NCS000368_COMPLIANCE_20111013

--WSTORMWATER-DIVISION-CODING_SHEET-­
PERMIT NO.
N c S q.00 1L�l
DOC TYPE
❑ FINAL PERMIT
❑ MONITORING INFO
❑ APPLICATION
k COMPLIANCE
❑ OTHER
DOC DATE
❑ )-o111 o 1 l
YYYY M M D D

MJ-A'
NC®ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
October 13, 2011
Powerlab Inc. Powerlab Inc.
Attn: Forrest Tunnell, Executive Vice President Attn. Jeff Ward, Plant Manager
P.O. Box 913 3352 Old Lexington Road
Terrell, TX 75160 Winston-Salem, NC 27107
Subject: Compliance Evaluation Inspection & Notice of Deficiency
NPDES Individual Stormwater Permit NCS000368
Powerlab, Inc.
Forsyth County
Dear Mr. TunnelilMr. Ward:
1, Ron Boone of the- Winston-Salem Regional Office of the NC Division of Water Quality (DWQ)
conducted a compliance evaluation inspection (CEI) at the subject facility on October 11, 2011.
Your assistance and cooperation, as well as that of Chris Brady, Operations Engineer, :were
greatly appreciated. An inspection checklist is attached for your records and the inspection
findings are summarized below.
2. The facility is located at 3352 Old Lexington Road, in Winston Salem, Forsyth County, North
Carolina. Stormwater related to industrial activity is discharged from two separate stormwater
discharge outfalls (SDO) at the site, to an unnamed tributary (UT) of Salem Creek, this section of
which is currently classified as- Class C waters in the Yadkin Pee -Dee River basin. It is noted that
the plant was shut down from March, 2009, through August; 2010.
Documentation & Monitoring Review
3. The site has a good Stormwater Pollution Prevention Plan (SP3) but it does not meet all permit
conditions and has not yet been fully implemented. Deficiencies noted with the actual SP3
document, and its implementation, are listed below:
a. The general location map only lists the latitudellongitude for one of the stormwater discharge
outfalls (SDO). It should specify an accurate latitudellongitude for each of the SDOs.
b. The site map does not specify the percentage of the site, or of each drainage area, which is
impervious.
c. The spill prevention and response plan (SPRP) does not contain a list of emergency contacts
for spills, such as environmental cleanup companies, the local HAZMAT team, and NC DWQ
contact numbers.
North Carolina Division of Water Quality, Wmston-Satem Regional Office
Location: 585 Waughtown St. Winston-Salem, North Carolina 27107 One
Phone: [phone] FAX: [phone] Customer Service: 1-877.623-6748 North Carolina
Internet: www.ncwaterquality.org �j w r all
An Equal Opportunity 1 Affirmative Action Employer �/ ►� v� ` l

Powerlab, Inc
Attn: Forrest Tunnell, Executive Vice President
Compliance Evaluation Inspection, NCS000368
1011312011, Page 2 of 3
d. The SP3 was originally written in November, 2001, and then revised in September, 2006, and
again in January, 2008. However, annual reviews/updates have not been
conducted/documented as required.
e. The original certification of the SDOs was accomplished in September, 2006. It was done
again in January, 2008. It has not been done annually, as required.
f. The list of spills has not been updated since 2008. It is noted, however, that you stated during
the inspection that there have been no reportable spills.
g. Annual training was accomplished in 2008 and 2011. It was not accomplished in 2007 or in
those partial years that the plant was in operation (plant was shut down from March, 2009,
through August, 2010).
h. Facility inspections were not conducted in 2009 and only one was conducted in each year of
2010 and 2011. Bi-annual inspections were conducted in all other years from 2002 through
2008, as required.
4. Qualitative monitoring was accomplished in August, 2010, and February, 2011, as well as bi-
annually in every year from 2002 through 2008. For those partial years when the plant was in
operation (plant was shut down from March, 2009, through August, 2010), documentation should
have been made as to why qualitative monitoring was not accomplished at least once.
5. Concerning analytical monitoring, Powerlab was using a non -NC certified laboratory until the issue
was brought -to their attention in the December, 2007 and January, 2008 inspections.. Additionally,
not all analytical monitoring has been conducted as required (i.e. bi-annually) and the monitoring
that has been done has resulted in several exceedences of the lead and pH benchmark values.
Results for lead ranged from 0.05 milligrams per liter (mg/1), at its best, to 4.37 mgll at its worst.
Although modest, there has been some documentation of activities undertaken to find and correct
the cause of lead exceedences. Please note that the tiered requirements in the new draft
permit require that you undertake aggressive investigative. measures to find and correct
the cause of the lead exceedences, and institute monthly analytical monitoring, until three
consecutive samples show lead concentrations below the benchmark. These investigative
measures must also be very well documented. In order to get a head start on finding the
cause of the lead exceedences, it may be to Powerlab's advantage to institute these
investigative measures and monthly monitoring immediately, instead of waiting for the new
permit to come into effect. Powerlab may also need to consider the need for outside help
from an environmental consultant or laboratory.
Site Review
6. In general the site was very clean. Mr. Boone noted no deficiencies or violations. Mr. Boone did
note, however, that Powerlab could eventually qualify for what the Division calls a No Exposure
Certification (NEC), with relative ease. The NEC is a special permit which acknowledges the
site's unique condition of not having any industrial materials or activities exposed to precipitation
of any Kind. In fact, the site would qualify for the NEC now, had it not been for the SP3
deficiencies and lead exceedences discussed above. As soon as the SP3 deficiencies and lead
exceedence are corrected, as long as Powerlab maintains current site conditions (i.e. no industrial
material or activity exposed to precipitation), a NEC may be feasible. A NEC would eliminate the
need for the SP3, the qualitative monitoring, and the analytical monitoring.

'r
Powerlab, Inc
Attn: Forrest Tunnel1, Executive Vice President
Compliance Evaluation Inspection, NCS000368
10/1312011. Page 3 of 3
7. You are reminded that violations of the NCS000368 individual stormwater permit are
subject to civil penalty assessments not to exceed $25,000 per day per violation. Please
reply in writing to this Notice of Deficiency within 30 business days of receiving it. Your
written response should include corrective actions with implementation schedules for each
deficiency noted above in paragraphs 3 through 5.
8. Thank you for your cooperation in this matter. Should you have any questions, please feel free to
contact Mr. Boone or me at [phone],
Sincerely,
W. Corey Basinger
Water Quality Regional Supervisor
Winston-Salem Region
Division of Water Quality
Attachments:
1. BIMS Inspection Checklist
cc �Swp;:::WSRO'
Central Files
Stormwater Permitting Unit

Compliance Inspection Report
Permit: NCS000368 Effective: 10/01/06 Expiration: 09/30/11 Owner: Powerlab Inc
SOC: Effective: Expiration: Facility: Powerlab Incorporated
County: Forsyth 3352 Old Lexington Rd
Region: Winston-Salem
Winston Salem NC 27107
Contact Person: Carl Comstock Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Certification: Phone:
Inspection Rate: 10/1112011 Entry Time: 09:00 AM Exit Time: 12:00 PM
Primary Inspector; Ron Boone ? Phone: [phone]
Secondary Inspector(s);
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: I

Permit: NCS000368 Owner -Facility: Powerla6 Inc
Inspection Date: 10/1112011 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Please refer to the attached inspection summary letter
Page: 2

Permit: NCS000368 Owner -Facility: Powerlab Inc
Inspection Date: 10/11/2011 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"?
■ ❑
❑ ❑
# Does the Plan include a detailed site map including outfali locations and drainage areas?
■ Cl
❑ ❑
# 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?
■ ❑
Cl ❑
# 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 Slormwater Pollution Prevention Plan been implemented?
■ Cl
❑ ❑
Comment: Please refer to the attached inspection summary letter.
Qualitative Monitoring
Yes No
NA NE
Has the facility conducted its Qualitative Monitoring semi-annually?
■ ❑
❑ ❑
Comment: Please refer to the attached inspection summary letter.
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?
D ❑
■ 0
Comment: Please refer to the attached inspection summary letter.
Permit and Outfalls
Yes No
NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site?
MOO
❑
# 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?
■ ❑
❑ ❑
Comment: Please refer to the attached inspection summary letter.
Page: 3

