NCS000527_Inspection Report_20190606

ROY COOPER
Governor
MICHAEL S. REGAN
Secretory
S. DANIEL SMITH
Interim Director
NORTH CAROLINA
Environmental Quality
June 6, 2019
IPS Structural Adhesives, Inc.
Attn. Kevin Connolly
Vice President of Operations
600 Ellis Road
Durham, NC 27703
Subject: Compliance Inspection
Permit No. NCS000527
IPS structural Adhesives, Inc.
Durham County
Dear Mr. Connolly:
On May 16, 2019, Alaina Morman and Lauren Garcia, inspectors with the North
Carolina Department of Environmental Quality (NCDEQ) - Division of Energy, Mineral and
Land Resources (DEMLR), met with Kevin Connolly, Vice President of Operations, at the
facility located at 600 Ellis Road, in Durham County, to conduct a compliance inspection.
The inspection consisted of reviewing: the Stormwater Pollution Prevention Plan (SWPPP)
and each of its components, the facility's outfalls, and the overall site conditions. The
inspection was conducted to ensure stormwater best management practices are being
followed, and to help fulfill NCDEQ's goal of inspecting all permitted facilities during each
permit period.
Permit:
This facility has Individual Stormwater Permit NCS000527 to discharge stormwater from
the industrial activity of manufacturing miscellaneous chemical products - adhesives and
sealants [SIC 2891] under the National Pollutant. Discharge Elimination System (NPDES).
The permit was originally issued on May 29, 2009, became effective on June 1, 2009, and
expired on May 31, 2014.
Records/Reports:
The facility is required to develop and maintain a SWPPP in accordance with Part II, Section
A of the permit. All qualitative and analytical monitoring records are required to be
maintained with the SWPPP for a minimum of five years.
• The facility provided all necessary records.
North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
Sit North Salisbury Street i 1012 Mail Service Center i Raleigh, North Carolina 27699-1612
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The facility is required to review and update the SWPPP on an annual basis in accordance
with Part II, Section A, Item, of the permit.
• The facility appeared to update the SWPPP on an annual basis. Inspectors
recommended that the SWPPP be updated with the current contact information.
• Overall, the SWPPP was well put together and record keeping was very organized
and ready for NCDEQ to review.
Facility Site Review:
The facility blends and mixes chemical constituents used to manufacture adhesives for
industrial customers. Packaging, warehousing, and distribution of adhesive products and
blended catalysts are also part of the facility's operations.
There is only one building present at the site. All facility operations take place inside the
building, except for the outside storage of pallets, drums, and totes. The outside storage
area is located at the southern exterior of the property structure and is paved. Some
equipment is also located in the same area. The remainder of the property not improved
with the building is developed with parking lots and a large grass field, that occupies most
of the southern half of the site. An AST is located near the southernmost border of the site,
in the grass field. Product is pumped from the AST into the building.
• All materials, machinery, and tanks were stored/located within proper secondary
containment.
• The site appeared to be very well maintained.
There is one sampled outfall present at the facility, located in the southwestern corner of
the site. This outfall collects the stormwater from the paved storage area and grass field. A
storm drain located in Ellis Road collects water from beyond the borders of the facility and
drains to the same outfall. This water is not considered the responsibility of IPS Structural
Adhesives.
Receiving Waters:
Stormwater at the site discharges to Third Fork Creek, a class WS-V; NSW stream in the
Cape Fear River Basin. Third Fork Creek is an impaired waters experiencing problems with
benthos, toluene, selenium, arsenic, dissolved oxygen, dieldrin, turbidity, PCB, cadmium,
chlorinated benzenes, cadmium dissolved chronic, methoxychlor, nickel, aldrin, lead
dissolved chronic, water temperature, mirex, beryllium, parathion, cyanide, DDT 4,4, pH,
demeton, silver dissolved chronic, total suspended solids, lindane, chromium dissolved
chronic, endosulfan, hardness, iron, chlorinated phenols, carbon tetrachloride, selenium
dissolved chronic, toxaphene, heptachlor, copper dissolved chronic, chloride,
tetrachl oro ethylene, phenols, zinc dissolved chronic, chromium, lead, fluoride, nickel
dissolved chronic, chlordane, benzene, sulfate, PAHs, beryllium dissolved chronic, endrin,
tri chl oro ethylene, manganese, tetrachloroethane, vinyl chloride, mercury,
hexachlorobutadiene, arsenic dissolved chronic, and selenium.
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Additionally, Third Fork Creek discharges into waters upstream of the Upper New Hope
Arm of the Jordan Reservoir, experiencing problems with nutrients and chlorophyll a
violations (indicative of excess nutrient loads). A Total Maximum Daily Load (TMDL) for
total suspended solids (TSS) was approved in January 2005 to address turbidity
impairment of a segment of Third Fork Creek further downstream.
Self -Monitoring Program:
The facility is required to provide qualitative and analytical monitoring data twice
annually.
• The facility has monitored twice annually in accordance with the permit.
The facility has not experienced a benchmark exceedance since at least 2014.
Previous benchmark exceedances appear to have been addressed in accordance
with the permit.
The facility is considered to be in compliance. The facility provided all necessary records
and has upheld the conditions of the stbrmwater permit. The only corrective action is to
update the SWPPP with the current contact information. If you have any questions or need
additional information, please contact Lauren Garcia at [phone] or
[e-mail].
Sincerely,
q� A�vl�t�
La en Garcia
Environmental Specialist II
Stormwater Program
Division of Energy, Mineral, and Land Resources
North Carolina Department of Environmental
Quality
Enclosures: Inspection Report
cc: Kevin Connolly, kevin.connolly scigrip.com
Thad Valentine, DEMLR Raleigh Regional Office, [e-mail]
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Compliance Inspection Report
Permit: NCS000527 Effective: 06/01/09 Expiration: 05/31/14 Owner: Ips Structural Adhesives Inc
SOC: Effective: Expiration: Facility: IPS Structural Adhesives
County: Durham 600 Ellis Rd
Region: Raleigh
Durham NC 27703
Contact Person: Matt Elshenawy Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 05/16/2019
Primary Inspector: Alaina Morman
Secondary Inspector(s):
EntryTime: 10:OOAM
Lauren Garcia
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Certification: Phone:
Exit Time: 11:30AM
Phone: [phone]
Inspection Type: Compliance Evaluation
Page 1 of 3

