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HomeMy WebLinkAboutNCG090006_COMPLETE FILE - HISTORICAL_20170817STORMWATER DIVISION CODING SHEET NCG PERMITS PERMIT NO. /V C.,& o G o 'oa10 DOC TYPE IZ- HISTORICAL FILE ❑ MONITORING REPORTS DOC DATE ❑ 40 17 0 � ! % YYYYMMDD AWMA, NCDENR Division of Energy, Mineral and Land Resources Land Quality Section / Stormwater Permitting Program National Pollutant Discharge Elimination System (NPDES) PERMIT OWNER AFFILIATION DESIGNATION FORM (Individual Legally Responsible for Permit) FOR AGENCY USE ONLY Date Received Year MT-tb Day if NO CHANGE in company or facility ownership or name has occurred. If a Name Change and/or Ownership Transfer at the facility has prompted this change, do NOT use this form. You must fill out the Name -Ownership Change Form and provide all necessary supporting documentation instead. 1) Enter the permit number for which this change in Legally Responsible Individual ("Owner Affiliation") applies: Individual Permit N c S 2) Facility Information: Facility name: Company/Owner Organization: Facility address: (or) Certificate of Coverage INICIG101qL010 10 161 MA!1arj^ eretIc PoIywltrS Soo N! ore- kea A Address C6r loot NC 2 $a/ 2 City State Zip To find the current legally responsible person associated with your permit, go to this website: http://portal.ncdenr.org/web/Ir/sw-permit-contacts and run the Permit Contact Summary Report. 3) OLD OWNER AFFILIATION that should be removed: Previous legally responsible individual: First ti k Sa M A rki h C First M1 Last 4) NEW OWNER AFFILIATION (Legally responsible for the permit): Person legally responsible for this permit: RECEIVED AUG 14 201 S('o+ irst WPIjc. Last r- I u t rvi A In f Title 2. $00 M o re- htad R_� Mailing Address G%ar l o+4c AI G 0 e.2 4 � City State Zip DENR-LAND QUALITY 0) 54 7 n 6 ZZ w k ,r►c o f imerS. cam STORMWATER PERMITTING Telephone E-mail Address Fax Number Page I of 2 SW U-OW NERAFFII_-22May2o14 NPDESStormwater Permit OWNER AFFILATION DESIGNATION Form (if no Facility Name/Ownership Change) 5) Reason for this change: lEf Employee or management change A result of: ❑ Inappropriate or incorrect designation before Other If other please explain: Road t7_ Qme • was z_,A Q h QL !j . What does "legally responsible person' mean? That person is either: • the responsible corporate officer (for a corporation); • the principle executive officer or ranking elected official (for a municipality, State, Federal, or other public agency); • the general partner or proprietor (for a partnership or sole proprietorship); • or the duly authorized representative of that person above. The certification below must be completed and signed by the permit holder. PERMITTEE CERTIFICATION: I, _ , attest that this application for this change in Owner Affiliation (person legally responsible fol the permit) has been reviewed and is accurate and complete to the best of my knowledge. I understand that if all required parts of this form are not completed, this change may not be processed. $-11-)-7 Signature PLEASE SEND THE COMPLETED FORM TO: Division of Energy, Mineral and Land Resources Stormwater Permitting Program 1612 Mail Service Center Raleigh, North Carolina 27699-1612 Date For more information or staff contacts, please visit our website: htip://12ortal.ncdenr.org/web/Irlstorrnwater Page 2 of 2 5W tJ-OW NERAFFI L-22May2o 14 �A NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Governor Frank Samartino Mallard Creek Polymers Inc 14800 Mallard Creek Rd Charlotte, NC 28262 Dear Permittee: Charles Wakild, P. E. Director December 4, 2012 Dee Freeman Secretary Subject: NPDES Stormwater Permit Coverage Renewal Mallard Creek Polymers Incorporated COC Number NCG090006 Mecklenburg County In response to your renewal application for continued coverage under stormwater General Permit NCG090000 the Division of Water Quality (DWQ) is forwarding herewith the reissued General Permit. This permit is reissued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between the state of North Carolina and the U.S. Environmental Protection Agency, dated October 15, 2007 (or as subsequently amended). The following information is included with your permit package: • A new Certificate of Coverage (COC) • A copy of General Permit NCG090000 • A copy of the Technical Bulletin for the General Permit • Two copies of the Discharge Monitoring Report (DMR) Form • Two copies of the Qualitative Monitoring Report Form The General Permit authorizes discharges of stormwater, and it specifies your obligations for discharge controls, management, monitoring, and record keeping. Please review the new permit to familiarize yourself with all the changes in the reissued permit. Your facility has six (6) months from the time of receipt of the permit to update your current SPPP to reflect all new permit requirements. The first sample period of your permit begins January 1, 2023. Your facility must sample a "measureable storm event" beginning during the periods beginning January 1 and July 1 of every year (or, if applicable, report "No Flow," as outlined in Part III, Section E). Also, please note that Tier 3 Actions in Part II of your permit are triggered by benchmark exceedances on four occasions beginning on the effective date of this permit and do not count prior exceedances. The more significant changes in the General Permit since your last COC was issued are noted either in the Draft Permit Fact Sheet that accompanied the public notice (http://Portal.ncdenr.org/web/wq/ws/su/current- notices), or in the Response to Comments / Summary of Changes and Technical Bulletin documents that are posted on the Stormwater Permitting Unit's website with the new General Permit. Please visit http://portal.ncdenr.org/web/wcl/ws/su/npdessw (click on 'General Permits' tab) to review that information for your specific General Permit carefully. 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbury St. Ralegh, North Caraiina 27604 Phone: 91 M07-630:. t FAX: 919-807-6492 Internet: www.nrwa.er ual' .org An Anal Opportunity °, Amin, native r.-6on Employer O NrthCarolina ;Vaturd ly Frank Samartino December 4, 2012 Page 2 of 2 Some of the changes include: Part II: • Section A: The Stormwater Pollution Prevention Plan (SPPP) section, if applicable, has been updated to the most current language of our permits. Additional conditions for specific industry sectors have been added to the SPPP ragilirements in some cases. • Sections 0, C. Failure to perform analytical stormwater monitoring may result in the division requiring that the permittee begin a monthly sampling scheme. • Sections B, C: A iowei TSS benchmark of 50 rng/i for HQW, URW, PNA and Tr Waters applies to these more sensitive waters. • Sections B, C: The monitoring parameter Oil & Grease (O&G) has been replaced by the parameter Total Petroleum Hydrocarbons (TPH) for vehicle maintenance areas, and In some cases, other analytical monitoring requirements. • Sections B, C, D: Inability to sample due to adverse weather must be recorded in the SPPP, or in separate on -site records if your General Permit does not require an SPPP. Adverse -weather Is defined in the "Definitions" section of the permit. • Sections B, C: The term "Representative Storm Event" has been replaced by "Measurable Storm Event." A measurable storm event is defined in the permit. • Section D: If the permittee fails to respond effectively to problems identified by qualitative monitoring, DWQ may require the permittee to perform corrective action. Please review Parts III and IV to understand the Standard Conditions of your new NPDES General Permit, including Compliance and Liability, Reporting, Monitoring and Records requirements; Operation and Maintenance obligations; and Definitions. Please note that all samples analyzed in accordance with the terms of this permit must be submitted to the Division on Discharge Monitoring Report (DMR) forms available on the Stormwater Permitting Unit's website above. DMR forms must be delivered to the Division no later than 30 days from the date the facility receives the sampling results from the laboratory. Also note that existing permittees do not need to submit a renewal request prior to expiration unless directed by the Division. Your coverage under the General Permit is transferable only through the specific action of DWQ. This permit does not affect the legal requirements to obtain other permits which may be required by DENR, nor does it relieve the permittee from responsibility for compliance with any other applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or decree. If you have any questions regarding this permit package, please contact the Division's Stormwater Permitting Unit at (919) 807-6300. Sincerely, b Le e for Charles Wakild, P.E. cc: DWQ Central Files Stormwater Permitting Unit Files Mooresville Regional Office M STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY GENERAL PERMIT NO. NCGO90000 CERTIFICATE OF COVERAGE No. NCG090006 STORMWATER NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance. with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Mallard Creek Polymers Inc is hereby authorized to discharge stormwater from a facility located at: Mallard Creek Polymers Incorporated 14800 Mallard Creek Rd Charlotte Mecklenburg County to receiving waters designated as Mallard Creek, a class C waterbody in the Yadkin River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, 111, and IV of General Permit No. NCG090000 as attached. This certificate of coverage shall become effective December 4, 2012. This Certificate of Coverage shall remain in effect for the duration of the General Permit. Signed this 41h day of December, 2012. for Charles Wakild, P.E., Director Division of Water Quality By Authority of the Environmental Management Commission Compliance Inspection Report Permit NCG090OD6 Effective: 11 /01112 Expiration: I O 31117 Owner: Mallard Creek Polymers Inc SOC: Effective: Expiration: Facility: Mallard Creek Polymers Incorporated County: Mecklenburg 148DO Mallard Creek Rd Region: Mooresville Charlotte NC 28262 ContactPerson: AJlan Oration Tifie: Phone: 704-547-W22 Ext.1009 Directions to Facility: System Classifications: Prtmary ORC: Secondary ORC(sy On -Site Representative(s): Retated Pemttta: Inspection Date: 12/14/2015 Entry Time: 10:OOAM Primary Inspector. Water Quality Program Meckenburg County Secondary Inspeetor(s): Certification: Phone: Exit Time: 12:20PM Phone: 704-336-5449 Zahid S Khan Phone: Reason for Inspection: Routine Inspection Type: Compliance Evaluation Pemdt Inspection Type: Paints, Varnishes, Lacquers Stomiwater Discharge COC Facility Status: Compliant Not Compliant Question Areas: ■ Storm Water (See attachment summary) Page: 1 peenit NCG090006 Owner - Facittty: Mallard Creek Polymers Inc tnspectton Date: 12114/2015 h apection Type: Compliance Evaluation Reason for VbM Routine Inspection Summary: Mallard Creels Polymers is located at 2800 Morehead road. The facility operates on approximately 50.50 acres of land. the business produces latex polymer products. This facility was observed to be in compliance with the City of Charlotte Storm Water Pollution Control Ordinance. However, secondary containment of the facility's storage area is not adequate. Several pallets of 275-gallon totes of various chemicals are often placed in the storage area until shipped out the stored chemicals exceed the 1320-gallon capacity which requires secondary containment. Charlotte MecklenburgStorm Water Services (CMSWS) instructed facility personnel to contact NCDEQ conceming the secondary containment. Page: 2 pemft NCGO90000 tnspection Dale: 12114J2015 Ownw - Fmffity: Mallard Creek Polymers Inc Type: Cornp6ance Evaluation Reason for visit: Roubrne Ana cal Monitoring Yes No NA HE Has the facility conducted its Analytical monitoring? ❑ ❑ ❑ # Has the facility conducted its Analytical monitoring from Vehicle Maintenancee areas? ❑ ❑ ❑ Comment: Monitoring was conducted January 7, 2015, April 15, 2015, and November 24 2015. Cadmium tested at 0.002mg/L, meeting lab limits: however, the permit limit is 0.001 mg/L_ CMSWS recommends r�wof testing procedures meet permit requirements. Permit and Outfalls # Is a copy of the Permit and the Certificate of Coverage available at the site? # 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: The TPH benchmark of 15mg/L was exceeded on April 7, 2014 with a value of 16mgIL. No stormwater pollution issues were observed at the outfal Is. Yea No NA NE ■❑❑❑ ■❑❑❑ E ❑ ❑ ❑ ❑ ❑ ❑ ❑ Qualitative Monitories Yes No NA WE Has the facility conducted its Qualitative Monitoring semi-annuafly? 0 [] ❑ ❑ Comment: Qualitative monitoring was conducted at the facility: December 24, 2014. March 30, 2015. and October 27 2015 Stormwat:er Pollution Prevention Plan 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 altematives to current practices? # Does the facility provide all necessary secondary containment? # Does the Plan include a BMP 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? Yes No NA NE ■❑❑❑ ❑ ❑ ❑ E ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ M ❑ ❑ ❑ ❑ ❑ ❑❑❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Page: 3 Permit NCGO90006 owner- FacEsty: MaOard Creek Polymers Inc Inspection Date: 121142015 b=p Type: Compliance Evakktm Reum fur Visit Roubne Stormwater Pollution Prevention Plan Yes No NA NE # Does the Plan include a Stormwater Facility Inspection Program? Has the Stormwater Pollution Prevention Plan been implemented? [� Comment: facility documented spills at the facility February 22, 2012, march 1. 2012. and April 7. 2014. Each spill was contained on site. CMSWS recommends that the facility records the ouof spills. CMSWS recommens that the facility NCDEQ concemina secondary containment of facility storage area. 275-gallon totes of chemicals are stored shipment. Adequate containment of totes is not in Mace. Storm water located inside containment areas is evaluated and released into a nearby sump and into the facility's industrial pond. Employee training is conducted at the fad lity annually. November 15, 2015 was the last training_ date. Responsible parties at the facility were updated December 3 2015. Stormwater facility inspections were conducted December 30, 2015 and iune 30. 2015. Page: 4 NCDENR North Carolina Department of Environment and Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director October 8, 2010 Allan Oracion Compliance Manager. 14700 Mallard Creek Road Charlotte, NC 28262 Natural Resources Subject: Compliance Evaluation Inspection Mallard Creek Polymers, Inc. 14700 Mallard Creek Road NPDES Stormwater Permit NCGO90000 Certificate of Coverage — NCG090006 Mecklenburg County Dear Mr. Oracion_ Dee Freeman Secretary On August 18 2010, Ms. Marcia Allocco from the Division of Water Quality (DWQ) and Mr. ,Jeff Mitchell from Charlotte -Mecklenburg Stormwater Services (CMSWS), conducted a site inspection of the Mallard Creek Polymers, Inc. facility located at 14700 Mallard Creek Road in Charlotte, Mecklenburg County, North Carolina. The site drains to an unnamed tributary to Mallard Creek, Class C waters located in the Yadkin -Pee Dee River Basin. The site visit and file review revealed that the subject facility is covered by NPDES General Stormwater Permit — NCG090000. This inspection was conducted as part of a cooperative working agreement between Mecklenburg County and the DWQ. 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. The following observations were noted during the Charlotte -Mecklenburg Stormwater Services 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 permittee should update the SPPP to include the name of the receiving water to which the facility's outfalls discharge, and indicate whether the receiving water is impaired or is located in a watershed for which a TMDL has been established, and what are the parameter(s) of concern. The permittee should add documentation that the facility has evaluated feasible alternatives to current practices in their SPPP or reference the location of the documentation in the SPPP. 2) Qualitative Monitoring Qualitative monitoring has been conducted and recorded in accordance with permit requirements. Yes N No ❑ Mooresville Regional Office Location: 610 Fast Center Ave., Suite 301 Mooresville, NC 28115 one Phone: (704) 663-1699 t Fax: (704) 663-60401 Customer Service: 1-877-623-6748 N-�orthCar'ol ina Intemet: http:llportal.ncdenr.org1webfwq /V/1 f 1/1"/i1Il1 Mr. Allan Ora_don, Malta4Creek,Polymers, inc. Compliance Evaluation Inspection, Page 2 October 8, 2010 3) Analytical Monitoring Analytical monitoring has been conducted and recorded in accordance with permit requirements. Yes ® No ❑ NA ❑ 41 Permit and Outfalls Tharb facg.!:it;y�.�_,... .sh.^_ii,-f ensure_ t_t. ;^=V, h.a�.been prnpuorl y t--- ;d:m..o....ster t-h..e f ;-`.R..y's Nat! ! �� a_ S ' r+, crag H! n t'- + r-c�lli.ifs�t ii5r;litr�c Elimination �v�icfri F�����1 Stormwater C�fiiiii s5 ici uiC?i� ii �'ci+# iii �t F:.,ii ('S 5 i1:_Iir general Permit any dorument this information in the SPPP. 5) C:ity of Charlotte Storrrtwater Ordinance Review - Uncovered metal parts were observed beside a building near the fire wnter retention pond on the southern po tion of the property The per mittee should consider covering the -netai pays or F � svvi; g them inuGorS An outfall on the southeasters i corner of the pro.pert'y was observed to have disturbed soil arour €d the, i€ seta corrugated outfall pipe. The permittee should stabilize the area around the outfall to ensure the outfall does not contribute to offsite sedimentation and negatively impact the unnamed tributary to Mallard Creek below the facility. Thank you for the assistance and cooperation during the inspection. Overall, the facility's Stormwater program was well developed and implemented and this Office commends the permittee's efforts to ensure compliance with your NPDES permit. If you have any questions, comments, or need assistance understanding any aspect of your permit, please do not hesitate to contact Mr. Jeff Mitchell with CMSWS or Ms. Marcia Allocco of the DWQ at (704) 235-2204. Sincerely, r for Robert B. Krebs Regional Supervisor Surface Water Protection Section Mooresville Regional Office cc: Rusty Rozzelle, MCWQP Craig Miller, City of Charlotte Water Quality Central Files Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 Phone: (704) 663-16991 Fax: (704) 663-60401 Customer Service: 1-877-623-6748 Internet: http:11portal.ncdenr.orgMeb1wq 011e NorthCalrolina An Equal Opportunity 1 Affirmative Action Employer - 30% Recycled110% Post Consumer paper Mr. Allan Oracion, Mallard Creek Polymers, Inc. Compliance Evaluation Inspection, Page 3 October 8, 2010 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 fail 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/weblwqlws/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 required 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 (NOI) 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 Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NO 28115 One Phone: (704) 663-16991 Fax: (704) 663-60401 Customer Service: 1-87TU3-6748 NOrthCaro"a Internet: httpJiportal.ncdemorg1weblwq _ Natuaaffil Mr. Allan Oracion, Mallard Creek Polymers, Inc. Compliance Evaluation Inspection, Page 4 October 8, 2010 o Collection, reporting, and recording of Qualitative Monitoring c Collection, reporting, and recording of Vehicle Maintenance Monitoring (if applicable) Ior:..r_ h ii �� -r.�-gym :��r n.0 'eCOruc in h f r_ifity �i�, ; i---! i�--`+,ii4ud? rld3{?i4U!!! S ,ci, .1 �,: ented a maintained at the a_.. with the vtorm'J Ater Pollution Prevciltion !'-Ian , iplt s Of till'; avail -`cal mcni-ri-f-, ',-U!;s Sllall also be maintained on site Thw— PF-nmitieF shAfl retain records of all m^nitorinq information, including all calibration and maintenance t'e,-ords and all original str'p-'hart recordings for continuous monitoring instrumentation, and copies of all repwis required by this general permit for a period of at least 5 years front the date of the sample measurement, report, or, application. 