((D
Powerlab
January 24, 2008
Mr. Steve W. Tedder
Water Quality Regional Supervisor
Winston-Salem Region
Division of Water Quality
585 Waughtown Street
Winston-Salem, NC 27107
Dear Mr_ Tedder,
This letter is in response to the storm water inspection that was performed on our facility in the Salem
Business Park in Winston-Salem North Carolina on December 11, 2007. Powerlab is appreciative of
knowing of the areas that were pointed out as being outside of the permit or incomplete during the
inspection. Powerlab prides itself on being environmentally a good neighbor and a responsible
corporate citizen_ There was never intent to violate any rule or regulation as to storm water discharge at
the facility. We have completely reviewed our SWPPP and revised it to conform to the issues that came
to light during the inspection and some issues we discovered while re-evaluating our SWPPP.
I will now respond to the compliance issues that were brought to our attention during the inspection.
The missing certification of the SWPP date was an oversight on our part and has been corrected
in the attached revised SWPPP that is attached to this letter along with the certification to the
revised plan training.
The permit issued from the NCDENR did not spell out that we had to use a North Carolina
Certified Lab for our water analysis. Powerlab was unaware that this was a requirement of the
permit. We have plants in two other states and use the same laboratory in Texas for all our
outside analytical work. If we had known about this requirement we would have used a North
Carolina Certified Lab. We will use a North Carolina Certified Lab for all future storm water
analysis as you have instructed.
• Powerlab had previously checked the abandoned pipes that are referred to as illicit discharges in
the inspection report and found no affluent coming from the pipes. We have now capped each of
Powerlab, Inc. - P. O. Box 913 - Terrell, Texas 75610
972-563-1477 - 800-346-5140 - FAX:[phone]

the pipes as instructed to do so by your inspectors to make certain there are no discharges from
the pipes. (Photos in Attachment A attached)
• Storm water Pollution Plan is incomplete and not being followed: We have revised the plan and
eliminated one of the three outfalls that was in the original SWPPP. We have relocated Outfall
#2 location to make sure it includes all the water from the raised parking area outside the plant
office. It is now located at the southwest corner of the raised parking area in the tiled drainage
ditch along the railroad track. (Photo in Attachment A attached) This location will make certain
that all water leaving the building and parking areas in front of the office is included in the
sample.
• The missing semi-annual inspection for the Spring of 2006, that was noted in the report is in the
SWPPP book at the facility. A copy should have been with all the others in the SWPPP that was
sent to your office. Powerlab has not missed any inspections or required analysis that is
required under the permit.
The issue of poor housekeeping was the area around the garbage dumpster located in the
abandoned truck dock near outfall # 1. Some paper and trash had been dropped or fell from the
dumpster. This area has been cleaned and a daily inspection is being made of the area to prevent
any trash from being outside the container. (Photo in Attachment A attached)
• All Powerlab personnel have received training in the SWPPP. This was documented along with
their training in other areas of the facility that is required at least annually. Powerlab was not
maintaining a copy of this training in the SWPPP as we stated in our plan. We have now
addressed this problem and the documentation of the training is placed in Appendix F of our
SWPPP and will be done so in the future. Training on the revised plan has been done and
documented as required.
Powerlab has re-evaluated all storm water drainage from the area that is leased from Salem Business
Park and using this information we have revised our Storm Water Pollution Prevention Plan. (Copy
included with this letter) Powerlab will continue to evaluate the plan as data is collected from the two
outfalls and revise the plan if the need arises. The elimination of the old Outfall #3 will eliminate an
area where we had the most potential for contamination of storm water by lead at the facility. Even
though we had a valve that could be closed in case of a spill during the loading process, we still had the
potential of contaminating the storm water. This has been eliminated by using this water in our process.
It also will save Powerlab some expense of purchasing water for cooling the process_ The contract with
a plumbing company has been let for these changes and they will be completed by January 25.2008.
(Photo in Attachment A attached)
Powerlab, Inc. - P. O. Box 913 - Terrell, Texas 75610
972-563-1477 - 800-346-5140 - FAX:[phone]

Powerlab again wants to thank you and your staff for the help you have given us in complying with the
Storrn water requirements for the State of North Carolina.
If you or your staff needs additional information please let us know.
Sincerely,
A;W,
Donald Rabon
Manager of Engineering
POWERLAB, INC.
Attachment "A"
Powerlab, Inc. NC SWPPP Revised
Powerlab, Inc. - P. O. Box 913 - Terrell, Texas 75610
972-563-1477 - 800-346-5140 - FAX.[phone]

ATTACHMENT "A"
Photos for Storm Water Pollution Prevention Plan
January 2008
y
1:1
vutrail fNo. 1 -- Ananaonea 1 rucK UocK now usea for parKing ana recycle ana trash bins.
n
�V'n�:I
Outfall No. 2 Sampling Site
r `F��
All
Abandoned Pipe Capped
Powerlab, Inc. - P. O. Box 913 - Terrell, Texas 75610
972-563-1477 - 800-346-5140 - FAX:[phone]

ATTACHMENT "A" Continued
Abandoned Pipe Plugged Old Outfall No. 3
No Discharge
New Sump Pump to Process
Being Installed 1 /23/08
Powerlab, Inc. - P. O. Box 913 - Terrell, Texas 75610
972-563-1477 - 800-346-5140 - F'AX:972-563-8473

\ Stormwater Inspection
• • • ■ • / C ■ . • • • f • • • F a • • ■ • a • • • ■ ■ • • • • ■ ■ ■ • a • • a • ■ • ■ • • ■ ■ • • 2 • / • ■ i ■ ■ • 0
Facility Nstoe a w E O—w 0
Permit Number c- 5 oo 0-;6q Ac.fivity
Facility Address
County
Mailing Address - — - -
City State Zip
Facility Contact
Title
Telephone Number
Inspection late 61 j 2- O? Time
Entry Time
Inspector(s)
Facility. Representative(s)
Other Agencies
Representatives
Exit Time

II Part 11 MonitorMQ. Controls and Limitations for Permitted Discharp-e I
Section A: Storm -water Pollution Prevention Flan.
.1. Site Plan —shall provide a description of the physical facility and the potential pollutant sources which may be
expected to contribute to contamination of stormwater discharges. The site plan shall contain the following:
a. General Location ',\'Ia — USGS quadrangle ap orequivalent sho«'ing:
Facilit}' location in relation to transportation routes and surface waters.
Tile hale of the receiving water(s) to which (lie stortdlwaler outfall(s) discharges:
OR if the discharge is to a municipal separate storm sewer system, the name of the municipality and the
ultimate receiving waters:
Accurate latitude and longitude of the point(s) of discharge.
b. Narrative description of:
Storage practices (raw materials, fuels, intermediate products, byproducts. waste materials, finished
products)
✓
Loading and unloading activities.
�JL}
Outdoor process areas (types of processes and equipment used).
.l
Dust or particulate generating or control processes (crushing, mixing, burning, drying operations).
�✓ waste disposal operations (solids, liquids, residuals/sludges).
C. Site tna drar�'n to scale rith distance legend indicating:
Location of industrial activities (including storage.of materials, disposal areas, process areas, loading and
unloading areas)
✓ Drainage structures (outfalls, stormwater conveyance system, retention ponds, diversion structures,
ditches. culverts, swales, porus pavement, sediment trans, erosion control, storm drain inlets).
✓ Drainage areas for each outfall (now pattern).
Activities occurring in the drainage area.
Building locations.
Existing BMP's and impervious surfaces.
yC % of each drainage area that is impervious.
For each outfall; a narrative description of potential pollutants tti'llich could be expected to be present.
✓ Location of exposed significant raterials.
IvA Location of past spills and leaks.
ivA Fueling stations.
/,/A Vehicle and equipment maintenance.
NL# Vehicle and equipment washing.
vl- Loading and unloading areas.
IVA above ground liquid storage (,inks.
y( Industrial waste management areas and outside manufacturing.
Outside storage of raw materials, by-products or finished products.

