NCS000324_EPA Inspection Report_20190603

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A UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
AwTW REGION 4
o c ATLANTA FEDERAL CENTER
a� oa 61 FORSYTH STREET
PRO V,-e ATLANTA, G EORG IA 30303-8960
MAY 2 8 2019
CERTIFIED MAIL 7017 1450 0000 7973 2793
RETURNED RECEIPT REQUESTED
Mr. Adam Hamilton �
RE ._
EHS Manager
Consolidated Metco, Inc. JUN 0 3 2019
780 Patton Avenue DENR-LAND QUALIT'(
Monroe, North Carolina 28110 STORNMATyR P'ERIt �,i i i ING
Re: Compliance Evaluation Inspections
Consolidated Metco, Inc.
NPDES Permit No. NCS000324
Dear Mr. Hamilton:
On March 21, 2019, the U.S. Environmental Protection Agency Region 4 and North Carolina
Department of Environmental Quality (NCDEQ) conducted a Compliance Evaluation Inspection (CEI)
at the Consolidated Metco, Inc., facility located at 780 Patton Avenue in Monroe, NC. The purpose of
the CEI was to evaluate Consolidated Metco, Inc., facility's compliance with the requirements of
Sections 301 and 402(p) of the Clean Water Act (CWA), 33 U.S.C. §§ 1311 and 1342(p); the
regulations promulgated thereunder at 40 C.F.R. § 122.26; and, the State of North Carolina's NPDES
Stormwater Permit NCS000324.
The EPA and NCDEQ appreciate your cooperation in conducting this CEI. Enclosed is the EPA's CEI
report, which includes EPA's observations. Please review the report and contact Ms. Lauren Garcia at
the NCDEQ office within 14 days of receiving this letter by calling [phone] or by sending an
email to lauren.aarci.aLq?ncdenr.gov.
There is no need to respond directly to the EPA at this time; however, please note that the EPA will
continue to closely coordinate with NCDEQ to ensure compliance at this facility. If you do happen to
have questions for the EPA, you can contact Mr. Kenneth Kwan, P.E., at the above address, by email at
[e-mail], or at [phone].
Enclosures
Sincerely,
z / er
Daniel J. O'Lone, Chief
Surface Water and Ground Water Section
Water Enforcement Branch
cc: Ms. Annette Lucas
NCDEQ
Internet Address (URL) • http://www.epa.gov

1"'� U.S. Environmental Protection Agency, Region 4
61 Forsyth Street SW, Atlanta, GA 30303
o=
Water Compliance Inspection Report
FACILITY DATA
NPDES ID: NCS000324 Effective Date: Expiration Date:
Facility Name: Consolidated Metco, Inc SIC Code:
Address:
On -Site Representative(s), Title, Phone Number: Responsible Official, Title, Phone Number, Mailing Address:
Adam Hamilton
EHS Manager
780 Patton Ave
Monroe, NC 28110
704-226-5338
INSPECTION DATES/TIMES
EntryDate/Time: 03/21/19, 3:00 pm Exit Date/Time: 3/21/19, 5:55 pm
NAMES OF '♦ AND STATE INSPECTORS
EPA Inspectors: Ahmad Dromgoole and Kenneth Kwan
NCDENR Inspectors: Lily Kay, Chris Graybeal, Angela Lee
AREAS1 DURING INSPECTIONareas
X Permit Self -Compliance Program Pretreatment
X Records
Compliance Schedule Pollution Prevention
X Facility Site Review
Laboratory X Storm Water
X Effluent / Receiving Waters
X
Operations & Maintenance Combined Sewer Overflow
Flow Measurement
Sludge Handling/ Disposal Sanitary Sewer Overflow
INSPECTION NOTES
The inspection team, consisting of EPA inspectors and state inspectors from various regional offices, arrived at the facility on March
21, 2019 to perform an unannounced Compliance Evaluation Inspection (CEI). This CEI, which focused on the facility's NPDES
Industrial Stormwater permit, was performed as both a joint inspection with the state and a training opportunity for state inspectors.
Upon their arrival, the inspectors presented credentials and facilitated an opening conference. The CEI included both a records
review portion and a facility walk through. At the end of the inspection, a summary of the preliminary findings was provided, and
facility personnel were informed that an inspection report will be sent to the facility by EPA.
.♦ REPRESENTATIVES
Inspector Signature/Name Office/Phone Number Date
USEPA Region 4/WPD-CWEB-SRES
404-562-9212
Ahmad Dromgoole, Environmental Engineer
USEPA Region 4/WPD-CWEB-SRES
404-562-9752
Kenneth Kwan, Environmental Engineer
Management Signature/Name
Office/Phone Number
Date
USEPA Region 4/WPD-CWEB-SRES
404-562-9434
Daniel J. O'Lone, Chief
Stormwater and Residuals Enforcement Section
Page 1 of 6