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 snail' submit forms acid fees as are required by Ll fe ogee y U th rued to ic� .e 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. e 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: (704) 663-16991 Fax: (704) 663-60401 Customer Service: 1-877-623-6748 Internet: httpJ1portal.ncden;.org1webiwq NorthCarolina Aarturally An Equal Opportunity , Affirmative Action Employer - 30% Recycledi10 % Past Consumer paper Compliance Inspection Report Permit: NCG090006 Effective: 11/01/07 Expiration: 10/31/12 Owner: Mallard Creek Polymers Inc SOC: Effective: Expiration: Facility: Mallard Creek Polymers incorporated County: Mecklenburg 14800 Mallard Creek Rd Region: Mooresville Charlotte NC 28262 Contact Person: Ailan Oracion Title: Phone: 704-547-0622 Directions to Facility: System Classifications: Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 08/1812010 Entry Time: 08:54 AM Exit Time: 01.11 PM Primary Inspector: Water Quality Program Meckenburg County Phone: 704-336-5449 Secondary Inspector(s): Marcia Allocco Phone: 704-663-1689 Ext.2204 Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Paints, Varnishes, Lacquers Stonmwater Discharge COC Facility Status: ■ Compliant ❑ Not Compliant Question Areas: ■ Storm Water (See attachment summary) Page: 1 Permit: NCGO90006 owner -Facility; Mallard Creek Polymers Inc Inspection Date: 08/1B12010 Inspection Type: Compliance Evalualion Reason for Visit_ Routine Inspection Summary: Facility Description: rvtallared Week Pn_l y ners, ln`_' is a chemical manufactzirfnrl pIanf 9ngagFr3 in making latex for various products. The facility operates seven days a week o.n a 24 hour -a -day schedi-Ae. Its manufactur'Tou operations are cl;4ssilfied as `Plash. - Materials and Synthetic Resigns and Non -Vulcanized Elastortl; rs " Compliance History n review of Mecklenburg Courity Water Quality Program (MCWQP) files shows the following: The permittee was inspected by htCWQP as part of a cooperative working agreement between Mecklenburg County and the Division of Water Quality (DWQ) on March 18. 2008 and April 23, 2009. The permittee was issued a Notice of violation (NOV) by DWQ for q e initial inspection. The. permittee was found to be in compliance dining the follow-up inspection. A NOV was issued by DWQ to Mallard Creek Poiymers, Inc. for an illicit discharge that occurred on June 2. 201Ui The illicit discharge contained styrene and caused a fish kill in an unnamed tributary to Mallard Creek, Class C waters in the Yadkin -Pee Dee River Basin Industrial Operations/City of Charlotte Stormwater Ordinance Review: Uncovered metal parts were observed beside a building near the fire water retention pond on the southern portion of the property. The permittee should consider covering the metal parts or moving them indoors. An outfall on the southeastern comer of the property was observed to have disturbed soil around the metal corrugated outfall pipe. The permittee should stabilize the area around the outfall to ensure the outfall does not contribute to offsite sedimentation and negatively impact the unnamed tributary to Mallard Creek below the facility. During the inspection a dry weather flow was observed flowing through an open channel between the fire water retention pond and peroxide building to a stormwater catch basin that is connected to the facility's wastewater pond via a sump pump. The source of the flow was determined to originate from tank cleaning that is performed at the facility. The facility personnel indicated the sump pump in the catch basin could be shutdown in the event the wastewater pond was near capacity. The facility personnel was informed the release of a mixture of stormwater and wastewater would be considered an illicit discharge of wastewater The facility personnel assured the inspectors that the water allowed to discharge from the drain would be thoroughly flushed by the storm event before a release would be allowed. The facility personnel was informed the release of stormwater from the overflowing catch basin would need to be treated as an outfall and would be subject to the requirements of the general permit. Page: 2 Permit: NCG090006 Owner - Facility: Mallard Creek Polymers Inc Inspection Date: 08/18/2010 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 n # Does the Plan include a General Location (USGS) reap? ■ n n n # Does the Plan include a "Narrative Description of Practices'? ■ n n n # Does the Plan include a detailed site map including outfall locations and drainage areas? ■ n n n # Does the Plan include a list of significant spills occurring during the past 3 years? ■ n n n # Has the facility evaluated feasible alternatives to current practices? ■ n n n # Does the facility provide all necessary secondary containment? ■ n n n # Does the Plan include a BMP summary? ■ n n n # Does the Plan include a Spill Prevention and Response Plan (SPRP)? ■ n n n # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ■ n n n # Does the facility provide and document Employee Training? ■ n n n # Does the Plan include a list of Responsible Party(s)? ■ n n Q # Is the Plan reviewed and updated annually? ■ n n n # Does the Plan include a Stormwater Facility Inspection Program? ■ n n n Has the Stormwater Pollution Prevention Plan been implemented? ■ n n n Comment: The permittee should update- the SPPP to include the name of the receiving water to which the facility's outfalls discharge, and indicate whether the receiving water is impaired or is located in a watershed for which a TMDL has been established, and what are the parameter(s) of concern. DWQ personnel forwarded information regarding the receiving stream, impairement, and TMDL development to the permittee after the inspection to add in completing this task. The permittee should add documentation to the SPPP that the facility has evaluated feasible alternatives to current practices or reference the location of the documentation in the SPPP. Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ■ n n n Comment: Analytical Monitorin Yes No NA NE Has the facility conducted its Analytical monitoring? ■ n n n # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? n n ■ n Comment: Permit and Outfalls Yes No NA NE Page:3 Permit: NCG090006 Owner - Facility: Mallard Creek Polymers Inc Inspection Date: 0811812010 Inspection Type: Comp#iance Evaluation Reason for Visit: P,cutine # Is a copy of the Permit and the Certificate of Coverage available at the site? ■ 0 ❑ [l Were all outfalls observed during the inspection? ■ ❑ f] 1=l 4 If fhc rdCiVil'y rla " 0preseriidt"=".=lutfd'i jSn._= i5 'r ..^.gef!1' Mrtru,'71EntPd by the r ivision- l__l ^ ■ # Has 'he facility evaluated a41 W)ct! (non 51Urr1jwel1--i tji5iiiaiy'n� ® 01 n Comment: The facility personnel should ensure they have been properly at!thorized to administer the facility's NPDES Stormwater permit as required by Part Ill Section B 5b of the General Permit and docuniertl this infomnation in the SPI'P. Page: 4 . NCDE R North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Saves Perdue Ccleen H. Sullirls Dee=reeman Governor Director Secretary June 28, 2010 CERTIFIED MAIL #7008 1140 0002 2716 1244 RETURN RECEIPT REQUESTED Allan Oracion, Compliance Manager Mallard Creek Polymers Inc. 14700 Mallard Creek Road Charlotte, NC 28262 Subject: Notice of Violation Tracking Number: NOV-2010-DV-0254 and Incident Number: 201001970 Mallard Creek Polymers Inc. Stormwater Certificate of Coverage NCGO90006 Mecklenburg County, NC Dear Mr, Oracion: Chapter 143, Article 21 of the North Carolina General Statutes (G.S.) authorizes and directs the Environmental Management Commission of the Department of Environment & Natural Resources to protect and preserve the water resources of the State. The Division of Water Quality (DWQ) has the delegated authority to enforce adopted pollution control rules and regulations. On June 2, 2010, you reported an illicit discharge of process wastewater from the Mallard Creek Polymers, Inc. facility to Charlotte-Meckienburg Stormwater Services (CMSWS) and this Office. Mr. Jeff Mitchell from CMSWS conducted a spill investigation of the spill area at Mallard Creek Polymers Inc. and the unnamed tributary to Mallard Creek, Class C waters of the State in the Yadkin -Pee Dee River Basin; below the facility on June 2-4, 2010 and June 9, 2010. This investigation found impacts to the unnamed tributary, which included a change in the color and clarity of the stream, depressed dissolved oxygen readings (low of 0.3 mg/L), increased conductivity, and a fish kill of 105 fish in a 0.2 mile stream segment below the Mallard Creek Polymers, Inc. facility. The investigation was conducted as part of a cooperative working agreement between Mecklenburg County and the Division of Water Quality. As a result of the spill investigation the following violations, detailed below, are noted: (1) Control of sources of water pollution - permits required (2) Stream Standard Violation — Removal of Best Usage (3) Stream Standard Violation — Dissolved Oxygen Item1 -- Control of sources of water pollution - permits required The illicit discharge of process wastewater to the unnamed tributary to Mallard Creek and associated stream standard violations (noted below) is a violation of North Carolina General Statute (N.C.G S.) 143-215.1 (a)(6), which states that (a) activities for which permits are required - No person shall do any of the following things or carry out any of the following activities unless that person has received a permit from the Commission and has complied with all conditions set forth in the permit: (6) Cause or permit any waste, directly or indirectly, to be Mooresville Regional Office Location: 610 Past Center Ave.: Suite 301 Mooresville, NC 28115 One Phone: (704) 663-16991 Fax: (704) 663-6040 � Customer Seivice: 1-877-623-K48 NorthCarolina Internet: httpllportal.ncdenr.orghveblwq Xt7f1lraIfl/ Mr. Oration, Mallard Creek Polymers Inc. NOV-2010-DV-0254, Page 2 June 28, 2010 discharged to or in any manner intermixed with the waters of the State in violation of the water quality standards applicable to the assigned classifications or in violation of any effluent standards or limitations established for any point source, unless allowed as a condition of any permit, special order or other appropriate instrument issued or entered into by the Commission under the provisions of this Article. [tern 2 — Removal of Best Usage The water quality impacts and associated fish kill (105 fish) in, the unnar lied tnbiltcfry to I Ll Hard Cj-r-r' represents violations of North Carolina stream standard Title 15A NCaC 02B .0211 (2), which states that waters shall be suitable for aquatic life pr -,pagaticn and mair-tenance of biological integrity, wildlife. secondary recreation, and agriculture; sources of water pollution which preclude any of these uses on either a short-term or long-term basis shall be considered to be violating a water quality standard. Item 3 — Dissolved Oxygen The dissolved oxygen readinqs in the unnamed tributary of Mallard C€eek with a low of 0.3 mgiL represents violations of North Carolina stream standard Title 15A NCAC 02B .0211 (3)b, which states that Dissuived oxygen: not less than 6.0 mg/l for trout waters, for non -trout waters, not less than a daily average of 5.0 mgll with a minimum instantaneous value of not less than 4.0 mg/I; swamp waters, lake coves or backwaters, and lake bottom waters may have lower values if caused by natural conditions. The above noted violations and any future violations are subject to a civil penalty assessment of up to $25,000.00 per day for each violation. This Office is in receipt of your letter dated June 3, 2010, providing information on the June 2, 2010, release and the implementation of corrective actions to eliminate the potential for recurrent illegal discharges. We are requesting that you respond to this letter in writing within 30 days of receipt of this Notice expanding on the information provided in your letter dated June 3, 2010. Your response should be sent to this office at the letterhead address, to the attention of Mr. John Hennessey at the Wetlands and Stormwater Branch, NPS Assistance and Compliance Oversight Unit, 1617 Mail Service Center, Raleigh, NC 27699-1617, and to Mr. Rusty Rozzelle of MCWQP, 700 North Tryon Street, Charlotte, NC 28202. Your response should address the following items: (1) Please provide the final long-term corrective actions chosen by Mallard Creek Polymers to prevent a future release of process wastewater from the pre-treatment WWTP on site. Your response should include the option chosen and the associated implementation timeline. Once the work is completed photo documentation should be provided to this Office under separate cover at a later date. (2) Please provide a schedule for the repair of the retaining wall mentioned in your response. Once the work is completed photo documentation should be provided to this Office under separate cover. (3) Please provide a copy of the Spill Prevention and Response Plan as required by stormwater general Permit NCG090000, Please review the plan and ensure the following information is contained within the plan before submission to this Office: • Procedures and/or physical barriers that will used to prevent and mitigate the discharge of wastewater or other raw chemicals through the on -site stormwater outfall(s). • Actions to be taken once a release has occurred. This section should address prompt collection of discharged material, possible flushing of surface waters with collection of first flush liquids, locations along the unnamed tributary to Mallard Creek where impacts to tvtooresville Regional Office Location: 6 i0 East Center Ave., Suite 301 klooresville, NG 28115 Phone: (704) 663-16991 Fax: (704) 663-60401 Customer Service: 1-877-623-6748 Internet: httpJ1portai.ncdenr.org1web1wq One NorthCaroiina An Equal Opportunity 1 Affirmative Action Employer- 300% Recycled110% Post Consumer paper 41r. Oracion, Mallard Creek Polymers Inc. NOV-2010-DV-0254, Page 3 June 28, 2010 surface waters will be observed, and the reporting requirements for any releases. If you have any questions, please do not hesitate to contact Jeff Mitchell with CMSWS or Ms. Marcia Allocco of the Division of Water Quality at (704) 235-2204. cc: ru ..0 r` ru ru C3 0 0 M Sincerely, Robert B. Krebs Regional Superfisor Surface Water Protection Section Mooresville Regional Office Rusty Rozzelle, MCWQP NPS-ACO — Shelton Sullivan Central Files — NCG090006 Aostape S O�Gv V, Celled Fee �� Pojsfj t (rsemer squired} - R R Fee n (E„dorse,me Rm equV-0 LD a ALLAN ORACION, COMPLIANCE MGR. to MALLARD CREEK POLYMERS, INC Cl a n 14700 MALLARD CREEK ROAD r•- a CHARLOTTE NC 28262 ,__-------- swplma 6/28/10 PS Form 3800. AuguSt 0D. Mooresville Regional office Location; 610 East Center Ave., Suite 3o1 Mooresville, NC 28115 Phone: (704) 663-1699 I Fax: (704) 663-60401 Customer Service: 1-877-623-6748 Internet: hu J/PonaLncdenr.orgiweblwq - An Eouai r3eoor:unity 1 Afirmativ=- Action Employer - 30% Recycled110% Post Consumer paper NorthCarolina Naturallif CharfaM-Mecklenburg STORM WATER Services Dates: June 2. 2010 Wednesday Location: Mallard Creek Polymers Inc. 14700 Mallard Creek Road., Charlotte, NC 28262. Facility Contact: Allan Oracion, Compliance Manager (704) 547 - 0622 x1009 aoraci@mcpoly_mers.com Material Spilled: Process/Wastewater Responsible Party: Mallard Creek Polymers Inc. Responder: Jeff Mitchell, Environmental Specialist, Charlotte -Mecklenburg Storm Water Services Narrative of Events: Wednesday, June 2, 2010: Jeff Mitchell of Charlotte -Mecklenburg Storm Water Services (CMSWS) received a phone call from Allan Oracion of Mallard Creek Polymers (MCP), the Compliance Manager about a non -reportable spill. Mr. Oration explained that Styrene would be the chemical of concern in the discharge. Mr. Oration explained the reportable limit for Styrene was 1000 pounds and that it was estimated that around 1.5 pounds had been spilled. Mr. Mitchell asked Mr. Oration why he decided to contact CMSWS about a non -reportable spill and was told that CMSWS had inspected them in the past and that he wanted us to be aware of this spill should anyone call and report that the nearby stream was discolored. Mr. Mitchell asked Mr. Oration if the facility had a Nation Pollutant Discharge Elimination System (NPDES) Stormwater Permit and was told that they did have a NPDES Stormwater Permit. Mr. Mitchell informed Mr. Oration that any quantity that enters into the Municipal Separate Storm Sewer System or directly discharges into a stream is considered a reportable spill and that he should contact the Division of Water Quality (DWQ) and report the spill to the Mooresville Regional Office (MRO). Mr. Mitchell instructed Mr. Oration to ask for Marcia Allocco and report the spill to her and to contact him after he had done so. Mr. Oracion called Mr. Mitchell and informed him that he had asked for Ms. Allocco and was informed that she was unavailable and was directed to speak with Donna Hood but received her voicemail. Mr. Mitchell informed Mr. Oration that he would need to contact someone at DWQ and report the spill. Mr. Mitchell called and Spoke with Dee Browder with DWQ and informed her that a facility had reported a spill to him and that he was going to have the facility call her and report the spill directly to her. Mr. Mitchell spoke with Mr. Oracion and provided him a contact name to ask for when he called DWQ to report the spill and informed him that he needed to contact the National Response Center (NRC) and report the spill. Mr. Mitchell arrived at MCP at approximately 6:00 pm and was escorted around the facility by a supervisor. Mr. Mitchell was under the impression the amount of Styrene in the stream was measured at 2 ppb and that the stream had a white color from the process water. Mr. Mitchell was informed that the process water would discolor a stream in a similar manner that a latex based paint would discolor a stream. Mr. Mitchell was aware how a small amount of latex based paint can impact the coloration of stream over a large area without harmful affects to aquatic life. Mr. Mitchell inspected the area where the spill occurred and noted the stream below the facility was white in color. Mr. Mitchell informed the supervisor that he would check further downstream and speak with Mr. Oration the next day. Mr. Mitchell drove to Dixie Ann Drive, which is the first road crossing and observed the creek was whitish in color (Image 1). Mr. Mitchell drove to Sandringham Place and noted the creek appeared turbid. Mr. Mitchell did not observe any environmental impact to the stream with the exception of the stream was discolored. Mr_ Mitchell attempted to look up the water quality standard for Styrene ar,rl noted a reference to grit-�king water standard for Styrene is 0.I ppm. Mr. Mitchell noted the amount of 2 ppb «erg: well helow the drinking water standard acid decided to follow-up the Mr. Oration the next day. Thursday, June _3. 