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HomeMy WebLinkAboutNCG050352_Historical Docs re EPA inspection_20091211Sullivan, Shelton From: Al|ooco, Marcia Sent: Friday, December 11, 2009 8:00 AM To: Sullivan, Shelton; Krebs, Rob Co: SamerBou-3hmzo|e; K4aroia/U|0000; Maher, Niki; Hsd[ Erin R.; Turner, AliyahA. Subject: RE: Attachments: MauserFollowupBIMSChecklist.doc Shelton, That would have been information provided k]AliyGh Turner OfMecklenburg County. After |UOW0g at Follow - LIP Inspection Checklist (attached) forwarded by Aliyah to me for entry in BIMS and issuance of the inspection report an updated site map was provided tO/\||yBh on 12/8V08. "Ms.A|' hTurnerrecpivedanumdatedcopyofthefad|it/sSPPPonSeptember16,2OOO and acopy ofthe facility's updated site map onDecember 8,2O08." From. Sullivan, Shelton [moiKn:sheKDn.suUivon@ncdenr.00v] Sent: Tuesday, December08, 2009 5:59 PM To: Krebs, Rob Cc: SamorBou'Ghaza|e; MarciaAUoccn; Maher, Niki Subject., The attached CE|follow-up mentions information provided Vn12-8-U8. EPA was looking for that info inthe file. |donot see anything dated o/stamp dated on12'8'08. Let meknow what you find out. We got info from K8nck.County but nothing dated on 12'8-08. Thanks Shelton Sullivan Non -Point Source Assistance and Compliance Oversight Unit Wetlands and 5tonnwaterBranch NC Division ofWater Quality (91g)OO7'6361phone (919)8O7'64Q4fax Please note that mynew email is: *E'nnmYcorrespondence toondfrnn7this address may besubject tothe North Carolina Public Records Low and may be Stormwater Inspection Questions in BIMS -MCWQP NCG050352 Permit No.: Facility Name: Mauser Corporation NCSO Permit Effective: May 31, 2013 Discharges to: Paw Creek Inspection Date: September 22, 2008 Inspection Type CEI ❑ CSI ❑ Complaint ❑ Other ® Compliance Inspection Ins ector s : Aliyah Turner Agency: MRO ❑ MCWQP Entry Time: 11:45 am Facility Contact (s) Mike Frausto (704)398-2325 Exit Time 12:00 pm Work Days 1.0 Facility Status: Compliant ® Non -Compliant ❑ Facility Description: The facility uses High Density Polyethylene to manufacture plastic drums. The Polyethylene pellets are pumped into silos from railroad cars. Production activities are performed inside of buildings and are not exposed to stormwater. When the drums are produced they are stored in the facility's warehouse until being loaded into trailers for transport. Compliance History: Mauser Corporation was inspected by Ms. Aliyah Turner and Mr. Ron Eubanks of Charlotte - Mecklenburg Storm Water Services (CMSWS) on March 31, 2008. A Notice of Violation was issued by the Division of Water Quality on May 2, 2008. Page 1 of 7 Rev. 0, 1 /08 Stormwater Inspection Questions in BIMS -MCWQP City of Charlotte Stormwater Ordinance and General Good Housekeeping Recommendations: A stormwater inspection of Mauser Corporation by Ms. Aliyah Turner and Mr. Ron Eubanks of Charlotte -Mecklenburg Storm Water Services (CMSWS) conducted on March 31, 2008, found several housekeeping issues. The permittee stores used oil outdoors in totes that were covered with wood pallets. The used oil totes and pallets are exposed to stormwater. Oil staining was observed on the ground at the base of the totes. Also an abandoned tank was observed outdoors during the on -site inspection. A follow-up inspection of the Mauser Corporation facility conducted on September 22, 2008, by Ms. Aliyah Turner of CMSWS found that the permittee has ceased the storage of used oil outdoors. The permittee holds used oil in a containment pit inside the manufacturing building. The permittee contracts with Safety Clean Inc. to siphon and dispose of the used oil from the containment pit. Comments: Page 2 of 7 Rev. 0, 1 /08 Stormwater Inspection Questions in BIMS -MCWQP Stormwater Pollution Prevention Plan Yes No NA NE Does the site have a Stormwater Pollution Prevention Plan? ® ❑ ❑ ❑ Site Plan 1. Does the Plan include a General Location (USGS) map? ® ❑ ❑ ❑ Facility location in relation to roads and surface waters. Includes: name of receiving stream or name of municipal storm sewer system, and accurate lat. and long. of point of discharge. This helps the permittee to understand their location with respect to receiving waters. 2. Does the Plan include a "Narrative Description of Practices"? ® ❑ 1 ❑ I ❑ Should cover storage practices, loading and unloading areas, outdoor process areas, dust or particulate generating or control processes, and waste disposal practices, etc. 3. Does the Plan include a detailed site map including outfall locations and ® El❑ ❑ drainage areas? Should show • Location of industrial activities (storage areas, disposal areas, process areas, unloading and loading areas) • The drainage structures • Drainage areas for each outfall and activities occurring in the drainage area • Building locations • Existing BMPs and impervious surfaces and the % of each drainage area that is impervious • For each outfall, a narrative description of the potential pollutants which could be expected to be present in the stormwater discharge. This forces permittee to analyze the site with relation to stormwater discharges. It is also a tool for the inspector to understand if the site has changed over time, i.e. if site map does not match facility they must update their plan. 4. Does the Plan include a list of significant spills occurring during the past 3 ® ❑ ❑ Elyears? Needs to include corrective actions that were taken. The permittee needs to know what the reportable quantities are for wastewater, oil pollution, and SARA Title III. 5. Have stormwater outfalls been evaluated for the presence of non-stormwater ® El❑ discharges? Signature required: • Corporation - signed by Responsible Corporate Officer or assigned manager • Partnership or Sole Proprietorship — General Partner or the Proprietor • Municipality, State, Federal, or other public agency — either principal executive officer or ranking elected official Comments: Page 3 of 7 Rev. 0, 1 /08 Stormwater Inspection Questions in BIMS -MCWQP Stormwater Management Plan Yes No NA NE 1. Has the facility evaluated feasible alternatives to current practices? ® ❑ ❑ ❑ • Provide 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. • In areas where elimination of exposure is not practical, the stormwater management plan shall document the feasibility of diverting the stormwater runoff away from areas of potential contamination. 2. Does the facility provide all necessary secondary containment? ® ❑ I ❑ I ❑ • Applies to liquid raw materials, manufactured products, waste materials, or by-products • Single AST capacity > 660 gallons • Multiple AS containers in close proximity to each other with a total combined capacity of > 1,320 • If connected to SW conveyance; controlled by manually activated valves or other similar devices? (Closed?) • Collected water observed for color, foam, outfall staining, visible sheens, and dry weather flow prior to release • Document individual making observation, description of water, date, and time of release (RR=5 yrs) 3. Does the Plan include a BMP summary? I ® I ❑ 1 ❑ 1 ❑ Narrative description of BMPs to be considered including oil and grease separation, debris control, vegetative filter strips, infiltration and stormwater detention or retention, where necessary. • The need for structural BMPs 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. 4. Does the Plan include a Spill Prevention and Response Plan (SPRP)? ® ❑ I ❑ 1 ❑ • Assessment of potential pollutant sources based on materials inventory of the facility • Facility personnel responsible for implementing the SPRP shall be identified • Responsible person shall be on -site at all times during facility operations that have the potential to contaminate stormwater runoff through spills or exposure of materials associated with the facility operations. 5. Does the Plan include a Preventative Maintenance and Good Housekeeping ® ❑ ❑ ❑ Plan? • Document schedules of inspections and maintenance activities of stormwater control systems, plant equipment and systems • Inspect material handling areas • Regular cleaning schedules of these areas 6. Does the facility provide and document Employee Training? ® ❑ 1 ❑ I ❑ • Provide at a minimum, annual training for all personnel including: proper spill response, cleanup procedures, preventative maintenance activities for all personnel involved in any of the facility's operations that have the potential to contaminate stormwater runoff • Develop training schedule and identify facility personnel responsible for implementing the training Page 4 of 7 Rev. 0, 1 /08 Stormwater Inspection Questions in BIMS -MCWQP Yes No NA NE 7. Does the Plan include a list of Responsible Parties? ® ❑ ❑ ❑ Identify position responsible for the overall coordination, development, implementation, and revision of the SPPP 8. Is the Plan reviewed and updated annually? I ® I ❑ I ❑ I ❑ Have there been any changes to the design, construction, operation, or maintenance of the facility, which would have a significant effect on the potential for the discharge of pollutants to surface waters? Does plan include changes? 