GPS
Coordinates
Coordinates
1. FACILITY LOCATION INFORMATION
Latitude 34059'51.83"N Longitude
80033'36.97"W
Receiving
Site
Weather
Water(s) or
Bearskin Creek
Acreage
23
Condition
Partially cloudy
MS4
Does the site
Date of
Discharge to 303(d)
discharge pollutants
Permit
11/21/13
SIC
3265
listed or TMDL
Yes,
contributing to the
No
Application
Code(s)
waters
Mercury
receiving stream
impairment.
2. BASIC STORMWATER POLLUTION PREVENT PLAN (SPPP) INFORMATION
SPPP TOPICS (Part H)
YES
NO
N/E
SPPP on -site (obtain a copy of the plan) Section A
X
SPPP was not signed and have the necessary certification statement per Part III, Section B.3 of the permit.
Site Description Section A(1)(b)
X
(storage practices, loading/unloading activities, outdoor processes, dust generating processes, and waste
processes)
Identify potential Pollutant Sources and Particular Pollutants Section A(1)(b)
X
(include inventory of materials handled at the site, information pertaining to any pollutant sources, information
pertaining to the storage and application of pest control chemicals)
Site Maps (general location map and site specific map) Sections A(1)(a & c)
X
(include identification of receiving waters and/or MS4s, identification of impaired waters, lat/long of discharge
points, drainage areas to each discharge point, site boundaries, site topography, drainage features and flow
directions, impervious areas, industrial activities, and site best management practices (BMPs)
The site map did not outline the drainage area to the wet detention basin, and area north east of the facility that
sheet flow of the property toward the creek.
Spill History (3 year history or spills and corrective actions) Section A(1)(d)
X
No significant spills or leaks was stated in the SPPP. However, it is uncleared this statement truly represent
spills and leaks during the previous 3 years since the SPPP was dated 3/09.
SPPP Certification Section A(1)(e)
X
(Annual recertification of no evidence of non-stormwater discharging)
The latest annual certification that the stormwater outfalls have been evaluated for the presence of non-
stormwater discharges was dated 3/17/09 in the SPPP.
Stormwater Management Strategy (Feasibility Study) Section A(2)(a)
X
(Analysis of control options like eliminating exposure or controlling runoff)
The SPPP did not contain a feasibility study on the feasibility of changing methods operations and/or storage
practices to reduce exposed material and outdoor industrial process to containment stormwater runoff.
Stormwater Management Strategy (Secondary Containment) Section A(2)(b)
X
(Should include a table or summary clearly inventorying the sources and procedure for making visual observations
of accumulated liquid and how to dispose of it)
The SPPP did not contain a table of all storage tanks and stored materials, and their associated secondary
containment capacity. Also, the SPPP did not have a procedure to release uncontaminated stormwater
accumulate within the containment area.
Page 2 of 6

