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HomeMy WebLinkAboutNCS000528_COMPLIANCE_20170328------STORIVIUVATER-D1VISfON-CODING-SHEET-- PERMIT NO. DOC TYPE 0 FINAL PERMIT ❑ MONITORING INFO ❑ APPLICATION 'J� COMPLIANCE ❑ OTHER DOC DATE 2.a'I 03� YYYYM M DD Energy, Mineral and Land R esources ENVIRONMENTAL QUAL.ITY March 28, 2017 Premiere Fibers, Inc. Attn: Dewey Fulton, Owner P.O. Box 8930 Bristol, VA 24203 Subject: COMPLIANCE EVALUATION INSPECTION NPDES Stormwater Individual Permit NCS000528 Premiere Fibers Anson County Dear Mr. Fulton: ROY COOPER Governor MICHAEL S. REGAN Secretary TRACY DAVIS Director On March 21, 2017, a site inspection was conducted for the Premiere Fibers facility located at 1.0056 US Highway 52 N, Ansonville, Anson County, North Carolina. A copy of the Compliance Inspection Report is enclosed for your review. Ted Kalamatas, EHS Manager was also present during the inspection and his time and assistance is greatly appreciated. The site visit and file review revealed that the subject facility, is covered by NPDES Stormwater Individual Permit NCS000528. Permit coverage authorizes the discharge of stormwater from the facility to receiving waters designated as a UT (unnamed tributary) to Buffalo Creek, a Class C stream in the Yadkin -Pee Dee River Basin. As a result of the inspection, the facility was found to be in compliance with the conditions of the NPDES Stormwater Individual Permit NCS000528. Please refer to the enclosed Compliance Inspection Report for additional comments and observations made during the inspection. If you or your staff has any questions, comments, or needs assistance with understanding any aspect of your permit, please contact me at 910-433-3384 or by e-mail at melissa.joyner@ncdenr.gov. Sincerely, Melissa Joyner Environmental Specialist DEMLR Enclosure: Compliance Evaluation Inspection cc: Ted Kalamatas, EHS Manager -- Premiere Fibers (via email) FRO — DEMLR, Stormwater Files-NCS000528 State of North Carolina i Environmental Quality I Energy, Mineral and band Resources Fayetteville Regional Office 1 225 Green Street, Suite 714 1 Fayetteville, NC 28301 410-433-3300 Compliance Inspection Report Permit: NCS000528 Effective: 06/01115 Expiration: 05/31/20 Owner: Premiere Fibers SOC: Effective: Expiration: Facility: Premiere Fibers County: Anson 10056 US Hwy 52 N Region: Fayetteville AnsonviNe NC 28007 Contact Person: Dewey Fulton Title: Phone: 276-645-9719 Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): On -site representative Related Permits: Inspection Date: 03/21/2017 Primary Inspector: Melissa A Joyner Secondary Inspector(s): Certification: Phone: Ted Kalamalas 704-826-6321 Entry Time: 10:30AM Tim L LaBounty Reason for Inspection: Routine Permit Inspection Type: Stormwater Discharge, Individual Facility Status: Compliant Not Compliant Question Areas: Storm Water (See attachment summary) Exit Time: 11:35AM Phone: inspection Type: Compliance Evaluation Page: 1 Permit: NCS000528 Owner - Facility: Premiere Fibers Inspection Dater 0312112017 Inspection Type : Compliance Evaluation - - Reason for Visit: Routine Inspection Summary: Melissa Joyner and Tim LaBounty, PE, met with Ted Kalamatas, EHS Manager, on March 21, 20V at the Premiere Fibers facility. The Stormwater Pollution Preventioin Plan (SPPP) was reviewed. An Individual Permit, NCS000528 was issued for the facility on May 4, 2015. The SPPP appeared neatly organized and contained the majority of the required information with the exception of documentation of an annual/review update which should include all items listed under #8 a-d. Also, the SPPP did not contain annual documentation of employee training as well as the facility personnel responsible for implementing the Spill Prevention and Response Procedures (SPRP)in a written list with the personnel/individual's name, signature and date, acknowledging their/his responsibilities for the plan. The analytical and qualitative monitoring records were reviewed and