9. Does the Plan include a Stormwater Facility Inspection Program? I ® I ❑ I ❑ I ❑ • Inspect at a minimum semiannually once in Fall (Sept. -Nov) and once in Spring (Apr -June) • Inspection and subsequent maintenance activities performed shall be documented o Record date and time o Individual performing inspection o Narrative description of the stormwater outfall and plant equipment and systems • Records should be incorporated into the SPPP 10. Has the Stormwater Pollution Prevention Plan been implemented? ® ❑ 1 ❑ ❑ Have they done what they said they were going to do and have they documented it. Examples include: • Monitoring and measurements including sampling data • Inspections • Maintenance activities • Training provided to employees • Activities to implement BMPs associated with industrial activities including vehicle maintenance. (RR=5 yrs) Comments: A stormwater inspection of the facility conducted by Ms. Aliyah Turner and Mr. Ron Eubanks of CMSWS on March 31, 2008 revealed the permittee had developed an SPPP but it was last updated in February 2006. The permittee had not developed or implemented parts of the SPPP as required by the permit including a narrative description of practices, a list of significant spills in the last three years, and annual employee training documentation. Also, the permittee needed to develop accurate site maps of the facility. Ms. Aliyah Turner received an updated copy of the facility's SPPP on September 16, 2008, and a copy of the facility's updated site map on December 8, 2008. Qualitative Monitoring Yes No NA NE 1. Has the facility conducted its Qualitative Monitoring semi-annually? ® ❑ ❑ ❑ Page 5 of 7 Rev. 0, 1 /08 Stormwater Inspection Questions in BIMS -MCWQP Sampling in Spring (April -June) and Fall (September -November) Color Odor Clarity Floating Solids Suspended solids Foam Oil Sheen Other indicators Comments: A stormwater inspection conducted by Ms. Aliyah Turner and Mr. Ron Eubanks of CMSWS on March 31, 2008, revealed that the permittee performed qualitative monitoring activities on March 10, 2008. No other documentation was provided regarding the permit requirement to conduct semi-annual qualitative monitoring during the inspection. Post inspection, the permittee provided documentation of qualitative monitoring activities conducted on April 5, 2008, and September 10, 2008. These records were included in the facility's updated SPPP. Analytical Monitoring Yes No NA NE 1. Has the facility conducted its Analytical monitoring? ❑ ❑ ® ❑ 2. Has the facility conducted its Analytical monitoring from Vehicle Maintenance ❑ ❑ ® ❑ areas? Comments: The permittee does not perform vehicle maintenance on site therefore analytical monitoring is not required. Permit and Outfalls Yes No NA NE 1. Is a copy of the Permit and the Certificate of Coverage available at the site? ® ❑ ❑ ❑ 2. Were all outfalls observed during the inspection? ® ❑ ❑ ❑ 3. If the facility has representative outfall status; has it been documented by the ❑ ❑ ® ❑ Division? Page 6 of 7 Rev. 0, 1 /08 Stormwater Inspection Questions in BIMS -MCWQP Comments: A stormwater inspection conducted by Ms. Aliyah Turner and Mr. Ron Eubanks of CMSWS on March 31, 2008, revealed that the permittee did not have a copy of the stormwater permit and Certificate of Coverage available on site. The facility's non-stormwater discharge documentation did not include a signature and date of the person that conducted the evaluation. Finally, of the facility's five documented outfalls it was found that three of the outfalls were actually storm drain inlets. It was recommended that the SPPP be updated to reflect these changes. The follow up inspection conducted by Ms. Aliyah Turner of CMSWS on September 22, 2008, found that the facility has obtained a copy of the stormwater permit and Certificate of Coverage. These records were available on site. As of December 8, 2008, the Mauser Corporation has completed all components of the general storm water permit NCG05000 and the site specific Stormwater Pollution Prevention Plan. Page 7 of 7 Rev. 0, 1 /08 Maher, Niki From: Rozzelle, Rusty [Rusty.Rozzelle@mecklenburgcountync.gov] Seat: Tuesday, December 08, 2009 1:28 PM To: Maher, Niki Cc: Krebs, Rob Subject: Copy of the File for Mauser Corporation Attachments: Mauser Inspection Information 3-31-08.pdf Niki, At your request, please find attached a digital copy of the information in our file for the Mauser Corporation. The only thing in our file that is not attached is a copy of the permit which I am sure you have in your file. The attached includes the following information in 49 pages: ® Work Order containing a brief summary of the work performed, • DWQ NOV, • Compliance Inspection Report dated 3/31/08, • field notes from the inspection, ® various facility information including their Storm Water Pollution Prevention Plan, Storm Water Management Plan, locations of outfalls, qualitative monitoring reports and training documentation, ® response letter from Mauser received by DWQ MRO on June 12, 2008, • follow up inspection report dated 9/22/08, ® follow up letter from DWQ indicating that the required actions specified in the NOV have been addressed, and ® a copy of the original Compliance Inspection Report dated 3/31/08. Please let me know if you need additional information. Rusty Rozzelle Water Quality Program Manager Mecklenburg County Land Use & Environmental Services 700 North Tryon Street Charlotte, N.C. 28202 Phone: 704-336-5449 Fax: 704-336-4391 0 i AUSER CORP ,4 Yxpd�vt'D .12499 Tar Heel Rorifl Charlotte, lVortli Carolina 28208 Phone., 704-398-2325 Fox., 704-3,9$-1946 Ms. Marcia Allo(= Division of Water Quality 610 East Center Ave., Suite 301 Mooresville, NO 28115 Dear Ms. Alb. -,co: NC DIENR MR0 DV!1Q.-&,1rfcjc0 at protc W Ct',-011 Subject: Notice of Violation Compliance Evaluation Inspection Mauser Corp- Stormwater Permit No> COO NCGO50352 Mecklenburg County, NG This Is the written response requested in your letter dated May 2, 2008. Your letter outlined that Mauser failed to perform semi-annual qualitative monitoring in violation of its Stormwater Permit and North Carolina General Statute (G,S.) 143-216.1, Mauser had a management change and the qualitative monitoring requirements had not been communicated to the new management team, Mauser had conducted qualitative monitoring prior to the arrival of the new management team. To prevent future occurrences, we have put together a scheduled program to alert all Mauser plants, subject to thesi-tonnwater requirements, when monitoring and other stormwater requirements are to be completed, This program will be monitored by the corporate office at least tvvIC4 annually. Should you have any questions or need further explanation, please telephone me Fit the number listed below. Sincerely, Charles Brooks Corporate Quality Manager 404-916-.8028 Mazztec OSA, Inc. ttlw Material itvuterCl�u ictist FRhI-flM C'liarlt>ttc Raw M tg�da[ Ti-,jms&,,r f. r✓ last 'ALL ITEMS MUST BE INITIALED BY ASSOCIATE PERFORMING EACH GHEEC <. HOLD OK. INSPECTION /ACCEPTANCE Record physical properties bf resin: HLMf _ and Density - verify Certificate of Analysis tins been approved. Attach a copy of the COA to this checklist (GONs kept in office). Check security of Seats - no evidence of tampering, Consistent color. No specs, burnt pullets or ovidonco of cantamination. Check that material is dry. No signs of moistureA Sample of material marked with date from each compartment, lot number, and railcar number and placed on -the in speatio�n stand at the back wait next to the large overload dolt for hick -tip by the Qunlity Minvgemant, MATERIAL APPROVED FOR USE 110LD FOR REVIEW- - HOLD OK PRE -TRANSFER Confirm that there Is no spillage or free pellets Visible anywhere in the unloading site before transferring material. ANY SPILLAGE REQUIRES IMMEDIATE REMSJVAL.. _ Remove all objects from shirt pockets before climbing on top of the railcar. Ne er leave railcar connected to unloader without top vent In place, Inspect soreen between unloadings. Store any foreign material in a Zipioc bag. gate and clearly identify sarrlpitr with date and railcar number or lot number and turned over to the Quality Management, -- - HOLD OK TRANSFER Record Silo level _Feet When opening railcar, put a neat or half drum. in place under railcar on each side to keep resin off the ground. Open top of car and Install vent cover. Maker sure vent is secure and will not let contaminants, water, critters, etc., V into railcar. Double check that vents are installer) on correct compartment, Nook up hose or insert probe in to railcar, it rifling silo,. hook up 4 In. metal hose. If material is directly feeding a machine, use probe. Check security of all connections. — _ Railcars are never to be unloaded in heavy rain. Haft unloading upon heavy rains. Date of Transfer. / / lime of Transfer, __.__. Transletred 13y., HOLD OK POST -TRANSFER — Before unhooking railcar, turn oft suction. This vylil keep contaminants from being. puffed Into the systi rn. Remove vent only after disconnecting unloadedr. When unhooking miicer, close tip all openings on car and cap hoses. Store probes and vents in assigned location(&). All material conveying lines must be sealed at all times. Before releasing shipment ensure that all compartments are actually and totally empty. Confirm that there Is no spillage or free pellets visible anywhere in the unloading. site before releasing milosar. ANY SPILLAt4E REQUIRES IMMEDIATE REMOVAL. Notify Plant Managernont to release railcar for pickup by railroad. Railcar Release Date., _ j... ! Released by: Performed By: Batch/Lot Cate: Vendor. 