2. BASIC STORMWATER POLLUTION PREVENT INFORMATION
SPPP TOPICS (Part II)
YES
NO
N/E
Stormwater BMP Summary Section A(2)(c)
X
(Include all structural and non-structural BMPs at the site)
Storm drain inlet protection with silt sock/hydrocarbon absorbent was not discus in the Measures and Controls
section of the SPPP. Also, the proper installation and routine maintenance of this BMP need to be address in the
SPPP.
Spill Prevention & Response Procedures (SPRP) Section A(3)
X
(Stormwater specific plan identifying the various responsible officials and their signatures)
Spill prevention and response for all oil and chemical storage areas are addressed in the facility's SPCC Plan.
Preventative Maintenance and Good Housekeeping Program Section A(4)
X
(address maintenance and cleaning schedules of control systems, outfalls, adjacent waters, handling of industrial
activities, drainage structures, and BMPs - Include a list of the areas incorporated in the program)
As part of the good housekeeping practices, a mechanical sweeper was used to sweep paved areas to remove metal
fines on a weekly schedule. This good housekeeping practice needs to be incorporated into the Measures and
Controls section of the SPPP. The storm drains with silt sock/hydrocarbon absorbent are remove and clean once
every six months. This routine preventative maintenance of the storm drains also needs to be incorporated into the
Measures and Controls section of the SPPP.
Employee Training Section A(5)
X
(minimal annual training of spill response and cleanup/prevention and potential areas of industrial stormwater)
No records of annual employee training were noted in the SPPP.
Identify the Responsible Party Section (A)(6)
X
SPPP Modified or Update to Current Conditions Section (A)(7)
X
(review and update at least annually, recertify, and include the review of most recent benchmarks samples)
No records of annual review and update of the SPPP. Also, each review shall include a re-evaluation of the
effectiveness of the BMPs on -site.
Schedule and Procedures for Routine Inspections (minimum of semiannually) Section A(8)
X
Consolidated Metco operates an aluminum forming facility in Monroe, NC that produces a variety of truck wheel end assemblies. This
facility, which has been in operation for roughly 55 years, operates 24 hours per day, seven days per week and employees approximately
580 employees. The various wheel ends are produced through a variety of processes including melting and forming. The primary raw
materials used in the process are aluminum ingots. The melted aluminum is formed to the products in sand molds. Once formed, the
products are sent through various finishing steps and then stored before shipping. The waste materials from the process include, but are
not limited to, spent sand, and metal trimmings and shavings (which can be recycled to the process). In addition to the manufacturing
process, the facility also has fuel and chemical storage and maintenance operations.
The Monroe facility currently operates under an administratively continued NPDES industrial stormwater permit, NCS000324.
Stormwater at the eastern haft of the facility is collected in storm drains throughout the site and drains north to the wet detention basin
on the north side. This pond discharges to the facility's only outfall, Outfall 001. Stormwater runoff from the western half of the facility
flows from the site as sheet flow runoff into the tributary leading to Stewarts Creek.
Page 3 of 6

4. RECORD REVIEW
Record Review
YES
NO
N/E
Representative on -site
X
Records of the Implementation of the SPPP Part II Section A(9), Part III Section D(6)
X
Samples of records from 2017-2019 were requested and provided during the inspection.
Records of Routine Inspections, Housekeeping, and Maintenance Programs Part II, Section A(9)
Samples of the inspection and maintenance records were requested and provided. Quarterly inspections are
X
performed by a contractor with the quarterly benchmark monitoring. Internally, the facility performs quarterly
inspections and replacements of the silt socks in the storm drains.
Records of Employee Training Part II, Section A(9)
Facility personnel have required annual LS.O training in which the facility incorporates the necessary stormwater
X
permit discussions.
Records for the Approval of Representative Outfalls Part III Section D(5)
X
The facility had not requested the use of a representative outfall.
Records of Benchmark Monitoring Part II, Section B & D, Part III Sections D, & E(I)
Benchmark records from 2017 and 2018 were provided and reviewed. From the review of the records, the
X
appropriate lab methods and holding time appeared to have been met. The facility had one reportable benchmark
exceedance in 02/2018 for aluminum.
Records of Qualitative Monitoring Part II Section C, Part III Section D
Qualitative monitoring is performed internally monthly and quarterly by the contractor. The records were
X
available the provided during the inspection.
Records of Tiered Approach to Benchmark Exceedances Part III Sections B
A benchmark exceedance for aluminum occurred in February 2018. In response to the exceedance, the facility
X
implemented a Tier I response which included the addition of additional housekeeping measures and operating
practices.
Records of Bypasses Part III Sections E(7)
X
Records of 24 hr Reporting Part III Sections E(8 &9)
X
5. SITE EVALUATION : SWP3 IMPLEMENTATION
Pollutant Sources
Note location, quantitative description, design issue, O&M deficiencies (including the nature and
extent), and pollutants off -site
Loading/Unloading
Loading and unloading operations at the facility occuring in the loading areas along the west side of the site.
Area
Material at the facility is typically received by container trucks. These trucks can dock at one of the loading
areas on west side of the site and transfer material directly into the building.
Material storage areas were identified throughout the site. Pallets and shipping materials are stored at the site
Material Storage
in outdoor storage areas. Some of these storage areas, seen in photos DSCN1978-DSCNI979 and DSCN1985
Facilities
were located under shed cover (some with three walls and some with just a cover). Equipment and gas storage
areas were observed along the southwest side of the site. The equipment area can be seen in photo DSCN1983
while the gas and CO2 storage area can be seen in photo DSCN1985.
Process Operations -
Furnace, Rolling,
forming (including
No issues noted during the inspection
air pollution control
equipment areas)
Product Storage
Finished products at the site are typically stormed outdoors storage piles around the facility. One of the storage
Areas
areas was observed on the north side of the site (seen in photo DSCN1972).
Page 4 of 6