covered the monitoring periods stipulated in the permit. No exceedances.were noted since the previous inspection on 1/22/2015. Observations were made of the site conditions including the outfalls. Outfalls #145 were observed with no issues noted. There was a stockpile on the site. If this is a continuing active stockpile it is recommended that silt fence be installed, containing the stockpile to prevent migration of sediment. There is no vehicle maintenance, including washing of vehicles on the grounds of the facility. Preventative maintenance and good housekeeping activities are initiated on a monthly basis. Page: 2 t ,E Permit: NCS000528 Owner - Facllity;PremiereFibers Inspection Date: 03/2112017 Inspection Type : Compliance Evaluation Reason for Visit: Routire, Analytical Monitoring Has the facility conducted its Analytical monitoring? # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? Comment: 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: (,Qualitative Monitoring Has the facility conducted its Qualitative Monitoring semi-annually? Comment: Stormwater 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 alternatives 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? # Does the Plan include a Stormwater Facility Inspection Program? Has the Stormwater Pollution Prevention Plan been implemented? Comment: Yea No NA NE N 110 ❑ 013013 Yes No NA NE ❑ ❑ ❑ ■❑❑❑ ❑ ❑ ❑ ❑■❑❑ Yes No NA NE ❑ ❑ ❑ Yes No NA NE ❑ ❑ ❑ ❑ ❑ ❑ ■❑❑❑ ■❑❑❑ ❑ E ❑ ❑ ❑■❑❑ ❑ ❑ ❑ ■❑❑❑ ❑ ❑ ❑ ■❑❑❑ N ❑ ❑ ❑ ❑■❑❑ ❑■❑❑ ❑ ❑ ❑ ■❑❑❑ Page: 3 i n U.S. Postal Service,,,, CERTIFIED MAILrr., RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) For delivery infotmation visit our websifl!e at www.usps.comi r - Will .9 � 1 r - PS Form 3860, Anyum 20D6 Sec NOVOrse for wtlructign5 ■ Compiwe items 1, 2, and 3. Also complete item 4 if Restrlcted Delivery is desired. ■ Print your name and address on the reverse so thailwe can return the card to you. ■ Attach this card to the back of the mailpiece, or on the front if space permits. 1- Article Addressed to: PREMIER£ FIBERS ATTN: DEWEY FUL.TON P.O. BOX 8930 BRISTOL, VA 24203 , Y A. gnature X Agent Addressee B Re ived by (Pri ed Name} C. 16te of Delivery D, Ydelivery address different from item i? 0 Yes S If YES, enter delivery address below: 0 No FEB 2 3 2015 I 3. Service.Type, : . ,� .' ") I Certified Mail ' ❑ Express Mall `__SCE 11 Registered Return Receipt for Merchandise C] Insured Mail 0 C.O.D. 4, Restricted Delivery? (&Ira Fee) ❑ Yes 2. isticle Number (Transfer from service label) 7010 3090 0001 3216 0214 PSJForm 38111 Feb €uary 200Aj I {silt Re turn Receipt 102595•o2-M-1640 . Pat McCrory Governor NCDENR North Carolina Department of Enviroliment and Natural AesourcbS' February 6, 2015 CERTIFIED MAIL: 7010 3090 0001 3216 0214 RETURN RECEIPT REQUESTED Premiere Fibers Attn: Dewey Fulton PO Box 8930 Bristol, VA 24203 Subject: NOTICE OF DEFICIENCY (NOD-2015-PC-0037) Premiere Fibers NPDES Stormwater Individual Permit-NCS000528 Anson County Dear Mr. Fulton: Donald R. van der Vaart Secretary On January 22, 2015, Mike Lawyer and Lori Britt from the Fayetteville Regional Office along with Julie Ventaloro and hick Riddle with the Stormwater Permitting Program of the Division of Energy, Mineral and Land Resources, conducted a site inspection at the Premiere Fibers facility located at 10056 US Hwy 52 N, Ansonville, Anson County, North Carolina. A copy of the Compliance Inspection Report is enclosed for your review. Mr. Kevin Bowers, Technical Manager, and Mr. Ted Kalamatas, EHS Manager, were also present during the inspection and their time and assistance is greatly appreciated. The site visit and file review revealed that the subject facility is covered by NPDES Stormwater Individual-Permit-NCS000528. Permit coverage authorizes the discharge of stormwater from the facility to receiving waters designated as a UT (unnamed tributary) to Buffalo Creek, a Class C stream in the Yadkin -Pee Dee River Basin, As a result of the site inspection, the following deficiencies are noted: 1) Qualitative Monitoring Qualitative monitoring has not been conducted and recorded in accordance with permit requirements. 