'pWw Agate-dat Tmnstcr COecl-list Page I of 3 Rovisi(m Dato 041,27.104 C�mtraltcAT3istribuiiort: &fasted+d:ttttraf,IU%v MalcriatThannfcr:Nateizook Retixertct l Aistritrutiun: rroduction Area I b3 4bV. �J, 0 -!g rg rL Ll CA 6 C7 0 40 0 :3 141 ep lr 4X rr . . . . . ........... if . Rl. cx lz 21 tP CD f EMPIAMPIE, TRAWMG Ons' I)Oacdb(, the 8MPICYee training proamm tmyour .faclifty WIowp 'Me proffram SbOuld, at a InAnimwn addrM SPW PrOV=tion and mspans,�, good hovwkeeping, ,Ind VWmial mansg=wt Pradio%- Wovida a- whedule fbr the un-king proX-nm �md Est the employees who ottWd Uaiaxing s=. ions. BlIer Wksmiption a Tr aft 11ragramm"teriab Scheft 4e er for Training Topics SPIN rVan%dom Locato: Raw Matelials August Maintenance/ stomge am by vigm drfll Spill rewnso pro lure Hamtkeeping DamOnatraflon, Post, August 49"S 6 t sito Auglist etcMwAals. lubels rssaes 011ca Overt' All Name and Official "Title ofAuthorized Representative Name; Mike Frausto Title: Plant Manager Dale� Signature, STORM WATER, A4ANAGENENT PLAN The HDPE pellets used to manufacture plastic drums are pumped from railroad cars to storage; silos and info the blowmold machines, Mauser uses good housekeeping practices and catch basins under the railroad cars unloading pipes to captureresidue from the railroad cars, Also condenmle ftorn the air compressors are captured in drums to and the air compressors are contained within an overhead structure. It is not feasible to cover the silos or railroad can, or to divert the sti.,n].11 wVater runoff away from these storage units. There is no storage of bulk liquids exposed to storni water in the Charlotte plant. SKUPREVENTION AND IZESPONS PLAN The purpose of the spill prevention mid response procedures is to identify areas where spill-5 can occur on site and their drainage points, specify materials handling procedures, storage requirements, And use of equipments; identify procedures used. for clewring up spills, and inforiii personnel about these procedures, and provide the appropriao cloali lip equipment and personnel. Tho.Mauser personnel responsible for the SPRP are Mausers maintenance porson:11.01 ,Aihoinclude, Morris Rendleman, Gary Beiniett, Archie Wilson, Louis Ordoliez and McKinley Falls, and Operations SupetiisorReynoldo Chcno7. 'I'he imajorpotential for spills is the HDPE pellets stored in railroad cars and silos. The HDPE pellets are solid can be shoveled into drums in the event of a breech of dae containment vessels. PREVENTATIVE MAINTENANCE AND GOOD f.-TOUSEKEEPING A Taw Material Transfor Cbedidist is completed each tirno a railroad c,,,.tr transfers.H.D.1`13 pellets to a silo. Employee training in tire: SPRIand tlio SPCC will. be coaductod at least an-nually durnig, Safb-ty Day or whonever an oniployce resporisibility includes items outlined in t1w SPRIP or SPCC plans. POLLUTION PREVENTION TEAM MEMBEk ROSTER. Leader: Mike Frausto Title: Plant Manager Office Pbone., 704-398-2335 704-401-7790 SignatoryauChority, coordinates all stages of plan development -and coordinates.employoe training and record Rceping and ensures reports are submitted. Member; Morris Rendlemm Title.- Maintenanoe Sixpeiwisor Off c-o Phone: 704-398-2325 En-iergcncy Phone, 704-326-6579 Assist Plant Manager fia prograin coordination, conducts inspections, notes process cburges, selects and proposes,.BMP options, impleme nts ents Blqp. Member., Genie Mead Title, Quality !Manager OfflicePhoine: 704-398..2325 firnergxoncyPhono: 704-326-6577 Conducts inspections, oversees good liousekeepiijg practices, spill re5pouso team coordinator. Member., Roynoldo Chove7 Title- Operations Supenisor Office Phone: 704-398-2325 Emergency Phone.- 704-326-6576 Conducts inspections, oversees good houselweping practices, spill response team coordinator, 019•'16!: () 0q TJL 3.2t d5 FAI. rzjoo2/¢1.7 STORM WA'l'PR POLLUTION PREVENTION PLAN' MAIISER CORP. 1209 TAR FIBEI.. ROAD, CHARLO'i`j'Y?, NTOWI'H CARO.T.;fNA 110 lAv"I'R (JDCiM'ION TI-ae FedcrartWater Pollution Omitr'ot Act, aLsn known as tiia Clean WEIter Act (MA), requires National Pollutant Discharge El.irnination System (.N: MESS poaniits .fox• Storrs water dischRrge;s associated with industrial activity. The State of North Carolina Dep;artrrrent of Ein ironmeiat and Natural Resources )Divisioan of Water Quality issued Gencral Permit No, Ni TCO0.5U000 to dischargc storm water strider tlae 1`di'DES. M:aauser. Cotp.'s Charlotte plant Porniit No. iti Ni GG0S0352 whicla becRTne effective on 03/18/OC. 2.0 STORM WA"ITIA POLLUTION PREVE1,17I014 PLAN Mauser Corp. is as plastic dnum,rrhanufWtaring plant Which consists rsf tvao coimected suites and sahother saute, connected by a tunnel, The area of the buildings total. 120,000 square fed, 'I'fre potential aonoillinatioat sources in.ciude IMPE pellets frrom tlae manufacturing procosses stOred in Silas and railroad cars, non -contact cooling water in chi -tiers, dumpstcr containing solid waste, find air compressors contah)i.rig oil. A site din -Amiga map for the f;3a~ility and.. two outfalls axe, shown in Fi ilre 1, The two outfalls aar(-, subject'to the q iiali,fative ni aaritoring reqi irethmrtts. Outfaril nornbar one's Potential polluta-nts are air totnpressors oil, and cautfall number two poteaati.al .polluttuats are drainage from the parking; lot. The longitude of ou:tfall number orae is 80.28 'kvost and the latitude is 33A S .nortfa. The 1t n-fritude of outfall number two .is 8 L02 west and file. latitucle is 35.E 3 north. Tho receiving water for the two outfalls is Paw Creek. The receiving water is not all Norita Ctuolina',q 303(cl) list of impaired waors. The Mauscr Charlotte -(facility hao- not had a history of any past spills or le4l(s. 3est. Management Practices (Ri`r11?s) that the Charlotte plauat ha sclecte d to iucludc in fho I?.l.an are good bouselceeping, preventative maintenance, re.gtalasa- inspections, and spill �e�pOrrSc a.0 STC)RMWATER. MANACrFNIENT PLAN Mattser aloes not have production operations o'i the outside. of the faril.ity. 11ie BI)PE pellets are contained in silos or raitro ad tank cars irl tlae rear of the fsacitity. HDPE pellets 0A'16/200� T51E 7 t.2tti3/01 _..__..........___� — . _ 45 PAX f .._.. ,._w......... __.. __._.._.._._ . --- -..��.,...__._........__....__......_.._-..... _._.... _-____ l i l f �.�' ar> � t-dcuuxcaed into the production operations i.11 a Closed syste€aa; Hnses are tiasec} to vacumn. the HDPU pellets into tlae building. C:o,ntaai►mient cntrh btrckets are. pl<,ced uaz ter the railroad t nlr car tacases to, contain pellets during the cauPling and uncouplin6 process, The air co€xapressors and chillers axe Xac�•€ ed 41 the fi'v it of the building in closed loop Systom There, is inmiffiz.ient space Ynthin the 1=aeilit5 tc7 h0140, {lu€ silos use to Store the pallets or to house tite air Compressors. To minimize; tite Potential exposure to storm"'ater tilt, silos €sr los ated iri the reru of tlae l�uildirl , Tb we within it contained area oil t concrete pact SO-J-1matod f€om'dw door watet drainage by ttn area of vi gv;t atioz€. At least €nonthly Mauscr employees vill monitor the parking lots, silos, and railroad tracks to control dells which may impact star..rnwater. SPILL PREVENTION AND 17ESPONilE PLAN Sto€ mwtarer Pollution Prevention Teaixr for. RS's Homestead Road plam silt is show i below: N41ke Drag,, "''''"`'`jrJ i�i(tt!( lmllrtlJ.�,CT 1 Wrris Avidleman Omic M ind Olvis licster mar(atm mur, 5upccvisor OA. mar l-v'a L�npini:criu{ The responsibilities of tl)e indi'Vidu<tls are a, follows: 1�lenzbexi'J itle klike FraustO Plzor€i__ __ (704)39&.-2325 (of- ice) R_es ausibihlies Program In -Charge: Provide Plant 'Ma€iager (704) 401-7790 (cell) adequate resources to the toam arid review progreun implementz,:lRai iiad Tualce iYlarris Rcxadl(,rs±ail (704)398-23") (afaice) m-'wssaTy revisions Team Leader, doord-mates Maintcila.nc,e (704) 320-6579 (call) and implemem SP"k.P; D'rt�rsee inspootionS, F,�cvrdkeep ng, submittal, and 000rdination; provide training and review; p('11 MI of Coordinate Utai'tk:Slj+'viSllc=1 2'tlilili t(arl n� (704) 398-2323 A.ssistii)lt Leader- Asii T ualit1 lvtariav( r _1diX:t( iaalaCe )�'.l�C.€.76rer Curds Hester __....._._...._........_...._._.. (704. 3� 9&__:_2.32.5 (offcef — BM:P reviews, site �. 0>'i .) 6/2008 �TUO is a 45 1?Ai.. (........ ..._........_. _ M... _....._._ 14004,' oil En8tneer his'pections, maintenance, recordkc:eping, analytical s6l?missimisy perform or coordinate quarterly visual marmori The facilitymay also utilizer and coordinate SPRP related activities with third -party consultants or contractors as nooded.. Mauser lias developed a comprehensive S7'CC and.Emergency Response Flan and Procedtives. `l'heputpose of these procedures is to idmlify areas wliore, spills could occur ou-site, draina.gepoirits and there i.tlipact oil stormwater. Specific material handling motbods, storage:, areas., and ttse of equip7malt, includim contairmicut are discroscd. Mausea will follow these plam and procedunr,s, and also will conduct. annita:l vinployee tratFnirtl;. The training shall be conducted by t17e plant maimnance manager, Mauser emptoyces will.fol•low the Manser SPGC plan inthe event of asp -ill, if stamiNvater is impacted in the event of a spill cmployer•,s will take measures outlined in Ivlau.ser perror1118 regular and preventive maintix,,a icv for all tntu;liiilej< amd equiprtcn.t. It blclodes: o Inspection and testing to uncover conditions that could. citLtso breakdowns or fa11.1 ecs rosult'ing tI1 disgltarcyCS o Prolmr niii.atmiance of facility ecIiiipmes)t o Inspection of piping, storage uviiks, and Ial0crial storage areas 4torinwater oorttrol sysic m rna:16teiiance and inspr cation sliall lac performed at leant flu Aerly to ilMte that the sysf r ats axu tadquaw and functioning properly. 4.0 PLAIN .AaNIEZINDt�1EN7` Maatser will, artaeaY(i the Stormy atcr Plaan if tlier e is a change in plant d si&m, constmetiort; operation, or ruaintenatme which offects Otorat,)vMc--r discharge or pollution to surface waiters. Tht plant rnana;er or _his designee Ceiti.fics Hiatt the Stormavater Pollittion Prevention Plari is reviewed mmu ally and updated. as necessary. Included in the eaertification is a list of spills or leaks the fkility exlieri�mccd in the Previous tlime years or a statement that throe have been no spill" or leal.s in thvprevioats tlix4e years. The imill I'll re.•CertiticatiOil will also include a statement that tli.e cutfa,lls have been evaluated for the p3:e;>vncc, of rion- storrnwatcr discharges. V a ` ! 5 i "1, ra _l --�!3 _ _ A 4 8 ,3x—. _._....__..__.,......__.... , ..... _.._.. _ ......__.. r_.. f� 4 J 5 / fi 1.I i .Ccertify 1'larn aand haave rtcrxde any rant essrary clzang os and Itsied any spills aaimilenced in thepr<avious three years, SPff, S OR LEAST PREVIOUS THREE YFAId 3. elf, ,5. 6. 