NCS000156_Inspection_20220809

ROY COOPER
Governor
ELIZABETH S. BISER
secretary
BRIAN WRENN
Director
August 22, 2022
Bakelite, LLC
Attn Ronald Bazinet
333 Neils Eddy Road
Riegelwood, NC 28456
NORTH CAROLINA
Environmental Quality
Subject: Compliance Evaluation Inspection
NPDES Individual Stormwater Permit NCS000156
Bakelite Synthetics
Columbus County
Dear Mr. Bazinet:
On August 9, 2022, Brian Lambe from the Wilmington Regional Office of the Division of Energy, Mineral, and
Land Resources (DEMLR), conducted a compliance evaluation inspection for Bakelite Synthetics located in Neils
Eddy Road, Columbus County, North Carolina. The site drains to Livingston Creek, which is currently classified as
Class C Waters in the Lumber River Basin.
The following observations were noted during the DEMLR inspection (please see the attached addendum for
additional information about your permit):
1) Stormwater Pollution Prevention Plan (SPPP)
A Stormwater Pollution Prevention Plan (SPPP) has been developed, recorded, and properly implemented. The
SPPP needs to be revised to better facilitate compliance with the permit. Tier 3 requirements are not recorded
in the SPPP.
2) Qualitative Monitoring
Qualitative monitoring has been conducted and recorded in accordance with permit requirements.
3) Analytical Monitoring
Analytical monitoring has not been conducted and recorded in accordance with permit requirements. Review
sampling requirements and protocols. Provide toxicity testing for this year.
Other Observations:
Permit is under review for renewal.
Thank you for your assistance and cooperation during this inspection. Please be advised that violations of the
NPDES Stormwater General Permit may be subject to a civil penalty assessment of up to $25,000.00 per day
for each violation. If you have any questions, comments, or need assistance with understanding any aspect of
your permit, please do not hesitate to contact Daniel Sams or me at [phone] or [e-mail]
Lambe
Environmental Specialist
Land Quality Section
Attachments: BIMS Inspection Checklist
cc: WiROFiles — Land Quality
Central Files — Laserfiche
D E QZ� North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
Wilmington Regional Office 1 127 Cardinal Drive Extension I Wilmington, North Carolina 28405

Compliance Inspection Report
Permit: NCS000156 Effective: 11/01/10 Expiration: 10/31/15 Owner: Bakelite LLC
SOC: Effective: Expiration: Facility: Bakelite Synthetics
County: Columbus 333 Neils Eddy Rd
Region: Wilmington
Riegelwood NC 28456
Contact Person: Emily Thompson Title: Phone: [phone]
Directions to Facility:
Hwy 74 W to Riegelwood area, right on NCSR 1878 go approx. 2 miles, right on NCSR 1820, go approx. 1/4 mile, left on NCSR
1818, go approx, 1/4 mile to plant entrance on left.
System Classifications: SWNC,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 08/09/2022 EntryTime 10:OOAM
Primary Inspector: Brian P Lamb / /
Secondary Inspector(s): I /
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ❑ Compliant 0 Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Exit Time: 12:OOPM
Phone:
Inspection Type: Compliance Evaluation
Page 1 of 4

Permit: NC5000156 Owner - Facility: Bakelite LLC
Inspection Date: 08/09/2022 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Met with Emily Thompson and Joel Johnson of Bakelite.
Reviewed the SPPP and conducted facility inspection.
Review of the SPPP revealed that the SPPP must be revised and updated to meet permit requirements
Sampling protocols need to be reviewed and conducted according to the permit.
Tier response must be followed and documented.
Toxicity testing must be conducted by the end of the year.
Page 2 of 4

Permit: NCS000156 Owner- Facility: Bakelite LLC
Inspection Date: 08/09/2022 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?
❑ ❑ ❑
# Does the Plan include a General Location (USGS) map?
❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices'?
0
❑ ❑ ❑
# 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 alternatives to current practices?
❑
0 ❑ ❑
# Does the facility provide all necessary secondary containment?
0
❑ ❑ ❑
# Does the Plan include a BMP summary?
0
❑ ❑ ❑
# 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)?
0
❑ ❑ ❑
# Is the Plan reviewed and updated annually?
❑
0 ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
0
❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
0
❑ ❑ ❑
Comment: The document provided for review was not sinned and dated for many of the reauired sections
For example. the Annual Certification was not signed and dated. Staff inquired as to the
significance of this requirement considering the electronic nature of the SPPP My response is
that the SPPP must be signed to document the required sections.
Some sections of the SPPP should be edited to better align with the permit requirements. For
example, the Corporate Certificate section is attempting to be two requirements at the same
time. The first paragraph is the Annual Certification for the SPPP The second paragraph
qualifies the stormwater outfalls for non stormwater discharges The second paragraph also
describes SD0006 (duck pond) as a non stormwater outfall. This page tries to accomplish
many tasks at once.
Facility inspections must occur semi annually.
Employee training must be documented in the SPPP.
The Stormwater Prevention Team must be updated and documented in the SPPP.
Qualitative Monitoring
Yes No NA NE
Has the facility conducted its Qualitative Monitoring? E ❑ ❑ ❑
Comment:
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? ❑ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ ❑
Page 3 of 4

Permit: NCS000156 Owner -Facility: Bakelite LLC
Inspection Date: 08/09/2022 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Comment: Facility is currently in Tier 3. Facility has not conducted any tier response actions per permit
requirements. Documentation of tier response is required
Sampling must be occurring on a monthly schedule Greater effors to collect the samples must
occur.
Toxicity sample was missed this year. Toxicity sample must be taken in first half of the year.
Collect Toxicity sample as soon as possible.
Permit and Outfalls Yes No NA NE
# 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:
Page 4 of 4