2) Analytical Monitoring Analytical monitoring has not been conducted and recorded in accordance with permit requirements. Other Observations: Please refer to the enclosed Compliance Inspection Report for additional comments and observations made during the inspection. Requested Response: A written response is not requested at this time. Division of Energy, Mineral, and Land Resources Land Quality Section Fayetteville Regional Office, 225 Green Street - Suite 714, Fayeneville, North Carolina 28301 Phone: 910-433-3300 / FAX: 910-486-07071 Internet: hftg: ponal.ncdenr.org/web/ir/ An Equal Opportunity 1 Affirmative Action Employer - 50% Recycled 110% Post Consumer Paper Thank you for your attention to this matter. This office requires that the deficiencies, as noted above, be properly resolved. Failure to address these items could result in the issuance of a Notice of Violation, which is subject to a civil penalty assessment of up to $25,000 per day for each violation. Should you have any questions regarding this matter, please contact Mr. Lawyer or myself at (910) 433-3300. Sincerely, Brad Cole, PE Regional Engineer Land Quality Section BC/m i Enclosure cc: Kevin Bowers, Technical Manager - Premiere -Fibers (via -e-mail) Ted Kalamatas, EHS Manager - Premiere Fibers (via e-mail) Bradley Bennett, Supervisor - Stormwater Permitting Program FRO - Land Quality Section, Stormwater Files-NCS000528 Compliance inspection Report Permit: NCS000528 Effective: 04/01/09 Expiration: 03/31/14 Owner: Premiere Fibers SOC: Effective: Expiration: Facility: Premiere Fibers County: Anson 10056 US Hwy 52 N Region: Fayetteville Ansonville NC 28007 Contact Person: Dewey Fulton Title: Phone: 276-645-9719 Directions to Facility: System Classifications: Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): On -site representative Kevin Bowers 704-826-8321 On -site representative Ted Kalamatas 704-826-8321 Related Permits: Inspection Date: 01/22/2015 Entry Time: 01: PM Exit Time: 03:20PM Primary Inspector: Mike Lawyer Phone: 910-433-330 721J_ Secondary Inspector(s): �f/��f—j� Julie Ventaloro Phone Lori H Britt Phone Rick L Riddle Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Stormwater Discharge, Individual Facility Status: ❑ Compliant Not Compliant Question Areas: Storm Water (See attachment summary) Page: 1 Permit: NCS000528 Owner - Facility: premiere Fibers Inspection Dater 0112MO15. _ Inspection Type r Compliance Evaluation Reason for Visit: Routine Inspection Summary: Current permit expired on March 31, 2014. Application for permit renewal has been submitted and is being processed with renewed permit under draft review: Inspection conducted to determine compliance with conditions of currentlexpired permit. Met with Kevin Bowers, Technical Manager, and Ted Kalamatas, EHS Manager. Reviewed facility's Stormwater Pollution Prevention Plan (SPPP) and available monitoring records. The SPPP contained all permit -required components with the exception of documentation of an annual reviewlupdate, which should include all items listed under Part II, Section A, item 7 of the current permit. Available analytical monitoring records showed several exceedances of the benchmark value for TSS (Total Suspended Solids) at several outfalls possibly due to recentlon-going construction activities for a warehouse addition. Although not triggered into monthly monitoring since exceedances of the TSS benchmark value were non-consecutive, some additional sampling was conducted in April 2014 for TSS and pH. This sampling would not count for the April -September 2014 monitoring period because it was conducted less than 60 days from the previous sampling event and not all parameters were tested at all outfalls. Although permit coverage expired on March 31, 2014, the permit contains language