7. , Vrere Ir ve et'rt 746 spills oa I6rkS at the Uae+st': pltzrrt i):47T Mauve evaluated IFae Avo outfaal4 for tile Presence qf discharges. 1havc lc ken the farlowirsg corrective azctlon for- any outf rfl that has recedved any rm., starrmwater• discharges. CORRECUTT, AC'T`100 1. . 3. 4, 5, 6. 7. No .corrective actions are rGCI1Gir:[l; nccre rare: no non-stornnuata>r• r.I4xharrgas in any of rlre AUTO- OWZED Rr-P ESEN';;AnvF, I Certify incur bmialty of,'law chat this document and all attachments weir, prg)aceeI. uxidw my &rcx Lion (yir .supervision in aiccoxdame with a system desiggcd to awsuro that qualified J9/1&1 F)G3 TUE 12� '$ FAX i��)sft,r.7 person A6 properly gather mid evaluate the in£`orination submitted, Lased on my inquiry of [he pCrson or person, who tnana.ge the system, car those persons directly responsible for gathering the ilrrorination, the information submitted is, to the best of my laiowtr dge and belief, true, accurate, and complete. 1 am, aware that tb re are, significant penalties foi• suhrnitting false inl'o�la3tio�s, iricludin th.s; pnssibil.ity of 1inus noel ir�tprisonment for Knowing vi.olotion i. :Name and Official Title of Authorized Representative Name: 'Mike Fratrsto Title: plant Manager Signature.-� �� - ...� . _.lDate- STORM Thy: f DPE pellet;: used to ulanufa.uture plastic drums are purnped from railroad cars to storage silos and itzto the blowvnrold aia6l roes. Mauser uses good housekeeping practices a.rrd catch basins under the railroad Cars urdowling pipes to capture residue from. the railwa.d oars. Also tond.mute from tl•re air compressors are, captured hi drums to and the air oozxrpressors are co7rtained within are overhead structure. It is nest teasible to uovcr the 4ilos or railroad cars or to divert the storm wa.tor ranoff aw,ry ,fron7 these storage uri.1ts. There is no stontt e of bulb liquids exposed to stoiTa water in the Charlotte plant. 81'111, PRFVFNTJ;C N' ANT) RESPWS PLAN `i'.ho piatpose Of the spill prevention and response procedures is tea identify r+rezts Ywhr re, spills ca:rl occur oft site and their drainage points, specify matefiAs handling lirocodtrres, storage, regixirements, and use of equipments; identify procedures used .for cleaning up spills, WkI. inform personnel about these pros-eduxev, and provide the appropriate clean up egturment and personnel. The ]Niauser persomiel responsible for the SPI-0. are Mauler's triaintenance, personnel who include: Morris Rer_dlernwi, Gary Lomett, iVchie Wilson, :l_otu5 Ordonez and NIcKinley Fails, and Operations Supervisor.Roynoldo G.licvez, The major pwentiaJ for spills i5 the r3DPE pallets stored in. railroad cars and siEc s. Tho HDPE pellets are solid can be shoveled into dr•u.rris in the every€ of a breech of the contaiurnent vessels. it tit f "'>• tJ r 6 l r ry` 4 Stormwater Discharge OutfaH. (SDO) Qualitative Monitoring Report County. P110110 No. .7 j Date OfTnSpection: By this SignIW176, x1 CC',76* dIat UJiS rOport is agpurate mid complete to the best of my knowledge:: (Signature of Pena tee or Designee) MSCAPtion Outfall. No. Stracture, (pipe, dit6h, etG,) ReceMugStream: Describe the industrial activities that occur within the out -Ball drainage area: 1, er /w'-. :>S,Z' Describe lite color of the discharge-Usingbasir, colors (red, brown, bhie, etc.) and tint (light, medimn, O' 0(e C.� dark) as descriptors: __ C, )r;,, C ("A" 3. Odor Doseribo any distinct odors that the 11-scharge Illay IUM (Le., smells strongly of oil, weak cb1orino odor, o.- 4. Clarity Choose the numberRMoh best d", fribes the clarity of the discharg ,e whem I is clear and 10 is very cloudy: 2 4 SWU-242-020705 5 6 7 8 9 10 Pago I E•• 5. Floating Solids a «. Ghooso the number which bsst ilcscribcs the amoarzt of floating, solids is the stun-nNyater disahargo where, I is no solids and I0 is the surface covered with floatuzg solids: l 2 (3 4 5 6 7 8 9 10 6. Suspended Solld.9 Choose the best describes the amount of suspended sorlids in the stonnwater discharge inhere I is no solids and 10 is extromely middy.- 2 3 d 5 6 7 8 9 10 7, Foam Is there azuy foam in the storrnwater discharge? Yes �NO) S. 0..11 Sheen lzs t:hero an oil sheen in the stornmater disoharge? yes CUD) 9. Deposition at t.?otfall Is there deposition of material (sediment, Oto) at or inn lodlately below the oatfail? Yes l N 1.01 Erosion at C3aatfail � Is there ermion at or inan edi.ateiy belQw the outfhll? Yes CIO) 1, Other Obvious Indicators of Stormwatcr pollution Nate: Law clarit}t, high solids, and/or the pmence of foam, oil sheen, deposition or erosion may by indicative ofeonditioixs tia.at Want further investigatiop and comvtive action. :,,WU-M-020705 Page 2 09/18/?048 TV8 L2i 47 FR/ 04LI/p17 Suer wager .Discharge O1' tfall (SDO) QUalitative onito Iris. .Repor t Facility l 4111o; _...._.A&! � C;_o Date of hispeetiun: � f c7u _ y___. or t: Ktiifdcato of Covorap I`ro,: Total Event Procilfizt.ion Qmhos): ,.._._.-6_1.. 3 0 -- Was tluii -1 Star' Event? (See ftif+oz`tn tion below) 6 Y`�s 0 �40 ,Please check yom- pzrmir to verj� zl (Jualircrtlt+e �t�ar�r'tc>riFJg rrit�t b� purfnr�r���'drn h�a tr r, press tt[t�tire storm event {requryem&.,ts ijary), .A "Representative Storm 13vonC" is a storm event that ttleasures greatar t.11an 0.1 inches of rainf'ali and fbat: is larcr..edU- l by at least 72 hom , (3 days) in whicdt no storm event measuring gteater than 0.1 Ir4os l-ias r7ccurred. A sipahl storm evotltfnay cortt�:4rr up to 10 Consecutive hours ofao prtcipittution. BY this signalm- , I certify fliat this retort is I, . I } � —,.." (Sim 11%r, of'i ernilttee orDesipee) and complete to the best of my lcnorvlecigrc: I. oettfalf &9eliptiom: t trtf it No. ,,,�,., — Structure (prl5e, ditch, rtc.) ifs%,{�- . 0 e %te:tcribe ahe irttdustria/lt artivitics that Occur the outflill drainage arr✓ -, _ i. )1--c '3i 2. Colors Dcs:cribp this solar of the dischtirge using- basic colors (reel, brawn, blue, etc.) and tint (diglit; mcd.3ltm„ dar.�) as tlesc:riptors: a____ �j � ` • � � a+ Odors Dmcribe, any distinct odors that the ohlorina odor, our,.): - --_M. NIZ D A C- - - !'rcr, t of SWV� 2.ay.om3 have (LB., smells stcokgIy UI oil, weak OY,r? 6/G M TUM 12; 4rAX Q10L2/01.7. Qualitative Monitoring Report Permit Y�io.: iJC i�r / / / Gt/ pj t3� czr C' eriirrcate crf<;'overage No.* SLQ. ; Facility Zuni : County:V . _ phone No. � " _.fit{.; �. � t.'�.c. �-i ..._ _-.�..�,J• ._._.._._... Date of Time: of Inspection: TQtal l3Viont1 recipitation (inches): Was this a Reproset wive Storm T s•ent? (See informatiou be lqw) Yes []Ida Plug e tahookyoro-,permit to vf:w�fy ��7uralit'arile.M0rtitQ;gng must be perforsned:drTln, a r'eprosanixu ve :sfdrrrr �verzi {requir4'rerrrs vary%, ".R.cTiresenn3tive Stotxn .Ea ezzt'> is a Stour event that nleasi'Mi Vt,'aler than 0.1 lnr hes of rainfalland that is pr0ce4d by at least 77 hours (:3 days) in which no :rtnrrrt event measuring greater tliaxr 0.1 inc4cs Iran occurred, A sirxpje stanri event may catztain up tU 10 COnSecutive 11OW':s of no DreciuiWinn_ Dy this signature, I.- at dais l (8igxstr�xc refl'ermitteoorDesimc is azccorate and cozn*W to the best of my knowledf c, .1. outfall Descripti - t)ui%ti]! No.true re, (pave, ctitz ll, etc. Receiving stream: � � �° ... � ) Describe e the is1dj1slri1T1 aciiviiie; tltrrt Occur within the outfall dmina Qe area; t, r ........k.M.. f�.f`_•_:2 _`;l Yt .r 'S d 0 of t elf 2. C019M NSCribe the color of the discharge using basic colors tt, brown, blue, f:tr.) and lint (lif ltfi, me-dlum, deuk.) as (lusccriptors:. _ CJ 4Li� 3. Odor, Describe try distinct odors that khe chlorine ador, ew.)- papc I of SYRJ4A2,05 t 6$ (i.e., smells strongly of oil, weak a 0$%16f2008 TUE 1.21,50 PAX II/01.7 Fa Tnuimbllg Sim. -Up Sheet pep .bate ' er _ 5� of tap 0 R TUB 12: 4 PP,F-Vi�,-N'rATrVE'MALNT'F,NiANCr-, AND (300D I-IOUSISKEEPING7 A Raw Matotini TTan$j,0,r C jje,cjist is oonjplete ,d eje11 tinje a railroad car Iransfrs HDPE P0114C,, to a. silo, ET',PIQYQQ t1ailling in The 91IRP mid the, SPCC wilt be conducted at least are wally during ,Sa:fo(.Y Day or whenever an employc,(- responsibility includes itenvoutlined in tho. 9111d) or SPCC ph -.Las. POLLUTION PREVENTION TEAM MBINTBFR Offic,ePhorlo, 704-398-2335 Emergency Phme, '704--401-7790 SiPatou authority, coordinates all stages of plait devooptntrit and implomeatation, coordinates employce training and record k4epirjg and ansiircsreports are submilted. Member- Momis Rendleman Title., Main.tcnanot Supervisor Office Phone: 704-393-2325 13MOTgency Phone: 70-4-326-6579 A.q6,j.gL Plant Manager in program o0ordination, miductq insp t, noteg process S0bXW Uld PTOPOScs, BIW wtions, implernents BIA.-P. Mornbff: Gene Mead Thle, QualiqlMaiiager Office l"hone., 704-398-2325 Emergency Phone: 704-326-6577 Conducts inspections, oversposgoad housekeeping; itraGtiCes, $pill response tea lu coordl.nator- -M(;,xnbojr, Reynoldo Chevoz Title: Operations 'Supervisor OffIccPhOne: 70,1-399-2325 Emerg-ency Phone: 704-326-6576 Conducts inspections, oversees good hansakeoping practlem, spill rGsporxse teen coordinator, Work Order Number: 76639 Supervisor: FARMER, RICHARD WO Initiated Date: 619/08 11:49:07 AM Actual Finish Date: 6/16/09 9:32:00 AM Activities Completed By: TURNER, ALIYAH A Completed Date: 6/16/09 9:32:00 AM Closed Date: 6/29109 1:54:16 PM Hard File Location: Mauser Corporation WATER QUALITY WORK ORDER Project Name: IN-1(1) Gdneral Location: 1209 TARHEEL ROAD Facility Name: Mauser Corporation Basin: 61 Jurisdiction: CITY Associated Service Request: ACTIVITIES Comments: By TURNER, ALIYAH A: 8/13/2008 9:25:54 AM 04/28/2008 Aliyah Turner conducted a file review for the Mauser Corporation facility. 04/30/2008 Aliyah Turner and Ron Eubanks conducted a storm water inspection of the mauser Corporation facility. 04/30-5/14/2008 Aliyah Turner worked on report for Mauser Corporation facility. 