2010: Mr. Mitchell arrived at Dixie .1.nn Drive at approximately 9.00 am and noted that the creek was not as discolored as it was the day before but noted that n fish kill had occurred at the site (Image 2 & 3). Mr. Mitchell walked a portion of the stream and noted 30 dead fish and reported the findings to a Supervisor. Mr. Mitchell returned to the office and spoke with Tony Roux about identifying the fish for the required fish kill field investigation form that needs to be completed in the event that twenty-five or more fish die in a fish kill event. Mr. Roux agreed to accompany Mr. Mitchell to the site and assist in the collection and identification of the dead fish. While collecting dead fish, Mr. Mitchell used a YSI 600 XL and a YSI 650 hand held unit to observe the physical parameters of the stream. Mr. Mitchell and Mr. Roux noted high conductivity levels and low Disolved Oxygen (DO) levels throughout the stream. The bulk of the dead fish were collected between the road crossing at Dixie Ann Drive and Sandringham Place. Mr. Mitchell and Mr. Roux returned to MCP and spoke with Mr. Oration about the dead fish Iocated downstream of the plant. Mr. Mitchell asked Mr. Oration what the chemical composition of the process water consisted of and was told the chemical of concern should have been styrene. Mr. Mitchell asked about the concentration of.the styrene that tested in the stream and was told it was measured at 2 ppm. Mr. Mitchell confirmed that the concentration -was in parts per million and not in parts per billion as Mr. Mitchell originally thought. Mr. Mitchell asked if the process water in the tank where the spill occurred had been tested and was told that the process water directly from the tank and been test and the concentration was 380 ppm of styrene and that a small pool of the process water in front of the tank had been test and contained approximately 266 ppm of styrene. Mr. Mitchell and Mr. Roux of CMSWS accompanied Mr. Oration of MCP for a walk from the spill location to the stream behind the facility. The stream behind the facility was walked to a point where Mr. Mitchell had observed the stream earlier that day. Five additional fish were observed during the stream walk behind the plant. A total of 94 dead fish were collected, identified and properly disposed of (Image 4). Mr. Mitchell, Mr. Roux and Mr. Oration returned to Mr. Oracion office to further discuss the spill event and the resulting fish kill. Mr. Mitchell called Marcia Allocco and spoke with her and Dee Browder with DWQ at the MRO and informed them of the fish kill. Mr. Mitchell asked Marcia if she needed any additional information from Mr. Oration or wanted any specific task performed while he was onsite. Ms. Allocco asked if the creek had been flushed and was informed that it had not but would be flushed within the next hour. After the phone conversation with Ms. Allocco, Mr. Oration was instructed to flush the creek. The creek flushing began at 3:00 pm and would be terminated once the stream returned to conditions at or above the state's water quality standards (Image 5). Between 6.00 and 7:00 pm, Mr. Mitchell collected a water sample from below Dixie Ann Drive and Sandringham Place road crossing. Around 9:00 pm, Mr. Mitchell called and spoke with a supervisor of MCP and asked him to continue to flush the creek until 2:00 am. _Fridav, June 4. 2010: Mr. Mitchell dropped the water samples off at the lab that were collected the day before to be analyzed for volatile organics (EPA 8260 Method). Mr. Mitchell monitored the physical parameters of the stream throughout the day and noted eleven additional dead fish in the stream. The total collected and identified fish for the fish kill report is 105. Mr. Mitchell observed two crayfish, a darter, a few sunfish and minnows at the Tryon Street (HWY 29) road crossing. Mr. Mitchell went further upstream and noted the presence of minnows at the Clackwyck Lane road crossing. No aquatic life was observed any further upstream of the Clackwyck Lane road crossing. Wednesday June 9, 2010 Mr. Mitchell monitored the physical parameters of the stream and noted a few minnows below the Sandringham Place road crossing. No aquatic life was observed any further upstream of the Sandringham Place road crossing. Monday June 14, 2010 Mr. Mitchell received the results of the water sample and noted that styrene was below the detection level and that acetone was detected in both samples below DWQ's water quality standard (See pdf attachment: Lab Results). Physical parameters of tributary to Mallard Creek Locations Date Time I Temp C Sp coed DOsat DO pH (4) Dixie Ann Drive - Up 6/3/2010 10:24 19.09 914 3.3 0.3 7.18 (4) Dixie Ann Drive - Down 6/3/2010 10:27 20.24 454 12.6 1.14 7.47 (3) Below Confluence 6/3/2010 10:34 19.98 479 57.9 5.26 7.54 (3) Above Confluence 6/3/2010 10:37 19.96 502 57.5 5.23 7.66 I i3) Tributary 6/3/2010 10:40 20.03 389 80.3 7.29 6.88 (5) Sandringham Place - Down 6/3/2010 ; 11.29 2n.28 326 325 28.1 t- 3.3 2.54 7.49 (5) Sandringham Place - Qowa) (1) MCP uutfaii 6!`3/2010 6/312010 ! ! 11:j2 12:21 12:48 20.54 1 19.73 I 20.25 i 2-911 ; 7.53 745 10.4_ j 0.95 j 3.43 l7,73 9_ e5 i (2) Perennial Start 6/3/2010 i 18 37.9 (4) Dixie Ann Drive - Up 6/3/2010 17;02 21.05 449 70 1 6.24 7.71 _ (5) Sandringham Place - Dawn 6/3/2010 I 17:28 20.49 327 1 9-1 0.81 7.55 (5 Sandringham Place - Down (5) Sandringham Place - Down 6/3/2010 6/3/2010 17:53 17:56 20.79 21.83 337 5 40G 15.5 54.7 138 1 4.79 7.6 7.73 i i6i Ciackwyc,k Lane - Up ! 6/3/2010 18:28 24.46 316 77.7 6.48 6.77 ! 8 7.7 i (6) Clackwyck Lane - Down 6/3/2010 18:34 ; 22.81 i 321 i 78.7 ; A) Caprington Avenue - Up 6/3/2010 19:08 21.65 151 90.7 7.99 8.24 (7) Tryon (HWY 29) - Up 6/3/2010 19:16 22.49 249 85.8 7.43 8.19 (6) Clackwyck Lane - Up 6/3/2010 19:24 23.73 323 84.4 7.14 8.07 (4) Dixie Ann Drive - Down 6/3/2010 19:54 22.65 157 84.1 7.26 7.61 (4) Dixie Ann Drive - Down 6/4/2010 7:35 21.22 221 80.6 7.15 7.02 (5) Sandringham Place - Down 6/4/2010 7:47 20.89 204 58.5 5.23 7.25 (6) Clackwyck Lane - Up 6/4/2010 8:07 21.06 199 88.1 7.84 7.52 (7) Tryon (HWY 29) -Up 6/4/2010 8:16 21.14 193 90.5 8.04 7.72 (1) MCP Outfall 6/4/2010 15:20 21.77 182 46.8 4.1 7.03 (1) 20 feet down from MCP Out 6/4/2010 15:22 23.05 166 63.2 5.41 7.2 (6) Clackwyck Lane - Up 6/4/2010 15:48 23.65 227 80.9 6.85 7.69 (5) Sandringham Place - Down 6/4/2010 15:58 21.43 213 58.5 5.17 7.5 (4) Dixie Ann Drive - Down 6/4/2010 16:16 22.76 298 64.6 5.56 7.25 (7) Tryon (HWY 29) - Up 6/9/2010 10:51 20.7 224 105.2* 9.43* 7.63 (6) Clackwyck Lane -Up 6/9/2010 I 12:37 21.54 353 92.7* 8.17* 7.51 (5) Sandringham Place - Down 6/9/2010 12:47 20.4 342 50.4* 4.57* 7.15 (4) Dixie Ann Drive - Down 6/9/2010 12:57 21.41 512 64.6* 5.71* 7.03 Numbers depict location on map Fish kill occurred between area's numbers 2-5 * Indicates DO Probe failed check in Map of physical parameter monitoring •,- � � k'�'.� f ��'M '4� ( '�..'�-.�1""z.."°�y } .. � r-Y Y`' � ; ' ..,i%gRt�.S'�''- � - � � ,tom-, � � rt �1=' '.�t 1,i �, i, t .. 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Report Date: 6/14/2010 11:35:59 AM LABORATORY SERVICES DIVISION LOCATION: Dixie Ann Drive LOC ID: W-SPEC SAMPLE DATE -TIME 6/3/2010 18:07 SAMPLE DESCRIPTION: Grab CHAIN OF CUSTODY #: 100604008 Parameter Result Units RL Method Start Date 1 Time Analyst AD53201 trans-1,2-Dlchloroethene Less than ug1L 5 SW846/8260B 6/812010 15:17 SDA AD53201 1,2-Dichloroethane Lessthan ug/L 3 SW846/8296 6/8/2010 15:17 SDA AD53201 Benzene Less than ug/L 3 SW84618260B 6/8/2010 15:17 SDA AD53201 2-Butanone (MEI() 15 ugli_ 10 SW84618260B 6/8/2010 15:17 SDA AD53201 1,1,1-Trichloroethane Lessthan ug1L 3 SW846182608 6/8/2010 15:17 SDA AD53201 Carbon Tetrachloride Lessthan ug/L 5 SW846/8260B 6/8/2010 15:17 SDA AD53201 Chloroform Lessthan ug/L 3 SW846182608 6/8/2010 15:17 SDA AD53201 Bromochloromethane Lessthan ug/L 3 SW846 / $2608 618/2010 15:17 SDA AD53201 cis-1,2- Dichloroethene Less than uglL 3 SW84618260B 6/812010 15:17 SDA AD53201 Vinyl acetate Less than ug/L 5 SW846182608 6/8/2010 15:17 SDA AD53201 Acrylonitrile Lessthan ug/L 50 SWS46/8260B 6/8/2010 15,17 SDA AD53201 Chloromethane Less than ug/L 5 SW846/8260B 6/812010 15:17 SDA AD53201 Methyl-tert-butyl-other (MTBE) Lessthan ug/L 3 SW8461825GS 6/82010 15:17 SDA AD53201 1,2-Dichlorpropane Less than uglL 3 SW846/82608 6/812010 15:17 SDA AD53201 Acetone 200 ug/L 50 SW84618260B 6/82010 15:17 SDA AD53201 Methylene Chloride Lessthan ug1L 5 SW84618260B 6/812010 15:17 SDA AD53201 Acrolein Less than uglL 50 SW84618260B 618/2010 15:17 SDA AD53201 lodomethane Less than ug/L 5 SW84618260B 6/8/2010 15:17 SDA AD53201 Carbon Disulfide Lessthan ug/L 5 SW84618260B 6/8/2010 15:17 SDA AD53201 1,1-Dichloroethene Less than ug/L 3 SW846/8260B 6/8/2010 15:17 SDA AD53201 Trichlorofluoromethane Less than ug/L 5 SW8461826DB 6/812010 15:17 SDA AD53201 Chloroethane Less than ug/L 5 SW846 / 8260B 61812010 15:17 SDA AD53201 Bromomethane Lessthan ug/L 5 SW84618260B 6/8/2010 15:17 SDA AD53201 Vinyl Chloride Lessthan ug1L 5 SW84618260B 6/8/2010 15:17 SDA AD53201 1,1-Dichloroethane Lessthan ug1L 3 SW84618260B 6/82010 15:17 SDA AD53201 2-Hexanone Less than ug/L 10 SW846182608 6/8/2010 15:17 SDA AD53201 1,2-Dichlorobenzene Lessthan ug/L 3 SW946182606 618/2010 15:17 SDA AD53201 1,4-Dichlorobenzene Lessthan ug/L 3 SW84618260B 6/812010 15:17 SDA AD53201 1,3-Dichlorobenzene Less than ug1L 3 SW84618260B 6/8/2010 15:17 SDA Page 1 of 3 dh Laboratory Analysis Report �- IIlr1RU[Yf''1E'IB. Report Date: 6/14/2010 11:35:59 AM -"0M"wm wftLm LABORATORY SERVICES DIVISION LOCATION: Dixie Ann Drive LOC ID: W-SPEC SAMPLE DATE -TIME 61312010 18-.07 SAMPLE DESCRIPTION: Grab CHAIN OF C.USTODY #. 100604008 Parameter Result Units RL Methcd Start Date 1 Time Analyst AD5320i 1,2,3-Trichloropropane Less than ug1L 5 SW8461MOB 61812010 15:11 SDA A053201 11,1,2,2 TelraChl4roethane Loss than i1glL 3 SwAk61A2608 61812010 15 17 SDA A053201 trans-1,4-Dichloro-2-butane Less than ug/L 5 5W846182508 618/2010 15:17 SDA AD53201 Bromolorm Less than ug/L 3 SW846 i 8260B 51812U i U 5:17 SDA AD53201 Styrene Less than ug/L 5 SW84618260B 6/8/2010 15:17 SDA AD63201 Total Xylenes Less than ug/L 3 SW84618260D 618/2010 115717 SDA AD53201 1,1,1,2-Tetrachloroethane Less than ug/L 3 SW846/82608 61812010 15:17 SDA AD53201 Trichloroethene Less than uSiL 3 SW846182606 6IM010 15:17 SDA AD53201 Ethylbenzene Less than ug/L 3 SW846182608 61812010 15:17 SDA A053201 Dibromomethane Less than ug/L 5 SW84618260B 51812010 15A7 SDA AD53201 1,2-Dibromoethane Less than ug/L 3 SW846182608 618/2010 15:17 SDA AD53201 Dibromochloromethane Less than ug1L 3 SW84618260E 602010 15:17 SDA AD53201 1,1,2-Trichloroethane Less than ug/L 3 SW84618260B 618/2010 15:17 SDA AD53201 Tetrachloroethene Less than ug/L 3 SW84618260B 6/8/2010 15:17 SDA A053201 trans-1,3-Dichloropropene Less than ug/L 5 SW846182608 5/8/2010 15.17 SDA AD53201 4-Methyl-2-pentanons Less than ug/L 10 SW84618260B 6/8/2010 15:17 SDA AD53201 Toluene Less than ug/L 3 SW846/82608 6/8/2010 15:17 SDA AD53201 cis-1,3-Dichloropropene Less than ug/L 5 SW846182600 6/8/2010 15:17 SDA AD53201 2-Chloroethyl vinyl ether Less than ug/L 10 SW84618260B 6/8/2010 15A7 SDA AD53201 Bromodichloromethane Less than ug/L 3 SW846182608 6/8/2010 15:17 SDA AD53201 1,2-Dibromo-3-chloropropane Less than ug/L 10 SW846182608 6/8/2010 15:17 SDA AD53201 Chlorobenzene Less than ug/L 3 SW846182609 6/8/2010 15:17 SDA Page 2 of 3 dX Laboratory Analysis Report Report Date: 6/14/2010 11:35:59 AM �n,r� nuw LABORATORY SERVICES DIVISION LOCATION: Dixie Ann Drive LOC ID: W-SPEC SAMPLE DATE -TIME 6/3/2010 18:07 SAMPLE DESCRIPTION: Grab CHAIN OF CUSTODY #: 100604008 Parameter Result Units RL Method Start Date ! Time Anat"t Comment: 8260: Acetone was analyzed on a 1:5 dilution 618l10 at 1618. Laboratory Supervisor: CMU-Environmental ratorI/IServices N.C. Certification No.192 N.C. DHHS Certification No. 37417 4222 Westmont Drive. Charlotte. North Carolina 28217 Page 3 of 3 Laboratory Analysis Report -� Report Date: 6/14/2010 11:36:28 AM (ImLO'1'f'E. LABORATORY SERVICES DIVISION LOCATION: Sandringham Place LOC ID- W-SPEC SAMPLE DATE -TIME 6131201 f,: 18:58 SAMPLE DESCRIPTION: Grab CHAIN OF CUSTODY #: 100604008 Parameter Resuit units RL Method Start Date 1 Time Analyst A053202 Vans-1,2-Dichloroelhene Less than uglL 5 SN84618260B 61812010 15:43 SOA AD53202 1,2-Dichlornethano Leas than ug1L 3 SW846182MB 61812010 15:48 SDA AD53202 Benzene Less than ug1L 3 SW8461526013 618/2010 15:48 SOA AD53202 2-Butanone (MEK) Less than uglL 10 1,50,1846, 8260E 5?8t2010 15.48 SOA AD53202 1,1,1-Trichloroethane Less than ug1L 3 SW84618260B 6/812010 15A8 SDA AD53202 Carbon Tetrachloride Less than ug1L 5 SW84618260B 6/812010 15:48 SDA AD53202 Chloroform Less than ug{L 3 SW84618260B 61812010 15:4B SDA AD53202 Bromochloromethane Less than ug1L 3 SW84618260B 61812010 15:48 SDA A053202 cis-1,2- Dlchloroethene Less than uglL 3 SW846 /82605 61B12010 15AB SDA AD53202 Vinyl acetate Less than ug1L 5 SW846182608 6/8/2010 15:48 SDA AD53202 Acrylonitrile Less than ugfL 50 SW8461826CB 618/2010 15:48 SDA AD532D2 Chloromethane Less than uglL 5 SW846 18260E 618/2010 15:48 SDA AD53202 Methyt-tert-butyl-ether (MTBE) Less than uglL 3 SW84618260B 6/8/2010 15:48 SDA AD53202 1,2-Dichlorpropane Less than uglL 3 SW845 8260E 6/8/2010 15:48 SDA AD53202 Acetone 65 ug1L 10 SW846182603 6/8/2010 15:48 SDA AD53202 Methylene Chloride Less than ug1L 5 SW84618260B 6/8/2010 15:48 SDA AD53202 Acrolein Less than ug1L 50 SW84618260B 6/8/2010 15:48 SDA A053202 lodomethane Less than ug1L 5 SW84618260B 618/2010 15:48 SDA AD53202 Carbon Disulfide Less than ug1L 5 SW846182WB 6/8/2010 15:48 SDA AD53202 1,1-Dlchloroethene Less than ug1L 3 SW846182608 6/8/2010 15:48 SDA AD53202 Trichlorofluoromethans Less than ug1L 5 SW846182608 6/812010 15:48 SDA AD53202 Chloroethane Less than ug1L 5 SW84618260B 618/2010 15:48 SDA AD53202 Bromomethane Less than ug1L 5 SW846182606 6/8/2010 15:48 SDA AD53202 Vinyl Chloride Less than ug1L 5 SW84618260B 6/8/2010 15:48 SDA A053202 1,1-01chloroethane Less than ug/L 3 SW846182608 6/8/2010 15:48 SDA A053202 2-Hexanone Less than uglt 10 SW846 18260B 6/8/2010 15:48 SDA AD53202 1,2-Dichlorobenzene Less than uglL 3 SW84518260B 6/8/2010 15:48 SDA AD53202 1,4-Dichlarobenzene Less than uglL 3 SW646182609 618/2010 15.48 SDA AD53202 1,3-Dichlorobenzene Less than ug1L 3 SW84618260B 618/2010 15:48 SDA Page 1 of 3 Laboratory Analysis Report Report Date: 6/14/2010 11:36:28 AM �p7lLW[a6LOICi Vd1TH LABORATORY SERVICES DIVISION LOCATION: Sandringham Place LOC ID: W-SPEC SAMPLE DATE -TIME 6/3/2010 18:58 SAMPLE DESCRIPTION: Grab CHAIN OF CUSTODY #: 100604008 Parameter Result Units RL Method Start Date / Time Analyst AD53202 1,2,3-Trichloropropane Less than ug/L 5 SW846182606 6/8/2010 15:48 SDA AD53202 1,1,2,2-Tetrachloroethane Less than ug1L 3 SW846182608 618/2010 15:48 SDA AD53202 trans-1,4-Dichtoro-2-butene Less than ug/L 5 SW846182606 618/2010 15:48 SDA AD53202 Brornotorm Less than ug/L 3 SW846182608 6/8/2010 15:48 SDA AD53202 Styrene Less than ug/L 5 SW846182606 6/8/2010 15:48 SDA AD53202 Total Xylenes Less than ug/L 3 SW846182609 6/8/2010 15:48 SDA AD53202 1,1,1,2-Tetrachloroethane Less than ug1L 3 SW84618250B 618/2010 15-48 SDA AD53202 Trichloroethene Less than ug/L 3 SW846182609 6/8/2010 15:48 SDA AD53202 Ethylbenzene Less than uglL 3 SW845182606 6/8/2010 15:48 SDA AD53202 Dibromomethane Less than ug/L 5 SW84618260E 6/8/2010 15:48 SDA AD53202 1,2-Dibromoethane Less than ug/L 3 SW846182606 6/8/2010 15:48 SDA AD53202 Dibromochloromethane Less than ug/L 3 SW84618260B 6/8/2010 15:48 SDA AD53202 1,1,2-Trichloroethans Less than ug/L 3 SW84618260B 61812010 15:48 SDA AD53202 Tetrachloroethene Less than ug/L 3 SW846182608 6/8/2010 15:48 SDA A053202 trans-1,3-Dichl oropro pone Less than ug/L 5 SW846 / 8260B 618/2010 15:413 SDA AD53202 4-Mothyl-2-pentanone Less than ug/L 10 SW84618260B 6/8/2010 15:48 SDA AD53202 Toluene Less than ug/L 3 SW846182606 618/2010 15:48 SDA AD53202 cis-1,30chloropropene Less than ug1L 5 SW84618260B 618/2010 15:48 SDA AD53202 2-Chloroethyi vinyl ether Less than ug1L 10 SW84618260B 6/812010 15:48 SDA AD53202 Bromodichioromethane Less than ug/L 3 SW64618260B 618/2010 15:48 SDA A053202 1,2-Dibromo-3-chloropropane Less than ug/L 10 SW646182608 618/2010 15:48 SDA A053202 Chlorobenzene Less than ug/L 3 SW846 / 8260B 6/8/2010 15:48 SDA Page 2 of 3 06h Laboratory Analysis Report Report Date: 6/14/2010 11:36:28 AM ryMo"Dwommum Vtuna LABORATORY SERVICES DIVISION LOCATION: Sandringham Place LOC ID. W-SPEC SAMPLE DATE -TIME &12010 18:58 SAMPLE DESCRIPTION: Grab Comment' CHAIN OF G'UG T ODY #. 100604008 Parameter Result Units RL Method Start Dale ! Time Analyst Laboratory Supervisor: CMU-Environmental ratoryArvices N.C. Certification No.192 N.C. DHHS Certification No. 37417 4222 Westmont Drive, Charlotte, North Carolina 28217 Page 3 of 3 CHARLOTTE-MECKLENBURG UTILITIES - LABORATORY SERVICE'S DIVISION CINU ESF Laboratory, 422 Wes"onl Or., Cherlotte NC, 28217 VO4) 336.28541(704) 622-7280 CLIENT: MECKLENBURG COUNTY, LUESA - WATER QUALITY PROGRAM FACILITY: PROJECT: LABCOOE: lCF1 iV!►� �''� 4�� CHAIN OF CUSTODY RECORD PAGE 1 OF I t Re To: COpt;fo0(ooLfLcX 70ON Tryon St Ste. 205 S- WW By r ml �I Charbt�, NC 28202'S \� ammmmmoralmn SRI M E N N 0 RIM MOMMINMEMMENNUME ON No mum IN IMMENIMINMENEMEMM ON MEIJI IMENEMEME EMEN mmiinmm EMMEMMEN Emomlim NOMINEE IN =MEMO MEMO ENE IMMINIMMI IN MIMMEMINIMEMNIMMENIMEMINE MEN .�= 0 .ECC....��110100110SEEM ME MMIMIMNMEMMMMMMNMMMIMMMM NOT ers•a+.r . f (7 1 G COMINENTS: Amwm P Form Rsvlslon 3: ereect}va 7ro1l0a l0�3i'A -,, �r nueu fe 3-t'm.�A Ala/lo n .l - 7 , r: L Y ,v *.may J �, 7 r' ?'ir• �) .-r 44 r � � �, ► � Grp. 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[Jeffery.Mitchell@mecklenburgcountync.gov] Sent: Thursday, June 24, 2010 7:01 PM To: Allocco, Marcia Subject: RE: Fish Kill Mecklenburg County Marcia I have upload several pictures. You may want to go to the folder labeled Specific Locations as I have numbered the pictures to correspond to their location and added the time. Do note I added an hour to the creation date as my camera was an hour off. ftp://ftpl.co.mecklenbuEg.nc.us/WaterQuality/MCP%2OJune%202010/ FYI: the lab results are from samples that taken after flushing had started. Using the information that was provided by Mr. Oracion of 67, 760 gallons of water was used to flush the creek over a period of 11 hours would indicate a flow rate of 6,160 gallons an hour. The flushing began at 3:00 pm and the first sample was taken at 6:07 pm and second sample was taken at 6:58 pm. These samples would be severely diluted, I was surprised anything showed up in the samples. Jeff Mitchell Environmental Specialist Water Quality Program Mecklenburg County Land Use & Environmental Services Agency 700 N. Tryon St. Charlotte, NC 28202 Office 704.336.3926 Cell 980.721.3565 Fax 704.336.4391 From: Allocco, Marcia[mailto:marcia.allocco@ncdenr.gov] Sent: Thursday, June 24, 2010 4:32 PM To: Mitchell, Jeffery G. Subject: RE: Fish Kill Mecklenburg County Jeff, Can you place your photos on the ftp site for me to download? Would like to see the picture of the turbid creek. Thanks, Marcia From: Mitchell, Jeffery G. [mailto:Jeffery.Mitchell@meckienburgcountync.gov) Sent: Thursday, June 24, 2010 3:42 PM To: Allocco, Marcia Subject: RE: Fish Kill Mecklenburg County Gotcha, I thought I sent that earlier. Here is the fish kill report and corresponding YSI readings and map if needed. Jeff Mitchell Environmental Specialist Water Quality Program Mecklenburg County Land Use or "cq olt57-1 DWQ Fish Kill Field Investigation Form ps ••" cq O 9 Page 3 of 2 > Rev. 6/07 a < ' Send To: DWQ Environmental Sciences Section Attn. Mark Hale or Elizabcth•Fensin. -7777 i�lv4gsmrkeCaft1 ftNCV699-1sn. "733.W Fmc" ' jllfe Inett t. Investizators: Ki1i [umber WSB use Oniti'1: Investigation Date and Time:6/3-4/2010; 10:00 AM Manhours Required:18 hr Investigators:deff Mtichell and Tony Roux Organization: Mecklenburg County Water Quality Program Regional Office:MRO Address:700 N. Tryon St, Charlotte, NC 28202 Phone: 704-336-5500 Reporting Party: Mallard Creek Polymer Inc Address:14700 Mallard Creek Road Phone:704-547- 0622 x1009 Coinvestigators: Address: I Phone: Kill Event Location: Waterbody:Unnamed tributary to Mallard Creek Station: Subbasin:Mallard Creek County:Mecklenburg Nearest Town/Landmark:Charlotte, near UNCC Tributaries or other waters affected: Latitiude: I Longitude: Attach map describing area of event and provide coordinates Complete For Fish Kill and Disease Events Date Event Began (First reported): 6/2/2010 Time- 4:00 PM At time of investigation, kill event is: in progress ❑ completed: Area covered by kill: River (miles): 0.2 Lake /Estuary (acres, square miles): Event Duration: Days: I Hours: Fintivh .Sneriev Affrrtrd Species: Lepomis cyanellus I Size Range: 3-6 inches I Approx Number: 20 In Distress / Dying ❑ Dead ® Decayed ❑ Percent observed with sores or lesions: 0 Species: Semotilus atromaculatus Size Range: 2-6 inches Approx Number: 69 In Distress / Dying ❑ Dead ® Decayed ❑ I Percent observed with sores or lesions: Species: Clinostomus funduloides I Size Range: 2-4 inches I Approx Number: 14 In Distress / Dying ❑ Dead ® Decayed ❑ Percent observed with sores or lesions: Species: Notropis sp. I Size Range: 2 inches I Approx Number: 2 In Distress / Dying ❑ Dead ® Decayed ❑ I Percent observed with sores or lesions: Other Organisms Affected: Total Finfish Mortality: 105 1 Total Mortality of Other Organisms: Fish Disease Observations: Lesions/Sores ❑ Injuries ❑ Flared Gills ❑ Excessive mucus ❑ Tumors ❑ Visible Parasites ❑ Gaming ❑ Loss of equilibrium ❑ Erratic behavior ❑ Attempts to leave water ❑ Lethargy ❑ Convulsions ❑ Other❑ Describe: General Lesion and Sore Observations: Size(em}: Location (view diaa ams below): Appearance/ Comments: C C 0 9 D B A A B l D Page 2 of 2 ?h sical Observations and Water Quality Measurements: Station:Dixie Ann Drive (Road Station No.: Time: 12:00 PM Crossing) Cloud Cuver: light Wind Direction: Bottom Depth: 12 inches Outfalls Present: Y N Spills in area `% Y ®ti Other Activity: Seas: I Air Temp: 85 1 Preci : none Wind Speed: I Secchi Depth: na Prior Weather (3-4 days): some rain ] Describe: storm drain. outfall from Mallard Creek Polymer , Inc.