NCG070156_Response to NOV_20190114

_ SEI.CORPOR EE Al
January 14, 2019
Mr. Stanley E. Aiken
Regional Engineer
Land Quality Section
Department of Environmental Quality
2090 U.S. Highway 70
Swannanoa, NC 28778
Subject: Response to Notice of Violation
Tracking No.: NOV-2018-PC-0478
NPDES Permit No.: NCG070000
Certificate of Coverage No.: NCG070156
Dear Mr. Aiken,
The Notice of Violation letter concerning our site inspection on December 6, 2018 was received by
SELEE Corporation on December 24, 2018. We take the upmost concern for compliance with our permit
and immediately implemented a Plan of Action for address these permit violations.
Plan of Action:
1) Stormwater Pollution Prevention Plan (SPPP)
• A full review and revision of the SPPP was completed in December. A notebook
containing all relevant documentation for the SPPP was created and is now stored in a
central location of the facility. Due to the way we organize our quality system, records
pertaining to the SPPP were previously stored in various locations. We appreciate the
time that Isaiah Reed took to explain the preferred format for our SPPP and these
changes have been implemented.
• Annual training for all employees on the SPPP is scheduled for February 2019.
2) Secondary Containment Requirements and Records
• The Monoaluminum Phosphate tank will be completely emptied of material and
removed from use by the end of January. The material will be relocated to a storage
area inside the facility. The empty tank will be locked out and tagged so that it cannot
be used.
• Empty wastewater totes stored outside the building have been reduced to a maximum
of four totes in any one location. We were unaware that empty totes would fall under
the bulk storage secondary containment requirement. This was a lesson learned for us
and we appreciate your understanding. This process change was communicated to all
employees during our monthly meeting on January 8, 2019. It will be communicated
again during our full SPPP training in February 2019.
• The cooling water tank without secondary containment will be removed and a new,
double walled tank installed. We had not previously considered the need for secondary
containment for this bulk storage tank, but fully understand why it is a requirement. We
pervair
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700 Shepherd Street, Hendersonville, NC 28792 USA
[phone] [phone] Fax: [phone]

Mr. Stanley E. Aiken
January 14, 2019
Page 2 of 2
are currently receiving quotes for the new tank and expect installation to be complete
by May 2019.
In addition to the above actions, as part of our Best Management Practices (BMPs), we have installed a
cover on our metal recycling container.
We thank you for considering our responses to this Notice of Violation. Please do not hesitate to
contact Alesia Griesmyer at aareismyer0selee com [phone] or myself at wiackson0selee com
[phone] if any additional information is required.
Sincere
Watt Jackson, President
SELEE Corporation
Ec: Alesia Griesmyer, EHS Manager
psrvair
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700 Shepherd Street, Hendersonville, NC 28792 USA
[phone] [phone] Fax: [phone]