07/22/2008 Aliyah Turner performed follow up inspection for Mauser. There were no changes to used oil area and the facility had not yet updated the Storm Water Pollution Prevention Plan. 08/12/2008 Aliyah Turner conducted a second follow up inspection of the facility. Used oil containment area had been moved inside of building, Facaility is still working on the storm water pollution prevention plan. By TURNER, ALIYAH A: 9/22/2008 4:39:46 PM 09/22/2008 A. Turner conducted follow up of the Mauser facility, By TURNER, ALIYAH A: 11/18/2008 3:55:15 PM 10/2/2008 A. Turner went to Mauser to review SWPPP due to maps not having accurate information. 11/18/2008 Spoke with Mr. Brooks about the maps. He stated that maps will be here by November 26, 2008. Custom Field Category Custom Fields Custom Field Names Custom Field Values F WATF � RQ�i Michael F. Easley, Governor y William G. Ross Jr., Secretary ? S North Carolina Department of Environment and Natural Resources =1 Ca ^C Coleen H, Sullins, Director Division of Water Quality May 2, 2008 CERTIFIED MAIL 70071490 0004 4509 5058 RETURN RECEIPT REQUESTED Mr. Mike Frausto, Plant Manager Mauser Corporation 1209 Tar IIeel Road Charlotte, North Carolina 28208 Subject: Notice of Violation Tracking Number: NOV-2008-PC-0316 Compliance Evaluation Inspection Mauser Corporation Stormwater Permit -Number COC NCG050352 Mecklenburg County, NC Dear Mr. Frausto: Enclosed is a copy of the Compliance Evaluation Inspection (CEI) report for the inspection conducted at the subject facility on March 28, 2008, by Ms. Aliyah Turner and Mr. Ron Eubanks of Charlotte -Mecklenburg Storm. Water Services, This inspection was conducted as part of a cooperative working agreement between Mecklenburg County and the Division of Water Quality. In addition, the inspection was conducted on behalf of the City of Charlotte in compliance with the City's NPDES Permit, NCS000240, Part II Section H. Thank you for your assistance and cooperation during the inspection. The inspection found that Mauser Corporation has developed and partially implemented a Stormwater program and this Office commends the permittee's efforts to ensure compliance with your NPDES permit. However, this report is being issued as a Notice of Violation (NOV) due to the permittee's failure to perform semi-annual qualitative monitoring in violation of the subject Stormwater Permit and North Carolina General Statute (G.S.) 143-215.1, as detailed in the Qualitative Monitoring section of the enclosed report, Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates or fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G,S, 143-215.1. It is requested that a written response be submitted to this Office by . June 6, 2008, addressing the deficiencies noted in the Stormwater Pollution Prevention Plan and Qualitative Monitoring sections of the enclosed report. In responding to the violations, please address your comments to the attention of Ms. Allocco at the letterhead address, ��i6 NCDENR NorthCarolina Naiurallrl Mooresville Regional Office Division of Water Quality Phone 704-663-1699 Customer Service Internet: wyvw.ncwaterquality org 610 East Center Ave, Suite 301 Mooresville, NC 28115 Fax 704-663-6040 1-877-623-6748 An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper Mr. Mike Frausto, Mauser Corporation NOV-2008-PC-0316, Page 2 May 2, 2008 The enclosed report should be self-explanatory; however should you have any questions concerning this report or have any questions regarding your permit, please do not hesitate to contact Ms. Marcia Allocco of this Office at (704) 663-1699. Sincerely, for Robert B. Krebs Regional Supervisor Surface Water Protection Section Mooresville Regional Office Enclosure cc: NPS-ACO Unit Rusty Rozzelle, Mecklenburg County Craig Miller, City of Charlotte Compliance Inspection Report Permit: NCG050352 Effective: 08/18/06 Expiration: 04/30/08 SOC: Effective: Expiration: County: Mecklenburg Region: Mooresville Contact Person: Mike Frausto Title: Directions to Facility:. 1-85 N-Brookshire left to Hoovis Road. Left to Tarheel Road. System Classifications: Primary ORC: Certification Secondary ORC(s): On -Site Representative(s): Related Permits: Owner: Mauser Corp Facility: Mauser Corp 1209 Tarheel Rd Charlotte NC 28208 Phone: 704-398-2325 Phone: Inspection Date: 03/31/2008 Entry Time: 09:50 AM Exit Time: 12:00 PM Primary Inspector: Water Uuality Program Mecklenburg County Phone: Secondary lnspector(s): Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Apparel/Printing/Paper/Leather/Rubber Stormwater Discharge COC Facility Status: ❑ Compliant ■ Not Compliant Question Areas. Storm Water (See attachment summary) Page: 1 Permit: NCC050352 Owner - Facility: Mauser Corp Inspection Date: 03/31/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: Facility Description: The facility uses high -density polyethylene to manufacture plastic drums. The polyethylene pellets are pumped into silos from railroad cars. Production activities are performed inside of buildings and are not exposed to stormwater. Post -production the finished plastic drums are stored in the facility's warehouse until they are loaded into trailers for transport. Compliance History: I he permittee/facility does not have any prior compliance Issues with either the NC Division of Water Quality or Charlotte -Mecklenburg Storm Water Services. Industrial Operations/City of Charlotte Stormwater Ordinance Review: Abandoned Industrial Equipment - During the inspection an empty tank was observed on the ground. The facility should explore options to promptly dispose of abandoned industrial equipment. Used Oil Area - The facility stores used oil outdoors in totes that are covered with wood pallets. The used oil totes and pallets are exposed to stormwater. Oil staining was observed at the base of the totes. The facility should explore options to avoid contact of stormwater with used oil. Permit and Outfalls (cont.) The inspectors observed two stormwater outfalls and one piped stormwater drainage system for which the stormwater outfail could not be observed. The inspectors noted that the piped stormwater drainage system was filled with sediment and debris. The permittee is required by Section A item #4 to develop and implement a preventative maintenance program which includes the removal of sediment from storm drainage structures, Page: 2 Permit: NCG050352 Owner -Facility: Mauser Corp Inspection Date: 03/31/2008 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 outfall locations and drainage areas? ■ ❑ n n # Does the Plan include a list of significant spills occurring during the past 3 years? ❑ ■ ❑ Cl 4 1 Itis the facility evaluated fe&,ible alternatives lu current praclices? ■ ❑ ❑ ❑ # Does the facility provide all necessary secondary containment? ■ U U U # 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? ❑ ■ ❑ Cl # Does the Plan include a list of Responsible Party(s)? ■ ❑ ❑ ❑ # Is the Plan reviewed and updated annually? ❑ ■ ❑ ❑ # Does the Plan include a Stormwater Facility Inspection Program? ■ ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? ❑ ■ ❑ ❑ Comment: The permittee has developed a Stormwater Pollution Prevention Plan but it was last updated in February 2006. The permittee Ilas not developed or implemented parts of the SPPP as required by the permit including a narrative description of practices, a list of significant spills in the last three years, br annual employee training. Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ❑ ■ ❑ ❑ Comment: The permittee provided the inspector with documentation of qualitative monitoring conducted on March 10, 2008. No other documentation was provided to the inspector regarding the permit requirement to conduct semi-annual qualitative monitoring. An�tical Monitoring . Yes No NA NE Has the facility conducted its Analytical monitoring? n n ■ ❑ # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? n ❑ ■ ❑ Comment: The permittee does not perform vehicle maintenance on site and is therefore is not required to conduct analytical monitoring. Permit and Outfalis Yes No NA NE Page: 3 Permit: NCGO50352 Owner -Facility: Mauser Corp Inspection Date: 03/31/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine # Is a copy of the Permit and the Certificate of Coverage available at the site? 0 ■ 0 D # Were all outfalls observed during the inspection? ■nnn # If the facility has representative outfali status, is it properly documented by the Division? n ■ ❑ Q # Has the facility evaluated all illicit {non stormwater} discharges? e ❑ Q Q Comment: The permittee did not have a copy of the stormwater permit and individual Certificate of Coverage available on site. The permittee has evaluated its stormwater outfalls for the presence of non-stormwater discharges. However, the name of the person who conducted the evaluation and date on which the evaluation was performed was not documented. The permittee has identified five stormwater outfalls in the Stormwater Pollution Prevention Plan. However, it was discovered during the inspection that two of the identified stormwater outfalls were actually storm drain inlets that connected to stormwater outfalls and did not need to be qualitatively monitored. Please update your SPPP accordingly. Please see the Summary section of the inspection report for additional information regarding the Permit and Outfalls. Page: 4 I k•�v�wy yyyyyrrrrrAAAAA����� � .. . ' iii"`"'"'"'����---•����PPPP'"'�1111�.r.i t. 'f"'.k w k 6 v0i Ara o�CC' r .�_- t..�4, i ��..LJW ..-..... G�4 1 ,.i....�✓.Y .!�,�} ..-. i�3� ...31A l� V�jjj;qq (1 ,/� i i 11 f_ _ e IPA I I U4. va N Q6...� ci r'vwra , i jfd _... ....-__...._ 1 ....i . �NL�. 1 h Y"Y!•e ON! G Y,lJ E 3n"1 A ... rEiipp f ` ty . .�S�w� 1..,�i �... _ _1•.{,..�.b.. i ��..�. i .. �1�..11.._�.�.. ��Y ���..ttr`l� :...__... _... .. _....... ... ....... �.k ��f,.. ".'1„+,,,,1 f i.. �. ... ...._... :vni ! .1.4. .: � � �-^..3.i 3}�.