__ bescribe: Styrene and other compounds in processiwastewater. - — ---- Dept—_ th (meters) I Dissolved Osygen(mg/1,) % Saturation pit 'Temperttture uC I f'--ndt�� 0vioy I salinity (ppt) Surface See YSI Readin s Attachment l0 1 .0 3.0 4_0 S.0 Algal Bloom: Fill out this section if bloom occurs in conjunction with fish kill or disease. If bloom occurs without affected fish, fill out Aigai Bloom Report form only and send to Division of Water Quality ESS Attn: Ecosystems Unit Staff Visual characteristics: LJ Discolored Water Describe: Flecks, ❑ Balls, ❑Filaments ❑ Surface Film LI Other h to lankton Samples Sent to ESS? Yes ❑ No❑ Phytoplankton Sample Quantity: One 500ml polyethylene container preserved with 2-3 ml Lugols solution and one 500ml polyethylene container unpreserved Send to DWQ Laboratory Section marked Attn: Ecosystem Unit Staff. Bioloeical and Chemical Samples Collected Durine Investieation: Fish Describe): iced, Preserved ? Station: Sample No.: Contact for Results: Phone: Algae/Plants (Describe): Iced, Preserved ? Station: Sample No.: Contact for Results: Phone: Other (Describe): Iced, Preserved ? Station: Sample No.: Contact for Results: Phone: Chemical Samples: Metals❑ Pesticides❑ Nutrients❑ Chlor A❑ Other® Describe: EPA Method 8260 Station: Dixie Ann Drive & Sandringham Place (Road Crossing) Sample No.: Contact for Results: Jeff Mitchell (MCWQP) Phone: (980) 721-3565 Photographs and /or videos taken? YX NU Where on file? Name:MCWQP: Work Order 83397 Phone: (980) 721-3565 Additional Comments, Observations, Conclusions, etc. (attach additional sheet if necessary): Attachments: Y5I Readiogs.docx - Physical parameters of stream; Draft version of narrative of events with pictures removed to reduce email burden. CILAR.LOTTEsm April 1, 2010 Mr. Allan Oracion Mallard Creek Polymers Incorporated 14700 Mallard Creek Road Charlotte, NC 28262 Subject: Evaluation of Monitoring, Permit # 2000 Dear Mr. Samartino; Enclosed are the data summaries for Self Monitoring conducted at February 9-12, 2010 at Mallard Creek Polymers. There were no permit limits violations during this monitoring. If you have any questions or need further assistance, please call me at 704-336-4636. Thank you for your cooperation. S' cer Bill Gintert Environmental Compliance Specialist System Protection Division enclosure: data summaries copy: file System Protection 4222 Westmont Dr. Charlotte, NC 28217 Phone: 704-336-4407 Fax: 704-336-5077 Charlotte -Mecklenburg Utilities Page: i - 3126/2010 Charlotte Nittiklenburg Utility Department 15:21:08 System Protection Division Charlotte N.C. 39530 Period: 02101/ 10 to 02128/2010 Attn: ALLAN ORACION MALLARD CREEK POLYMERS, INCORPORATED 14700 MALLARD CREEK ROAD CHARLOTTE NC - 28262 J.U. No.: 2000 Sic No: 2821 Reporting Units: mGIL and [6slday FINAL PERMIT: 09/2212008 to 0513112010 Pipe # 1 2/1/2010 2/2/2010 213/2010 214/2010 2/912010 Period CM Cm Cm CM Sm Average _ FLOW 0.05221 0A561 0,056174 0,056025 0.053033 1,1,1-TRICHLOROETHANE 1,1,2-TRICK LOROETHAME 1,1-DICHLOROETHANE - 1,1-DICHLOROETHYLENE 1,2,4-TRICHLORO BENZENE 1,2-DICHLOROBENZENE 1,2-DIGHLOROE=THANE ^ 1,2-DICHLOROPROPANE 1,30CHLOROBE;NZENE 1,3-DIC HLOROPROPYLEN E 1,4-DICHLOROBENZENE 2,4-DIMETHYLPHENOL 2-NITROPHENOL 4,Ea-DINiTRO-O-CRES0L 4-NITROPHENOL A Violations of Daily Maximum Limit on Permit B- Violations of Maximum Average Limit on Permit *- Denotes Technical Review Criteria (TRC) Violation Page: 2 3/26/2010 Charlotte Ni"Wenhurg Utility Department 15:21:08 System Protection Division Charlotte N.C. 39630 Period: 02/01110 to 02/28/2010 Attn: ALLAN ORACION MALLARD CREEK POLYMERS, INCORPORATED 14700 NIALI-ARO GREEK pear) CHARLOTI'F NC 28262 I.V. No.: 2000 Slc No 2821 Reporting Units: mG1L and Ibsiday FINAL PERMIT: 0912212003 to 05/31/2010 PIP0 0 1 211120i0 2!212010 21312010 214/2010 219i2010 Perlod CM CM CM CM SM Average ACENAPIAT HE NE AMMONIA 25.962729 lbs AN1THRACENE ARSENIC, TOTAL BENZENE B1S(2-ETHYLHEXYL PHTHALATE) BOQ-5 DAY C-BOD 60,594445 lbs CADMIUM, TOTAL - - - - — CARBON! TETRACHLORIDE CHLOROBENZENIE CHLOROETHANIE CHLOROFORM CHROMIUM, TOTAL COD 163.20694 ills COPPER,TOTAL A- Violations of Daily Maximum Limit on Permit & Violations of Maximum Average i.imlt on Permit *- Denotes Technical Review Criteria (TRC) Violation Page: 3 ai2612010 Charlotte �i%�4klenburg Utility Department # 15:21:08 System Protection Division Charlotte N.C. 39530 Period: 02/01110 to 02/2812010 Attn: ALLAN ORACION MALLARD CREEK POLYMERS, INCORPORATED 14700 MALLARD CREEK ROAD CHARLOTTE NC 28262 I.U. No.: 2000 Sle No: 2821 Reporting UnIts: mG1L and Ibslday FINAL PERMIT. 09/2212008 to 05/3112010 Pipe # 1 2/1/2010 2/212010 2/3/2010 214/2010 21912D10 Period CM CM CM CM SM Average CYANIDE, TOTAL OI-N-BUTYL PHTHALATE -DIETHYL PHTHALATE DIMETHYL PHTHALATE ETHYLBENZENE FLUORANTHENE FLUORENE HFXACHLOROBENZENE HEXACHLOROBUTADIENE HEXACHLOROETHANE LEAD, TOTAL. - — — - - MERCURY, TOTAL METHYL CHLORIDE TC�1;17>L�►i�;7�iT.itTa MOLYBDENUM, TOTAL NAPHTHALENE A- Violations of Daily Maximum Limit on Permit B- Violations of Maximum Average Limit on Permit *- Denotes Technical Review Criteria (TRC) Violation Page: 4 312612010 Charlotte N,,Lklenburg Utility Department 15,21.08 System Protection Division Charlotte N.C. 39530 Period: 02/01/10 to 02/28/2010 AIM, ALLAN ORACION MALLARD CREEK POLYMERS, INCORPORATED 14700 MALLARD CREEK ROAD CHARLOTTE KC 28262 W. No.. 2000 SIG No: 2821 Reporting linos,. mO1L and IGstday FINAL PERMIT, 0912212008 to 06/31/2010 Pipe # t 211/2010 21212010 2/3/2010 2W2010 2/912010 Perlod CM CM CM CM SM Average NICKEL, TOTAL 0.01548 lbs NITRATE (NITRITE NITROBENZENE; NITROGEN OIL 8, GREASE - TOTAL < 5 mg/I m PHENANTHRENE PHENOL PHOSPHOROUS PYRENE SELENIUM, TOTAL SILVER, TOTAL TETRACHLOROETHYLENE TKN TOLUENE TOTAL SUSPENDED SOLIDS 6.192133 Ibs TRANS 1,2-DICHLOROETHYLENE A- Violations of Daily Maximum Limit on Permit B- Violations of Maximum Average Limit on Permit *- Denotes Technical Review Criteria (TRC) Violation Page: 5 3/26/2010 Charlotte Niw.:iclenburg Utility Department t 15:21:08 System Protection Division Charlotte N.C. 39530 Period: 02/01/10 to 0212812010 Attn: ALLAN ORACION MALLARD CREEK POLYMERS, INCORPORATED 14700 MALLARD CREEK ROAD CHARLOTTE NC 28262 I.U. No.: 2000 Sic No: 2821 Reporting Units: mG1L and Ibsiday FINAL PERMiT: 0912212008 to 0513112010 Pape A 1 21V2010 21212010 213/2010 214/2010 2/9/2010 Period CM Cm. CM CM SM Average TRICHLOROETHYLENE VINYL CHLORIDE ZINC, TOTAL pH A- Violations of Daily Maximum Limit on Permit B- Violations of Maximum Average Limit on Permit *- Denotes Technical Review Criteria (TRC) Violation 0.046883 lbs 8.4 Page: 5 3/26/2010 Charlotte Ni xklenburg Utility Department 15:21:08 System Protection Division Charlotte N.C. 38530 Period: 02101/10 to 02/2812010 Attn: ALLAN ORACION MALLARD CREEK POLYMERS, INCORPORATEX? 14700 MALLARD CREEK R FAO CHARLOTTE NC 28262 I.U. No.,. 2000 Sic No: 2821 Reporting Units: MGIL and Ibslday FINAL_ PERMIT: 09122/2008 to 0513112010 Pipe p 1 211012010 2/1112010 211212010 Period _ 5M SM_ SM Average FLOW 0.052584 0,051612 n.:1508E4 0.0536128 1,1,1-TRICHLOROET;iANE < 0.001103 0.001103 lbs 1,1,2-TRICHLOROETHANE < 0,001103 0.001103 lbs 1,1-DICIiLOROETHANE < 0.001103 _ 0.001103 lbs 1,1-0ICHLOROETHYLENE < 0.001103 0.001103 lbs 1,2,4-TRICHLOROBENZENI< 0.004411 0.004411 lbs 1,2-DICHLOROSENZENE < 0.004411 0.004411 lbs 1,2-DICHLOROETHANE < 0,001103 0.001103 lbs 1,2-DICHLOROPROPANE < 0.001103 0.001103 lbs 1,3-OICHLOROBENZENE < 0.004411 0.004411 lbs 1,3-DICHLOROPROPYLENf < 0.001103 _ 0.001103 lbs 1,4-DICHLOROBENZENE < 0.004411 0.004411 lbs 2,4-DIMETHYLPHENOL 2-NITROPHENOL < 0.004411 0.004411 lbs 4,6-DINITRO-0-CRESOL < 0.004411 0.004411 lbs 4-NITROPHENOL < 0,004411 0.004411 lbs A- Violations of Daily Maximum Limit on Permit B- Violations of Maximum Average Limit on Permit '- Denotes Technical Review Criteria {TRQ Violation Page: 7 3/2612010 Charlotte Ni.cklenburg Utility Department 15:21:08 System Protection Division Charlotte N.C. 39530 Period: 02/01/10 to 02128/2010 Attn: ALLAN ORACION MALLARD GREEK POLYMERS, INCORPORATED 14700 MALLARD CREEK ROAD CHARLOTTE NC 28262 I.U. No.: 2000 Sic No: 2821 Reporting Units: mGIL and Ibslday FINAL PERMIT: 09122/2008 to OW3112010 Pipe 1# 1 2110120i0 SM 211112010 SM 2/1212010 SM Period Average _ ACENAPHTHENE < 0.004411 0.004411 lbs AMMONIA 29A38732 29.872819 29.736824 23.802776 lbs ANTHRACENE < 0.004411 0.004411 lbs ARSENIC, TOTAL BENZENE < 0.001103 0,001103 lbs BIS(2-ETHYLHEXYL PHTW 0.006792 0,006792 lbs E30D-5 DAY C-SOD 69.245252 58.109951 60.237218 62.046717 lbs CADMIUM, TOTAL CARBON TETRACHLORIDE < 0.001103 0.001103 lbs CHLOROSENZENE < 0.001103 0.001103 lbs CHLOROETHANE < 0.001103 0,001103 lbs CHLOROFORM < 0.001103 0.001103 lbs CHROMIUM, TOTAL COD 168.48208 179.92563 165.86445 169.36977 - lbs COPPER, TOTAL T A- Violations of Daily Maximum Limit on Permit B- Violations of Maximum Average Limit on Permit *- Denotes Technical Review Criteria (TRQ Violation Page: 8 3126f2010 Charlotte N.-cklenburg Utility Department 15:z�:aa System Protection Division Charlotte N.C. 39530 Period: 02/01/10 to 02128/2010 Attn: ALLAN ORACION MALLARD CREEK POLYMERS, INCORPORATED 14700 PAALLARD CREEK ROAD CHARLOTTE NC 28282 W. Nu..- 2000 Sit, Na: 14021 ReporUng units: mG1L and Ibslday FINAL PERMIT: 09122/2008 to 0513112010 Pipe p 1 V1012010 2M 1/2010 2/12/2010 Period 5M SM SM Average CYANIDE, TOTAL DI-N-BUTYL PHTHALATE, < 0.004411 0,004411 Ibs DIETHYL PHTHALATE < 0.004411 0.004411 Ibs DIMETHYL PHTHALATE < 0.004411 0.004411 Ibs E=THYLBENZENE < 0.001103 0.001102 Ibs FLUORANTHENE < 0.004411 0.004411 lbs FLUORENE < 0.004411 0.004411 Ibs HEXACHLOROBENZENE < 0.004411 0.004411 Ibs HEXACHLOROBUTADIENE < 0.004411 0-004411 Ibs HEXACHLOROETHANE < 0.004411 0.004411 Ibs LEAD TOTAL MERCURY, TOTAL METHYL CHLORIDE < 0.001103 0.001103 Ibs METHYLENE CHLORIDE < 0.001103 0.001103 Ibs MOLYBDENUM, TOTAL. NAPHTHALENE < 0,004411 0.004411 Ibs . A- Violations of Daily Maximum Limit on Permit 8- Violations of Maximum Average Limit on Permit *- Denotes Technical Review Criteria (TRC) Violation Page: 9 3126/2010 Charlotte lf..+cklenburg Utility Department 15:z1:B System Protection Division Charlotte N.C. 39530 Period: 02/01110 to 02/2812010 Attn: ALLAN ORACION MALLARD CREEK POLYMERS, INCORPORATED 14700 MALLARD CREEK ROAD CHARLOTTE NC 28262 I.U. No.: 2060 Ste No: 2821 Reporting Units: mG11., and Ibslday FWAL PERMIT: 0912212008 to 05/31/2010 Pipe # 1 211012010 211 U2010 2/12/2010 Period SM SM SM Average NICKEL, TOTAL 0.0113673 0.015496 0.01315 0.0144498 lbs WRATEMITRITE NITROBENZENE < 0.004411 0.004411 lbs NITROGEN OIL & GREASE - TOTAL < 5 14 13 9.25 mgf l PHENANFHRENE < 0.004411 0.004411 Is PHENOL < 0.004411 0.004411 lbs PHOSPHOROUS PYRENE < 0.004411 0.004411 lbs SELENIUM, TOTAL SILVER, TOTAL TETRACHLOROETHYLENE < 0,001103 - 0.001103 lbs TKN TOLUENE < 0.001103 0.001103 lbs TOTAL SUSPENDED SOLIE 13.231577 18.93954 15.271407 13.408664 lbs TRANS 1,2-DICHLOROETH < 0.001103 0.001103 lbs A- Violations of Daily Maximum limit on Permit B- Violations of Maximum Average Limit on Permit *- Denotes Technical Review Criteria (TRC) Violation Page:10 3/2612040 Charlotte 1►-Alenburg Utility Department 15:21:08 System Protection Division Charlotte N.C. 39630 Period: 02/01/10 to 02/28/2010 Attn: ALLAN ORACION MALLARD CREEK POLYMERS, INCORPORATED 14700 MALLARD CREEK ROAD CHARLOTTE NC 28262 W, No.: 2000 Sic No: 2821 Rapwthlg Jnits: mG,I- and lbsiday FINAL PERMIT: 09/2212000 to 0513112010 Pipe # 1 2/10/2010 2111/2010 21121,,2010 Perlod Sm SM SM Average TRICHLOROETHYLENE < 0,001103 0.001103 lbs V€NYL CHLORIDE < 0.001103 u.001 i 03 lu; ZINC, TOTAL 0.043664 0,055958 0.042845 0.0473375 lbs pH 9.1 8.6 8.9 Evaluated by: A- Violations of Daily Maximum Limit on Permit B- Violations of Maximum Average Limit on Permit *- Denotes Technical Review Criteria (TRC) Violation Mcp YM S` .tune 3. 2010 Dee Browder Division of Water Quality Subject: 06-02-10 Stormwater Permit Event Mallard Creek Polymers, Inc. Stormwater Permit No. NCG090006 Ms. Browder, As per our discussion. below is an event summary and corrective action plan regarding Mallard Creels Polymers' 06-02-10 Storniwater Permit event. Event Summary A 2" hose ruptured while transferring processed water from tank T-951 to tank T-630. An air pump was situated at T-951 with hose connections from T-951 to the pump (suction) and from the pump to the hard pipe leading to "f-630 (discharge). The estimated flow of the pump was 25 gpm, and T-630 was pulling fluid with a vacuum. The leak occurred at a F ruptured hole on the discharge line close to the pump. It was estimated that the leak occurred over a 2 hour period with a volume of approximately 750 gal. The night shift supervisor noticed the leak during his normal walkthrough rounds and immediately shut the valve feeding the leak. The water was contained inside the property: however, some of the water did travel about 250 ft reaching one of our stormwater outfall points which feeds a tributary of Mallard Creek beyond our fenceline. Under normal circumstances the processed water would be fcd to our stripper column which pulls vapors to be incinerated and sends the water to our wastewater stream to CMUD. On 6/2/10, the stripper column was down for maintenance and processed water was temporarily redirected to T-951. The chemical of concern associated to this processed water is styrene. It has a recordable quantity (RQ) of 1000 pounds. We took a water sample at approximately 200 yards from the fenceline. Gas chromatography analysis showed a 2 ppm concentration of styrene for the sample. A conservative estimate of the volume of water that reached the outfall point would be half ofthe 750 gal leak. Using, the volume of 750 gal as a worst case scenario and 2 ppm concentration, this equates to a total o1_ I.248 1b of' styrene released, which is well below the styrene RQ. Root Cause of Event A 2" hose used to connect pump on the discharge side ruptured due to wear and tear. 1 ofz [4801) Hallard Creek RvA. Charlotte. NC 28262: el: (704) 547-0677: I'ax: t7Qa) 547-9849 Period of Non Compliance The [ease occurred on 6/2/10 and was discovered and contained at 4:00 AM. On 6/2/10 at 7:00 PM, .Icf'f Mitchell, Mc:cldenberg County Water Quality perl'arrl,c<<I irlspc c'iimn ofthe tributary water. On 6/3/ l0 Mr. Mitchell continued with his inspection and did observe a dead tish count that was over the ?5, counts tllreshn!d. The 55111 were rcmovcd from tlic ihutcr. There were areas in the tributary that were below the threshold 5 mg/nil D.O. and that also showed high conductivity. Oil 6/3/10 at 3:00 PM, under (lie direction ol'Mr. Mitchell, Mallard Creek Polymers began a city water flush fallowing the path of tltc leak. The flushing ended at 2:00 AM on 6/4/10 as per instruction of Mr. Milchell_ All esiil?lated 67.760 gals of'city water was used during the flush. Oil 6/4/10 at 9:22 AM, Mr. Mitchell completed re -sampling and indicated that all levels were good and water was clear. The leak did not have any contact with the pretreatment water system, and this was discussed with Regina Cousar, CMUD Environmental Compliance Manager. The stormwater event was also reported to the National Response Center, Tim Smith, in which report # 942-592 was obtained. Details of the stormwater event were discussed with Jennifer McNew of the National Toxic Substance Incidents Program who received report of the incident from the NRC. Corrective Action Short -terns- Stripper column maintenance was completed and column was back in service on 6/2/10 at approximately 12:30 PM. T-951 was emptied and water was sent to the stripper column. In the event the stripper column needs to be put out of service and T-951 used again. all pumping operations will be planned by an employee until the transfer is completed and valve is closed. Long-term- Mallard Creek Polymers is investigating a long -terra solution to prevent reocurrence. The primary option is to hard -pipe all suction and discharge lines of the pump situated at T-951. Stainless steel pipe will be used if this primary option is selected which is optimal For compatibility. Protection of lines from accidental damage will be ensured. In addition, the retaining wall which should have prevented any process water front entering the outfall point will be repaired. If you have any questions or concerns, please feel tree to call ire a 704-547-0622. Sincerely, Allan Qracion Compliance Manager Cc: File 14800 Ndi lard C'rre€c Road. Charlotte. NC 28262: Td: (704) 5474)&72: (704) 547-8849 Page 2 of'2 0 MCP y Polmers July 19, 2010 Mr. John Hennessey Wetlands and Stormwater Branch NPS Assistance and Compliance Oversight Unit 610 East Center Ave., Suite 301 Mooresville, NC 28115 SUBJ: Request for Information Notice of Violation Tracking Number: NOV-2010-DV-0254 and Incident Number: 201001970 Mallard Creek Polymers, Inc. Stormwater Certificate of Coverage NCG090006 Mecklenberg County, North Carolina Mr. Hennessey: Below please find information which was requested by the NCDENR regarding the June 2, 2010, spill that occurred at the Mallard Creek Polymers (MCP) facility located at 14700 Mallard Creek Road, Charlotte, Mecklenberg County, North Carolina. This information is considered confidential business information by Mallard Creek Polymers. 1. Final Long -Term Corrective Action: To prevent a future release of process wastewater, MCP has completed hard -piping the suction and discharge lines of the pump situated at T-951, and the pump situated at T-951 is permanently fixed. The pipe is a two (2) inch, all welded, stainless steel pipe which is optimal for compatibility. Stainless steel, flexible hose is used directly at the pump to prevent any issues that may result from pumping vibration. The pipe is supported with concrete footings. Photo documentation is attached (Attachment 1A-1 E). In addition, the tank has been structurally tested by Non -Destructive Evaluation International (NDEI ) and is confirmed to be structurally sound. Documentation is attached (Attachment 2). T-951 and T-952 are included in the preventative maintenance schedule for structural testing every five (5) years. Mallard Creek Polymers, Inc, 14700 Mallard Creek Road, Charlotte, NC 28262-0499 704-547-0622 2. Repair of the Retaining Wall: MCP has completed the repair of the retention wall that should have re- directed spilled water to a MCP sump, which could then be re -directed to the MCP Industrial Pond. (Investigations found that water had seeped underneath the retention wall to reach the stormwater outfall).The repair included fortifying the retention wall by pouring a one (1) foot wide by three (3) foot deep concrete slab on the inside of the retention wall. The new concrete slab was sealed to the existing retention wall to prevent water from entering in-between. The three foot depth extension prevents water from penetrating below the wall. Performance of the repair was observed during a heavy rain event on 6-30-10 in which there were no penetrations of the retention wall. An invoice of the repair is attached (Attachment 3) as well as photo documentation (Attachments 4A-4D). 