5. SITE EVALUATION & SWP3 IMPLEMENTATION
Pollutant Sources
Note location, quantitative description, design issue, O&M deficiencies (including the nature and
extent), and pollutants off -site
Storm drains throughout the site were in place to collect stormwater and direct it of the retention pond. These
Storm drains
inlets were observed in the various impervious areas of the site and can be seen in photos DSCN1972 and
DSCN1980-DSCNI981.
Some evidence of fluid and sediment trailing was observed in various areas of the site indicating the potential
need for additional housekeeping measures. In the storage area on the north side of the site, coolant was
Housekeeping
observed to be leaking from the process with no containment or measures in place (seen in photo DSCN1973).
In the areas near the loading docks and waste bins for sand, sediment trailing was observed leading to the
various storm drain inlets (seen in photos DSCN I 980-DSCNI 98 1).
Tanks and some of the fluid containing mechanical processes located outdoors at the facility were located
Liquid Storage
within a secondary containment structure. The pump area, seen in photo DSCN1977, was located within a
Tanks
secondary containment structure. Accumulated water in this containment structure can be periodically pumped
out to the waste water tank. The materials in this tank are periodically sent off site for disposal and/or treatment.
The facility operates a variety of best management practices throughout the site to help manage stormwater
runoff. The primary control device used at the site was the retention pond on the north side (seen in photo
DSCN1976). The pond receives stormwater runoff from the storm drains throughout the site and discharges
Best Management
through the riser pipe seen at one end of the pond.
Practices (BMPs)
In the storm drains throughout the site, the facility used silt sacks to collect and manage sediment runoff. These
silt sacks, seen in photo DSCN1972, were observed in the various storm drains but often did not scratch across
the entire storm drain inlet.
Spills/Leaks Handing
No issues noted during the inspection
Waste from the process included, but was not limited to, spent sand from the forming lines, metal shavings and
trimmings, and waste oil and chemicals. The used sand and waste metals are typically stored outdoors in open
top dumpsters. The facility was observed as having sheds in places for these open top dumpsters, seen in photos
DSCN1979, DSCN1982, and DSCN1984. Although the sheds were in place, several of the dumpsters with
Disposal/Waste
finance sand were observed being stored outside of the covered area.
Handling Areas
For some of the domestic waste, the facility operates a trash compactor which was located along the west side
of the facility. For other miscellaneous waste at the facility, including used oil, chemicals, and accumulated
liquid pumped out of the secondary containment structures, the facility has a covered shed near the southwest
corner of the site. This area, seen in photo DSCN1986, was under a three sided covered shed.
Vehicle Maintenance
The facility does not use more than 55 gallons of motor oil per month and is therefore not required to sample
Areas
stormwater for oil and grease.
STORMWATER
DISCHARGE & RECEIVING WATER OBSERVATIONS
Outfall, Stormwater
Discharge &
YES
NO
Receiving Water
Number & location
of stormwater
Describe: Per the facility's site plan, there is one permitted outfall (Outfall 001). This outfall
discharge(s)/outfall(s)
X
(seen in photo DSCN1975) discharges from the wet detention basin to unnamed tributary on the
consistent with the
north side. Just down gradient of the outfall from the pond, a second corrugated pipe was
SPPP
observed discharging into the tributary (seen in photo DSCN1976).
Page 5 of 6