�-'S Ljf� �x�. fki 4/..F_..�_. .9. i_X•. � i f 4 V a L �3t: S L Y , pp : 4 t :f .4 r March 24, 2009 Mr. Charles Brooks, Corporate Quality Manager Mauser Corporation 1209 Tar Neel Road Charlotte, NO 28208 Subject: Follow-up Compliance Evaluation Inspection Mauser Corporation Stormwater Permit Number COC NCG050352 Mecklenburg County, NC Dear Mr. Brooks: Enclosed is a copy of the Follow-up Compliance Evaluation Inspection (CEI) report for the inspection conducted at the subject facility on September 22, 2008, by Ms. Aliyah Turner of Charlotte - Mecklenburg Storm Water Services. This inspection was conducted as part of a cooperative working agreement between Mecklenburg County and the Division of Water Quality. In addition, the inspection was conducted on behalf of the City of Charlotte in compliance with the City's NPDES Permit, NCS000240, Part it Section H. Thank you for your assistance and cooperation during the follow-up inspection. The follow-up inspection found that Mauser Corporation has implemented the corrective actions as stated in the subject facility's response letter dated June 11, 2008 and the follow-up information provided on December 8, 2008. The corrective actions included: • Movement of used oil storage and abandoned industrial equipment indoors within the manufacturing building, • Removal of sediment and debris from the storm drain inlet, • Updating the Stormwater Pollution Prevention Plan including the site map for the Mauser Corporation facility. The enclosed follow-up inspection report should be self-explanatory; however should you have any questions concerning this report or have any questions regarding your permit, please do not hesitate to contact Ms. Allocco of this Office at (704) 663-1699. Sincerely, for Robert B. Krebs Regional Supervisor Surface Water Protection Section Mooresville Regional Office Enclosure cc: NPS-ACO Unit Rusty Rozzelle, Mecklenburg County Craig Miller, City of Charlotte Mr. Mike Frausto, Mauser Corporation Compliance Inspection Report Permit: NCGO50352 Effective: 08/18/06 Expiration: 04/30/08 SOC; Effective: Expiration: County: Mecklenburg Region: Mooresville -Contact Person: Mike Frausto Title: Directions to Facility: 1-85 N-Brookshire left to Hoovis Road. Left to Tarheel Road. System Classifications: Primary ORC: Certification: Secondary ORC(s): On -Site Representative(s): Related Permits: Owner: Mauser Corp Facility: Mauser Corp 1209 Tarheel Rd Charlotte NC 28208 Phone: 704-398-2325 Phone: Inspection Date: 03/31/2008 Entry Time: 09:50 AM Exit Time: 12:00 PM Primary Inspector: Water Quality Program Mecklenburg County Phone: Secondary Inspector(s); Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Apparel/Printing/Paper/Leather/Rubber Stormwater Discharge COC Facility Status: ❑ Compliant ® Not Compliant Question Areas: ® Storm Water (See attachment summary) Page: 1 Permit: NCG050352 Owner -Facility: Mauser Corp Inspection Date: 03/31/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: Facility Description: The facility uses high -density polyethylene to manufacture plastic drums. The polyethylene pellets are pumped into silos from railroad cars. Production activities are performed inside of buildings and are not exposed to stormwater. Post -production the finished plastic drums are stored in the facility's warehouse until they are loaded into trailers for transport. Compliance History: The permittee/facility does not have any prior compliance issues with either the NC Division of Water Quality or Charlotte -Mecklenburg Storm Water Services. Industrial Operations/City of Charlotte Stormwater Ordinance Review: Abandoned Industrial Equipment - During the Inspection an empty tank was observed on the ground. The facility should explore options to promptly dispose of abandoned industrial equipment. Used Oil Area - The facility stores used oil outdoors in totes that are covered with wood pallets. The used oil totes and pallets are exposed to stormwater. Oil staining was observed at the base of the totes. The facility should explore options to avoid contact of stormwater with used oil. Permit and Outfalls (cont.) The inspectors observed two stormwater outfails and one piped stormwater drainage system for which the stormwater outfall could not be observed. The inspectors noted that the piped stormwater drainage system was filled with sediment and debris. The permittee is required by Section A item #4 to develop and implement a preventative maintenance program which includes the removal of sediment from storm drainage structures. Page: 2 Permit: NOG050352 Owner -Facility: Mauser Corp Inspection Date: 03/31/2008 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? ®❑ Q 0 # Does the Plan include a "Narrative Description of Practices"? 0 W i] ❑ # Does the Plan include a detailed site map including outfall locations and drainage areas? ®❑ 0 f_I # Does the Plan include a list of significant spills occurring during the past 3 years? Q E 0 Q # Has the facility evaluated feasible alternatives to current practices? ®❑ ❑ # Does the facility provide all necessary secondary containment? ®❑ 0 n # Does the Plan include a BMP summary? ® 0 El 11 # Does the Plan include a Spill Prevention and Response Plan (SPRP)? ' ®❑ Q El # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ®❑ ❑ n # Does the facility provide and document Employee Training? ❑ ®Q n # Does the Plan include a list of Responsible Party(s)? ®❑ 0 n # Is the Plan reviewed and updated annually? ❑ a 0 0 # Does the Plan include a Stormwater Facility Inspection Program? ®❑ (] Q Has the Stormwater Pollution Prevention Plan been implemented? ❑ m 0 0 Comment: The permittee has developed a Stormwater Pollution Prevention Plan but it was last updated in February 2006. The permittee has not developed or implemented parts of the SPPP as required by the permit including a narrative description of practices, a list of significant spills in the last three years, or annual employee training, Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ❑ ® Q n Comment: The permittee provided the inspector with documentation of qualitative monitoring conducted on March 10, 2008. No other documentation was provided to the inspector regarding the permit requirement to conduct semi-annual qualitative monitoring. 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? ❑ ❑ ® L Comment: The permittee does not perform vehicle maintenance on site and is therefore is not required to conduct analytical monitoring. Permit and Outfalls Yes No NA NE Page: 3 Permit: NCGO50362 Owner -Facility: Mauser Corp Inspection Date: 03/31/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine # 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 outfail status, is it properly documented by the Division? # Has the facility evaluated all illicit (non stormwater) discharges? Comment: The permittee did not have a copy of the stormwater permit and individual Certificate of Coverage available on situ. The permittee has evaluated its stor mwater outfalls for the presence of non-stormwater discharges. However, the name of the person who conducted the evaluation and date on which the evaluation was performed was not documented. The permittee has identified five stormwater outfalls in the Stormwater Pollution Prevention Plan. However, it was discovered during the inspection that two of the identified stormwater outfalls were actually storm drain inlets that connected to stormwater outfalls and did not need to be qualitatively monitored. Please update your SPPP accordingly. Please see the Summary section of the inspection report for additional information regarding the Permit and Outfalls. Page: 4 Permit: NCG050352 SOC: County: Mecklenburg Region: Mooresville Compliance Inspection Report Effective: 06/01/08 Expiration: 05/31/13 Owner: Mauser Corp Effective: Expiration: Facility: Mauser Corp 1209 Tarheel Rd Contact Person; Mike Frausto Title: Directions to Facility: 1-85 N-Brookshire left to Hoovis Road. Left to Tarheel Road. System Classifications; Primary ORC: Certification: Secondary ORC(s): On -Site Representative(s): Related Permits: Charlotte NC 28208 Phone: 704-398-2325 Phone: Inspection Date: 09/22/2008 Entry Tine: 11:45 AM Exit Time: 12:00 PM Primary Inspector: Water Quality Program Mecklenburg County Phone: Secondary Inspector(s): Reason for Inspection: Follow-up Inspection Type: Compliance Evaluation Permit Inspection Type: Apparel/Printing/Paper/Leather/Rubber Stormwater Discharge COC Facility Status: ® Compliant ❑ Not Compliant Question Areas: ® Storm Water (See attachment summary) Page: 1 Permit: NCG050352 Owner -Facility: Mauser Corp Inspection Date: 09/22/2008 Inspection Type: Compliance Evaluation Reason for Visit: Follow-up Inspection Summary: Facility Description: The facility uses high -density polyethylene to manufacture plastic drums. The polyethylene pellets are pumped Into silos from railroad cars. Production activities are performed inside of buildings and are not exposed to stormwater. Post -production the finished plastic drums are stored in the facility's warehouse until they are loaded into trailers for transport. Compliance History: Ms. Allyah Turner and Mr. Roii Eubanks of Ctar lotte-Mecklenburg Sturm Water Services (CMSWS) inspeoted Mauser Corporation on March 31, 2008. The Division of Water Quality issued a Notice of Violation for the inspection on May 2, 2008. Industrial Operations/City of Charlotte Stormwater Ordinance Review: A stormwater inspection Of Mauser Corporation by Ms. Aliyah Turner and Mr. Ron Eubanks of Charlotte -Mecklenburg Storm Water Services (CMSWS) conducted on March 31, 2008, found several housekeeping issues. The permittee stores used oil outdoors in totes that were covered with wood pallets. The used oil totes and pallets are exposed to stormwater. Oil staining was observed