3. Copy of the Spill Prevention and Response Plan indicating: « Procedures and/or physical barriers that will be used to prevent and mitigate the discharge of wastewater or other raw chemicals through the on -site stormwater outfalls- see attached (Attachment 5). • Actions to be taken once a release has occurred- see attached (Attachment 6). If you have any questions related to this Response to the Information Request, please contact Allan Oracion at (704)-547-0622 (x 1009). Sincerely, Dan Ned Frank Samartino Vice President and General Manager Operations Manager Mallard Creek Polymers, Inc. 14700 Mallard Creek Road, Charlotte, NC 28262-0499 704-547-0622 Attachment 1B .14 ff. 7--t'N" ; _ J : ��•v��• � 1v h r,�,�r, --ti `i w b. r.s"�R_ +.� . �� ` � ' � l'ttl's`"'; fffff'✓ v� r r � � ��� �.r! ,� �'� ��a' � +w 7 �" ; DOM gi mew INI 1p �n� fir'. ,ti �,, > ;' �. c '�;' .. -1 �`�t � � ram• .� �..-: .. .- +�.� V/fir � . ��t+- 1 � r W."' •'_���"ti.. R �, ; , ']�;� i ,�T•+� _ r �.: �..' . _ �r$::�r"�a, _,-. �� i'r'!r� c e'�•:� .�"�.r , +-•erg►--'.`+�"`�.-.. : :r=--ic--_----: i� �'y ..Er: �' ^�4 1. "1t.- �e -Tti" "' r �J.: �:� �q.�.. �,,, r S.•Lr 1 F r 0 �, .,jwT '� �OWf�'F *. i� �•.� �Ai i' i �... r' � '+i"5)4 �'F �•+r-ate': Y� . � #� � � ,4, / ti . .\ � -- . >,� err � � � � �f.•. J `1/'�' •.'y`n`: ¢�+� � ark j. � .. ,; � • r � .f..� Y3P � � Yjts ��. -i'.J� x t yl' � v ���IJ(, •. .a ��-iL� l Imo.-s ,ri .j"' \li' �� '� • 1 VNIA _ •� / y}�� ;+ems ��. � lkAla{ 4. '�•1 f,�., _ - it < T �S '�� •�' Attachment 2 July 9, 2010 Mallard Creek Polymers Storage Tanks T-951 & T-952 RE: Tank Corrosion Rate and Suitability for Service Calculations Corrosion Calculations were prepared in accordance with API-653 for Storage Tanks T-951 and T-952. The calculations were made for the first course (bottom) only, using the following assumptions: The tanks were installed in 1985. The tank material of construction is an carbon steel grade. The tank joint efficiency was taken as 0.70 The product specific gravity is 1.0 The results of the calculations indicate the tank has experienced only minor metal loss due to corrosion during the estimated twenty-five (25) years in operation. The calculations indicate the tank is in satisfactory condition for continued service with an estimated remaining service life in excess of approximately fifty (50) years. A copy of each calculation is attached. Prepared by: James A. Conroy, P.E. New Jersey Registration No. GE-30112 API-653 Certificate No. 329 Attachment r %tpopy INVOICE NO. K30-018A HIPP NET 10 DAYS TO; Mallard Creek Polymers INVOICE DATE: 6/29/10 14700 Mallard Creek Road Charlotte, NC 28262 ATTENTION- Mr. Larry Mull RE: Containment Curb 1. Furnish labor, materials and equipment to pour containment curb per quote. 4,443.00 2. Extra cost incurred to increase length appx. 25,'. 448.00 TOTAL AMOUNT DUE. Thank you, Hipp Construction Company BY: Jeold T'.-' , H JTH/f ep resident ),I REMIT TO. HIPP CONSTRUCTION COMPANY POST OFFICE BOX 26854 s, CHARLOTTE. NORTH CAROUNA 2B221-6B64 * [704) 5E6-7493 * FAX (7041595-3794 RD NO. 56-0897288 1 j .t/" : •' �' � A�- ' jai / i/� � f , �1 I Sir -}�`•,j`' y • 'y:� -7`?.; r� ti Ssr, f, E / / rl t: r �Vi � �j" Jl�e CIS �'��/ _ f-f� `tF �4 •,l �j..� + { -1 }�' t �"• r 's'1�+yr+,�J`c�.� s•. r fj�� ")_q"S� ��RF�s�i s 4 ?_ c:� M- . � f tLL I t., �� .l � i f� ' 'fit i •.1 'J"" C ! r ,�L. f_, rS ! � r ��s !y�`r,' . '• '-� �¢ ' r4.4' � '� . h. s F? '.�'K � f'. f-s-K �>'� yj ;7 `r.�' �f t n � -�ytn�y.���f �, 1�-�y� �}s�4•hf•+ �t -�:; � t1�<� �r:1;��C"� a N"i' jfre• i �; �- it x 3,,.t��'� JP- •.: s��f��• ,a. ^�. 4 �•�(�!/�yr),�k. ��t° �1:_ ' s r 'f � i ' � '+# � •�r'I s r9 f rr' ��.' �Y�.���� •`�1�.�✓�rvf "�7._ f � i�i r r, :t ; ;� Jar ,r,�,��� ��4 4,+, 4�� •1•�t �+,#�` � {�k A 5. 'y1��{� �r�`�9w- � _ � •}�. � � � , ��r' 6 ���i.F. •rye r •r.r + c- : . LQ 11r, 'i . t , ! -• �•, 3, tC�-its ri' • ('_ ["�' OF ' ♦ s r ArfAif (,�44 s� a „„"��s"{����,5 c- rl�S s �Fsf tom• ►�ri#r��l � ���,�r1 Y.1']� f}.�f. a I _ fr � • J �' �r��1 ;,��.ta`y� �v � ��� `yS-i� .,.�` -s .•1�' ���,. �i�}{r'�; ''t�. � \ � + � 1 � •.� > �� i p'S� 1. ► p��, �i.7r'u....r, �� �''•r�3'e�a.r��IT �- r���i1r�-_,'w� -rp� _ �/. i.1�I�,, 74 it - "� �'7`' ' �,� .� «Il",1+�'•P�>'�'r��t f Vll� I+- 4 Attachment 5 7.7.2 Ouarterly Inspections A more detailed visual inspection of the petroleum equipment and containment systems shall be conducted every quarter and shall follow the checklist included in Attachment 6. Record spills or leaks that are discovered on the MCP All form, and any repairs will be top priority. Work orders will be written to address potential leakage problems. Spill or leak A/I reports will be logged into the All database/spreadsheet. Any corrective actions to prevent recurrence will be noted on the A/I file, 7.7.3 Prevention of Discha a to On -Site Storrnwater Outfalls The following procedures or physical barriers are incorporated into the design of the storage containers/facilities at the MCP's plant site to prevent releases. • Above -ground storage tanks are constructed with either an earthen berm or concrete dike containment system which will hold the volume of material in the largest tank in addition to a 6-inch rainfall or where more than one tank is contained, the containment shall hold 10% of the total volume, whichever is greater. Note- T-951 & T-952 temporary -use tanks are hard -piped and all -welded • Process Area Operations Facilities are configured with a concrete pad and trench containment system which drains to the site wastewater storage pond. • Tank trailer transloading facilities are equipped with concrete or asphalt containment systems. Most transfer pumps are configured with double mechanical seals to reduce the potential of leakage. Operators are trained on proper transfer procedure, will follow proper transfer procedure and are in attendance during the transfer process. • Transfer piping is predominantly welded, and where threaded pipe exists, concrete containment is provided. • The plant is equipped with curbing and water impoundments and is divided into four areas which drain liquids that are outside of containment systems or dike containments to one of the four corresponding collection sumps. The sumps are equipped with a submersible Flygt pump with a rated capacity of 120 GPM at 35 feet of head. The sumps are automatically activated and can be pumped to either the Industrial or Stormwater Pond. • A secondary containment wall/system re -directs water to sump nos. 1, 2 or 3 and prevents releases from accessing stormwater outfalls. CP Engineering and Environmental Solutions 21 SPCC Plan (Revision #1) Tel: (704) 541-4042 Mallard Creek Polymers, Inc. Email: cvpakala@carolina.rr.com 14700 Mallard Creek Road CPEES Project No. 1010-018 Charlotte, NC 28262 • Bi-annual inspections of stormwater management devices and facilities are conducted which will include observation of the secondary containment wall during a rain event. • Preventative maintenance of critical facility equipment. • Daily inspections of dike containment areas and tanks. 0 Daily inspection of area and facility sumps. • Daily inspections of stormwater and wastewater accumulation areas. • Periodic visual inspection and integrity testing of tank structural integrity. • Pollution prevention training will be held annually for employees who are involved in any of the facility's operations that have potential to contaminate stormwater runoff. • Protective guards are placed around tanks and piping to prevent vehicle or forklift damage. • Tanks, associated valves and piping are clearly labeled to reduce human error. 7.7.4 Records The Compliance Manager is responsible for maintaining all records related to the SPCC Plan, including employee training, inspections, and certifications. All records pertaining to this SPCC plan will be maintained for a minimum of 3 years. Training records may be maintained with the facility training records. The remaining SPCC records will be maintained in the SPCC files. 7.7.5 Inspection and Record keeping II12.7(e)1 The following forms are to be completed when appropriate as designated below. Copies of each completed form are to be maintained with this SPCC Plan or as designated below. • Oil Spill History (Attachment 1)- Required/Maintained in SPCC Plan • Five Year Plan Review (Attachment 2)- Required/Maintained in SPCC Plan • Record of Tank Integrity Tests (Attachment 3)- Supplement to Test Records/Maintained in SPCC Plan • Spill Prevention Briefing (Attachment 4)- Sample Only/Do not use • Environmental Incidents and Spill Reporting Form (Attachment 5)- Supplement to A/I Report/Maintained in A/I Folder • Oil Tanks Inspection Form (Attachment 6)- Required/Maintained in SPCC Plan • Drainage Discharge Disposal Form (Attachment 7)- Use as Needed/Maintained in SPCC Plan CP Engineering and Environmental Solutions 22 SPCC Plan (Revision 41) Tel: (704) 541-4042 Mallard Creek Polymers, Inc. Email: evpakala@carolina_rr.com 14700 Mallard Creek Road CPEES Project No_ 1010-018 Charlotte, NC 28262 Attachment 6 EPA State 112.4 c Regional Administrator Regional Supervisor US EPA, Region 4 NCDENR - Water Quality Section Sam Nunn Atlanta Federal Center Charlotte Regional Office 61 Forsyth Street, SW 610 East Center Ave. Suite 301 Atlanta, GA 30303 Charlotte, North Carolina 28115 404-562-9900 or 800-241-1754 704-663-1699 8.6 Hazardous Substance Discha a Notification Procedures The MCP has hazardous substances stored at a quantity greater than the CERCLA reportable quantity (RQ) for that substance. The RQ is determined based on the undiluted volume released. Material that is released to impervious surfaces and subsequently cleaned up does not require reporting. However, if this hazardous substance is released to the environment (i.e., soil or water) and the volume is greater than the RQ limits, the release must immediately be reported to the following agencies: • National Response Center (U.S. Coast Guard) • EPA Region IV — Atlanta, GA • North Carolina Emergency Response Commission • Mecklenburg County Emergency Management These agencies will likely require follow-up reports and copies shall be maintained with the SPCC file. 8.7 Release/Discharge to Surface Waters Procedure The following measures should be implemented upon the discovery of a release: 1. Assess The Risk- The risks (toxicity, ignitability, and/or corrosivity) presented by a release should be. assessed the momenta release is observed or discovered. Because risks can change throughout an emergency, assessing the_risk should continue throughout the duration of the incident. • Eliminate possible sources of ignition if necessary. • Shut off engines, if necessary. • Shut off electrical power, if necessary.. CP Engineering and Environmental Solutions 29 SPCC Plan (Revision #I) Tel: (704) 541-4042 Mallard Creek Polymers, Inc. Email. cvpakala@carolina.rr.com 14700 Mallard Creek Road CPEES Project No. 1010-018 Charlotte, NC 28262 2. Control The Release- Every effort shall be made to keep a spill from entering the storm system. Facility personnel shall immediately commit all necessary manpower, equipment, and materials. Control methods include: • Closing valves • Shutting off pumps • Using absorbent materials such as clay, sawdust, or vermiculite to absorb liquids. Place material in direct contact with the liquid. Start on the outer border working inward. • Dikes, dams, diversions, and retention - Temporary dikes, dams, diversions, or retention pits can be used to retain spills, change the direction of flow of the liquid, or minimize stormwater run-on to the impacted area. • Place plastic sheets or mats over outfall entrances or drains leading to outfalls. Weigh them down with heavy objects or gravel. Use booms to divert spills around drains leading to outfalls. • Liquids can be transferred from a leaking or damaged container or tank. Care must be taken to ensure transfer hoses and fittings are compatible with the liquid. When flammable liquids are transferred, proper concern for grounding must be observed. • Consider assistance from outside contractors if necessary. Haz mat (704)332-5600. 3. Report the Release- Immediately after initiating appropriate emergency measures to confine the release, the supervisor should report any environmental release to the Operations Manager and/or Compliance Manager. The Operations or Compliance Manager will make the proper notifications to government agencies as soon as possible but no later than 24 hours. Notifications include: * Local Fire Department if necessary (911) * Police Department if necessary (911) * NCDENR Water Quality (704)663-1699 * Mecklenberg County Water Quality (704)336-5500 * National Response Center (800)424-8802 * Charlotte Mecklenberg Utilities Department (704)336-4636 When the release involves a hazardous chemical with a defined Reportable Quantity (RQ the quantity of the chemical release will need to be determined and information provided during the government agency notifications. There can be severe penalties for failing to notify immediately. Be prepared to provide the following information: The chemical name or identity of any substance involved in the release; An indication of whether the substance is an Extremely Hazardous Substance; An estimate of the quantity of any such substance that was released; CP Engineering and Environmental Solutions 30 SPCC Plan (Revision #1) Tel: (704) 54I-4042 Mallard Creek Polymers, Inc. Email: cvpakala@carolina.rr.com 14700 Mallard Creek Road CPEES Project No. 1010-018 Charlotte, NC 28262 * The time and duration of the release; * The medium or media into which the release occurred; * Any known or anticipated acute or chronic health risks associated with the emergency and where appropriate, advice regarding medical attention necessary for exposed individuals; * Proper precautions taken because of the release, including evacuation; and * The names and telephone numbers of the person or persons to be contacted for farther information. Keep a telephone notification log. Worksheet E2 of Appendix E of the SWPP Plan should be used to document telephone notifications. Notification information to be documented includes: * Date/time of call; * Agency and officials contacted; * Who made the call; and *_ Any comments made by officials, including any reference number assigned to the incident by the agency.: According to the North Carolina Stormwater General Permit No. NCG090000, MCP must provide oral notification of the release to surface waters within 24 hours to the appropriate regional office. A written submission to the same agency must be provided within 5 days of the time that the facility became aware of the circumstances of the non-compliance. 4. Clean Up The Impacted Area- Cleanup should begin as soon as possible. Samples will be taken at points throughout the unnamed tributary to Mallard Creek for the analysis of D.O., pH and TSS. Fish kill will be observed throughout the tributary. Sample points include:. • The drain pipe at the fenceline. • Approximately 200 yards from the drain pipe. • Approximately 500 yards from the drain pipe (end of wooded area). • Bridge at Dixie Ann Drive • Points beyond as needed. CP Engineering and Environmental Solutions 31 SPCC Plan (Revision 91) Tel: (704) 541-4042 Mallard Creek Polymers, Inc. Email: cvpakala@carolina.rr.com 14700 Mallard Creek Road CPEES Project No. 1010-018 Charlotte, NC 28262 Local spill response contractors, who can provide clean up services is Haz—mat. (704)332-5600. Local lab that can provide sample analysis is Par Labs. (704)588-8333. Clean up efforts will be coordinated with officials of NCDENR and Mecklenberg County Water Quality after notification has been made. A clean-up option is: • 10-1.2 hour water flush of tributary using city water. The_Conipliance Manager will determine and arrange for proper treatment, storage, and disposal of spilled materials. 5. Follow Up Action- An MCP team will review the cause of the release and initiate appropriate corrective actions to prevent similar occurrences. All spill kits and sorbent material will be restocked. The Compliance Manager will be responsible for preparing and submitting any written follow-up reports required by government agencies and for reporting the release to the Management Team through the Accident/Incident Reporting System, as well as updating this plan, as appropriate. 