d. List of significant spills or leafs of pollutants that have occurred at the facility during the 3
previous ears:
List of significant spills or leaks (includes hazardous substances in excess of reportable quantities reported
to National Response Center/ Appendix I-1).
Corrective actions to mitigate spill impacts.
e. Certification that the stormwater outfalls have been evaluated for the presence of non-
stormwater discharges.
Certification statement signed in accordance with Part III, Standard Conditions, Section B. Paragraph 5.
tischarge tested (dye tracing, chemical analyses)for presence of non-stormwater discharge (process water,
vehicle/c tri )ment wash water, sanitar , waste, etc). disconnect or a I for r1PDES permit].
2. Stormwater Management Plan.. The stormwater management plan shall contain a narrative description of
the materials management practices employed which control or minimize'the exposure of significant materials to -
stormwater, including structural and non-structural measures. The stormwater management plan, at a minimum,
shall incorporate the followin
a. Feasibility study. A review of the technical and economic feasibility of changing the methods of operations
and/or storage practices to eliminate or reduce exposure of materials and processes to stormwater. Wherever
tactical the permittee shall;
7c
Prevent exposure of all storage areas. (roof, enclose, drainage diversion; move materials inside, pallets)
>c
Nlaterial handling operations.
,{
Manufacturing operations.
fueling operations.
x
Loading and unloading areas. (roof; berms, grading)
X
Outdoor process areas. ( street sweeping, structural devices)
Dust or particulate control.
;{
Waste disposal practices. (lids, roof)
b. Secondary Containment Schedule. for bulk storage of liquid materials, storage of Section 313 of"title III
of the SARA water priority chemicals (appendix 1), or storage of hazardous substances to prevent leaks and spills
from contaminating stormwater runoff.
Secondary Containment - spill containment for the contents of the single largest tank within the
N
containment structure plus sufficient freeboard to allow for 25 yr, 24 lir storm event 5-6 irpl.
Bulk storage of liquids (single above ground container with capacity greater than 660 gallons or Multiple
/JA
containers in close proximity with combined storage capacity greater than 1,320 gallons). [ex. More than
24, aS alEon drums]
11lanually activated valves w/ locks- If secondary containment devices are connected directly to stormwater
rjA
conveyance systems, connection ;rust be controlled by manually activated valves or similar devices [which shall
be secured with loc'.knin devices]
Records documenting stormwater release from secondary containment (5 years) — any stormwater that
accumulates in the containment area shall be at a minimum visually observed for color, foam, outfall staining,
visible sheens and dry weather flow, prior to release of the accumulated stormwater. .Accumulated stormwater
shall be released if found to be uncontarninated by the material scored within the containment area. Records
documenting the individual making the observation, the description of the accurnidated stormwater and the date
and time of the release shall be kept fora pe.riod of five years.
C. _ IMP
Summary.
A narrative description shall be provided of 13NIP's to be considered such as, but not limited to, oil and grease
separation, debris control, vegetative biter strips, infiltration and stormwater detention or retention, where
✓
necessary. The need for structural BNIP's shall be based on the assessment of potential sources to contribute -
significant quantities of pollutants to stormwater discharges and data collected through monitoring of stormwater
discharges.

d. Ins ection Schedule
f ✓ Schedules for inspection of.storrnwater conveyances, controls, and measures to be taken to limit or prevent
erosion associated with the stormwater systems.
3. Spill Prevention and Response Plan. The Spill Prevention and Response Plan (SPRP) shall incorporate
an assessment of potential pollutant sources based on a materials inventory of the facility.
Materials Inventory
✓
Facility personnel (or team) responsible for implementing the SPRP identified.
A responsible person — shall be on site at all times during facility operations that might have the potential to
contaminate stormwater runoff through spills or exposure of_material associated with the facility operations.
SPRP must be site stormwater specific. SPCC play be a component of SPRP.
Areas where spills can occur and their discharge points.
/V
Spill response team
�.
Spill response equipment and locations.
Spill containment, diversion, isolation, and cleanup.
Reporting procedures along with names and numbers.
.r
Material handling and storage procedures.
✓
Safety measures.
L4,. PreventativeI'Vlaintenance and Good Housekeeping Program. A preventative maintenance program
all be developed. The program shall document:
✓
Schedules of inspections of stormwater control systems.
Schedules of maintenance activities of stormwater control systems.
Schedules of inspections and maintenance of plant equipment and systems.
,.
Inspection of material handling areas.
Rebular cleaning schedules of material handling areas.
F,t
Errtployee Training. Training schedules shall be developed and training provided at a minimum of an
ual basis on proper spill response and cleanup procedures and preventative maintenance activities for all
onnel involved in any of the facility's operations that have the potential to contaminate stormwater runoff.
.i Facility personnel (or team) responsible for implementing the training identified.
r/ Training schedules developed.
10A Annual training provided on spill response and cleanup.
6. Respottsibl: 1'arfy. The SPPP shall iiletitify a specific position(s) responsible for the overall coordination,
development, implementation, and revision to the Plan. Responsibilities for all components of the Plan shall be
documented and position assi uments provided.
✓ Position identified.
,,-I Responsibilities assigned and documented.
7. Plan ?amendment. The permittee shall amend the plan whenever there is a change in design, construction,
operation, or maintenance which has a significant effect on the potential for the discharge of pollutants to surface
waters.
Plan is current. (design, operation, construction, maintenance) �I
WA SWPP reviewed and updated on 211 annual basis. If

�. Facility Inspections. Inspections of the facility and all stormwater systems shall occur at a tninimum :onja
semi-annual schedule; 5 years
A
Fall Inspection (September -November)
,,vA
Spring Inspection (April -,tune)
Maintenance activities documented. (date and time of inspection, individual making the inspection, and a
narrative description of the facility's stormwater control systems, plant equipment and Systems).
N F
Inspection records incorporated into SPPP
9. Impletrlentation. Implementation of the plan shall include documentation of all monitoring; measurements,
inspections and tnnintenance activities taken to iniplentent I3NW's associate(' with the industrial activities, including
vehicle maill tt"nalice activities. Such documentation shall be kc.pt oat -site for a period of five years and made
available to the Director or his authorized representative immediately upon request.
JNlonitoring
Inspections
Maintenance activities
Documentation (5 years)
Additional Comments: r7 �
/V, y J `NATO—r4�E j O or f}/J'z eyvv—c7 r �+�✓

I
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NC®ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
October 13, 2011
Powerlab Inc. Powerlab Inc.
Attn: Forrest Tunnels, Executive Vice President Attn: Jeff Ward, Plant Manager
P.O. Box 913 3352 Old Lexington Road
Terrell, TX 75160 Winston-Salem, NC 27107
Subject: Compliance Evaluation Inspection & Notice of Deficiency
NPDES Individual Stormwater Permit NCS000368
Powerlab, Inc.
Forsyth County
Dear Mr. Tunnell/Mr. Ward:
1. Ron Boone of the Winston-Salem Regional Office of the NC Division of Water Quality (DWQ)
conducted a compliance evaluation inspection (CEI) at the subject facility on October 11, 2011.
Your assistance and cooperation, as well as that of Chris Brady, Operations Engineer,'were
greatly appreciated. An inspection checklist is attached for your records and the inspection
findings are summarized below.
2. The facility is located at 3352 Old Lexington Road, in Winston Salem, Forsyth County, North
Carolina. Stormwater related to industrial activity is discharged from two separate stormwater
discharge outfalls (SDO) at the site, to an unnamed tributary (UT) of Salem Creek, this section of
which is currently classified as Class C waters in the Yadkin Pee -Dee River basin. It is noted that
the plant was shut down from March, 2009, through August, 2010.
Documentation & Monitoring Review
3. The site has a good Stormwater Pollution Prevention Plan (SP3) but it does not meet all permit
conditions and has not yet been fully implemented. Deficiencies noted with the actual SP3
document, and its implementation, are listed below:
a. The general location map only lists the latitude/longitude for one of the stormwater discharge
outfalls (SDO). It should specify, an accurate latitude/longitude for each of the SDOs.
b. The site map does not specify the percentage of the site, or of each drainage area, which is
impervious.
c. The spill prevention and response plan (SPRP) does not contain a list of emergency contacts
for spills, such as environmental cleanup companies, the local HAZMAT team, and NC DWQ
contact numbers.
North Carolina Division of Water Quality, Winston-Salem Regionai Office
Location: 585 Waughtown St. Winston-Salem, North Carolina 27107
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
An Equal Opportunity 1 Affirmative Action Employer
NoithCarolina
Naturally

Powerlab, Inc
Attn: Forrest Tunnel[, Executive Vice President
Compliance Evaluation Inspection, NC5000368
10113/2011, Page 2 of 3
d. The SP3 was originally written in November, 2001, and then revised in September, 2006, and
again in January, 2008. However, annual reviews/updates have not been
conducted/documented as required.
e. The original certification of the SDOs was accomplished in September, 2006. It was done
again in January, 2008. It has not been done annually, as required.
f. The list of spills has not been updated since 2008. It is noted, however, that you stated during
the inspection that there have been no reportable spills.
g. Annual training was accomplished in 2008 and 2011. It was not accomplished in 2007 or in
those partial years that the plant was in operation (plant was shut down from March, 2009,
through August, 2010).
h. Facility inspections were not conducted in 2009 and only one was conducted in each year of
2010 and 2011. Bi-annual inspections were conducted in all other years from 2002 through
2008, as required.
4. Qualitative monitoring was accomplished in August, 2010, and February, 2011, as well as bi-
annually in every year from 2002 through 2008. For those partial years when the plant was in
operation (plant was shut down from March, 2009, through August, 2010), documentation should
have been made as to why qualitative monitoring was not accomplished at least once.
5. Concerning analytical monitoring, Powerlab was using a non -NC certified laboratory until the issue•
was brought to their attention in the December, 2007 and January, 2008 inspections. Additionally,
not all analytical monitoring has been conducted as required (i.e. bi-annually) and the monitoring
that has been done has resulted in several exceedences of the lead and pH benchmark values.
Results for lead ranged from 0.05 milligrams per liter (mg/1), at its best, to 4.37 mgll at its worst.
Although modest, there has been some documentation of activities undertaken to find and correct
the cause of lead exceedences. Please note that the tiered requirements in the new draft
permit require that you undertake aggressive investigative measures to find and correct
the cause of the lead exceedences, and institute monthly analytical monitoring, until three
consecutive samples show lead concentrations below the benchmark. These investigative
measures must also be very well documented. In order to get a head start on finding the
cause of the lead exceedences, it may be to Powerlab's advantage to institute these
investigative measures and monthly monitoring immediately, instead of waiting for the new
permit to come into effect. Powerlab may also need to consider the need for outside help
from an environmental consultant or laboratory.
Site Review
6. In general the site was very clean. Mr. Boone -noted no deficiencies or violations. Mr. Boone did
note, however, that Powerlab could eventually qualify for what the Division calls a No Exposure
Certification (NEC), with relative ease. The NEC is a special permit which acknowledges the
site's unique condition of not having any industrial materials or activities exposed to precipitation
of any kind. In fact, the site would qualify for the NEC now, had it not been for the SP3
deficiencies and lead exceedences discussed above. As soon as the SP3 deficiencies and lead
exceedence are corrected, as long as Powerlab maintains current site conditions (i.e. no industrial
material or activity exposed to precipitation), a NEC may be feasible. A NEC would eliminate the
need for the SP3, the qualitative monitoring, and the analytical monitoring.
W4