on the ground at the base of the totes. Also an abandoned tank was observed outdoors during the on -site inspection. A follow-up inspection of the Mauser Corporation facility conduoted on Soptombor 22, 2008, by ME. Aliyah Turnor of CMSWS found that the permittee has ceased the storage of used oil outdoors, The permittee holds used oil in a containment pit inside the manufacturing building. The permittee contracts with Safety Clean Inc. to siphon and dispose of the used oil from the containment pit. Page: 2 Permit: NOG050352 Owner -Facility: Mauser Corp Inspection Date: 09/22/2008 Inspection Type: Compliance Evaluation Reason for Visit: Follow-up Stormwater Pollution Prevention Plan Yes No NA NE Does the site have a Stormwater Pollution Prevention Plan? ■ ❑ Cl ❑ # Does the Plan include a General Location (USGS) map? ■ Cl ❑ ❑ # Does the Plan include a "Narrative Description of Practices"? ■ ❑ Cl ❑ # Does the Plan include a detailed site map including outfall locations and drainage areas? ■ ❑ ❑ ❑ # Duns liio Plaii InQlude a list of slgnlnuanl spills uccurring during llie puss 3 years? ■ ❑ ❑ ❑ # Has the facility evaluated feasible alternatives to current practices? ■ ❑ ❑ ❑ # Does the facility provide all necessary secondary containment? ■ ❑ ❑ Q # 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? ®❑ 0,11 # 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? ®❑ 011 # Does the Plan include a Stormwater Facility Inspection Program? ■ ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? ■ ❑ ❑ ❑ Comment: A stormwater inspection of the facility conducted by Ms. Aliyah Turner and Mr. Ron Eubanks of CMSWS on March 31, 2008 revealed the permittee had developed an SPPP but it was last updated in February 2006. The permittee had not developed or implemented parts of the SPPP as required by the permit including a narrative description of practices, a list of significant spills in the last three years, and annual employee training documentation. Also, the permittee needed to develop accurate site maps of the facility.Ms. Aliyah Turner received an updated copy of the facility's SPPP on September 16, 2008, and a copy of the facility's updated site map on December 8, 2008. Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ®❑ ❑ ❑ Comment: A stormwater inspection conducted by Ms. Aliyah Turner and Mr. Ron Eubanks of CMSWS on March 31, 2008, revealed that the permittee performed qualitative monitoring activities on March 10, 2008. No other documentation was provided regarding the permit requirement to conduct semi-annual qualitative monitoring during the inspection.Post inspection, the permittee provided documentation of qualitative monitoring activities conducted on April 5, 2008, and September 10, 2008. These records were included in the facility's updated SPPP. Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? ❑ ❑ ■ ❑ Page: 3 Permit: NGG050352 Inspection Date: 09/22/2008 Owner -Facility: Mauser Corp Inspection Type: Compliance Evaluation # Has the facility conducted its Analytical monitoring from Vohiclo Maintenance areas? Comment: The permittee does not perform vehicle maintenance on site therefore analytical monitoring is not required. Permit and Outfalls # is a copy of the Permit and the Certificate of Coverage available at the site? # Were all outfalls observed during the inspection? # If the facility has representative uulfall status, is it properly documented by the Division? # Has the facility evaluated all illicit (non stormwater) discharges? Reason for Visit: Follow-up Comment: A stormwater inspection oonduetod by MG. Aliyah Turner and Mr. Ron Eubanks of CMSWS on March 31, 2008, revealed that the permittee did not have a copy of the stormwater permit and Certificate of Coverage available on site. The facility's non-stormwater discharge documentation did not include a signature and date of the person that conducted the evaluation. Finally, of the facility's five documented outfalls it was found that three of the outfalls were actually storm drain inlets. It was recommended that the SIP PP be updated to reflect these changes. The follow up inspection conducted by Ms. Aliyah Turner of CMSWS on September 22, 2008, found that the facility has obtained a copy of the stormwater permit and Certificate of Coverage. These records were available on site.As of December 8, 2008, the Mauser Corporation has completed all components of the general storm water permit NCGO5000 and the site specific Stormwater Pollution Prevention Plan. I30®n Yes No NA NE 0nnn ®nnn 0000 M 0 0 0 Page: 4 W AT, oOF 9'q Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources C� C Coleen H. Sullins, Director Division of Water Quality July 17, 2008 Charles Brooks Mauser Corp 685 Rt 202-206 Bridgewater, NJ 08807 Subject: NPDES Stormwater Permit Coverage Renewal Mauser Corp COC Number NCG050352 MecklenburgCounty Dear Permittee: In response to your renewal application for continued coverage under stormwater General Permit NCG050000 the Division of Wator Quality (DWQ) ie forwarding horowith the reisouod stormwater Cenorraal r ermit. This permit is reissued pursuaiit to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between the state of North Carolina and the U.S. Environmental Protection Agency, dated October 15, 2007 (or as subsequently amended.) The following information is included with your permit package: • A new Certificate of Coverage • A copy of stormwater General Permit N00050000 • A copy of a Technical Bulletin for the General Permit • Five copies of the Discharge Monitoring Report (DMR) Form • Five copies of the Qualitative Monitoring Report Form The General Permit authorizes discharges of stormwater only, and it specifies your obligations with respect to stormwater discharge controls, management, monitoring, and record keeping. Please review the new permit to familiarize yourself with all the changes in the reissued permit. The more significant changes in the General Permit since the your last Certificate of Coverage include the following: • Permit cover page — Coverage is expanded to include industrial activities similar to the categorically identified industries. • Part I Section A — This part explains that the No Exposure Exclusion from permitting option may be available to the permittee. • Part II Section A — Several minor expansions and clarifications of the required content of the Stormwater Pollution Prevention Plan have been added. Please be sure that your plan is updated to comply with the new requirements. • Part II Section B — Qualitative monitoring must now be conducted during a representative storm event. • Part II Section B — The permittee is required to keep a written record of his response to problems identified by his qualitative monitoring observations. • Part 11 Section C - For facilities with vehicle maintenance activities using more than 55 gallons of new motor oil per month, new provisions require that discharges from the vehicle maintenance areas be sampled twice per year, and that the sampling results be compared to new numerical benchmark values. (The previous cutoff concentrations have been eliminated.) • Part II Section C — For facilities with vehicle maintenance activities using more than 55 gallons of new motor oil per month, new provisions require the permittee to execute Tier One and Tier Two response actions, based on the first benchmark exceedence (Tier One) and the second consecutive benchmark exceedence (Tier Two). Tier Two requires that the permittee institute monthly monitoring instead of twice -per -year monitoring, until three consecutive monitoring events show no benchmark exceedences. • Part II Section C — This part contains a new provision that four exceedences of any particular benchmark will trigger increased DWQ involvement in the permittee's stormwater management and control actions. DWQ may direct the permittee to apply for an individual permit, or may direct the implementation or installation of specific stormwater control measures. Nor thCarolina Naturally North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone (919) 733-7015 Customer Service Internet: h2o.enr.state.nc.us/su/stormwater.html 512 N. Salisbury St. Raleigh, NC 27604 FAX (919) 733-9612 1-877-623-6748 An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper Your coverage under the General Permit is transferable only through the specific action of DWQ. This permit does not affect the legal requirements to obtain other permits which may be required by DENR, nor does it relieve the permittee from responsibility for compliance with any other applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or decree. If you have any questions regarding this permit package please contact Bill Diuguidof the DWQ Stormwater Permitting Unit at (919) 807-6369. Sincerely, for Coleen H. Sullins cc: DWQ Central Files Stormwater Permitting Unit Files MooresvilleRegional Office STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY GENERAL PERMIT NO. NCG050000 CERTIFICATE OF COVERAGE No. NCG050352 STORMWATER DISCHARGES NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Cornrnissiuri, and the Federal Water Pollution Control Act, as amended, Mauser Corp is hereby authorized to discharge stormwater from a facility located at Mauser Corp 1209 Tarheel Rd Charlotte MecklenburgCounty to receiving waters designated as Paw Creek, a class C in the Catawba River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III, IV, V, and VI of General Permit No. NCG050000 as attached. This certificate of coverage shall become effective July 17, 2008. This Certificate of Coverage shall remain in effect for the duration of the General Permit. Signed this day July 17, 2008. for Coleen H. Sullins, Director Division of Water Quality By Authority of the Environmental Management Commission 0� \\VWNV A I Michael F. Easley, Governor William G. Ross Jr., Secret North Carolina Department of Environment and Natural Resources Coleen H. Sullins, Director Division of Water Quality May 2, 2008 Mr. Mike Frausto, Plant Manager Mauser Corporation 1209 Tar Heel Road Charlotte, North Carolina 28208 Subject: Notice of Violation Tracking Number: NOV-2008-PC-0316 Compliance Evaluation Inspection Mauser Corporation Stormwater Permit Number COC NCG(Y50352 Mecklenburg County, NC Dear Mr. Frausto: Enclosed is a copy of the Compliance Evaluation Inspection (CEI) report for the inspection conducted at the subject facility on March 28, 2008, by Ms. Aliyah Turner and Mr. Ron Eubanks of Charlotte -Mecklenburg Storm Water Services. This inspection was conducted as part of a cooperative working agreement between Mecklenburg County and the Division of Water Quality. In addition, the inspection was conducted on behalf of the City of Charlotte in compliance with ' the City's NPDES Permit, NCS000240, Part II Section H. Thank you for your assistance and cooperation during the inspection. The inspection found that Mauser Corporation has developed and partially implemented a Stormwater program and this Office commends the permittee's efforts to ensure compliance with your NPDES permit. However, this report is being issued as a Notice of Violation (NOV) due to the permittee's failure to perform semi-annual qualitative monitoring in violation of the subject Stormwater Permit and North Carolina General Statute (G.S.) 143-215. 