8.8 Disposal Plan The environmental cleanup contractor will handle the disposal of any recovered product, contaminated soil, contaminated materials and equipment, decontamination solutions, sorbents, and spent chemicals collected during a response to a discharge incident. Any recovered product that can be recycled will be placed into the gun barrel tank to be separated and recycled. Any recovered product not deemed suitable for on -site recycling will be disposed of with the rest of the waste collected during the response efforts_ If the facility responds to a discharge without involvement of a cleanup contractor, MCP will contract a licensed transportation/disposal company to dispose of waste according to regulatory requirements. The Compliance Manager will characterize the waste and arrange for the use of certified waste containers. All facility personnel using spill kits are trained once every year. CP Engineering and Environmental Solutions 32 SPCC Plan (Revision #1) Tel: (704) 541-4042 Mallard Creek Polymers, Inc. Email: cvpakala@carolina.rr.com 14700 Mallard Creek Road CPEES Project No. 1010-018 Charlotte, NC 28262 kb- t` RA NCDENR North Carolina Department of Environment and Natura Division of Water Quality Beverly haves Perdue Coleen H. Suilins Governor Director June 3, 2009 Mr. Allan Oracion, Compliance Manager Mallard Creek Polymers Corporation 14800 Mallard Creek Road Charlotte, NC 28262 Resources Subject: Follow-up Compliance Evaluation Inspection Mallard Creek Polymers 14800 Mallard Creek Road Stormwater Permit Number COC NCG090006 Mecklenburg County, NC Dear Mr. Oration: Dee Freeman Secretary Enclosed is a copy of the Follow-up Compliance Evaluation Inspection (CEI) report for the inspection conducted at the subject facility on April 23, 2009, by Ms. Aliyah Turner 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 II Section H. Thank you for your assistance and cooperation during the follow-up inspection. The follow-up inspection found that Mallard Creek Polymers Corporation has implemented the corrective actions as stated in the perrnittee's response letter dated October 20, 2008. The corrective actions include: The permittee recognizes that they are not eligible for a No Exposure Certification at this time. Qualitative and analytical monitoring have been performed at all documented stormwater outfalls, • The concrete berm has been repaired, • The diesel fuel aboveground storage tank (AST) has been labeled, the leak has been repaired, and the gravel surface affected by the leaking oil has been restored, • The permittee has implemented regular cleanings of grates that carry wastewater to the treatment system, and • The permittee has updated and implemented the Stormwater Pollution Prevention Plan (SPPP) as of October 2008. Mooresville Regional Office Location: 610 East Center Ave„ Suite 301 Mooresville, NG 28115 One Phone: (704) 663-16991 Fax: (704) 663-60401 Customer Service: 1-877-623-6748 NorthCa� o�ina Internet: www.ncwaterquality.org An Equal Opportunily , Aifinra8ve Adon Employer -- 50% Recyc!edAO% Post Censur,;er paper Naturally' r Mr. Allen Oracion, Mallard Creek Polymers Follow-up CEi, Page 2 June 3, 2009 The enclosed follow-up inspection 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. Marcia Allocco of this Office at {'+04 1 663-1699. Sincerely, for Robert B. Krebs Regional Supervisor Surface Water Protection Section Mooresville Regional Office Enclosure cc: S. Sullivan, NPS-ACO Unit Rusty Rozzelle, Mecklenburg County Craig Miller, City of Charlotte Permit: NCGO90006 SOC: County: Mecklenburg Region: Mooresville Compliance Inspection Report Effective: 11/01/07 Expiration: 10/31/12 Owner: Mallard Creek Polymers Inc Effective: Expiration: Facility: Mallard Creek Polymers Incorporated 14800 Mallard Creek Rd Contact Person: Allan Oracion Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Charlotte NC 28262 Title: Phone:704-547-0622 Certification: Phone: Inspection Date: 04123/2009 Entry Time: 09:53 AM Exit Time: 11:15 AM Primary Inspector: Water Quality Program Mecklenburg County Phone: Secondary Inspector(s): Reason for Inspection: Follow-up Inspection Type: Compliance EValuation Permit Inspection Type: Paints, Varnishes, Lacquers Stormwater Discharge COC Facility Status: ■ Compliant 0 Not Compliant Question Areas: ■ Storm Water (See attachment summary) Page 1 Permit: NCGO900C6 owner -Facility : Mallard Creek Polymers fnc Inspection Date: 0412312009 Inspection Type: Compliance Evaluation Reason For Visit: Follow-up Inspection Summary: Facility Description: ihig fariiity is a rhpmir91 mantjfarttiring plqnf Pnqaged in making I?tpY for variniiG prnrii.irtg ThP far,rlity nparatag 7 rlavc a wQex On a iu hniijr-a-day grhQri lie t.r-�mplianci- Histnry' The Mecklenburg County Water Quality program (N1CVVQP.) record dates back to 1995 and there have been no incidents noted by MCWQP at the facility during this period. The facility reported no significant incidents within the last five years. Charlotte Mecklenburg Storm Water Services inspected the facility on March ib. 2008. ` ne Division of Water Quality issued a Notice of Violation as a result of the inspection. Industriai OperationsfCit'y of Charlotte Stormwater Ordinance Review. During the initial inspection the facility stated its non -discharge operating strategy for wastewater/stormwater onsite. The inspector thought the permittee should review a few areas related to this strategy including: the ability of the facility pump stations to pump during high flow situations and assess areas where the concrete berm containment structure may be compromised (breaks/leaks/gates). The inspector also noted an unlabeled AST, which was also leaking. The inspector noted a discharge from Cooling Tower #3 which could be a source of stormwater contamination. On April 23, 2009, Ms. Aliyah Turner of MCWQP conducted a follow-up inspection and observed that the facility has addressed all the deficiencies and recommendations in the Industrial Operations/City of Charlotte Stormwater Ordinance Review section from the initial inspection report. The permittee has reinforced the berm to prevent wastewater discharges from passing through the berm and entering into the storm water conveyance system. According to facility personnel, coolant water was not leaking onto the ground as was previously reported. The leak was discharging from broken emergency shower piping The leaking substance did not contain any contaminants. Page: 2 Permit: NCGO90006 Owner - Facility: Mallard Creek Polymers Inc Inspection Date: 0412312009 Inspection Type: Compliance Evaluation Reason for Visit: Follow-up Stormwater Pollution Prevention Plan Yes No NA NE Does the site have a Stormwater Pollution Prevention Plan? ■ ❑ Q U # Does the Plan include a General Location (USGS) map? ■ U D n # Does the Plan include a `Narrative Description of Practices"? ■ D U U # Does the Plan include a detailed site map including outfall locations and drainage areas? ■ D U D # Does the Plan include a list of significant spills occurring during the past 3 years? ■ 0 D U # Has the facility evaluated feasible alternatives to current practices? ■ ❑ ❑ D # Does the facility provide all necessary secondary containment? ■ n U D # Does the Plan include a BMP summary? ■ n n n # Does the Plan include a Spilt Prevention and Response Plan (SPRP)? ■ U D U # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ■ n n U # Does the facility provide and document Employee Training? ■ D D U # Does the Plan include a list of Responsible Party(s)? ■ ❑ Q ❑ # Is the Plan reviewed and updated annually? ■ n n n # Does the Plan include a Stormwater Facility Inspection Program? ■ n n n Has the stormwater Pollution Prevention Plan been implemented? ■ ri n n Comment: During the follow -tap stormwater inspection conducted on April 23, 2009, the permittee's updated Stormwater Pollution Prevention Plan (SPPP) was observed. The facility site map and general location map (USGS) reflected the facility's documented outfalls. The plan also included a detailed narrative description of practices, list of spills within the last five years (there have not been any spills), included a feasibility study, secondary containment records, BMP summary, Spill Prevention and Response Plan (SPRP), Preventative Maintenance and Good Housekeeping Plan, employee training, an updated list of responsible parties, and a stormwater facility inspection program. Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ■ U U U Comment. The initial inspection found that the permittee had not conducted qualitative monitoring at all outfalls on site due to the two additional outfalls identified by the inspector. During the follow-up stormwater inspection conducted on April 23, 2009, the permittee provided qualitative monitoring documentation dated 8/26/2008. The permittee has conducted qualitative monitoring at the facility's three documented outfalls. Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? .0000 Page 3 Permit: NCGO90006 owner - Facility: Mallard Creek Polymers Iric Inspection Date: G4123t2009 Inspection Type: Compliance Evaluation Reason for Visit: Follow-up # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? 0 0 ■ n Comment: The initial inspection found that the permittee had not conducted analytical monitoring at all outfalls on site due to the two additional outfalls identified by the inspector. During the follow-up stormwater inspection, the permittee provided analytical monitoring documentation dated 8/26/2008. The per€;iittee conducts analytical toonitorinc3 at the facility's three documented outfalls. Permit and 9utfatls c Yas No NA NE # is a copy of the Permit and the Certificate of Coverage available at the situ ■ 0 ❑ 0 # Were all outfails obserted during the inspection? ■ rl t_-t ni # If the facility has representative outfall status, is it properly documented by the Division? 0 0 ■ 0 # Has the facility evaluated all illicit (non stormwater) discharges? ■ C33 D Comment: During the initial inspection two additional outfalls were identified and the inspector found that an evaluation of illicit discharges at the stormwater outfalls had not been completed. During the follow-up stormwater inspection conducted on April 23, 2009, three stormwater outfalls were observed and had been documented in the facility SPPP. The permittee provided documentation of an evaluation of non-stormwater discharges for all outfalls. Page: 4 Mtcn= r_ tasiev, Ctovernor William G. Ross Jr., Secret North Carolina Department of Environment and Natural Resourc r Coleen H. Sullins, Director `f Division of Water Quality July 15, 2008 CERTIFIED MAIL 7007 1490 0004 4509 5928 RETURN RECEIPT REQUESTED Mr. Frank Samartino, Operations Manager Mallard Creek Polymers, Inc. 14800 Mallard Creek Road Charlotte, North Carolina 28262 Subject: Notice of Violation Tracking Number: NOV-2008-PC-0520 Compliance Evaluation Inspection Mallard Creek Polymers facility Stormwater Permit Number NCG090000, COC NCG090006 Mecklenburg County, NC Dear Mr. Samartino: Enclosed is a copy of the Compliance Evaluation Inspection (CEI) report for the inspection conducted at the subject facility on March 18, 2008, by Mr- Christopher Elmore and Ms. Aliyah Turner 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 II Section H. Thank you for your assistance and cooperation during the inspection. This report is being issued as a Notice of Violation (NOV) due to the permittee's failure to properly maintain and implement the required Stormwater Pollution Prevention Plan in violation of the subject Stormwater Permit and North Carolina General Statute (G.S.) 143-215.1, as detailed in the Stormwater Pollution Prevention Plan, Qualitative Monitoring, Analytical Monitoring, and Permit and Outfalls sections of the enclosed report. 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. ATA One Noo��tttCaro ina NCDENR Aaturally Mooresville Regional Office Division of Water Quality Phone 704-663-1699 Customer Service Internet: wwu.ncwater uali r 610 East Center Ave, Suite 301 Mooresville, NC 28115 Fax 704-663-6040 1-877-623-6748 An Equal Opportunity/Affirmative Acf on Employer — 50% Recyded/10% Post Consumer Paper Mr. Samartino, Mallard Creek Polymers NOV-2008-PC-0520, Page 2 Julv 15, 2008 In addition, several conditions identified during the inspection must be addressed in order to comply with the City of Charlotte Stormwater Ordinance and to maintain good housekeeping. These conditions are documented in the Industrial Operations/City of Charlotte Stormwater Ordinance Review section of the report. It is requested that a written response be submitted to this Office by August 15, 2008, addressing the above -noted violations/de iciencies in the enclosed report. In responding to the violations, please address your comments to the attention of Ms. Marcia Allocco at (lie letterhead address_ The enclosed report should be sell-explanwory; 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 (7041 663-169g, 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 U.S. Postal Service,f., CERTIFIED MAIL,„ RECEIPT (Domestic Mail Only, No Insurance Coverage provided) For delivery information visit our website at www.usps.coms grim _ .: mom r '-q MR FRANK SAMARTINO, OP. MGR. r� MALLARD CREEK POLYMERS � 14800 MALLARD CREEK ROAD •............ r` °f' CHARLOTTE NC 28262 swplma 7115/08 Permit: NCG090006 SOC: County: Mecklenburg Region: Mooresville Compliance inspection Report Effective: 11/01/07 Expiration: 10/31/12 Owner: Mallard Creek Polymers Inc Effective: Expiration: Facility: Mallard Creek Polymers Incorporated 14800 Mallard Creek Rd Contact Person: Glen R Moses Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Charlotte NC 28262 Title: Phone: 704-547-0622 . Ext.1009 Certification: Phone: Inspection Date: 03/18/2008 Entry Time: 08A1 AM Exit Time: 12A5 PM Primary Inspector: Water Quality Program Mecklenburg County Phone: Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Paints, Varnishes, Lacquers Stormwater Discharge COG Facility Status: ❑ Compliant ■ Not Compliant Question Areas: E Storm Water (See attachment summary) Page: 1 Permit: NCGO90006 Owner — Facility: Mallard Creek Polymers, Inc Inspection Date 03/18/08 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary Facility Description: This facility is a chemical manufacturing plant engaged in making latex for various products. The facility operates 7 days a week on a 24 hour -a -day schedule. Compliance History: The permittee/facility does not have any prior compliance issues with either the NC Division of Water Quality or Charlotte -Mecklenburg Sto, m Water Serv!ces Industrial Onerations/City of Charlotte Stormwater Ordinance Review: Can -site Wastewater/Stormwater Treatment - The permittee indicated that the facility has beer) operating under a non -discharge strategy for the past two years and management expressed an interest in applying for a No Exposure Certification. The facility has an on -site wastewater treatment plant which discharges to Charlotte -Mecklenburg Utilities system under a pretreatment permit. Four pump stations at the tacrlrty collect and route wastewater and stormwater to the wastewater treatment plant The wastewater and stormwater are controlled by a corierete berm, which runs along the side of the plant and prevents water from flowing off site. Water is conveyed to one of the pump stations by flowing over the ground along this berm or within trenches and pipes. Floor drains at the facility were reported to lead by this system to the wastewater treatment plant. The facility pump stations should be evaluated to ensure that stormwater/wastewater volumes do not overwhelm the pump stations' capacity and result in bypasses of the wastewater treatment system. It was noted at the time of the inspection that several conditions existed, which compromised, or may compromise, the non -discharge status of the facility. The first was a section of the concrete berm where a fire hydrant is located. At this point, the concrete berm is open to allow for space around the hydrant. This undermines the effectiveness of the containment. Evidence that wastewater leaves.'the site via this space was found at the time of inspection. A small leak in a joint in the concrete berm was noted during the time of inspection. A small volume of wastewater was observed escaping the containment through the joint. A gate is located along one section of the berm. The gate is situated over a grate that leads to a pump station. The area outside the gate is slightly elevated to act as a berm. The gatelberm area should be evaluated to ensure that stormwater and wastewater volumes do not overwhelm the area and escape containment. The leak found in the joint of the berm must be repaired. The gap in the berm associated with the fire hydrant must be addressed so that wastewater or contaminated stormwater flows are not discharged into the environment. Storage Tanks - There are numerous storage tanks located outside within secondary containment structures at the plant. An unlabeled diesel fuel AST was found at the site. The diesel fuel tank should be labeled to reflect what is being stored inside it. The AST was leaking from a line leading from the tank. The leak from the tank should be fixed and any contaminated soil removed and disposed of properly. Cooling Towers - A cooling tower (designated by the facility staff as Cooling Tower #3) was found leaking water to the ground at the time of inspection. This could be a source of stormwater contamination. Cooling Tower #3 should be evaluated to determine if the leak is contaminating run-off, which could escape containment and leave the site. If this condition is found steps must be taken to resolve it. Page: 2 Permit: NCGO90006 Owner — Facility: Mallard Creek Polymers, Inc Inspection Date: 03/18/08 Inspection Type: Compliance Evaluation Reason for Visit: Routine Industrial Operations/CityOperations/City of Charlotte Stormwater Ordinance Review (cont.): Stormwater Outfalls — The permittee was determined to have three stormwater outfalls during the inspection. One of these outfalls coveys stormwater from the facility's documented outfall, and also conveys stormwater from a previously undocumented swale off the property. Water conveyed by the swale appears to bypass the facility's treatment system. The other two outfalls convey stormwater off the property and appear to bypass the facility's treatment system. These two outfalls are not documented in the facility's Stormwater Pollution Prevention Plan (SPPP). The facility also has three ponds used to contain wastewater and stormwater on -site. Stormwater Pollution Prevention Plan (cont.) The permittee has an inspection and maintenance program but it does not include inspections of the Stormwater Facilities. The permittee needs to develop and implement a Stormwater Facility Inspection Program and document it in the SPPP in accordance with the requirements of the General permit. As part of this program, the outfalls not previously identified by the permittee must be evaluated to determine if they are conveying stormwater/pollutants off - site. Any identified illicit discharges must cease immediately. Page: 3 Permit: NCGO90006 owner - Facility: Mallard Creek Polymers inc Inspection Bate: 0311812008 Inspection Type: Compliance Evaluation Stormwater Pollution Prevention Plan Does the site have a Stormwater Pollution Prevention Plan?.. # Does the Plan include a General Location (LISGS) map? # Does the Plan include a "Narrative Description of Practices"? # Does the Plan include a detailed site map including outfall locations and drainage areas? # tines the Plan include a list of significant spilis occurring :during the pas', 3 years? # Has the tocitrly evaluated feasible alternatives to currerz, nracifces'% # Does the facility provide all necessary secondary c.ontaimm�en t'� # Does the Plan include a 13MP summary? # Does the Plan include a Spill Prevention and response Plan (SPRP)" # Does the Plan include a Pteventattve Maintenance and Good Housekeepinq Pan? # 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? Reason for Visit: Routine Comment: The SPPP has not been updated since December 18, 2002. The following sections of the SPPP were not current and/or missing: General Location map, Site map, the evaluation of feasible alternatives, the secondary containment stormwater records, the BMP summary, the Spill Prevention and Response Plan, the Preventative Maintenance and Good Housekeeping Plan, the Narrative Description of Storage Practices, and the list of responsible parties. The list of significant spills is out of date although the permittee stated that no incidents have occurred within the last five years. The plan must be updated and reviewed annually as required by the General permit issued in November 2007. Employee training is being performed in conjunction with other spill response and emergency training. Please ensure that the training conforms to the requirements of the permit by addressing Stormwater management issues appropriately. Please see the Summary section for additional information regarding the SPPP. Qualitative Monitoring Has the facility conducted its Qualitative Monitoring semi-annually? v.