1 1 1 1 1 1 1 1 1 1[ I 1161
_I._ .1 _1
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA
--Reserved
671 1 69 70 IJ 71 U 72 I N I
73 W 74 751 1 1 1 1 1 11 80
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
12:30 PM 05/02/17
99/09/17
South Atlantic Services Incorporated
Exit Time/Date
Permit Expiration Date
us Hwy 421
Wilmington NC 28401
03:00 PH 05/02/17
04/05/30
Name(s) of Onsite Representative(s)/TiUes(syPhone and Fax Numbers)
Other Facility Data
Walter Kennedy///
Name, Address of Responsible Officiat/Trtle/Phone and Fax Number
Jeff W Griz2le, PO Box 1886 Wilmington MC 28402//910-763-3496/ Contacted
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Operations a Maintenance E Records/Reports
Pollution Prevention
Facility Site Review Storm Water
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) Inspector(s) AgenWOffice/Phone and Fax Numbers Date
Linda Willis / IGH� WIRO WQ///
/ 1
�IZ f Jo
Tom Moore,,,;�" WIRO WQ///
(4 � a� 10.5"
Signature of Management Q A Reviewer AgencylOffice/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.

Section D: Summary of FindingslComments
(Attach additional sheets of narrative and checklists as necessary)
1. Permit:
Your permit became effective September 17, 1999 and expired on September 30, 2004. The
permit is currently under review for renewal.
The permittee is reminded to read, understand and comply with all of the terms and conditions
contained in the permit. If you have questions concerning your responsibilities, call the
Wilmington Regional Office to speak to a Division of Water Quality staff member.
2. Facility Site Review:
The overall condition of the plant site was satisfactory. The appearance of the facility was in
acceptable condition indicating that the current housekeeping practices are fair_
3. Adequacy of Stormwater Pollution Prevention Plan (WPP ):
The SWPPP is adequate and incorporates the basic minimum requirements, which should be
reviewed and updated at least annually to incorporate changes and/or improvements made to
control storm water runoff from the facility. An annual review sign off sheet should be
maintained with the plan to document the updates made to the plan. Section A.7 of the plan
should be updated to include lire 003 Outfall as specified in the permit
It is recommended that the facility incorporate the SWPPP, Spill Prevention Control &
Countermeasure Plan, and the Emergency Response & Contingency Plan into one
comprehensive document or set of documents since they are incorporated by reference in the
plan.
4. Vehicle/Equipment Maintenance Area:
Not Applicable.
5. Vehicle/Equipment Wash Area:
Not Applicable.
6. Temporary Storage of Waste Materials:
Adequately addressed.
7. Outdoor Stora a of Materials:
Adequately addressed.
8. Spill Response and Cleanup Program:
A considerable amount of material was noticed to have spilled on the ground around some of
the loading areas, particularly the railcar unloading area. The facility should make all
efforts to minimize this spillage and/or clean up such spillage in a timely fashion as storm
drains were noticed inclose proximity to these areas. This spillage can easily be washed into
the storm drain system with the potential to be discharged from the facility.
9. Erosion Control on Site:
Adequately addressed.

10. Illicit Discharge Elimination:
A discharge pipe was found at the northwest corner of the Container Building about 50 yards
from the 002 Outfall. The discharge appeared to be for a roof drain from the building. The
facility should evaluate this discharge and consider incorporating into the existing 002
Outfall, otherwise, it should be identified as a separate outfall in the permit.
11. Wastewater Treatment Facilities:
Wastewater treatment is not required.
12. Stream Impacts/Results of Sampling:
Compliance sampling was not conducted during the inspection.
13. Summary:
A review of the facility indicates appropriate procedures and practices are being utilized for
stormwater management ensuring compliance with the permit. Several items were noted that
the facility should address.
a) Housekeeping could be improved in those areas where spillage during unloading loading
operations occurs regularly. The facility should evaluate regularly where improvements
made_to minimize -or eliminate- spillage -that has_the._potential_to get- into_the_ storm
_,- _
drain system.
b) The SWPPP does not currently incorporate the all information regarding the outfalls
presented in the permit application. This information should be included in the SWPPP
during the next annual update.
The regional office recommends that the stormwater permit be reissued as requested per the
renewal application.
Name and Signature of Inspectors:
Thomas F. Moore
Surface Water Protection Section
Wilmington Regional Office
Linda L. Willis
Surface Water Protection Section
Wilmington Regional Office
y a� os
Date
41.1 j /os
Date