that states: "The applicant must continue semi-annual monitoring until the renewed permit is issued." Observations were made of site conditions including the outfalls. Some suggestions were made to provide additional ground cover or other BMPs in drainage areas where solids could be entering'the storm drainsloutfalls. It was also suggested to verify the outfall numbering with the sampler and revise the site map as necessary. Page: 2 Permit: NCS000528 Owner - Facility: Premiere Fibers Inspection Date: 0112212015. Inspection Type: Compliance Evaluation Reason for Visit: Routine Stormwater Pollution Prevention Plan Yea No NA NE Does the site have a Stormwater Pollution Prevention Plan? E ❑ ❑ ❑ # Does the Plan include a General Location (USGS) map? 0 ❑ ❑ ❑ # 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 ❑Y ❑ ❑ # Does the facility provide all necessary secondary containment? N ❑ ❑ ❑ # 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? 0 ❑ ❑ ❑ # Does the Plan include a list of Responsible Party(s)? 0 ❑ ❑ ❑ # Is the Plan reviewed and updated annually? ❑ ■ ❑ ❑ # Does the Plan include a Stormwater Facility Inspection Program? 0 ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? 0 ❑ ❑ ❑ Comment: Plan needs documentation of an annual_rev_iew/update to include an updated fist of any significant spills over the previous three years or notation that none have occurred and re -certification that the stormwater outfalls have been evaluated for the presence of any non-stormwater discharges. Qualitative Monitoring Has the facility conducted its Qualitative Monitoring semi-annually? Yea No NA NE ❑ E ❑ ❑ Comment: Monitoring per the conditions of the Dermit was not conducted for the oehod of Aoril-Seotember 2014. Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? ❑ 0 ❑ ❑ # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ 1:10 ❑ Comment: Monitoring per the conditions of the permit was not conducted for the period of April -September 2014. Permit and Outfalls Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? ❑ ❑ ❑ E # Were all outfalls observed during the inspection? ■ ❑ ❑ Cl # If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ❑ # Has the facility evaluated all illicit (non stormwater) discharges? ❑ i ❑ ❑ Comment: Seecomment above regarding rding annual review/update. Page: 3 Premiere Fibers site visit 1/22/2015 Mike Lawyer, FRO Julie Ventaloro, CO Rick Riddle, CO Lori Britt, FRO (erosion control) Kevin Bowers, Premiere Fibers Ted Kalamatas, Premiere Fiber They contract with Waters Edge to do monitoring. Outfalls may be in reverse order than what reported in monitoring. Annual review was conducted and SPPP updated within past 4 months. Recent addition to warehouse. Had a small spill of spinning oil in 2008. New EHS manager (Ted Kalamatas) Have above -ground storage of diesel fuel with secondary containment. Dumpsters were covered with tarps. They are getting lids for them. May have had two consecutive exceedances of TSS, but couldn't tell conclusively since there was data missing from second periods of 2013 and 2014. Facility staff will contact Waters Edge about the missing data. They should also remind them that they need to mail copy of DMRs to Central Files. Send renewal materials (draft permit, final permit) to Kevin, Ted and Dewey Fulton ("owner," corporate EHS) Mike will follow up on inspection; may issue an NOD or NOV for permit conditions. Ventaloro, Julie From: Lawyer, Mike Sent: Thursday, November 20, 2014 9:47 AM To: Ventaloro, Julie Subject: RE: another permit question Follow Up Flag: Foiiow up Flag Status: Flagged I'll schedule an inspection, but it will likely be after Thanksgiving. Will let.you know what I observe. Michael Lawyer, CPSWQ Environmental Specialist NCDENR - Division of Energy, Mineral and Land Resources Land Quality Section Fayetteville Regional Office P: (910) 433-3394 F: (910) 486-0707 e-mail: mike.lawyer(@ncdenr.gov *E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be, disclosed