-- W... WA •IC Page, 4 Permit: NCGO90006 Owner - Facility: b1allard Creek Polymers Inc Inspection Date: 03/18/2008 inspection Type. Compliance Evaluation Reason for Visit: Routine Comment: The permittee has not performed qualitative monitoring due to a belief that the facility was collecting and processing its stormwater run-off through the on -site wastewater treatment plant. During the inspection it was determined that this may not be the case as the inspectors located two additional outfalls_ The additional outfalls must be monitored as required by the permit if they are found to directly discharge stormwater. Analytical Monitoring Has the facility conducted its Analytical monitoring? # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? Comment: The permittee has not performed analytical monitoring due to a belief that the facility was collecting and processing its stormwater run-off through the on -site wastewater treatment plant. During the inspection it was determined that this may not be the case as the inspectors located two additional outfalls. The additional outfalls must be monitored as required by the permit if they are found to directly discharge stormwater. Permit and Outfalls # Is a copy of the Permit and the Certificate of Coverage available at the site? # 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: Two outfalls not previously identified in the SPPP were found during the inspection. The permittee must evaluate the outfalls to determine to where they convey stormwater and include them in the SPPP. The permittee has not completed an evaluation ot-illicit discharges at the stormwater outfalls. As per the new General permit issued in November 2007 the permittee must complete this evaluation yearly and certify the results. Yes No NA NE D ■ D D DD■D Yes No NA NE ■DDD ■0D0 D D ■ D D■DD Page, 5 \NArF Michael'F. Easley, Governor �O Rp William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources co 7 Alan W. Klimek, P-E., Director Division of Water Duality August 23, 2002 MICHAEL D CARTY MALLARD CREEK POLYMERS INCORPORATED 14800 MALLARD CREEK ROAD CHARLOTTE, NC 28262 Subject: NPDES Stormwater Permit Renewal MALLARD CREEK POLYMERS INCORPORATED COC Number NCGO90006 Mecklenburg County Dear Permittee: In response to your renewal application for continued coverage under general permit NCG090000, the Division of Water Quality (DWQ) is forwarding herewith the reissued stormwater general permit. This permit is reissued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between the state of North Carolina and the U.S. Environmental Protection Agency, dated December 6, 1983. The following information is included with your permit package: * A new Certificate of Coverage * A copy of General Stormwater Permit NCG090000 * A copy of the Analytical Monitoring Form (DMR) * A copy of a Technical Bulletin for the general permit Your coverage under this general permit is not transferable except after notice to DWQ. The Division may require modification or revocation and reissuance of the Certificate of Coverage. This permit does not affect the legal requirements to obtain other permits which may be required by DENR or relieve the permittee from responsibility for compliance with any other applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or decree. If you have any questions regarding this permit package please contact Aisha Lau of the Central Office Stormwater and General Permits Unit at (919) 733-5083, ext_ 578 Sincerely, ft�/ f, t,►,� Bradley Bennett, Supervisor N'' OrpF. OF LPl`11ROM1IARi_)`T Stormwater and General Permits UTxr,0 t.nd;_ t�Fa01) ��FS i cc: Central Files Stormwater & General Permits Unit Files AUG 2 9 2002 Mooresville Regional Off -ice viAT R QuAlaI Y S:EC i l0D11 N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 (919) 733-7015 TOM NCDENR Customer Service 1- 8W-623-7748 \N A T� Michael F. Easley, Governor \O�� RQG William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Gregory J. Thorpe, Ph.D. Acting Director 5 Division of Water Quality December 27- 2001 MICHAEL D CARTY MALLARD CREEK POLYMERS INCORPORATED 148M MALLARD CREEK RD CHARLOTTE, NC 28213 Subject: NPDES Stormwater Permit Renewal MALLARD CREEK POLYMERS INCORPORATED COC Number NCG090006 Mecklenburg County Dear Pennittee: Your facility is currently covered for stormwater discharge under General Permit NCG090000. This permit expires on August 31, 2002_ The Division staff is currently in the process of rewriting this permit and is scheduled to have the permit reissued by late summer of 2002. Once the permit is reissued, your facility would be eligible for continued coverage under the reissued permit. In order to assure your continued coverage under the general permit, you must apply to the Division of Water Quality (DWQ) fix renewal of your permit coverage. To make this renewal process easier, we are informing you in advance that your permit will be expiring. Enclosed you will find a General Permit Coverage Renewal Application Form. The application must be completed and returned by March 4, 2002 in order to assure continued coverage under the general permit. Failure to request renewal within this time period may result in a civil assessment of at least $250.00. Largcr penalties may be assessed depending on the delinquency of the request. 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 $10,000 per day. Please note that recent federal legislation has extended the "no exposure exclusion" to all operators of industrial facilities in any of the I I categories of "storm water discharges associated with industrial activity," (except construction activities). If you feet your facility can certify a condition of "no exposure", i.e. the facilty industrial materials and operations are not exposed to stormwater, you can apply for the no exposure exclusion. For additional information contact the Central Office Stormwater Staff member listed below or check the Stormwater & General Permits Unit Web Site at http://h2o,enr.state.nc.us/su/stormwater.htm) If the subject stormwater discharge to waters of the state has been terminated, please complete the enclosed Rescission Request Form. Mailing instructions are listed on the bottom of the form. You will be notified when the rescission process has been completed. If you have any questions regarding the permit renewal procedures please contact Mike Parker of the Mooresville Regional Office at 704-663-1699 or Aisha Lau of the Central Office Stormwater Unit at (919) 733-5083, ext. 578 Sincerely. -ell Bennett, Supervisor Stormwater and General Permits Unit cc: Central Files Mooresville Regional Office e�A RUM N_ C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 (919) 733-7015 Customer Service 1- 800-623-7748 F W A roc Michael F. Easley, Governor �� 9Q William G_ Ross Jr., Secretary North Carolina Department of Environment and Natural Resources i^ Alan W. Klimek, P.E., Director 0 Division of Water Quality August 23, 2002 MICHAEL D CARTY MALLARD CREEK POLYMERS INCORPORATED 14800 MALLARD CREEK ROAD CHARLOTTE, NC 28262 Subject: NPDES Stormwater Permit Renewal MALLARD CREEK POLYMERS INCORPORATED COC Number NCG090006 Mecklenburg County Dear Permittee: In response to your renewal application for continued coverage under general permit NCG090000, the Division of Water Quality (DWQ) is forwarding herewith the reissued Stormwater general permit. This permit is reissued pursuant to the requirements of North Carolina General Statute 143-2I5.1 and the Memorandum of Agreement between the state of North Carolina and the U.S. Environmental Protection Agency, dated December 6, 1983. The following information is included with your permit package: * A new Certificate of Coverage * A copy of General Stormwater Permit NCG090000 * A copy of the Analytical Monitoring Form (DMR) * A copy of a Technical Bulletin for the general permit Your coverage under this general permit is not transferable except after notice to DWQ. The Division may require modification or revocation and reissuance of the Certificate of Coverage. This permit does not affect the legal requirements to obtain other permits which may be required by DENR or relieve the permittee from responsibility for compliance with any other applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or decree. If you have any questions regarding this permit package please contact Aisha Lau of the Central Office Stormwater and General Permits Unit at (919) 733-5083, ext. 578 Sincerely, Bradley Bennett, Supervisor Stormwater and General Permits Unit M. Central Files Stormwater & General Permits Unit Files Mooresville Regional Office ��L� NCDENR N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 (919) 733-7015 Customer Service 1- WO-623-7748 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY GENERAL PERMIT NO. NCG090000 CERTIFICATE OF COVERAGE No. NCG090006 STORMWATER DISCHARGES NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, MALLARD CREEK POLYMERS INC is hereby authorized to discharge stormwater from a facility located at MALLARD CREEK POLYMERS INCORPORATED 14800 MALLARD CREEK ROAD CHARLOTTE MECKLENBURG COUNTY to receiving waters designated as a UT to Mallard Creek, a class C stream, in the Yadkin - Pee Dee River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III, IV, V, and VI of General Permit No. NCGO90000 as attached. This certificate of coverage shall become effective September 1, 2002. This Certificate of Coverage shall remain in effect for the duration of the General Permit. Signed this day August 23, 2002. for Alan W. Klimek, P.E., Director Division of Water Quality By Authority of the Environmental Management Commission F W A TE Michael F. Easley, Governor _O�0 RQG William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources 6 5: Gregory J. Thorpe, Ph.D. Q Acting Director Division of Water Quality December 27, 2001 MICHAEL D CARTY MALLARD CREEK POLYMERS INCORPORATED 14800 MALLARD CREEK RD CHARLOTTE, NC 28213 Subject: NPDES Stormwater Permit Renewal MALLARD CREEK POLYMERS INCORPORATED COC Number NCG090006 MecklenburlCounty Dear Permittee: Your facility is currently covered for stormwater discharge under General Permit NCG090000. This permit expires on August 31, 2002. The Division staff is currently in the process of rewriting this permit and is scheduled to have the permit reissued by late summer of 2002. Once the permit is reissued, your facility would be eligible for continued coverage under the reissued permit. In order to assure your continued coverage under the general permit, you must apply to the Division of Water Quality (DWQ) for renewal of your permit coverage. To make this renewal process easier, we are informing you in advance that your permit will he expiring. Enclosed you will find a General Permit Coverage Renewal Application Form. The application must be completed and returned by March 4, 2002 in order to assure continued coverage under the general permit. Failure to request renewal within this time period may result in a civil assessment of at least $250.00. Larger penalties may be assessed depending on the delinquency of the request. 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 $10,000 per day. Please note that recent federal legislation has extended the "no exposure exclusion" to all operators of industrial facilities in any of the 1 l categories of "storm water discharges associated with industrial activity," (except construction activities). Ifyou feel your facility can certify a condition of "no exposure", i.e. the facilty industrial materials and operations are not exposed to stormwater, you can apply for the no exposure exclusion. For additional information contact the Central Office Stormwater Staff member listed below or check the Stormwater & General Permits Unit Web Site at http://h2o.enr.state.nc.us/su/stormwater.htmI If the subject stormwater discharge to waters of the state has been terminated, please complete the enclosed Rescission Request Form. Mailing instructions are listed on the bottom of the form. You will be notified when the rescission process has been completed. If you have any questions regarding the permit renewal procedures please contact Mike Parker of the Mooresville Regional Office at 704-663-1699 or Aisha Lau of the Central Office Stormwater Unit at (919) 733-5083. ext. 578 Sincerely. Bradley Bennett, Supervisor Stormwater and General Permits Unit cc: Central Files Mooresville Regional Office e�*A NCDENR N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 (919) 733-7015 Customer Service 1-800-623-7748 State of North Carolina Department of Environment, Health and Natural Resources W*VA Division of Water Quality Ar4i • James B. Hunt, Jr., Governor Wayne McDevitt, Secretary [DG C 1'***J F1 A. Preston Howard, Jr., P.E., Director September 5, 1997 MICHAEL D CARTY MALLARD CREEK POLYMERS, INC_ 14800 MALLARD CREEK ROAD CHARLOTTE, NC 28213 Subject: Reissued Stormwater General Permit for Certificate of Coverage No. NCGO90006 Mecklenburg County Dear Permittee: In response to your renewal application for continued coverage under the subject permit, the Division of Water Quality (DWQ) is forwarding herewith the reissued stormwater general permit. This permit is reissued pursuant to the requirements of North Carolina General Statute 143-215 .1 and the Memorandum of Agreement between North Carolina and the US Environmental Protection agency dated December 6, 1983. The following information is included with your permit package: ■ A copy of the stormwater general permit. ■ A Stormwater Pollution Prevention Plan Certification Form. This form certifies that you have developed and implemented the Stormwater Pollution Prevention Plan (SPPP) required in your permit. This form must be completed and returned to the Division within 30 days of receipt of this letter. DO NOT send the SPPP with the signed form. w Five copies of Analytical Monitoring forms. ■ Five copies of Qualitative Monitoring forms. 0 A copy of a Technical Bulletin on the stormwater program with outlines program components and addresses frequently asked questions. ■ A corrected Certificate of Coverage if you indicated a name or address change on the Renewal Form returned to the Division. Your certificate of coverage is not transferable except after notice to DWQ. The Division of Water Quality may require modification or revocation and reissuance of the certificate of coverage. This permit does not affect the legal requirements to obtain other permits which may be required by DWQ or permits required by the Division of Land Resources, Division of Air Quality, Coastal Area Management Act or any other Federal or Local governmental permits that may be required. If you have any questions concerning this permit or other attached documents, please contact the Stormwater Group at telephone number (919) 733-5083 Sincerely, b�,✓� for A. Preston Howard, Jr., P. E. P.O. Box 29535, Raleigh. North Carolina 27626-0535 Telephone 919-733-5083 FAX 919-733-0719 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10`7c post -consumer paper State .of North Carolina Department of Environment, Health and Natural Resources Division of Env.ironmental Management James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary A. Preston Howard, Jr., P.E., Director Mr. Michael D. Carty Mallard Creek Polymers, Inc. 14800 Mallard Creek Road Charlotte, North Carolina 28213 Dear Mr. Carty: A " T4 F DEHNF=1 February 17, 1995 = Subject: NPDES No. NCG090006 - Mallard Creek Polymers, Inc. formerly: Rohm and Haas Delaware Valley, Inc. : ram•. -. . Mecklenburg County In accordance with your request dated February 1, 1995, we are forwarding herewith the modified Certificate of Coverage page for the subject facility. The only change is in name and ownership. This Certificate of Coverage is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U. S. Environmental Protection Agency dated December 6. 1983. If any parts, measurement frequencies or, sampling t rsq�f,sments contained in this permit are unacceptable to you, you have the right t6z'Verguest an individual permit by submitting an individual permit application. Unless such demand is made, this certificate of coverage shall be final and binding. Please take notice that this certificate of coverage is not transferable except after notice to the Division of Environmental Management. The Division of Environmental Management may require modification or revocation and reissuance of the certificate of coverage. This permit does not affect the legal requirements to obtain other permits which may be required by the Division of Environmental Management or permits required by the Division of Land Resources, Coastal Area Management Act or any other Federal or Local governmental permit that may be required. If you- have any questions concerning this permit, please contact Steve Ulmer at telephone number -919/733-5083, Ext. 545. Sincerely, rest o rd, Jr., P.E. cc: Mooresville Regional Office Compliance -Jeanne Phillips, ISB Central Files William W. Toole, Robinson, Bradshaw, & Hinson, P.A. P_O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone 919-733-5083 FAX 919-733-9919 An Pniini i)nnnrtiinity Affirmative Ar:inn FmninvP: 5(10/ rervrlari! -tn% nost-nnn.gnmar nanar _a y<, STATE OF NORTH CAROLINA. s r'` DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES. DIVISION. OF -ENVIRONMENTAL MANAGEMENT GENERAL PERMIT NO, N CERTIFICATE OF COVERAGE NO, NCG090006 STORMWATER DISCHARGES NATIONAL_ POLLUTANT DISCHARGE ELIMINATIQN SYSTEM In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and reguiations'promulgated, and adopte&by the North Carolina Environmental Management Commission, and the Federal. Water Pollut &'Contml Act, as amended, Mallard Creek Polymers, Inc. is hereby authorized to discharge stormwater from a facility located at 14800 Mallard Creek Road Charlotte ' Mecklenburg County , +� to receiving waters designated as an unnamed tributary to Mallard Creek iW the_YadlrinY�.River Basin' in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and IV of General Permit No. NCGO90000 as attached.. This Certificate of Coverage shall become effective February 17, 1995. This Certificate of Coverage shall remain in effect for the duration of the General Permit. Signed this day February 17, 1995. Preston H Jr., P.E., Director ivision of vironmental Management By Authority of the Environmental Management Commission State of North Carolina Department of Environment, Health and Natural Resources Division of Environmental Management James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary A. Preston Howard, Jr., P.E., Director July 9, 1993 Michael D. Carty Rohm and Haas Company 14700 Mallard Creek Road Philadelphia, PA 19105 Subject: General Permit No. NCGO90000 Rohm and Haas Delaware Valley, Inc. COC NCGO90006 Mecklenburg County Dear Mr. Carty: In accordance with your application for discharge permit received on September 23, 1992, we are forwarding herewith the subject certificate of coverage to discharge under the subject state - NPDES general permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the US Environmental Protection agency dated December 6, 1983. If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable to you, you have the right to request an individual permit by submitting an individual permit application. Unless such demand is made, this certificate of coverage shall be final and binding. Please take notice that this certificate of coverage is not transferable except after notice to the Division of Environmental Management, The Division of Environmental Management may require modification or revocation and reissuance of the certificate of coverage. This permit does not affect the legal requirements to obtain other permits which may be required by the Division of Environmental Management or permits required by the Division of Land Resources, Coastal Area Management Act or any other Federal or Local governmental permit that may be required. If you have any questions concerning this permit, please contact Mr. Steve Ulmer at telephone number 919n33- 5083. cc: Sincerely, Original Signed % Coleen H, Soinns A. Preston Howard, Jr., P. E. Mooresville Regional Office P.Q. Sox 29535, Raleigh, North Carolina 27626-0535 Telephone 919-733-5083 FAX 919-733-9919 An Equal Opportunity Affirmative Action Employer 50%recycled/ 10%post-consumer paper STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES DIVISION OF ENVIRONMENTAL MANAGEMENT STORMWATER DISCHARGES In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Rohm and Haas Company is hereby authorized to discharge stormwater from a facility located at Rohm and Haas Delaware Valley, Inc. 14700 Mallard Creek Road Charlotte Mecklenburg County to receiving waters designated as an unnamed tributary to Mallard Creek in the Yadkin -Pee Dee River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I,11,111 and IV of General Permit No. NCGO90000 as attached. This Certificate of Coverage shall become effective July 9, 1993. This Certificate of Coverage shall remain in effect for the duration of the General Permit. Signed this day July 9, 1993. Original Signed By Coleen H. Sullins A. Preston Howard, Jr., P.E., Director Division of Environmental Management By Authority of the Environmental Management Commission UNITED STATES 5\d S DEPARTMENT OF THE INTERIOR DEPARTMEN ` GEOLOGICAL SURVEY [� SALrSBURY 25 M7. A5' 1 5230DDaE. �� YS 1524 525 xANNAP00S ajM,. 