)pV No NA N'
(If the present permit expires in 6 months or less). Has the permittee submitted a new application? M D ❑ ❑
Is the facility as described in the permit? ■ D ❑ ❑
Are there any special conditions for the permit? D ❑ 0 ❑
Is access to the plant site restricted to the general public? M ❑ ❑ ❑
Is the inspector granted access to all areas for inspection? E .❑ ❑ D
Commend: The SWPPP is adequate and incorporates the basic minimum requirements, which should be reviewed and
updated at least annually to incorporate changes and/or improvements made to control storm water runoff from the
facility. An annual review sign of sheet should be maintained with the plan to document the updates made to the plan.
Section A.7 of the plan should be updated to include the 003 Outfall as specified in the permit, It is recommended that
the facility incorporate the SWPPP, Spill Prevention Control & Countermeasure Plan, and the Emergency Response &
Contingency Plan into one comprehensive document or set of documents since they are incorporated by reference in the
plan.
Operations & Maintenance Yes No NA fE
Does the plant have general safety structures in place such as rails around or covers over tanks, pits, or wells? MOOD
is the plant generally dean with acceptable housekeeping? ■ ❑ ❑ ❑
Comment: A considerable amount of material was noticed to have spilled on the ground around some of the loading
areas, particularty the railcar unloading area. The facility should make all efforts to minimize this spillage and/or dean up
such spillage in a timety fashion as storm drains were noticed in dose proximity to these areas.
A discharge pipe was found at the northwest comer of the Container Building about 50 yards from the 002 Outfall. The
discharge appeared to be for a roof drain from the building. The facility should evaluate this discharge and consider
incorporating into the existing 002 Outfall, otherwise, it should be identified as a separate outfall in the permit.

Re: [Fwd: Re: S. Atlantic Services - NCS0000841
Subject: Re: [Fwd: Re: S. Atlantic Services - NCS000084]
From: Tom Moore <[e-mail]>
Date: Mon, 02 May 2005 14:30:41 -0400
To: Bethany Georgoulias �[e-mail]>
Hi Bethany,
I just completed my inspection report a couple of weeks ago. There were not any
major issues other than some better housekeeping. There was one roof drain that
discharged from a separate pipe that was not in the application or permit.
I will forward a copy to you and I will call you this afternoon to discuss.
Thanks,
Tom
Bethany Georgoulias wrote:
j Hi, Tom (or maybe Linda),
I checked with Ed about this renewal back in February, and I just wanted to check
the status of it since we still haven't received the staff report. (I talked with
Linda about Wright Corp. a while ago, so I'm guessing you're the one who's working
on this one.) Are there any outstanding issues for this site that we need to
address in the next permit?
If you've been swamped and just haven't had a chance to send it on, don't feel
badly; I'm still a ways off from drafting up Wright's permit! I just wanted to
make sure the report didn't get lost.
Thanks,
Bethany G.
--------- Original Message --------
Subject: Re: S. Atlantic Services - NCS000084
Date: Mon, 14 Feb 2005 09:49:42 -0500
From: Ed Beck <[e-mail]>
To: Bethany Georgoulias<[e-mail]>
References: <[e-mail]>
Bethany
I finally had to admit to myself that, with the additional responsibilities, I
needed to assign some projects to others. Linda Willis and Tom Moore will be
visiting SAS and Wright Corp and preparing recommendations for the renewal of the
permits. That should be done in the next few days. Since there were some messy
areas at SAS in the past, I am uneasy giving a sign off without a visit. Please
let me know if that schedule will meet your needs.
Ed Beck
Bethany Georgoulias wrote:
Hi Ed,
I'm sure things are busy as ever down your way with the transition from Rick
Shriver! I just wanted to check on the status of a staff report request I'd
sent back in December, since I had it scheduled to go to notice next week. The
facility is South Atlantic Services there in Wilmington, NCS000084. It's a
stormwa ter permit renewal that doesn't have any analytical monitoring
requirements. Do you know the status of that staff report, or could you let me
know who the reviewer is? Since there's no monitoring, I hate to hold it up
too much longer unless there are outstanding issues with the facility, or other
1 of 2 5/2/2005 2:47 PM

Re: [Fwd: Re: S. Atlantic Services - NCS000084]
Iissues the region feels need addressing. Thanks so much! I
Tom Moore <tom.LmooreL ncmaiLnet> j
j Environmental Chemist I
Surface Water Protection Section
i
j Wilmington Regional Office
l
2 of 2 502005 2:47 PM

Subject: Site Visit to South Atlantic Services
This facility is a specialty chemical blending and distribution operation.
Tony Evans in the central office and Ed Beck in the Wilmington regional office met with
Walter Kennedy and Jeff Grizzle South Atlantic Services on 613J99 and toured the plant
site.
Sometime during the c permit term this facility had a exposure of the dye they use
to color their antifreeze. The purpose of this site visit was to reassess the potential of
exposure of their industrial activity to stormwater.
The plant has unusually sandy soils that are well drained. The majority of the stormwater
that is collected onsite drains to a kind of retention area where it infiltrates into the
ground. The blending operation for blending a buffer solution with hydroxide, and an
ammonium chloride has potential to contaminate stormwater but since this drains to the
retention area there is little potential for these chemicals to leave the site. The bulk
loading of sodium sulfate (solid) produced a lot of waste sodium sulfate that is exposed to
stormwater. The bulk of the sodium sulfate is swept -up by the truck driver but there is
plenty of residue left to runoff in stormwater. The drainage area containing the sodium
sulfate residue produces a good amount of flow as evidence of the erosion at the end of
the rip -rap lined outlet to the pipe that drains this area. However, South Atlantic Services
property extends beyond the outlet of this pipe. Given the high permeability of the soils,
Mr. Kennedy and Mr. Grizzle said the stormwater never made it offsite.
This facility also use to transfer bulk hydrochloric acid from tank cars. The market for
this operation died so it was discontinued. This operation did not provide secondary
containment for the tank cars during this unloading. It is recommended that if this
operation or a if a similar operation were to begin, -previde-a�s.e€-secondary
containment for the bulk liquid being transferred.
AA& L.4- ?'Wd64