to third parties. From: Ventaloro, Julie Sent: Wednesday, November 19, 2014 4:33 PM To: Lawyer, Mike Subject: FW: another permit question Hey Mike, So I found only two sets of data in our database (which I think only goes back to 2011), so there might be some older data out there. One sample taken in 2012 looked fine for TSS and COD at all 5 outfalls; 1 outfall had low pH at 5.4. However, the 2013 sample was high for TSS at 3 out of 5 outfalls; 121, 397, and 1,430. This was after about an inch rainfall. COD and pH were fine. would you be willing/available to do a site visit in advance of the staff report/draft permit writing? I would like to find out if they have made any changes to their site that would qualify them for no exposure. Either way, your site visit could count either towards renewal or no exposure approval. Their renewal application states they haven't had any significant changes in their activities or storage practices, so I'm not optimistic about their chances for no exposure. But it seems to me to be worth checking into. Thanks! Julie From: Ventaloro, Julie Sent: Friday, October 17, 2014 8:33 AM To: Lawyer, Mike Subject: RE: another permit question They submitted data for just one sample date with their renewal materials. I'll have to look in our DMR database and see if they submitted any other data to us between 2008 and 2012. If that's all the data they've collected in the past 5 years, that's another issue we'll need to talk to them about. The data they did submit was fine as far as TSS and COD. One pH that was slightly low. I'll let you know what I uncover. Thanks for checking into it, Julie From: Lawyer, Mike Sent: Thursday, October 16, 2014 4:23 PM. To: Ventaloro, Julie Subject:.RE: another permit question Sorry for the delay. I had to go pull the file and refresh my memory on that one. It looks like my site visit in 2008 was not an inspection, but in response to their initial permit application. This would be their first renewal. Unfortunately, I have not been back to the site nor has anyone else apparently. There's nothing in the file except their initial application, -.draft permit, staff report and final permit for 2009 to 2014. In addition to the uncovered dumpsters, my comments also indicated that there were a few pieces of old equipment and used pallets stored outside. Did they submit any analytical monitoring data with their renewal application? If so and there are any exceedances or elevated results, then I think we should process.the renewal: If not, or all of their results are well below benchmarks, then I could do.a site visit to see if they could qualify -for no exposure: Michael Lawyer; CPSwQ Environmental Specialist NCDENR - Division of Energy, Mineral and Land Resources Land Quality Section Fayetteville Regional Office P: (910) 433-3394 F: (910) 486-0707 e-mail: mike.lawyer@ncdenr.gov<mailto:mike.lawyeroncdenr.gov> E-mail correspondence to and from this address is subject to the North Carolina Public Records Law.and'may be disclosed to third parties unless the content is exempt by statute or other regulation. From: Ventaloro, Julie Sent: Thursday, October 16, 2014 3:55 PM To: Lawyer, Mike Subject: another permit question Mike, I'm reviewing an individual permit renewal application for Premiere Fibers in Anson County (NCS000528). I see that you inspected the site during the last renewal in 2008. At that time, you said that if they covered their dumpsters, they may qualify for No Exposure. Have you been back to that site since then, and do you know if they've made those changes to their site? Just thinking that if they now qualify for NEC, we wouldn't need to go through the renewal process with them at this point. Thanksl Julie Ventaloro Stormwater Permitting Program NC Division of Energy, Mineral, and Land Resources 1612 Mail Service Center, Raleigh, NC 27699-1612 Phone: (919) 807-6370 Fax: (919) 807-6494 Web5lte:'htt watersu 1 watershed.nc. ov<htt watersu 1 watershed.nc. ov > 2