Powerlab, Inc
Attn: Forrest Tunnell, Executive Vice President
Compliance Evaluation Inspection, NCS000368
1011312011, Page 3 of 3
7. You are reminded that violations of the NCS000368 individual stormwater permit are
subject to civil penalty assessments not to exceed $25,000 per day per violation. Please
reply in writing to this Notice of Deficiency within 30 business days of receiving it. Your
written response should include corrective actions with implementation schedules for each
deficiency noted above in paragraphs 3 through 5.
8. Thank you for your cooperation in this matter. Should you have any questions, please feel free to
contact Mr. Boone or me at [phone].
Sincerely,
W. Corey Basinger
Water Quality Regional Supervisor
Winston-Salem Region
Division of Water Quality
Attachments:
1. BIMS Inspection Checklist
cc7S1Nl?_7_1NSR01
Central Files
Stormwater Permitting Unit

Compliance Inspection Report
Permit: NCS000368 Effective: 10/01/06 Expiration: 09/30/11 Owner: Powerlab Inc
SOC: Effective: Expiration: Facility: Powerlab Incorporated
County: Forsyth 3352 Old Lexington Rd
Region: Winston-Salem
Winston Salem NC 27107
Contact Person: Carl Comstock Title; Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 10/11/2011
Primary Inspector: Ron Boone
Secondary Inspector(s):
Certification:
Phone:
Entry Time: 09:00 AM Exit Time: 12:00 PM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ❑ Compliant ■ Not Compliant
Question Areas:
E Storm Water
(See attachment summary)
Page: 1

Permit: NCS000368 Owner - Facifity: Powerlab Inc
Inspection Date: 1011 V2011 Inspection Type: Compliance Evaluation Reason far Visit: Routine
Inspection Summary:
Please refer to the attached inspection summary letter
Page: 2

Permit: NCS000368 Owner - Facility: Powerlab Inc
Inspection Date: 10/11/2011 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"?
■
n
n
❑
# 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?
■
0
❑
Cl
Has the Stormwater Pollution Prevention Plan been implemented?
■
❑
❑
❑
Comment: Please refer to the attached inspection summary letter.
Qualitative Monitoring
Yes No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
■ ❑
❑
Cl
Comment: Please refer to the attached inspection summary letter.
Analytical Monitoring
Yes No
NA
NE
Has the facility conducted its Analytical monitoring?
■ ❑
❑
❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
❑ ❑
■
❑
Comment: Please refer to the attached inspection summary letter.
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?
■ ❑
Cl
❑
Comment: Please refer to the attached inspection summary letter.
Page: 3

(6
POVERLAb
RECEIVED
November 16, 2011 N•C.
Not of RNR
NOV 2 12011
Winston-Salem
Regional offlea
North Carolina Division of Water Quality,
Winston-Salem Regional Office
Attn: W. Corey Basinger
585 Waughtown St.
Winston-Salem, NC 27107
RE: Compliance Evaluation Inspection & Notice of Deficiency
NPDES Individual Stormwater Permit NCS000368
Powerlab, Inc.
Forsyth County
Dear Mr. Basinger,
After carefully reviewing the notice of deficiency and recalling the inspection with Ron
Boone, we at Powerab, Inc. in Winston-Salem, have devised several steps to correct our
current issues of compliance.
In regards to paragraph 3 parts a-c, the SP3 plan will be updated to document the
previously missing figures. These figures include correct lat/long of each outfali, percent
impervious, and emergency contacts as described in the permit.
As for paragraph 3 part d-h and paragraph 4, it seems our problem lies mainly with
documentation. To our knowledge, most of these inspections/reviews/updates etc. occurred but
were never recorded properi'y and t`erefcrc, ,cr comrliart. !n order to alleviate this we have
revised the section 4,1.9 on best management practices on recordkeeping and'added to the
Pollution Prevention Team. We have included the BMP of internal auditing of documentation.
This audit will be performed by the team member addition, Chris Brady -Operations Engineer
(myself). This audit is scheduled bi-annually 45 days prior to the end of each 6 month testing
period. This will not only assure the analytical and qualitative monitoring has been done but will
also assure proper documentation of such.
As for paragraph 5 we have already started the process of addressing this issue and
have set up an implementation schedule to ensure we meet the benchmark in hopes to apply
for a No Exposure Certification. We have sourced our lab analyses to the local NC certified
laboratory, Research & Analytical Laboratories, Inc. We have set up the service to comply with
the conditions of the new permit including its tiered responses to missing the benchmark if
needed. Concerning the issue of missing the benchmark, as advised by Ron, we have hired an
environmental consulting agency to gain more insight on the contributing factors. Beth Morton,
POWERLAB, INC. • P.O. BOX 913 • TERRELL, TEXAS 75160 • TELEPHONE [phone] • FAX: [phone]

3
of Morton Environmental Consulting, Inc., visited our site and wrote a report on what she
believes to be contributing to high lead readings adding suggestions on how-to remedy the
situation. From this.report we have come up with a scheduled plan. We will -move thee,
construction debris -to the area around old outfall #3 so that any lead contaminated rain water
will flow in to the drain which leads back into the system..The debris'will be removed .
permanently shortly after construction is complete.'We are also planning on eliminating Outfall
#1 after,learning that the grated drain is not an -actual outfall and an, inappropeiate sampling
point because it does not discharge to waters of the state. It seems that a major cause for
missing the benchmark at Outfall #2 is due to roof drainage. To remedy this we have decided to
spray a sealant on the roof to lock in current residual lead dust. We also are going to add
housekeeping measures of HEPA vacuuming the air ventilation ducts routinely as needed to
help prevent further fugitive dust particles from escaping onto the roof. If these measures do not
fix our problem at Outfall #2 we are prepared to consider completely closing off the air roof
vents.
It was with careful consideration and the professional help of Beth Morgan that these
measures listed above were conceived with full intention in becoming compliant with all state
regulations. We would also like to extend our thanks to Ron Boone for his help and guidance.
Sincerely,
Chris Brady
Operations Engineer
Powerlab, Inc
P.O. Box 913
Terrell, TX 75160
di"
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' WA7" Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
G3 Coleen H. Sullins Director
] Division of Water Quality
December 28, 2007
CERTIFIED MAIL 7007-0710-0001-5586-9936
RETURN RECEIPT REQUESTED
Mr. Jeff Ward
Powerlab, Inc.
3352 Old Lexington Rd.
Building 43
Winston-Salem, NC 27107
Subject: NOTICE OF VIOLATION
NOV-2007-PC-0848
Stormwater Inspection
Powerlab, Inc.
Permit No. NCS000368
Forsyth County
Dear Mr. Ward:
A Compliance Evaluation Inspection was conducted by Marc Stokes and Rose Pruitt of the Winston-
Salem Regional Office on December 11, 2007. Powerlab Managers Jeff Ward and Robert Gonzales
were present for the inspection. The inspection consisted of two parts, an on -site inspection of the
facility and a file review. The facility was found to be in violation of permit NCS000368 for the
following:
Inspection Area
Stormwater
Certification
Analytical Monitoring
Illicit discharges
Stormwater Pollution Plan
Semi-annual inspection
L Permit
Compliance Issue
Failure to comply with the permit
No date' of certification signature
Analysis not performed by a NC Certified Lab
Multiple illicit discharges are present
SP3 plan is incomplete and not being followed
Documentation not present for the Spring '06 inspection
The NPDES Stormwater Permit, NCS000368, for the Powerlab, Inc. facility became effective
October 1, 2006 and expires on September 30, 2011. The permitted facility is authorized to
VvA
&C—DCkR
585 Waughtown Street Winston-Salem, NC 27107 [phone] Fax [phone]

