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Home My WebLink AboutNCG500267_Compliance Evaluation Inspection_20191219ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Director NORTH CAROLINA EhWbW enta!Quaffty December 19, 2019 CERTIFIED MAIL # 7015-1450-0001-6450-0788 RETURN RECIPT REQUESTED Mr. William G. Pleasant Cobble Creek Lumber 225 Hice Ave West Jefferson, NC 28694 SUBJECT: Notice of Violation NOV-2019-PC-0777 Compliance Evaluation Inspection Cobble Creek Lumber NPDES Permit No. NCG500267 Ashe County Dear Mr. Pleasant, On December 18, 2019, Kelli Park and Paul DiMatteo of this office, met with Mike Best to perform a Compliance Evaluation Inspection at Cobble Creek Lumber. This type of inspection consists of two basic parts: an in -office file review and an on -site inspection of the treatment facility. The attached EPA inspection form details the areas that were evaluated during this inspection. Miss Park and Mr. DiMatteo found the following violations during the inspection: 1) Insufficient effluent monitoring has been done. Effluent was only tested in February 2019 for chemical oxygen demand, pH, and total residual solids (not a permit requirement). Per permit requirements there must also be a record of effluent temperature, total residual chlorine, oil/grease, and a flow estimate. Additionally, chemical oxygen demand, pH, temperature, total residual chlorine, oil/grease, and a flow estimate must be tested semi- annually, and there was no record of a second analysis for the 2019 year. Please perform a full analysis immediately. 2) There was no chain of custody attached to the February data sheet. Please ensure that chain of custodies are kept on file with all analytical results. These issues represent deficiencies and violations of the facility's NPDES permit. Thus, this letter is being sent to you as a Notice of Violation. Please reply in writing to this letter within 10 calendar days of receiving it. Your written reply should address each of the noted violations/deficiencies and provide a corrective action plan along with an implementation/completion schedule to remediate them. A review of your response will be considered along with any additional information provided. Please be aware that violations of your NPDES permit, or the NC statutes and regulations under which it is promulgated, are subject to fines of up to $25,000 per day, per violation, as set forth in NC General Statute (NCGS) 143-215.6A, Enforcement Procedures, Civil Penalties. If we do NOT receive your written reply within 10 calendar days of your receipt of this notice, we may draft an enforcement case for the noted deficiencies/violations. If you have any questions regarding the inspection or this report, please contact Kelli Park or me at (336) 776-9800 or by email at kelli.park(a-)_ncdenr.gov or Ion.snider(a-)_ncdenr.gov. Sincerely, EDocuSigned by: L uti T SMder 145B49E225C94EA... Lon Snider Regional Supervisor Water Quality Regional Operations Division of Water Resources Attachments: EPA Water Compliance Inspection Report cc: WSRO Page 2 of 2 United States Environmental Protection Agency Form Approved. EPA Washington, D.C. 20460 OMB No. 2040-0057 Water Compliance Inspection Report Approval expires 8-31-98 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 1 IN I 2 15 I 3 I NCG500267 111 12 I 19/12/19 I17 18 I S J 19 L G] 201 I 211111 1 1 I I I I II I I I I I I I I I I I I 1 I I I I I I I I I I II I I I I I f6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved ------------------- 671 70 I I 71 I I 72 I r I 73 I I 174 751 I I I I I I I80 u ty I I i Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date POTW name and NPDES oermit Number) 11:30AM 19/12/19 15/11/24 Cobble Creek Lumber 225 Hice Ave Exit Time/Date Permit Expiration Date West Jefferson NC 28694 12:OOPM 19/12/19 20/07/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Contacted David M Blair,PO Box 760 Wilkesboro NC 28697//336-838-1751/3368382287 No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Records/Reports Self -Monitoring Program 0 Facility Site Review Effluent/Receiving Waters Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date Kelli A Park DocuSigned by: DWR/WSRO WQ/336-776-9689/ Paul DiMatteo Ess, PA4 DWR/WSRO WQ/336-776-9691/ 12/20/2019 eanalDCE74C34139_. by:Agency/Office/Phone and Fax Numbers Date Signature of Management Q A R rieQ?cuSigned �ti ? S"je, 12/19/2019 145B49E225C94EA... EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type (Cont.) NCG500267 I11 121 19/12/19 117 18 JCJ Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) On December 18, 2019, Kelli Park and Paul DiMatteo of this office, met with Mike Best to perform a Compliance Evaluation Inspection at Cobble Creek Lumber. This type of inspection consists of two basic parts: an in -office file review and an on -site inspection of the treatment facility. The attached EPA inspection form details the areas that were evaluated during this inspection. Miss Park and Mr. DiMatteo found the following violations during the inspection: 1) Insufficient effluent monitoring has been done. Effluent was only tested in February 2019 for chemical oxygen demand, pH, and total residual solids (not a permit requirement). Per permit requirements there must also be a record of effluent temperature, total residual chlorine, oil/grease, and a flow estimate. Additionally, chemical oxygen demand, pH, temperature, total residual chlorine, oil/grease, and a flow estimate must be tested semi-annually, and there was no record of a second analysis for the 2019 year. Please perform a full analysis immediately. 