1 1
1DISCHARGE ; RECEIVING WATER OBSERVATIONS
Outfall, Stormwater
Discharge & YES NO
Receiving Water
Evidence of off -site
accumulation of
pollutants observed
X
Describe: During the inspection, no offsite accumulation was observed in the tributary.
in receiving water
Other potential
Describe: Stormwater runoff from the western half of the facility flows from the site as sheet
discharges off -site
flow runoff into the tributary leading to Stewarts Creek. This area which have scrap equipment
(through outfalls not
X
and hub storage was not evalualted in the SPPP for potential contaiment stromwater runoff and
included in the
the need for additional BMPs. Also, the SPPP need to determine whether this sheet flow from
SPPP)
the western half of the faciliy need to be permitted as an addtioonal stormwater discharge point.
Non-stormwater
X
Describe:
discharge observed
Additional inspection summary, narrative, findings, comments, photos, and schematic diagram of the facility area as
necessary:
An exit conference was held with Adam Hamilton. During the conference, the following observations were relayed:
• SPPP observations
o The site plan which was dated 2009 and did not include records of annual reviews and/or updates
o There were no dated updates to the spill records
o There was no documented feasibility study
o The plan did not include any description of the procedures/measures in place for the pumping out and disposing of
accumulated liquid in the secondary containment structures
o The site plan needed to include a maintenance and cleaning schedule
• Records observations
o No issues were found during the inspection
• Site observations
o The filter socks observed in the storm drain inlets were not stretched completely across the storm drain inlet
o Trails of coolant (near pollutant point 6) and sediment were observed in the various areas of the site leading to inlets
o Some open/uncovered drums were observed around the site
o Open top roll off bins with used sand were observed being staged in areas of the site not under shed cover.
Page 6 of 6

SW-NCS000324-032119
Consolidated Metco
780 Patton Ave
Monroe, NC 28110
Overview Map
SW-NCS000324-032119 Page 1 of 17

DSCN 1971.J PG
Attributes
File Name
DSCN1971.JPG
Description
Photograph of a finished wheel hub storage area.
Latitude
N 34° 59' 54.14"
Longitude
W 80' 33' 36.48"
SW-NCS000324-032119 Page 2 of 17

DSCN 1972.J PG
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Attributes
File Name
DSCN1972.JPG
Description
Photograph of a storm drain inlet near the outdoor wheel hub storage area. A silt sack was
observed protecting the inlet with a hydrocarbon absorbent. This silt sack, like many of those
throughout the site, was observed as not completely stretching across the storm drain opening
(with the corners unprotected).
Latitude
N 34' 59' 54.71"
Longitude
W 80' 33' 36.94"
SW-NCS000324-032119 Page 3 of 17

DSCN 1973.J PG
t-Y � � # •F Y �t
■ 1 •
Attributes
File Name
DSCN1973.JPG
Description
Photograph of an outdoor storage area near the northeast corner of the site. A trail of coolant
was observed in this area discharging towards the east side of the site.
Latitude
N 34° 59' 56.52"
Longitude
W 80' 33' 38.41"
SW-NCS000324-032119 Page 4 of 17

DSCN 1974.J PG
Attributes
File Name
DSCN1974.JPG
Description
Photograph of the discharge pipe from the storm drains to the permitted outfall.
Latitude
N 34° 59' 57.46"
Longitude
W 80' 33' 38.54"
SW-NCS000324-032119 Page 5 of 17

DSCN1975.JPG
Attributes
File Name
DSCN1975.JPG
Description
Photograph of the outfall ditch where the discharge from the storm drains connects with the
discharge pipe from the wet detention basin (seen in the top of the picture).
Latitude
N 34° 59' 57.51"
Longitude
W 80' 33' 38.58"
SW-NCS000324-032119 Page 6 of 17