;Powerlab, Inc
Page 2
discharge stormwater from a facility located at 3352 Old Lexington Rd., Winston-Salem, North
Carolina to receiving waters designated as an Unnamed Tributary to Salem 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 Permit No. NCS000368.
The permittee is authorized to discharge stormwater to the surface waters of North Carolina, which
have been adequately.treated and managed in accordance with the terms and conditions of the listed
permit. All discharges shall be in accordance with the conditions of this permit.
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.
A site inspection of this facilith' indicated poor housekeeping practices and illicit
discharp_es which_ could cause stream standard violations.
The permit identifies two potential monitoring requirements that apply to this facility:
➢ Qualitative Monitoring for Stormwater Discharge Outfalls per Part 11, Section B.
➢ Analytical Monitoring for each Stormwater Discharge Outfall per Part 11, Section B.
Copies of the permit documents can be accessed from the following web page:
http://h?o.enr.state.ne.us/su/l; orms_Docuinents.litm#StormwaterG P
II. Records/Reports
NPDES Permit NCS000368 requires certain monitoring to be documented and the records
maintained at the facility.
Section D: Monitoring and Records, part (6) Records Retention; requires Visual monitoring be
documented and records maintained at the facility along with a Stormwater Pollution Prevention
Plan. Copies of analytical monitoring results shall also be maintained on site. The permittee shall
retain records of all monitoring information, including all calibration and maintenance records and
all strip chart recordings fvr continuous monitoring instrumentation, and copies of all reports
required by this general permit for a period of at least S years from the date of the sample,
measurement, report or application. This period may be extended by request of the Director at any
time.
In addition Section D: Monitoring and Records, part (2) Recording Results states: For each
measurement, sample, inspection or maintenance activity performed or collected pursuant to the
requirements of this general permit, the permittee shall record the fallowing information:
a. The date, exact place, and time of sampling, measurements, inspection or maintenance
activity;
b. The individual(s) who performed the sampling, measurements, inspection or maintenance
activity;
c. The date(s) analyses were performed,-
d. The individuals) who performed the analyses;
e. The analytical techniques or methods used; and
f. The results of such analyses.

Powerlab, Inc
Page 3
The following records are required at this site per the NPDES permit:
Stormwater Pollution Prevention Plan as specified per Part I1, Section A.
2. Stormwater Discharge Outfalls (SDO) shall have Qualitative monitoring performed as
described in Part 1I, Section C, Table 4.
3. Stormwater Discharge Outfalls (SDO) shall have Analytical monitoring performed as
described in Part 11, Section B, Tables 1, 2 and 3.
A review was performed of the available records and reports of Powerlab for the years 2005, 2006
and 2007.
This review indicated deficiencies in the following records:
•:• The facility analytical monitoring was not performed by a NC Certified Lab.
The Stormwater pollution prevention plan was incomplete and was not being followed
by the facility as written.
A guidance document to assist you in developing Stormwater Pollution Prevention Plans for
Stormwater Runoff at Industrial Activities is available at the Division website.
http:/Al2o,enr_state.ilc.us/su/ManuaIs�Factsheets. htm
III. Facility Site Review
Mr. Jeff Ward and Robert Gonzales, Managers of Powerlab were present when the inspectors toured
the facility. The facility produces lead oxide powder. All manufacturing takes place indoors. There
are no vehicle maintenance activities noted at the facility.
At the time of the inspection poor housekeeping practices and illic_it_dischar2es -were evident in
some areas. These practices could result in water quality violations.
During the inspection it was noted that an additional outfall was discovered on the south side of the
facility.
Carefullv review these_ violations and deficiencies and respond in writing to this office within
thirty (30) working days of receipt of this letter. _ You should address the causes of
noncompliance and all actions taken to prevent the recurrence of similar situations. Your
response should include the following:
Describe steps taken to satisfy the requirements of the NPDES Permit, as listed above,
immediately. Please explain your failure to implement these requirements and discuss how
these requirements will be met in the future.

Powerlab, Inc
Page 4
➢ Provide this office with a copy of your completed Stormwater Pollution Prevention Plan
within the required response time noted above. A guidance document to assist you in
developing Stormwater Pollution Prevention Plans for Stormwater Runoff at Industrial
Activities is available at the Division website.
littp://li2o.enr.state.nc.tis/su/-Manuals Factsheets.htm
➢ Provide any other relevant factors, which you believe, should be considered.
Thank you for your attention to this matter. This Office is considering a recommendation for
enforcement regarding these issues. Your above -mentioned response to this correspondence. will be
considered in this process. If you should have any questions, please do not hesitate to contact Marc
Stokes at [phone].
Sincerely,
az
Steve W. Tedder
Water Quality Regional Supervisor
Winston-Salem Region
Division of Water Quality
Attachments
Cc: SWP-Central Files
«SRO
NPS Assistance and Compliance Oversight
Keith Huff, City of Winston-Salem Stormwater Division

Compliance Inspection Report
Permit: NCS000368 Effective: 03/29/00 Expiration: 03/31/05 Owner: Powerlab Inc
SOC: Effective: Expiration: Facility: Powerlab Incorporated
County: Forsyth 3352 Old Lexington Rd
Region: Winston-Salem
Winston Salem NC 27107
Contact Person: Carl Comstock Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 12/11/2007
Primary Inspector: Marc Stokes
Secondary Inspector(s):
Entry Time: 09:30 AM
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: n Compliant IN Not Compliant
Question Areas:
N Storm Water
(See attachment summary)
Certification: Phone:
Exit Time: 12:30 PM
Phone: [phone]
Inspection Type: Compliance Evaluation
Page: 1

Permit: NCS000368 Owner - Facility: Powedab Inc
Inspection Date: 12/11/2007 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
The facility manufactures lead oxide powder. Jeff Ward and Robert Gonzales were present during the inspection.
Multiple compliance issues were noted, amoung those:
- Failure to comply wwith the permit
- No date of certification signature
- Analysis not performed by a NC Certified Lab
- Mutiple illicit discharges
- SP3 plan incomplete and not being followed
- Documentation not present for Spring '06 inspection
- All discharge points not identified.
Page: 2

Permit: NCS000368 Owner - Facility: Powedab Inc
Inspection Date: 12/11/2007 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
# Does the Plan include a General Location (USGS) map?
■
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
e
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
In
n
# Does the Plan include a list of Responsible Party(s)?
n
n
n
# Is the Plan reviewed and updated annually?
n
n
■
n
# Does the Pian include a Stormwater Facility Inspection Program?
■
n
n
n
Has the Stormwater Pollution Prevention Plan been implemented?
n
e
n
n
Comment: Sp3 plan incomplete
Qualitative Monitoring
Yes
No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
®
n
n
n
Comment
Analytical Monitoring
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: Analysis not conducted by NC Certified Lab
Permit and Outfalls
Yes
No
NA
NE
# is a copy of the Permit and the Certificate of Coverage available at the site?
■
n
n
n
# Were all outfalls observed during the inspection)
■
n
n
# if the facility has representative outfall status, is it properly documented by the Division?
n
❑
®
n
# Has the facility evaluated all illicit (non stormwater) discharges?
n
■
n
n
Comment: Illicit discharges were observed
Page:3

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Powerlab, Incorporated.
3352 Old Lexington Road
Winston Salem, NC 27107
Subject: General Stormwater Permit Inspections
Powerlab Incorporated
Permit No. NCS000368
Forsyth County
Dear Sir or Madaam:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. director
Division of Water Quality
RECEIVED iI3
JAI I I Z��S
Salem
Regional 0+ lice
Your facility holds a General Permit from the North Carolina Division of Water Quality to
discharge stormwater associated with industrial activities performed at your facility. Please be
advised that the Winston-Salem Regional Office will be performing NPDES Stormwater
Inspections sometime in the near future.
If this office has not previously inspected your facility, you should be prepared to demonstrate
compliance with all terms and conditions included in the Permit. Specifically, we will be
evaluating the following: Stormwater Pollution Prevention Plan, Stormwater Outfall Locations,
Qualitative and Analytical Monitoring Data and any other activities required by your permit.
Copies of the general permits and accompanying documents can be accessed from the following
webpage: http:11h2o.enr. state. nc.uslsu/Forms_Documents. htm#Storm water GP.
If you have any questions, please contact Rose Pruitt in the Winston-Salem Regional Office at
[phone].
Sincerely,
Rose Pruitt
cc: NPS Compliance & Assistance Oversight Unit
SWP-Central Files
WSRO Files
iVJane Carolina
watura!!y
North Carolina Division of Water Quality 585 Waughtown Street Winston-Salem, NC 27107 Phone [phone] Fax [phone]
Internet: h2o.enc. state. nc.us
An Equal OpportunitylAffirma6ve Actor; Employer — 50% Recycled110% Post Consumer Paper