2) There was no chain of custody attached to the February data sheet. Please ensure that chain of custodies are kept on file with all analytical results. These issues represent deficiencies and violations of the facility's NPDES permit. Thus, this letter is being sent to you as a Notice of Violation. Please reply in writing to this letter within 10 calendar days of receiving it. Your written reply should address each of the noted violations/deficiencies and provide a corrective action plan along with an implementation/completion schedule to remediate them. A review of your response will be considered along with any additional information provided. Please be aware that violations of your NPDES permit, or the NC statutes and regulations under which it is promulgated, are subject to fines of up to $25,000 per day, per violation, as set forth in NC General Statute (NCGS) 143-215.6A, Enforcement Procedures, Civil Penalties. If we do NOT receive your written reply within 10 calendar days of your receipt of this notice, we may draft an enforcement case for the noted deficiencies/violations. If you have any questions regarding the inspection or this report, please contact Kelli Park or me at (336) 776-9800 or by email at kelli.park@ncdenr.gov or lon.snider@ncdenr.gov Additional findings: 1) Miss Park was told that the current boiler that is online will be replaced by a newer boiler placed uphill in a different location. This new boiler will perform most of the work, and the old boiler will be used only a couple times a year. Please let Miss Park know when construction begins, and when it is completed. Please keep in mind that you must be able to get samples from your boiler blowdown effluent before it reaches the storm drain or stream to remain compliant with the permit. 2) It is suggested that on days where additives are added to the blowdown that the amount of each additive is recorded. Page# Permit: NCG500267 Inspection Date: 12/19/2019 Owner - Facility: Cobble Creek Lumber Inspection Type: Compliance Evaluation 3) Currently the blowdown effluent falls onto the floor under the boiler, and flows outside of the building and then into a storm drain. It is suggested that a more efficient way for the blowdown to reach the storm drain is created so there is less likelihood of the effluent picking up unknown contaminants before entering the stream. Page# Permit: NCG500267 Owner - Facility: Cobble Creek Lumber Inspection Date: 12/19/2019 Inspection Type: Compliance Evaluation Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new ❑ ❑ 0 ❑ application? Is the facility as described in the permit? 0 ❑ ❑ ❑ # Are there any special conditions for the permit? ❑ 0 ❑ ❑ Is access to the plant site restricted to the general public? 0 ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? 0 ❑ ❑ ❑ Comment: Miss Park was told that the current boiler that is online will be reDlaced by a newer boiler placed uphill in a different location. This new boiler will perform most of the work, and the old boiler will be used only a couple times a year. Please let Miss Park know when construction begins, and when it is completed. Please keep in mind that you must be able to get samples from your boiler blowdown effluent before it reaches the storm drain or stream to remain compliant with the permit. Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? 0 ❑ ❑ ❑ Is all required information readily available, complete and current? 0 ❑ ❑ ❑ Are all records maintained for 3 years (lab. reg. required 5 years)? 0 ❑ ❑ ❑ Are analytical results consistent with data reported on DMRs? ❑ ❑ 0 ❑ Is the chain -of -custody complete? ❑ 0 ❑ ❑ Dates, times and location of sampling ❑ Name of individual performing the sampling ❑ Results of analysis and calibration ❑ Dates of analysis ❑ Name of person performing analyses ❑ Transported COCs ❑ Are DMRs complete: do they include all permit parameters? ❑ ❑ ❑ Has the facility submitted its annual compliance report to users and DWQ? ❑ ❑ ❑ (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator ❑ ❑ ❑ on each shift? Is the ORC visitation log available and current? ❑ ❑ 0 ❑ Is the ORC certified at grade equal to or higher than the facility classification? ❑ ❑ 0 ❑ Is the backup operator certified at one grade less or greater than the facility classification? ❑ ❑ 0 ❑ Is a copy of the current NPDES permit available on site? ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review? ❑ ❑ ❑ Page# 4 Permit: NCG500267 Inspection Date: 12/19/2019 Record Keeping Owner - Facility: Cobble Creek Lumber Inspection Type: Compliance Evaluation Yes No NA NE Comment: There were no COCs for the lab analyses that were done. Please ensure that chain of custodies are kept on file with all analytical results. It is suggested that on days where additives are added to the blowdown that the amount of each additive is recorded. Effluent Sampling Yes No NA NE Is composite sampling flow proportional? ❑ ❑ 0 ❑ Is sample collected below all treatment units? 0 ❑ ❑ ❑ Is proper volume collected? ❑ ❑ ❑ Is the tubing clean? ❑ ❑ 0 ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees ❑ ❑ ❑ Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type ❑ 0 ❑ ❑ representative)? Comment: 1) Insufficient effluent monitoring has been done. Effluent was only tested in February 2019 for chemical oxygen demand, PH, and total residual solids (not a permit requirement). Per permit requirements there must also be a record of temperature, total residual chlorine, oil/grease, and a flow estimate. Additionally chemical oxygen demand, PH, temperature, total residual chlorine, oil/grease, and a flow estimate must be tested semi-annually, and there was no record of a second analysis for the 2019 year. Please perform a full analysis immediately. Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? ❑ ❑ 0 ❑ Are the receiving water free of foam other than trace amounts and other debris? 0 ❑ ❑ ❑ If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ M ❑ Comment: Currently the blowdown effluent falls onto the floor under the boiler, and flows outside of the building and then into a storm drain. It is suggested that a more efficient way for the blowdown to reach the storm drain is created so there is less likelihood of the effluent Dickina uD unknown contaminants before enterina the stream. Page# 5