DSCN1976.JPG
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Tangy
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Attributes
File Name
DSCN1976.JPG
Description
Photograph of the wet detention basin on the north side of the site.
Latitude
N 34° 59' 57.07"
Longitude
W 80° 33' 40.85"
SW-NCS000324-032119 Page 7 of 17

DSCN 1977.J PG
Moi�IPE
a i r '4' 7T'a n iwr i
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Attributes
File Name
DSCN1977.JPG
Description
Photograph of the secondary containment structure around a facility pump area. Accumulated
liquids in this area are periodically pumped and sent to the waste water tank.
Latitude
N 34° 59' 56.84"
Longitude
W 80' 33' 40.47"
SW-NCS000324-032119 Page 8 of 17

DSCN 1978.J PG
Attributes
File Name
DSCN1978.JPG
Description
Photograph of a shed covered pallet and cardboard storage area.
Latitude
N 34' 59' 56.36"
Longitude
W 80' 33' 43.60"
SW-NCS000324-032119 Page 9 of 17

DSCN 1979.J PG
A
Col.,
n „ �
Attributes
File Name
DSCN1979.JPG
Description
Photograph of the outdoor storage area on the northwest corner of the site. This area contained
open top dumpsters and waste drums.
Latitude
N 34° 59' 55.70"
Longitude
W 80' 33' 44.20"
SW-NCS000324-032119 Page 10 of 17

DSCN 1980.J PG
'
r r
ar
•
Attributes
File Name
DSCN1980.JPG
Description
Storm drain inlet along the west side of the building in the loading dock area.
Latitude
N 34° 59' 54.77"
Longitude
W 80° 33' 43.01"
SW-NCS000324-032119 Page 11 of 17

DSCN1981.JPG
_ r=
MO E
er
• 11-o {
F• e *f .. .I
•f
Attributes
File Name
DSCN1981.JPG
Description
Photograph of a storm drain inlet in the truck loading/unloading area. A silt sack was observed
protecting the inlet with a hydrocarbon absorbent. This silt sack, like many of those throughout
the site, was observed as not completely stretching across the storm drain opening (with the
corners unprotected).
Latitude
N 34' 59' 53.88"
Longitude
W 80' 33' 42.86"
SW-NCS000324-032119 Page 12 of 17

DSCN 1982.J PG
Attributes
File Name
DSCN1982.JPG
Description
Photograph of the waste sand storage area. The waste sand is stored in open top roll off bins.
The facility had a shed in place for the roll offs, but the roll offs were observed during the
inspection not being staged completely under the shed cover.
Latitude
N 34' 59' 53.36"
Longitude
W 80° 33' 42.82"
SW-NCS000324-032119 Page 13 of 17

DSCN1983.JPG
MO
Attributes
File Name
DSCN1983.JPG
Description
Photograph of the scrap laydown area on the west side of the site.
Latitude
N 34° 59' 52.79"
Longitude
W 80' 33' 42.75"
SW-NCS000324-032119 Page 14 of 17

DSCN 1984.J PG
r
53
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I
4
xr-79 fin
Attributes
File Name
DSCN1984.JPG
Description
Photograph of the waste sand storage area. The waste sand is stored in open top roll off bins.
The facility had a shed in place for the roll offs, but the roll offs were observed during the
inspection not being staged completely under the shed cover.
Latitude
N 34' 59' 52.88"
Longitude
W 80° 33' 42.28"
SW-NCS000324-032119 Page 15 of 17

DSCN 1985.J PG
WE
+16..
Attributes
File Name
DSCN1985.JPG
Description
Photograph of the pallet, propane, and CO2 storage area on the west side of the site.
Latitude
N 34° 59' S0.86"
Longitude
W 80' 33' 42.60"
SW-NCS000324-032119 Page 16 of 17

DSCN1986.JPG
Attributes
File Name
DSCN1986.JPG
Description
Photograph of the shed area used for chips, chemical, and waste water storage.
Latitude
N 34° 59' 50.44"
Longitude
W 80° 33' 42.44"
SW-NCS000324-032119 Page 17 of 17