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day inspection Type Inspector Fac Type
1 1 N1 2 1 51 31 NCS000368 1 11 121 06/07/13 117 181 WI 191 SI 201 1I
Remarks
211111 1111 1111 1111 1111 1111 11111 A -I I I I I I II I I I I 11116
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 OA --- — Reserved----------
671 169 70131 711 1 721 N 1 73 M 74 751 1 1 1 1 I I 1 80
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
11.12 AM 06/07/13
00/03/29
Poweriab incorporated
Exit Time/Date
Permit Expiration Date
3352 Old Lexington Rd
Winston Salem NC 27107
11.16 AM 06/07/13
05/03/31
Name(s) of Onsite Representative(s)TTitles(s)/Phone and Fax Number(s)
Other Facility Data
Name, Address of Responsible OfficiaVTitle/Phone and Fax Number
Carl Ccrostock,3352 Old Lexinggton Rd Winston Salem NC Contacted
27107//336-650-0706/3366500771 No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Storm Water
Section D: Summary,of Find in/Comments Attach additional sheets of narrative and checklists as necessa
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency]Office/Phone and Fax Numbers Date
Rose Pruitt WSRO WQ//336-771-5000/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1
W

NPIDES yrlmolday Inspection Type
NCS000368 1
11 121
06/07/13 117 18IWI
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
07/20/2006 - looked at facility exterior for permit renewal. No problems seen.
Page # 2

RECEIVED
W A 7 N.C. t7eoL of ElFFt Michael F. Easley, Governor
O Rv� DEC 3 2 William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
U3 -slimston-Salem Alan W. Klimek, P. E. Director
Regional Office Division of Water Quality
-[ Coleen H. Sullins, Deputy Director
Division of Water Quality
STAFF REVIEW AND EVALUATION WSRO
NPDES Stormwater Permit
Facility Name:
Powerlab, Incorporated
NPDES Permit Number:
ffCS600368
Facility Location:
Winston-Salem, NC (Forsyth Co.)
Type of Activity:
Industrial —Produce Lead Monoxide Powder for Storage Batteries
SIC Code (if applicable):
2819
Receiving Streams:
UT to Salem Creek, index no. 12-94-12-(4) [IMPAIRED]
River Basin:
Yadkin -Pee Dee River Basin, Sub -basin 03-07-04
Stream Classification:
C
Proposed Permit Requirements:
See attached draft permit.
Compliance Schedule:
N/A
Basis for Monitoring:
See attached monitoring data in application. Retained lead monitoring
and added pH monitoring. Activities did not trigger vehicle
maintenance monitoring.
All monitoring has changed to Semi -Annual (spring and fall). This
change is based on the Division's revised strategy for stormwater
monitoring in renewal permits 'and makes stormwater discharge
sampling frequency consistent with qualitative monitoring. In
addition, DWQ has incorporated benchmark values into the permit.
These benchmarks are not permit limits but should be used as
guidelines for the facility's Stormwater Pollution Prevention Plan
(SPPP). ' New language in the permit specifies that if any
measurements exceed benchmark values, the facility should evaluate
the effectiveness of its BMPs, review and/or update its SPPP, and
document any efforts to address stormwater contamination (see Part
II, Sec. B & D).
Total Flow monitoring has also been removed per DWQ revised
strategy (Total Rainfall and Event Duration parameters retained).
Instead, Pan II. Sec. A clarifies that SPPP site map include drainage
area for each outfall in acres and percent impervious area in each
drainage area (should flow ever need to be estimated).
Basis for Other Requirements: TMDL language included in Part II, Section B.
Response Requested by (Date): January 16, 2006
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 [phone]
B*A
06ON-A
Customer Service
1-877-623-6748

NCS000368
Central Office Staff Contact: Bethany Georgoulias, [phone], ext. 529
DOCUMENTS REVIEWED
NPDES Stormwater Permit Application Materials
S/W Permit File
Analytical &Qualitative Monitoring Results summary
Yadkin -Pee Dee Basinwide Plan (rev. March 2003)
Orip-inal EPA application (1997)
Central Office Review Summary: .
Facility discharges stormwater to an unnamed tributary to Salem Creek (Middle Fork Muddy Creek), which is on
the 303(d) list of impaired waters as a result of fecal coiiform bacteria and impaired biological integrity
(unidentified stressors). The 2003 Yadkin Basinwide Plan addresses general stormwater (S/W) management
strategies for reducing urban runoff impact (from activities such as increased development and failing on -site
(domestic) wastewater systems), but does not have specific recommendations for individual industrial S/W
dischargers. Fecal coliform is likely not a pollutant of concern at this site. This watershed has been identified by
the Ecosystem Enhancement Program (EEP, formerly NC Wetlands Restoration Program) as an area with the
greatest need and opportunity for stream and wetland restoration efforts.
Since last renewal, the company has added two more production lines, more storage silos, and an addition to the
building. At renewal, the site was in the process of adding a fifth and sixth production system. The process, raw
materials, and storage practices have remained the same.
Permit file documents (November 1999 Memo from WSRO and 1999 staff report comments) indicated that all
manufacturing and storage is under roof at this facility but that the loading dock area may drain to surface waters.
The EPA Multi -Sector permit includes monitoring and benchmarks for total recoverable aluminum and iron for the
industrial inorganic chemicals industry; however, these metals are not pollutants of concern at this facility.
Qualitative Monitoring Results: Permittee sent results from 2000-04. Overall few problems; however, in late
2003-04, decrease in clarity and increase in solids observed. May have coincided with some of the construction for
the building addition (?).
Analytical Monitoring: See analytical monitoring summary in application --only two samples for each outfall.
No monitoring during first and second quarters of Year 4? (Not submitted and no DMRs in Central Files).
Retained lead (Pb) monitoring because levels exceeded 0.0338 mg/l benchmark at both outfalls in 2003. Reviewer
recommends adding pH monitoring because it can be important to interpreting toxicity of contaminants (including
some metals). This change is standard for all stormwater permit renewals with analytical monitoring this cycle.
Monitoring frequency will increase to semi-annually. This change ensures at least nine data points are collected
through the permit term and makes monitoring frequency consistent with qualitative monitoring. Also, benchmark
values for all parameters have also been added to the permit as a guide for the permittee to check the effectiveness
of BMPs (and document efforts) when necessary. The lead benchmark is based on '/2 FAV (final acute value) and
was derived from EPA's November 2002 Recommended Water Quality Criteria (assumed 50 mg/1 hardness).
No follow-up with the company contact was necessary.
Recommendation: Based on the documents reviewed, the application information submitted on November 4, 2004
is sufficient to issue an Individual Stormwater Pe it.
t
Prepared by (Signature VW, Date 7 /Z-O OS—
Stormwater Permitting Unit Super5visor • Date
Concurrence by Regional Office Date
Water Quality Supervisor Date

NCS000368
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MapQuest: Maps
http://www.mapquest.com/maps/print-adp?mapdata--UAmOU3b9NY...
4
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3352 Old Lexington Rd
Winston Salem I IC
27107-4119 US
Notes:
-Stay 6 nights and_..�I
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Fairly C?ddParents
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All rights reserved. Use 5ubiect to License/Copyright
This map is informational only. No representation is made or warranty given as to its content.
User assumes all risk of use. MapQuest and its suppliers assume no responsibility for any loss or
delay resulting from such use.
1 of I
7/13/2006 10:16 AM

Permit: NCS000368
SOC:
County: Forsyth
Region: Winston-Salem
Compliance Inspection Report
Effective:03/29100 Expiration: 03/31/05
Effective: Expiration:
Contact Person: Carl Comstock
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 12/20/2007
Primary Inspector: Rose Pruitt
Secondary Inspector(s):
Title:
Entry Time: 11:00 AM
Reason for Inspection: Follow-up
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ❑ Compliant ® Not Compliant
Question Areas:
® Storm Water
(See attachment summary)
Certification:
Owner: Powerlab Inc
Facility: Powerlab Incorporated
3352 Old Lexington Rd
Winston Salem NC 27107
Phone: [phone]
Exit Time: 02:00 PM
Phone:
Phone: [phone]
Inspection Type: Stormwater
Page 1