42�30" 527 J���%, : ;✓=�.f ��� I�� ��� �\i` . `; iF- r' � j(fiil� ..6�� ,�\ ids t ;,1� ����J� I�` �/� �,,� 42463) Ai // - � ! �•• � �� --, � J� .-mot` .. ti . 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A N p � A A S `-C*4 ,&N Y COUNTY�E-q,iL PC NPDES &1 0 0D D<p MAP i ✓� 7� 7i DSfq FLOW ki A SUS BASIN LATTITUDE 36 z I O LONGITUDE '' 41Z AY4 t� RECEIVING STREAM' Unln/AM,57D TY-4Qu�� STREAM CLASS yy� DISCHARGE CLASS - FbF-M W ATE EXPIRATION DATE'- p - 3 October 20, 2008 Ms. Marcia Allocco NCDENR Division of Water Quality 610 East Center Ave, Suite 301 Mooresville, NC 28115 Polymcreek RE ., F .; OCT 2 3 2008 Dwourfaae Victer an Subject: Compliance Evaluation Inspection Action Plan Notice of Violation Tracking Number NOV — 2008-PC-0520 Mallard Creek Polymers Facility Stormwater Permit Number_ NCG 090000, COC NCGO.90006 Mecklenburg County, NC Ms. Allocco: Attached please find the Mallard Creek Polymers Facility corrective action plan update and closure report addressing the noted program violations 1 deficiencies from the March 18, 2008, site inspection. Unless additional response is received, we consider the package to be closed. Sincerely, w �A' rd/mlj Allan Oracion Compliance Manager Mallard Creek Polymers, Incorporated Mallard Creek Polymers, Inc. 14700 Mallard Creek Road, Charlotte, NC 28262-0499 704-547-0622 MALLARD CREEK POLYMERS STORMWATER COMPLIANCE DEFICIENCIES Stormwater Compliance Deficiency #1: The facility pump stations should be evaluated to ensure that stormwaterlwastewater volumes do not overwhelm the pump stations' capacity and result in bypasses of the wastewater treatment system. MCP ACTION: IN A CONVERSATION WITH MR. CHRIS ELMORE ON 7/24/08, THIS CALCULATION IS NECESSARY IF WE ARE TO APPLY FOR A "NO EXPOSURE CERTIFICATION." AT THIS POINT MALLARD CREEK POLYMERS WILL NOT PURSUE THIS STRATEGY. RESPONSIBILTY: NIA TARGET DUE DATE: NIA ACTUAL DATE COMPLETED: NIA, Closed -No further action required Stormwater Compliance Deficiency #2: It was noted at the time of the inspection that several conditions existed, which compromised, or may compromise, the non -discharge status of the facility. The first was a section of the concrete berm where a fire hydrant is located. At this point, the concrete berm is open to allow for space around the hydrant. This undermines the effectiveness of the containment. Evidence that wastewater leaves the site via this space was found at the time of inspection. The gap in the berm associated with the fire hydrant must be addressed so that wastewater or contaminated stormwater flows are not discharged into the environment. MCP ACTION: CLOSED OUT SPACE ON CONCRETE BERN AROUND THE HYDRANT WITH CONCRETE. NO LEAKAGE HAS BEEN OBSERVED SINCE REPAIR. RESPONSIBILTY: MAINTENANCE ENGINEER TARGET DUE DATE: OCTOBER 15, 2008 (90 DAYS FROM REPORT) ACTUAL DATE COMPLETED: 5/21/2008, Closed -No further action required Stormwater Compliance DeficienEX #3: A small leak in a joint in the concrete berm was noted during the time of inspection. A small volume of wastewater was observed escaping the containment through the joint. The leak found in the joint of the berm must be repaired. MCP ACTION: FILLED AND SEALED JOINT IN CONCRETE BERM. NO LEAKAGE HAS BEEN OBSERVED SINCE REPAIR. RESPONSIBILTY: MAINTENANCE ENGINEER TARGET DUE DATE: OCTOBER 15, 2008 (90 DAYS FROM REPORT) ACTUAL DATE COMPLETED: 5/21/2008, Closed -No further action required Stormwater Compliance Deficiency #4: A gate is located along one section of the berm. The gate is situated over a grate that leads to a pump station. The area outside the gate is slightly elevated to act as a berm. The gate/berm area should be evaluated to ensure that stormwater and wastewater volumes do not overwhelm the area and escape containment. MCP ACTION: MAINTENANCE WAS PERFORMED ON THE GRATE SYSTEM. THE SYSTEM WAS OBSERVED DURING A RAINFALL EVENT, AND IT WAS VERIFIED TO BE WORKING PROPERLY. THE GRATE SYSTEM HAS BEEN ENTERED INTO THE T/I MAINTENANCE SCHEDULE TO ENSURE THAT IT IS CLEANED OUT PERIODICALLY. RESPONSIBILTY: MAINTENANCE ENGINEER TARGET DUE DATE: OCTOBER 15, 2008 (90 DAYS FROM REPORT) ACTUAL DATE COMPLETED: 8/22/08, Closed -No further action required Stormwater Com liance Deficient #5: There are numerous storage tanks located outside within secondary containment structures at the plant. An unlabeled diesel fuel AST was found at the site. The diesel fuel tank should be labeled to reflect what is being stored inside it. MCP ACTION: LABELED FUEL TANK "DIESEL FUEL", ADDED HMIS LABEL AND POSTED CUSTOMIZED DIESEL SIGN CONTAINING SAFETY, FIRE AND SPILL INFORMATION. RESPONSIBILTY: COMPLIANCE MANAGER / MAINTENANCE ENGINEER TARGET DUE DATE: OCTOBER 15, 2008 (90 DAYS FROM REPORT) ACTUAL DATE COMPLETED: 6/27/08, Closed -No further action required Stormwater Compliance Deficiency #6: The diesel AST was leaking from a line leading from the tank. The leak from the tank should be fixed. MCP ACTION: FIXED LEAK ON TANK. RESPONSIBILTY: MAINTENANCE ENGINEER TARGET DUE DATE: OCTOBER 15, 2008 (90 DAYS FROM REPORT) ACTUAL DATE COMPLETED: 6127/08, Closed -No further action required Stormwater Compliance Deficiency 97: .I The diesel AST was leaking from a line leading from the tank. Any contaminated soil should be removed and disposed of properly. MCP ACTION: REMOVED CONTAMINATED SOIL FOR PROPER DISPOSAL. RESPONSIBILTY: MAINTENANCE ENGINEER TARGET DUE DATE: OCTOBER 15, 2008 (90 DAYS FROM REPORT) ACTUAL DATE COMPLETED: 6/27/08, Closed -No further action required Stormwater Compliance Deficient #8: A cooling tower (designated by the facility staff as Cooling Tower #3) was found leaking water to the ground at the time of inspection. This could be a source of stormwater contamination. Cooling Tower #3 should be evaluated to determine if the leak is contaminating run-off, which could escape containment and leave the site. If this condition is found steps must be taken to resolve it. MCP ACTION: LEAKING WAS CAUSED BY UNDERGROUND SAFETY SHOWER PIPES. RELOCATED / REPLACED SAFETY SHOWER AND PIPING AND RE- WORKED TOWER LOUVERS. NO WATER ON GROUND HAS BEEN OBSERVED SINCE REPAIRS RESPONSIBILTY: MAINTENANCE ENGINEER TARGET DUE DATE: OCTOBER 15, 2008 (90 DAYS FROM REPORT) ACTUAL DATE COMPLETED: 6/3/2008, Closed -No further action required Stormwater Compliance Deficiency #9: The permittee was determined to have three stormwater outfalls during the inspection. One of these outfalls conveys stormwater from the facility's documented outfall, and also conveys stormwater from a previously undocumented swale off the property. Water conveyed by the swale appears to bypass the facility's treatment system. These two outfalls are not documented in the facility's Stormwater Pollution Prevention Plan (SPPP). The two outfalls not previously identified in the SPPP must be evaluated to determine where they convey stormwater and include them in the SPPP. The SPPP has not been updated since December 18, 2002. The following sections of the SPPP were not current and/or missing: General Location map, Site map, the evaluation of feasible alternatives, the secondary containment stormwater records, the BMP summary, the Spill Prevention and Response Plan, the Preventative Maintenance and Good Housekeeping Plan, the Narrative Description of Storage Practices, and the list of responsible parties. The list of significant spills is out of date although the permittee stated that no incidents have occurred within the last five years. As per the new General permit issued in November 2007 the permittee must complete this evaluation yearly and certify the results. MCP ACTION: THE SPPP HAS BEEN UPDATED WITH NOTED CHANGES UPDATED IN THE PLAN ON OCTOBER 11, 2008. RESPONSIBILTY: COMPLIANCE MANAGER / CONSULTANT TARGET DUE DATE: OCTOBER 15, 2008 (90 DAYS FROM REPORT) ACTUAL DATE COMPLETED: 10/11/08, Closed -No further action required Stormwater Compliance Deficient #10: The outfalls not previously identified by the permittee must be evaluated to determine if they are conveying stormwatcr/pollutants off -site. Any identified illicit discharges must cease immediately. The permittee has not performed qualitative monitoring due to a belief that the facility was collecting and processing its stormwater run-off through the on -site wastewater treatment plant. During the inspection it was determined that this may not be the case as the inspectors located two additional outfalls. The additional outfalls must be monitored as required by the permit if they are found to directly discharge stormwater. MCP ACTION: THE MCP HAS SAMPLED AND ANALYZED 3 OUTFALLS ON 7/31/08 AND HAS PERFORMED QUALITATIVE INSPECTIONS ON 8/13/08 & 8/26/08. MCP WILL CONTINUE THESE TASKS AS REQUIRED (TWICE/YEAR). RESPONSIBILTY: COMPLIANCE MANAGER TARGET DUE DATE: OCTOBER 15, 2008 (90 DAYS FROM REPORT) ACTUAL DATE COMPLETED: 8/13/08 Closed -No further action required Stormwater Compliance Deficiency #11: The permittee has an inspection and maintenance program but it does not include inspections of the Stormwater Facilities. The permittee needs to develop and implement a Stormwater Facility Inspection Program and document it in the SPPP in accordance with the requirements of the General permit. MCP ACTION: A STORMWATER FACILITY INSPECTION PROGRAM HAS BEEN IMPLEMENTED. THE INSPECTION PROGRAM HAS BEEN ENTERED INTO THE T/I MAINTENANCE SCHEDULE AND WILL BE PERFORMED AS REQUIRED (TWICE/YEAR). RESPONSIBILTY: COMPLIANCE MANAGER TARGET DUE DATE: OCTOBER 15, 2008 (90 DAYS FROM REPORT) ACTUAL DATE COMPLETED: 10/20/08 Closed -No further action required Stormwater Compliance Deficiency #12: Employee training is being performed in conjunction with other spill response and emergency training. Please ensure that the training conforms to the requirements of the permit by addressing stormwater management issues appropriately_ MCP ACTION: THE FINAL SPPP HAS BEEN RECEIVED. THE TRAINING PROGRAM WILL BE DEVELOPED TO ENSURE IT COVERS THE UPDATED SPPP AND CONFORMS TO THE REQUIRMENTS OF THE PERMIT. TRAINING HAS BEEN SCHEDULED AND WILL BE COMPLETED BY 11/14/08. RESPONSIBILTY: COMPLIANCE MANAGER TARGET DUE DATE: OCTOBER 15, 2008 (90 DAYS FROM REPORT) ACTUAL DATE COMPLETED: Closed -No further action required. OMCP Porymers July 30, 2008 Ms. Marcia Allocco NCDENR Division of Water Quality 610 East Center Ave, Suite 301 Mooresville, NC 28115 AUG -- 4 2008 NC DENR MRO DWG -Surface Weer Protection Subject: Compliance Evaluation Inspection Action Plan Notice of Violation Tracking Number NOV — 2008-PC-0520 Mallard Creek Polymers Facility Stormwater Permit Number NCG 090000, COC NCGO90006 Mecklenburg County, NC Ms. Allocco: Attached please find the Mallard Creek Polymers Facility corrective action plan addressing the noted program violations 1 deficiencies from the March 18, 2008, site inspection. Any questions or comments may be directed to me, Allan Oracion, Compliance Manager Mallard Creek Polymers. In addition, please change your contact person information to Allan Oracion. Sincerely, az �-" Allan Oracion Compliance Manager Mallard Creek Polymers, Incorporated Mallard Creek Polymers, Inc. 14700 Mallard Creek Road, Charlotte, NC 28262-0499 704-547-0622 MALLARD CREEK POLYMERS STORMWATER COMPLIANCE DEFICIENCIES Stormwater Comaliance Deficiency #1: The facility pump stations should be evaluated to ensure that stormwaterlwastewater volumes do not overwhelm the pump stations' capacity and result in bypasses of the wastewater treatment system. MCP ACTION: IN A CONVERSATION WITH MR. CHRIS ELMORE ON 7/24/08, THIS CALCULATION IS NECESSARY IF WE ARE TO APPLY FOR A "NO EXPOSURE CERTIFICATION." AT THIS POINT MALLARD CREEK POLYMERS WILL NOT PURSUE THIS STRATEGY. RESPONSIBILTY: NIA TARGET DUE DATE: NIA ACTUAL DATE COMPLETED: NIA, Closed -No further action required Stormwater Compliance Deficiency #2: It was noted at the time of the inspection that several conditions existed, which compromised, or may compromise, the non -discharge status of the facility. The first was a section of the concrete berm where a fire hydrant is located. At this point, the concrete berm is open to allow for space around the hydrant. This undermines the effectiveness of the containment. Evidence that wastewater leaves the site via this space was found at the time of inspection. The gap in the berm associated with the fire hydrant must be addressed so that wastewater or contaminated stormwater flows are not discharged into the environment. MCP ACTION: CLOSED OUT SPACE ON CONCRETE BERN AROUND THE HYDRANT WITH CONCRETE. NO LEAKAGE HAS BEEN OBSERVED SINCE REPAIR. RESPONSIBILTY: MAINTENANCE ENGINEER TARGET DUE DATE: OCTOBER 15, 2008 (90 DAYS FROM REPORT) ACTUAL DATE COMPLETED: 5/21/2008, Closed -No further action required Stormwater Compliance Deficiency #3: A small leak in a joint in the concrete berm was noted during the time of inspection. A small volume of wastewater was observed escaping the containment through the joint. The leak found in the joint of the berm must be repaired. MCP ACTION: FILLED AND SEALED JOINT IN CONCRETE BERM. NO LEAKAGE HAS BEEN OBSERVED SINCE REPAIR. RESPONSIBILTY: MAINTENANCE ENGINEER TARGET DUE DATE: OCTOBER 15, 2008 (90 DAYS FROM REPORT) ACTUAL DATE COMPLETED: 5/2112008, Closed -No further action required Stormwater Compliance Deficiency #4: A gate is located along one section of the berm. The gate is situated over a grate that leads to a pump station. The area outside the gate is slightly elevated to act as a berm. The gate/berm area should be evaluated to ensure that stormwater and wastewater volumes do not overwhelm the area and escape containment. MCP ACTION: THE GRATE WAS CLEANED OUT. IT WAS DETERMINED THAT THE GRATING WILL NEED INSPECTION EVERY 3-4 MONTHS TO ENSURE THAT THERE IS NO ROCK BUILDUP INSIDE THE GRATE. THE INSPECTION HAS BEEN PLACED ON THE MAINTENANCE T/I SCHEDULE TO ENSURE IT IS CHECKED AND REMAINS CLEAN. DUE TO THE HEAVY TRAFFIC THROUGH THE GATE, THIS AREA WILL BE FURTHER EVALUATED. RESPONSIBILTY: MAINTENANCE ENGINEER TARGET DUE DATE: OCTOBER 15, 2008 (90 DAYS FROM REPORT) ACTUAL DATE COMPLETED: OPEN Stormwater Compliance Deficiency #5: There are numerous storage tanks located outside within secondary containment structures at the plant. An unlabeled diesel fuel AST was found at the site. The diesel fuel tank should be labeled to reflect what is being stored inside it. MCP ACTION: LABELED FUEL TANK "DIESEL FUEL", ADDED HMIS LABEL AND POSTED CUSTOMIZED DIESEL SIGN CONTAINING SAFETY, FIRE AND SPILL INFORMATION. RESPONSIBILTY: COMPLIANCE MANAGER / MAINTENANCE ENGINEER TARGET DUE DATE: OCTOBER 15, 2008 (90 DAYS FROM REPORT) ACTUAL DATE COMPLETED: 6/27/08, Closed -No further action required Stormwater Compliance Deficiency #6: The diesel AST was leaking from a line leading from the tank. The leak from the tank should be fixed. MCP ACTION: FIXED LEAK ON TANK. RESPONSIBILTY: MAINTENANCE ENGINEER TARGET DUE DATE: OCTOBER 15, 2008 (90 DAYS FROM REPORT) ACTUAL DATE COMPLETED: 6/27/08, Closed -No further action required Stormwater Compliance Deficiency #7: The diesel AST was leaking from a line leading from the tank. Any contaminated soil should be removed and disposed of properly. MCP ACTION: REMOVED CONTAMINATED SOIL FOR PROPER DISPOSAL. RESPONSIBILTY: MAINTENANCE ENGINEER TARGET DUE DATE: OCTOBER 15, 2008 (90 DAYS FROM REPORT) ACTUAL DATE COMPLETED: 6/27/08, Closed -No further action required Stormwater Compliance Deficiency #8: A cooling tower (designated by the facility staff as Cooling Tower 43) was found leaking water to the ground at the time of inspection. This could be a source of stormwater contamination. Cooling Tower #3 should be evaluated to determine if the leak is contaminating run-off, which could escape containment and leave the site. If this condition is found steps must be taken to resolve it. MCP ACTION: LEAKING WAS CAUSED BY UNDERGROUND SAFETY SHOWER PIPES. RELOCATED / REPLACED SAFETY SHOWER AND PIPING AND RE- WORKED TOWER LOUVERS. NO WATER ON GROUND HAS BEEN OBSERVED SINCE REPAIRS RESPONSIBILTY: MAINTENANCE ENGINEER TARGET DUE DATE: OCTOBER 15, 2008 (90 DAYS FROM REPORT) ACTUAL DATE COMPLETED: 6/3/2008, Closed -No further action required Stormwater Compliance Deficient #9: The permittee was determined to have three stormwater outfalls during the inspection. One of these outfalls conveys stormwater from the facility's documented outfall, and also conveys stormwater from a previously undocumented swale off the property. Water conveyed by the swale appears to bypass the facility's treatment system. These two outfalls are not documented in the facility's Stormwater Pollution Prevention Plan (SPPP). The two outfalls not previously identified in the SPPP must be evaluated to determine where they convey stormwater and include them in the SPPP. The SPPP has not been updated since December 18, 2002. The following sections of the SPPP were not current and/or missing: General Location map, Site map, the evaluation of feasible alternatives, the secondary containment stormwater records, the BMP summary, the Spill Prevention and Response Plan, the Preventative Maintenance and Good Housekeeping Plan, the Narrative Description of Storage Practices, and the list of responsible parties. The list of significant spills is out of date although the permittee stated that no incidents have occurred within the last five years. As per the new General permit issued in November 2007 the permittee must complete this evaluation yearly and certify the results. MCP ACTION: A CONTRACT CONSULTANT IS UPDATING THE SPPP AND WILL EVALUATE OUTFALLS AND UPDATE SPPP TO INCLUDE ALL OUTFALLS AS WELL AS INCORPORATE CHANGES TO OTHER PLAN ELEMENTS. RESPONSIBILTY: COMPLIANCE MANAGER 1 CONSULTANT TARGET DUE DATE: OCTOBER 15, 2008 (90 DAYS FROM REPORT) ACTUAL DATE COMPLETED: OPEN Stormwater Coni pliance Deficiency #10: The outfalls not previously identified by the permittee must be evaluated to determine if they are conveying stormwater/pollutants off -site. Any identified illicit discharges must cease immediately. The permittee has not performed qualitative monitoring due to a belief that the facility was collecting and processing its stormwater run-off through the on -site wastewater treatment plant_ During the inspection it was determined that this may not be the case as the inspectors located two additional outfalls. The additional outfalls must be monitored as required by the permit if they are found to directly discharge stormwater. MCP ACTION: THE MCP CONTRACT LABORATORY HAS BEEN SCHEDULED TO SAMPLE AND ANALYZE ALL OUTFALLS DURING THE NEXT SIGNIFICANT RAIN EVENT. RESPONSIBILTY: COMPLIANCE MANAGER TARGET DUE DATE: OCTOBER 15, 2008 (90 DAYS FROM REPORT) ACTUAL DATE COMPLETED: OPEN Stormwater Compliance Deficiency #11: The permittee has an inspection and maintenance program but it does not include inspections of the Stormwater Facilities. The permittee needs to develop and implement a Stormwater Facility Inspection Program and document it in the SPPP in accordance with the requirements of the General permit. MCP ACTION: DEVELOP, TRAIN APPROPRIATE EMPLOYEES AND IMPLEMENT A STORMWATER FACILITY INSPECTION PROGRAM. INSPECTION CHECKLIST WILL BE INCORPORATED INTO THE SPPP AND PLANT INSPECTION PROGRAM. RESPONSIBILTY: 'COMPLIANCE MANAGER TARGET DUE DATE: OCTOBER 15, 2008 (90 DAYS FROM REPORT) ACTUAL DATE COMPLETED: OPEN Stormwater Compliance Deficiency #12: Employee training is being performed in conjunction with other spill response and emergency training. Please ensure that the training conforms to the requirements of the permit by addressing stormwater management issues appropriately. MCP ACTION: THE UPDATED/REVISED TRAINING PROGRAM WILL BE REVIEWED TO ENSURE IT COVERS THE UPDATED SPPP AND CONFORMS TO THE REQUIRMENTS OF THE PERMIT. RESPONSIBILTY: COMPLIANCE MANAGER TARGET DUE DATE: OCTOBER 15, 2008 (90 DAYS FROM REPORT) ACTUAL DATE COMPLETED: OPEN