Permit: NCS000527 Owner - Facility: Ips Structural Adhesives Inc
Inspection Date: 05/16/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On May 16, 2019, Alaina Morman and Lauren Garcia, inspectors with the North Carolina Department of Environmental
Quality (NCDEQ) — Division of Energy Minerals, and Land Resources (DEMLR), met with site contact, Kevin Connolly, at the
facility located at 600 Ellis Road, in Durham County, to conduct a compliance inspection per the authority of NCDEQ.
Permit:
The facility is required to develop and maintain a SWPPP in accordance with Part II, Section A of the permit. All qualitative
and analytical monitoring records are required to be maintained with the SWPPP for a minimum of five years. Under this
permit, analytical monitoring is required under the current operating procedures.
- The facility provided all necessary records.
Thee facility is required to review and update the SWPPP on an annual basis in accordance with Part II, Section A, Item, of
the permit.
- The facility appeared to update the SWPPP on an annual basis. Inspectors recommended that the SWPPP be updated
with the current contact information.
- Overall, the SWPPP was well put together and record keeping was very organized and ready for NCDEQ to review.
Facility Site Review:
The facility blends and mixes chemical constituents used to manufacture adhesives for industrial customers. Packaging,
warehousing, and distribution of adhesive products and blended catalysts are also part of the facility's operations.
There is only one building present at the site. All facility operations take place inside the building, except for the outside
storage of pallets, drums, and totes. The outside storage area is located at the southern exterior of the property structure
and is paved. Some equipment is also located in the same area. The remainder of the property not improved with the
building is developed with parking lots and a large grass field, that occupies most of the southern half of the site. An AST is
located near the southernmost border of the site, in the grass field. Product is pumped from the AST into the building.
- All materials, machinery, and tanks were stored/located within proper secondary containment.
- The site appeared to be very well maintained.
There is one sampled outfall present at the facility, located in the southwestern corner of the site. This outfall collects the
stormwater from the paved storage area and grass field. A storm drain located in Ellis Road collects water from beyond the
borders of the facility and drains to the same outfall. This water is not considered the responsibility of IPS Structural
Adhesives.
Receiving Waters:
Stormwater at the site discharges to Third Fork Creek, a class WS-V; NSW stream in the Cape Fear River Basin. Third Fork
Creek is an impaired waters experiencing problems with benthos, toluene, selenium, arsenic, dissolved oxygen, dieldrin,
turbidity, PCB, cadmium, chlorinated benzenes, cadmium dissolved chronic, methoxychlor, nickel, aldrin, lead dissolved
chronic, water temperature, mirex, beryllium, parathion, cyanide, DDT 4,4, pH, demeton, silver dissolved chronic, total
suspended solids, lindane, chromium dissolved chronic, endosulfan, hardness, iron, chlorinated phenols, carbon
tetrachloride, selenium dissolved chronic, toxaphene, heptachlor, copper dissolved chronic, chloride, tetrachloroethylene,
phenols, zinc dissolved chronic, chromium, lead, fluoride, nickel dissolved chronic, chlordane, benzene, sulfate, PAHs,
beryllium dissolved chronic, endrin, trichloroethylene, manganese, tetrachloroethane, vinyl chloride, mercury,
hexachlorobutadiene, arsenic dissolved chronic, and selenium.
Additionally, Third Fork Creek discharges into waters upstream of the Upper New Hope Arm of the Jordan Reservoir,
experiencing problems with nutrients and chlorophyll a violations (indicative of excess nutrient loads). A Total Maximum
Daily Load (TMDL) for total suspended solids (TSS) was approved in January 2005 to address turbidity impairment of a
segment of Third Fork Creek further downstream.
Self -Monitoring Program:
The facility is required to provide qualitative and analytical monitoring data twice annually.
- The facility has monitored twice annually in accordance with the permit.
- The facility has not experienced a benchmark exceedance since at least 2014. Previous benchmark exceedances appear
to have been addressed in accordance with the permit.
Page 2 of 3

Permit: NCS000527 Owner - Facility: Ips Structural Adhesives Inc
Inspection Date: 05/16/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Page 3 of 3