Permit: NCS000368 Owner -Facility: Poweriab Inc
Inspection Date: 12/20/2007 Inspection Type: Stormwater Reason for Visit: Fallow -up
Inspection Summary:
sp3 review
Stormwater Pollution Prevention Plan
Does the site have a Stormwater Pollution Prevention Plan?
■
n
n n
# Does the Plan include a General Location (USGS) map?
®
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 rl
# Does the facility provide and document Employee Training?
n
■
n n
# Does the Plan include a list of Responsible Party(s)?
n
■
n n
# Is the Plan reviewed and updated annually?
n
®n
n
# Does the Plan include a Stormwater Facility Inspection Program?
n
e
n n
Has the Stormwater Pollution Prevention Plan been implemented?
n
®
n n
Comment: sp3 incomplete
Page: 2

�O
\�\\ Stormwater Checklist SP3 Inspection
p { }
i r r r r r r r r r r a r r r r r r r a r r r r r ra r r r r r r r r r r a a r r r r ti r r r r d r r r r r r r r r r r r a a r r a r r r r r a
Facility Name
c ov�tOiS
Permit Number N L `� Activity i
1U Z0 o cv
Facility Address
County
Industrial Activity
SIC Code Size of Facility # Employees
Facility Contact
Title
Telephone Number
Inspection Date Time
Entry Time Exit Time
Inspector(s)
Facility Representative(s)
Other Agencies
Representatives

V'^t�rn�a.Y.l
I v� [p►v�Q i�
Part II Monitoring, Controls and Limitations for Permitted Discharge
Section A: Stormwater Pollution Prevention Plan.
1. Site Plan —shall provide a description of the physical facility and the potential pollutant sources which may be
expected to contribute to contamination of stormwater discharges. The site plan shall contain the following:
a. General Location Ma — USGS uadran le map orequivalent showing:
Facility location in relation to transportation routes and surface waters.
The name of the receiving water()�hihe�tor`�water
vT IsLNG
outfall(s) discharges:
OR if the discharge is to a mu cipaI separate storm sewer system, the name of the municipality and the
ultimate receiving waters: I MS L % W S
Accurate latitude and longitude of the point(s) of discharge.
b. Narrative description of:
Storage practices (raw materi Is, fuels, intermediate products, byproducts. waste materials, finished
products) W s
✓
Loading and unloading activities.
Qr
Outdoor process areas (types of processes and equipment used).
Dust or particulate generating or control processes (crushing, mixing, burning, drying operations).
Waste disposal operations (solids, liquids, residuals/sludges).
c. Site map drawn to scale with distance legend indicating:
Location of industrial activities (including stage of materials, disposal areas, process areas, loadin�and
unloadin areas
v
Drainage structures (outfalls, stormwater conveyance system, retention ponds, diversion structures,
ditches, culverts, swales, porus pavement, sediment traps, erosion control, storm drain inlets).
Drainage areas for each outfall (flow pattern).
Activities occurring in the drainage area.
Building locations.
Existing BMP's and impervious surfaces.
% of each drainage area that is impervious.
For each outfall; a narrative description of potential pollutants which could be expected to be present.
Location of exposed significant materials.
NP-
Location of past spills and leaks.
Fueling stations.
Vehicle and equipment maintenance.
Vehicle and equipment washing.
V/
Loading and unloading areas. .t—
Above ground liquid storage tanks.
Industrial waste management areas and outside manufacturing.
lie /or
Outside storage of raw materials, by-products or finished products.
,0 t- � \

Y
d. List of significant spills or leaks of pollutants that have occurred at the facility during the 3
previous ears:
List of significant spills or leaks (includes hazardous substances in excess of reportable quantities reported
Nakfd
to National Response Center/ Ajppendix H).
Corrective actions to mitigate spill impacts.
e. Certification that the stormwater outfalls have been evaluated for the presence of non-
stormwater discharges.
✓
Certification statement signed in accordance with Part 111, Standard Conditions, Section B, Paragraph 5.
XDischarge
tested (dye tracing, chemical analyses) for presence of non-stormwater discharge (process water,
vehicle/equipment wash water, sanitary waste, etc). [disconnect or apply for NPDES permiti.
V_R_ t_-�tl
2. Stormwater Management Plan. The stormwater management plan shall contain a narrative description of
the materials management practices employed which control or minimize the exposure of significant materials to
stormwater, including structural and non-structural measures. The stormwater management plan, at a minimum,
shall incorporate the following:
a. Feasibility study. A review of the technical and economic feasibility, f changing a methods of operations
and/or storage practices to eliminate or reduce exposure of materials and processes o stormwater. Wherever
ractic the permittee shall;
Prevent exposure of all storage areas. (roof, enclose, drainage diversion, move materials inside, pallets)
Material handling operations.
Manufacturing operations.
Fueling operations.
Loading and unloading areas. (roof, berms, grading)
Outdoor process areas. ( street sweeping, structural devices)
Dust or particulate control.
Waste disposal practices. (lids, roof]
A. Secondary Containment Schedule. for bulk storage of liquid materials, storage of Section 313 of Title III
of the SARA water priority chemicals (appendix 1), or storage of hazardous substances to prevent leaks and spills
from co taminating stormwater runoff.
Secondary Containment - spill containment for the contents of the single largest tank within the
containment structure plus sufficient freeboard to allow for 25 yr, 24 hr storm evens 5-6 in]).
Bulk storage of liquids (single above ground container with capacity greater than 660 gallons or Multiple
containers in close proximity with combined storage capacity greater than 1,320 gallons). [ex. More than
24, 55 gallon drums]
Manually activated valves w/ locks- If secondary containment devices are connected directly to stormwater
conveyance systems, connection must be controlled by manually activated valves or similar devices [which shall
be secured with locking devices]
Records documenting stormwater release from secondary containment (5 years) — any stormwater that
accumulates in the containment area shall be at a minimum visually observed for color, foam, outfall staining,
visible sheens dnd dry weather flow, prior to release of the accumulated stormwater. Accumulated stormwater
fshall
be released if found to be uncontaminated by the material stared within the containment area. Records
1
documenting the individual making the observation, the description of the accumulated stormwater and the date
and time of the release shall be kept fora eeriod of five years.
c. BM
P Summary.
A narrative description shall be provided of BMP's to be considered such as, but not limited to, oil and grease
separation, debris control, vegetative filter strips, infiltration and stormwater detention or retention, where
n
necessary. The need for structural BMP's shall be based on the assessment of potential sources to contribute
significant quantities of pollutants to stormwater discharges and data collected through monitoring of stormwater
discharges.

'eLu
d. Inspection Schedule
1 Sche ules for inspection of stormwater conveyances, controls, and measures to be taken to limit or prevent
erosio associated with the stormwater systems.
3. Spill Prevention and Response Plan. The Spill Prevention and Response Plan (SPRP) shall incorporate
an assessment of potential pollutant sources based on a materials inventory of the facility.
Materials Inventory
ve'
Facility personnel (or team) responsible for implementing the SPRP identified.
J
(111
A responsible person — shall be on site at all times during facility operations that might have the potential to
contaminate stormwater runoff throu h spills or exposure of material associated with the facility operations,
SPRP must be site stormwater specific. SPCC maybe a component of SPRP.
Areas where spills can occur nd their disch ints. 5 7,
Spill response team
Spill response equipment and locations.
Spill containment, diversion, isolation, and cleanup.
Reporting procedures along with names and numbers.
./
Material handling and storage procedures.
Safety measures.
4. Preventative Maintenance and Good Housekeeping Program. A preventative maintenance program
shall be develo ed. The program shall document:
Schedules of inspections of stormwater control systems.
Schedules of maintenance activities of stormwater control systems.
✓
Schedules f inspections and maintenance of plant equipment and systems.
Inspection of material handling areas.
Regular cleaning schedules of material handling areas.
5. Employee Training. Training schedules shall he developed and training provided at a minimum of an
annual basis on proper spill response and cleanup procedures and preventative maintenance activities for all
personnel involved in any of the facility's operations that have the potential to contaminate stormwater runoff.
Facility personnel (or team) responsible for implementing the training identified.
Training schedules developed.
Annual training provided on spill response and cleanup.Ps d"` �'^^P
6. Responsible Party. The SPPP shall identify a specific position(s) responsible for the overall coordination,
development, implementation, and revision to the Plan. Responsibilities for all components of the Plan shall be
documented and position assignments provided.
Position identified. aC't'6 W
Responsibilities assigned and documented.
7. Plan Amendment. The permittee shall amend the plan whenever there is a change in design, construction,
operation, or maintenance which has a significant effect on the potential for the discharge of pollutants to surface
waters.
X Plan is current. (design, operation, construction, maintenance)
SWPP reviewed and updated on an annual basis.

