NCG030156_CEI with cover letter_20190401

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Interim Director
Scotland Manufacturing Co., Inc.
Attn: Wayne Cain, General Manager
PO Box 1067
Laurinburg, NC 28352
NORTH CAROLINA
Environmental Quality
April 1, 2019
Subject: COMPLIANCE EVALUATION INSPECTION
NPDES General Permit NCG030000
Scotland Manufacturing Co., Inc.
Certificate of Coverage NCG030156
Scotland County
Dear Mr. Cain:
On March 26, 2019, a site inspection was conducted for the Scotland Manufacturing Co., Inc. facility located at 22261
Skyway Church Road, Maxton, Scotland County, North Carolina. A copy of the Compliance Inspection Report is enclosed
for your review. Mr. Matt Jones, Project Engineer, was also present during the inspection and his time and assistance is
greatly appreciated. The site visit and file review revealed that the subject facility is covered by NPDES General Permit
NCG030000 under Certificate of Coverage NCG030156. Permit coverage authorizes the discharge of stormwater from
the facility to receiving waters designated as Shoe Heel Creek (Big Shoe Heel Creek)(Maxton Pond), a Class C;Sw
waterbody in the Lumber River Basin.
As a result of the inspection, the facility was found to be in compliance with the conditions of the NCG030000 permit.
Please refer to the enclosed Compliance Inspection Report for additional comments and observations made during the
inspection.
Please be advised that violations of the NPDES General Permit are subject to a civil penalty assessment of up to
$25,000 per day for each violation. If you or your staff have any questions, comments, or needs assistance with
understanding any aspect of your permit, please contact me at [phone] or by e-mail at [e-mail].
Sincerely,
Michael Lawyer, CPSWQ
Environmental Program Consultant
DEMLR
Enclosure
ec: Matt Jones, Project Engineer — Scotland Manufacturing Co., Inc.
cc: FRO.— DEMLR, Stormwater Files-NCG030156
North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
tJoar�t cnaouwn a
Fayetteville Regional Office 1 225 Green Street, Suite 7141 Fayetteville, North Carolina 28301
Department of FnWronmental Uuallly 910.433.3300

Permit: NCG030156
SOC:
County: Scotland
Region: Fayetteville
Contact Person: Matt Jones
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
On -site representative
Related Permits:
Compliance Inspection Report
Effective: 11/01/18 Expiration: 05/31/21 Owner: Scotland Manufacturing Co Inc
Effective:. Expiration: Facility: Scotland Manufacturing Co Inc
22261 Skyway Church Rd
Maxton NC 28364
Title: Project Engineer Phone: [phone] Ext.7014
Inspection Date: 03/26/2019 EntryTime: - 10G
Primary Inspector: Mike Lawyer
Secondary Inspector(s):
Certification: Phone:
Matt Jones 910-844-3956 ext 701,
Exit Time: 12:10PM
Phone: [phone] Ext729'
33?,(
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Metal Fabrication Stormwater Discharge COC
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Storm water
(See attachment summary)
Page 1 of 3

Permit: NCG030156 Owner -Facility: Scotland Manufacturing Co Inc
Inspection Date: 03/26/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Met with Matt Jones, Project Engineer. Reviewed the facility's Stormwater Pollution Prevention Plan (SPPP) and monitoring
records associated with the current NCG030000 permit, which was recently reissued with an effective date of November 1,
2018 and an expiration date of May 31, 2021. The SPPP appears to contain all permit -required components and has been
updated with current facility personnel. Continued documentation of all associated documents such as semi-annual facility
inspections, housekeeping procedures and annual review/updates pertaining to spills, employee training, non-stormwater
certification, etc. was discussed. Monitoring records indicate that a stormwater discharge sampling event was conducted for
outfall 2 around mid -March of 2019 and showed no exceedances of benchmark values, however copper and zinc were not
tested. A stormwater discharge will need to be collected for copper and zinc testing before the end of June 2019 and
included with the other discharge characteristics listed in the NCG030000 permit for subsequent monitoring periods.
Qualitative monitoring was also conducted and recorded for outfall 2. Previous inspection reports stated that outfall 1 only
receives stormwater runoff from the employee parking lot and a portion of the facility's roof. While making observations of site
conditions, a significant amount of metal racks, empty totes and large dumpsters with cardboard and other debris was
observed stored outside in areas where stormwater runoff could potentially drain to outfall 1. Although not discussed during
the site inspection, it is recommended that an application for Representative Outfall Status be submitted to the Fayetteville
Regional Office for review and approval, which would allow for and better document the continued monitoring of outfall 2 only.
As noted in previous inspection reports, dumpsters used for disposal of scrap metal pieces that have a liquid residue along
with some totes, drums and other tanks are maintained inside a diked pad that has trench drains leading to an oil water
separator and lift station to the POTW.
Page 2 of 3

Permit: NCG030156 Owner- Facility: Scotland Manufacturing Co Inc
Inspection Date: 03/26/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan?
E ❑ ❑ ❑
# Does the Plan include a General Location (USGS) map?
❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
❑ ❑ ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
N ❑ ❑ ❑
# Does the Plan include 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?
❑ ❑ ❑
# Does the Plan include a BMP summary?
0 ❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
0 ❑ ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
0 ❑ ❑ ❑
# Does the facility provide and document Employee Training?
❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
❑ ❑ ❑
# Is the Plan reviewed and updated annually?
❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
0 ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
0 ❑ ❑ ❑
Comment
Qualitative Monitoring
Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? 0 ❑ ❑ ❑
Comment: See Inspection Summary for details.
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? 0 ❑ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ 0 ❑
Comment: See Inspection Summary for details.
Permit and Outfalls
Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? N ❑ ❑ ❑
# Were all outfalls observed during the inspection? ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ❑ ❑ ❑
Comment:
Page 3 of 3