1, as detailed in the Qualitative Monitoring section of the enclosed report. Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates or fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S. 143-215, 1. It is requested that a written response be submitted to this Office by June 6, 2008, addressing the deficiencies noted in the Stormwater Pollution Prevention Plan and Qualitative Monitoring sections of the enclosed report. In responding to the violations, please address your comments to the attention of Ms. Allocco at the letterhead address. O "A NQMne Carolina MCDENR 11vatu'rallb, Mooresville Regional Office Division of Water Quality Phone 704-663-1699 Customer Service Internet: wwwmcwaterquali ".or- 610 East Center Ave, Suite 301 Mooresville, NC 28115 Fax 704-663-6040 1-877-623-6748 An Equal Opportunity/Affirmative Action Employer — 50% Recycledf10% Post Consumer Paper IN Mr. Mike Frausto, Mauser Corporation NOV-2008-PC-0316, Page 2 May 2, 2008 The enclosed report should be self-explanatory; however should you have any questions concerning this report or have any questions regarding your permit, please do not hesitate to contact Ms. Marcia Allocco of this Office at (704) 663-1699. Sincerely, for Robert B. Krebs Regional Supervisor Surface Water Protection Section Mooresville Regional Office Enclosure cc, NPS-ACO Unit Rusty Rozzelle, Mecklenburg County Craig Miller, City of Charlotte ` Compliance Inspection Report . Permit: wCG050352 Effective: O8/18/08 ExpiraUun:O4/30/0O Owner: Mmuse,Corp sOC: Effective: Expiration: Facility: MwuoorCo/p County: Meuh�nbum 12O8Tophea/Rd ' �� Region: Mooresville CoNadPomnn. MikeFmusto Title: Directions h/Facility: /-85N'BnmkaWmleft mHooviaRoad, Left !nTorhee|Road, System Classifications: PdmoryPRC' C*rhMroVpn: uecondo,yORC(a): . On -Site Representative(s): Related Permits: Charlotte NC2828O Phone: 704-398-2325 Phu^w. Inspection Date; 03/3112008 Entry Time: 08.50AM Exit Time: 12:00PM Primary Inspector: Water UvmlityProgram Mecklenburg County Phone: Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: r/Ruhbo 8tonnwater Discharge Facility Status: [] compliantcompliantE Not Compliant Question Areas: . (See attachment summary) Permit: NCGO50352 Owner - Facility: Mauser Corp Inspection Date: 03/31/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: Facility Description: The facility uses high -density polyethylene to manufacture plastic drums. The polyethylene pellets are pumped into silos from railroad cars. Production activities are performed inside of buildings and are not exposed to stormwater. Post -production the finished plastic drums are stored in the facility's warehouse until they are loaded into trailers for transport. Compliance History. - The parmittoo/facility door, not have any prior compliance iseuea with dither tho NO. Diviryion of Wotor Quality or Charlotte -Mecklenburg Storm Water Services, Industrial Operations/City of Charlotte Stormwater Ordinance Review: Abandoned Industrial Equipment - During the inspection an empty tank was observed on the ground. The facility should explore options to promptly dispose of abandoned industrial equipment. Used Oil Area - The facility stores used oil outdoors in totes that are covered with wood pallets. The used oil totes and pallets are exposed to stormwater. Oil staining was observed at the base of the totes. The facility should explore options to avoid contact of stormwater with used oil. Permit and Outfalls (cont.) The inspectors observed two stormwater outfalls and one piped stormwater drainage system for which the stormwater outfall could not be observed. The inspectors noted that the piped stormwater drainage system was filled with sediment and debris. The permittee is required by Section A item #4 to develop and implement a preventative maintenance program which includes the removal of sediment from storm drainage structures. Page: 2 Permit: NCGO50352 owner - Facility: Mauser Corp Inspection mate: 03/31/2008 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? E Ej n f"l # Does the Plan include a General Location (USGS) map? M n ❑ ❑ # Does the Plan include a "Narrative Description of Practices"? ❑ E ❑ n # Does the Plan include a detailed site map including outfali locations and drainage areas? 0 n 0 ❑ # noes the Plan include a list of significant spills occurring during the past 3 years? n ❑ ❑ # Has the facility evaluated feav_ik)le alternativoy to ourront practioos? n n n # Does the facility provide all necessary secondary containment? Cl n n # Does the Plan include a BMP summary? Cl f 1 n # Does the Plan include a Spill Prevention and Response Plan (SPRP)? M n n # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? 0 n ❑ # Does the facility provide and document Employee Training? nin ❑ ❑ # Does the Plan include a list of Responsible Party(s)? is Cl 0 Cl # Is the Plan reviewed and updated annually? ❑ 11 n ❑ # Does the Plan include a Stormwater Facility Inspection Program? 0 n ❑ n Has the Stormwater Pollution Prevention Plan been implemented? ❑ E n n Comment: The permittee has developed a Stormwater Pollution Prevention Plan but it was last updated in February 2006. The permittee has not developed or implemented parts of the SPPP as required by the permit including a narrative description of practices, a list of significant spills in the last three years, or annual employee training. Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ❑ ❑ n Comment: The permittee provided the inspector with documentation of qualitative monitoring conducted on March 10, 2008. No other documentation was provided to the inspector regarding the permit requirement to conduct semi-annual qualitative monitoring. ,analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? n n IN n # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ?� ❑ ❑ Comment: The permittee does not perform vehicle maintenance on site and is therefore is not required to conduct analytical monitoring, Permit and ©utfalls Yes No NA NE Page:3 Permit: NCG050352 Owner • Facifity: Mauser Corp Inspection Date: 03/31/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine # Is a copy of the Permit and the Certificate of Coverage available at the site? 0 M 0 n # Were all outfalls observed during the inspection? M C! Q 0 # If the facility has representative outfali status, is it properly documented by the Division? n 0 n n # Has the facility evaluated all illicit (non stormwater) discharges? M 0 n ❑ Comment: The permittee did not have a copy of the stormwater permit and individual Certificate of Coverage available on site. The periTtittee has evaluated its stormwater outfalls for the presence of non-stormwater discharges. However, the name of the person who conducted the evaluation and date on which the evaluation was performed was not documented. The permittee has identified five stormwater outfalls in the Stormwater Pollution Prevention Plan. However, it was discovered during the inspection that two of the identified stormwater outfalls were actually stottrl drain itilets that c:onrtected to stormwater outfalls and did not need to be qualitatively monitored. Please update your SPPP accordingly. Please see the Summary section of the inspection report for additional information regarding the Permit and Outfalls. Page: 4 f 1209 Tar Heel Road ff Charlotte, North Ca - Ms. Marcia Allocco Division of Water Quality 610 East Center Ave, Suite 301 Mooresville, NC 28115 I NC DENR MRO Subject: Notice of Violation Compliance Evaluation Inspection Mauser Corp, Stormwater Permit No,, COC NCGO50362 Mecklenburg County, NC This is the written response requested in your letter dated May 2, 2008. Your letter outlined that Mauser failed to perform sernkannual qualitative monftoring in violation of its Stormwater Permit and North Carolina Oeneral 'Sitatute (G.S.) 143-215, 1. Mauser had a management change and the qualitative monitoring requirements had not been communicated to the new management team, Mauser had conducted qualitative monitoring prior to the arrival of the new management team. To prevent fLftre occurrences, we have put together a scheduled program to alert all Mauser plants, completed. This program will be monitored by the corporate office, at least twice annually, Sh ou Id vo u have anv is u �mYA na or n —*tiO Ili i Wrer ewifla ta b o;Imr asp uit7ft-4- Sincerely, Charles Brooks Corporate Quality Manager 404-915-8028