S. Facility Inspections. Inspections of the facility nd all stormwater systems sh II occur at a minimum on a
semi-annual schedule; 5 ears
Fall Inspection (September -November) A
�C
Spring Inspection (April -June)
Maintenance activities documented. (date and time of inspection, individual making the inspection, and a
narrative description of the facility's stormwater control systems, plant equipment and systems).
inspection records incorporated into SPPP
9. Implementation. Implementation of the plan shall include documentation of all monitoring, measurements,
inspections and maintenance activities taken to implement BMP's associated with the industrial activities, including
vehicle maintenance activities. Such documentation shall be kept on -site for a period of five years and made
available to the Director or his authorized representative mViediately upon request.
Monitoring A,o a-kX (,L,* , - (�� ,� ti,y o j
K
Inspections
Maintenance activities
Documentation (S years)
Additional Comments: nn
U U

■ Completeirems 1, 2, and 3. Also complete
item 4.if Restricted Delivery is desired.
■ Print your name and address on the reverse
so that we 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:
-Mr. Jeff Ward
Powerlab, Inc.
3352 Old Lexington Road; Bldg. 43
Winston-Salem, NC 27107
A. Signature
X ❑ Agent
_1174 Addre
B. Re iv ( Printed ame) C. Dat f De
PV Q 0
D. Is delivery address different from item 17 Ye
If YES, enter delivery address below: ❑ No
@Certified Mail ❑ press Mail I
❑ Registered (WRetum Receipt for Merchandise
❑ Insured Mail ❑ C.O.D.
4. Restricted Delivery? (Extra Fee) ❑ Yes
7007 0710 0001 5586 9936 f rajas nlov pc-()Fqg
PS Form 3811, February 2004 Domestic Return Receipt / m �G= _ 102595-02-M-1540

,Powerlab, Inc
Page 2
discharge stormwater from a facility located at 3352 Old Lexington Rd., Winston-Salem, North
Carolina to receiving waters designated as an Unnamed Tributary to Salem 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 Permit No. NCS000368.
The permittee is authorized to discharge stormwater to the surface seaters of North Carolina, which
have been adequately treated and managed in accordance with the terms and conditions of the listed
permit. All discharges shall be in accordance with the conditions of this permit.
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.
A site inspection of this facility indicated poor housekeeping practices and illicit
discharges which could cause stream standard violations.
The permit identifies two potential monitoring requirements that apply to this facility-:
➢ Qualitative Monitoring for Stormwater Discharge OutfalIs per Part II, Section B.
➢ Analytical Monitoring for each Stormwater Discharge Outfall per Part II, Section B.
Copies of the permit documents can be accessed from the following web page:
http://h2o.enr.state.ne.us/su/Forms_ Doc utnents.htm#StormwaterGP
11. Records/Reports
NPDES Permit NCS000368 requires certain monitoring to be documented and the records
maintained at the facility.
Section D: Monitoring and Records part 6 Records Retention; requires Visual monitoring be
documented and records maintained at the facility along with a Stormwater Pollution Prevention
Plan. Copies of analytical monitoring results shall also be maintained on site. The permittee shall
retain records of all monitoring information, including all calibration and maintenance records and
all strip chart recordings for continuous monitoring instrumentation, and copies of all reports
required by this general permit for a period of at least 5 years from the date of the sample,
measurement, report or application. This period may be extended by request of the Director at any
time.
In addition Section D: Monitoring and Records. part 2 Recording Results states: For each
measurement, sample, inspection or maintenance activity performed or collected pursuant to the
requirements of this general permit, the permittee shall record the following information:
a. The date, exact place, and time of sampling, measurements, inspection or maintenance
activity;
b. The individual(s) who performed the sampling, measurements, inspection or maintenance
activity,
c. The date(s) analyses were performed;
d. The individual(s) who performed the analyses,-
e. The analytical techniques or methods used; and
f. The results of such analyses.

Powerlab, Inc
Page 3
The following records are required at this site per the NPDES permit:
1. Stormwater Pollution Prevention Plan as specified per Part 11, Section A.
2. Stormwater Discharge Outfalls (SDO) shall have Qualitative monitoring performed as
described in Part II, Section C, Table 4.
3. Stormwater Discharge Outfalls (SDO) shall have Analytical monitoring performed as
described in Part I1, Section B, Tables 1, 2 and 3.
A review was performed of the available records and reports of Powerlab for the years 2005, 2006
and 2007.
This review indicated deficiencies in the followinp, records:
The facility analytical monitoring was not performed by a NC Certified Lab.
The Stormwater pollution prevention plan was incomplete and was not being followed
by the facility as written.
A guidance document to assist you in developing Stormwater Pollution Prevention Plans for
Stormwater Runoff at Industrial Activities is available at the Division website.
htt ://h2o.enr.state.nc.us/su/Manuals Factshcets.htm
II1. Facilibv Site Review
Mr. Jeff Ward and Robert Gonzales, Managers of Powerlab were present when the inspectors toured
the facility. The facility produces lead oxide powder. All manufacturing takes place indoors. There
are no vehicle maintenance activities noted at the facility.
At the time of the inspection poor housekeeping practices and illicit discharges were evident in
some areas. These practices could result in water quality violations.
During the inspection it was noted that an additional outfall was discovered on the south side of the
facility.
Carefully review these violations and deficiencies and respond in writinp, to this office within
thirty (30) workin[Z days of receipt of this letter. You should address the causes of
noncompliance and all actions taken to prevent the recurrence of similar situations. Your
response should include the following:
Describe steps taken to satisfy the requirements of the NPDES Permit, as listed above,
immediately. Please explain your failure to implement these requirements and discuss how
these requirements will be met in the future.

Powerlab, Inc
Page 4
➢ Provide this office with a copy of your completed Stormwater Pollution Prevention Plan
within the required response time noted above. A guidance document to assist you in
developing Stormwater Pollution Prevention Plans for Stormwater Runoff at Industrial
Activities is available at the Division website.
lhttp:/.%h 2o.enr.state.nc.us/stLll•4anuals_Fact sheets. htni
➢ Provide any other relevant factors, which you believe, should be considered.
Thank you for your attention to this matter. This Office is considering a recommendation for
enforcement regarding these issues. Your above -mentioned response to this correspond ence.will be
considered in this process. If you should have any questions, please do not hesitate to contact Marc
Stokes at [phone].
Sincerely,
at 1� r14
Steve W. Tedder
Water Quality Regional Supervisor
Winston-Salem Region
Division of Water Quality
Attachments
Cc: SWP-Central Files
WSRO
NPS Assistance and Compliance Oversight
Keith Huff, City of Winston-Salem Stormwater Division

Permit: NCS000368
SOC:
County: Forsyth
Region: Winston-Salem
Compliance Inspection Report
Effective:03/29/00 Expiration:03/31/05
Effective: Expiration:
Contact Person: Carl Comstock Title:
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 12/11/2007 Entry Time: 09:30 AM
Primary Inspector: Marc Stokes
Secondary Inspector(s):
Rose Pruitt
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ❑ Compliant ® Not Compliant
Question Areas:
i Storm Water
(See attachment summary)
Certification:
Owner: Powerlab Inc
Facility: Powerlab Incorporated
3352 Old Lexington Rd
Winston Salem NC 27107
Phone: [phone]
Exit Time: 12:30 PM
Phone:
Phone: [phone]
Phone:
Inspection Type: Compliance Evaluation
Page: 1

i
Permit: NC5000368 owner - Facility: Powerlab Inc
Inspection Date: 12/1112007 inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
The facility manufactures lead oxide powder. Jeff Ward and Robert Gonzales were present during the inspection.
Multiple compliance issues were noted, amoung those:
- Failure to comply wwith the permit
- No date of certification signature
- Analysis not performed by a NC Certified Lab
- Mutiple illicit discharges
- SP3 plan incomplete and not being followed
- Documentation not present for Spring '06 inspection
- All discharge points not identified.
Page: 2

P]
Permit: NCS000368 owner - Facility: Powedab inc
Inspection Date: 12/11/2007 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) map?
■
n
n
n
# Does the Plan include a "Narrative Description of Practices'?
■
n
n
In
# 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
n
# Is the Plan reviewed and updated annually?
n
n
■
n
# Does the Plan include a Stormwater Facility Inspection Program?
■
0
n
0-
Has the Stormwater Pollution Prevention Plan been implemented?
n
■
n .0
Comment: Sp3 plan incomplete
Qualitative Monitoring
Yes
No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
0000
Comment:
Analytical Monitoring
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: Analysis not conducted by NC Certified Lab
Permit and Outfalls
Yes
No
NA
NE
# Is a copy of the Permit and the Certificate of Coverage available at the site?
®
n
n
n
# Were all outfalls observed during the inspection?
®
n
n
n
# If the facility has representative eutfall status, is it properly documented by the Division?
n
n
■
n
# Has the facility evaluated all illicit (non stormwater) discharges?
n
■
n
n
Comment: Illicit discharges were observed
Page: 3