NCG090019_NOV Response_20190426

RPM Wood Finishes Group WdoD
FAisims
Post Office Box 22000 Hickory, NC 28603-0220 828.261.0325 FAX [phone] croup
Apri126, 2019
NC Department of Environmental Quality
Division of Energy, Mineral and Land Resources
Attn: Stanley E. Aiken, Regional Engineer, Land Quality Section
Subject: Response to Notice of Violation (NOV-2019-PC-0227)
NPDES Stormwater General Permit NCG090000
RPM Wood Finishes Group, Inc. Certificate of Coverage NCG090019
Caldwell County, NC
Dear Sir:
During our recent compliance evaluation inspection (March 21, 2019) we were notified that we were not in
compliance due to secondary containment not being provided where bulk liquid materials are stored. It was also
noted on the NOV that we were informed on the previous inspection report (March 12, 2018) that the current
storage practices were not in compliance with the General Permit.
At the time of the previous inspection Dr. Dauid Phillips was our EHS Director, howevsrhe was not present for
the inspection. That previous inspection report shows our facility status as compliant with a note stating "(t)he
facility is directed to provide secondary containment where applicable according to the general permit." It was
the understanding of Abbey Duggan, who accompanied Mr. Reed on the 2018 inspection, that we were not
required to provide secondary containment for empty, closed totes which we store and reuse.
We
are submitting a capital
request for construction of a covered area for storage of those used,
empty totes.
Our
fiscal year begins June
ls`, therefore funding for that project will not be available until then
at the earliest.
We
are also working with our
risk engineering consultant to determine the best location for said
covered area.
We did have several drums of a raw material in the parking lot during this year's inspection. We are in the
process of installing an above ground storage tank inside our diked tank farm to house this raw material. This
project should be completed by the end of July 2019.
If you have any questions or recommendations on our plans for resolving this issue we welcome your feedback.
Since
Aaron Berwick
Environmental, Health and Safety Manager
RPM Wood Finishes Group, Inc.