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HomeMy WebLinkAboutWQ0005809_Recission Staff Report_20220104Land Application Monitor Well Repairs Colonial Pipeline Company — Greensboro Junction Greensboro, Guilford County, North Carolina S&ME Project No. 216623 1 2 Location / Orientation MW-1 Photographer: G. Simcox Remarks Repaired Well with Lock and Cap. N O N M N N Photographer: G. Simcox Location / Orientation MW-2 Remarks Repaired Well with Lock and Cap. Land Application Monitor Well Repairs Colonial Pipeline Company — Greensboro Junction Greensboro, Guilford County, North Carolina S&ME Project No. 216623 3 4 Location / Orientation MW-3 Photographer: G. Simcox Remarks Repaired Well with Lock and Cap. N O N M N N Photographer: G. Simcox Location / Orientation MW-4 Remarks Repaired Well with Lock and Cap. Land Application Monitor Well Repairs Colonial Pipeline Company — Greensboro Junction Greensboro, Guilford County, North Carolina S&ME Project No. 216623 5 6 Location / Orientation MW-5 Photographer: G. Simcox Remarks Repaired Well with Lock and Cap. Location / Orientation MW-6 N O N M N N Photographer: G. Simcox Remarks Repaired Well with Lock and Cap. Land Application Monitor Well Repairs Colonial Pipeline Company — Greensboro Junction Greensboro, Guilford County, North Carolina S&ME Project No. 216623 7 8 NON.POT ward Location / Orientation MW-7 Photographer: G. Simcox Remarks Repaired Well with Lock and Cap. Location / Orientation MW-9 N O rn N N Photographer: G. Simcox Remarks Repaired Well with Lock and Cap. Land Application Monitor Well Repairs Colonial Pipeline Company — Greensboro Junction Greensboro, Guilford County, North Carolina S&ME Project No. 216623 9 Location / Orientation MW-183 Photographer: G. Simcox Remarks Repaired Well with Lock and Cap. Compliance Inspection Report Permit: WQ0005809 Effective: 07/27/17 SOC: Effective: County: Guilford Region: Winston-Salem Contact Person: John M Wyatt Directions to Facility: System Classifications: LA, Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: NCG510210 WQ0006317 0031046AC NC0031046 Expiration: 06/30/22 Expiration: Title: Colonial Pipeline Company - Colonial Pipeline Company - Colonial Pipeline Company - Colonial Pipeline Company - Certification: Colonial Pipeline Colonial Pipeline Colonial Pipeline Colonial Pipeline Inspection Date: 11/03/2021 Entry Time 10:03AM Primary Inspector: Caitlin Caudle Secondary Inspector(s): Reason for Inspection: Routine Owner : Colonial Pipeline Company Facility: Colonial Pipeline Company RLAP 411 Gallimore Dairy Rd Greensboro NC 27409 Phone: 423-713-7568 Phone: - Greensboro Junction WWTF - Greensboro Junction WWTF - Greensboro Junction WWTF - Greensboro Junction WWTF Exit Time: 10:54AM Phone: 336-776-9699 Inspection Type: Compliance Evaluation Permit Inspection Type: Land Application of Residual Solids (503 Exempt) Facility Status: Question Areas: Compliant ❑ Not Compliant ▪ Miscellaneous Questions Record Keeping ▪ Wells (See attachment summary) Land Application Site Page 1 of 4 Permit: WQ0005809 Owner - Facility: Colonial Pipeline Company Inspection Date: 11/03/2021 Inspection Type : Compliance Evaluation Reason for Visit: Routine Inspection Summary: On November 3, 2021, Division of Water Resources staff person Caitlin Caudle performed a scheduled compliance inspection for the purpose of reviewing the facility after a permit recission request. Maribeth Hughes of Colonial Pipeline was present during the entire inspection. A review of available records, the application site, and four of the five monitoring wells was completed. The residuals generated at this facility are sludges removed from the gas and oil tanks as they are cleaned and repaired every 10 years. Ms. Hughes stated that only a few barrels of material are removed when the tanks are cleaned out. Land application at this facility has not occurred since 2014, as a result no residuals analysis has been conducted in the form of nutrient analysis or TCLP, and no soil analysis has been completed. In 2014 1,557.72 dry tons were generated, and land applied on the four fields permitted at this facility. Seven tanks were reportedly emptied in 2014. Ms. Hughes stated that all residuals generated when tanks are cleaned will be managed by a hazardous waste company. There are no residuals generating equipment or storage areas that need to be decommissioned. Of the four monitoring wells reviewed, all were found to be noncompliant with the subject permit. Monitoring wells 3 and 4 are unique to the land application permit. Monitoring wells 1, 3, and 6 did not have a cap. A plastic jug had been placed over the well casings with a metal clamp keeping it in place. All four monitoring wells did not have a clear label marking the well number. This is a violation of 15A NCAC 02C .0108(1) and 15A NCAC 02C .0108(p)(6) which require locking well caps to ensure against unauthorized access and use, and a clear label of the well identification number or name. Please replace the metal caps on the well casings, as needed, and clear labels before the permit can be rescinded. Ms. Hughes inquired what will happen to the monitoring well 3 and 4 after the RLAP permit is rescinded. Page 2 of 4 Permit: WQ0005809 Owner - Facility: Colonial Pipeline Company Inspection Date: 11/03/2021 Inspection Type : Compliance Evaluation Reason for Visit: Routine Type Distribution and Marketing Land Application Record Keeping Is GW monitoring being conducted, if required? Are GW samples from all MWs sampled for all required parameters? Are there any GW quality violations? Is GW-59A certification form completed for facility? Is a copy of current permit on -site? Are current metals and nutrient analysis available? Are nutrient and metal loading calculating most limiting parameters? a. TCLP analysis? b. SSFA (Standard Soil Fertility Analysis)? Are PAN balances being maintained? Are PAN balances within permit limits? Has land application equipment been calibrated? Are there pH records for alkaline stabilization? Are there pH records for the land application site? Are nutrient/crop removal practices in place? Do lab sheets support data reported on Residual Analysis Summary? Are hauling records available? Are hauling records maintained and up-to-date? # Has permittee been free of public complaints in last 12 months? Has application occurred during Seasonal Restriction window? Comment: Applicaiton has not occurred since 2018. There monitoring wells. Land Application Site Is a copy of the permit on -site during application events? Is the application site in overall good condition? Is the site free of runoff/ponding? If present, is the application equipment in good operating condition? Are buffers being maintained? Are limiting slopes buffered? 10% for surface application 18% for subsurface application Yes No NA NE • Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ • ❑ ❑ ❑ ❑ ❑•❑ have been past exceedences in pH for all Yes No NA NE • ❑ ❑ ❑ ❑ ❑ • ❑ Page 3 of 4 Permit: WQ0005809 Owner - Facility: Colonial Pipeline Company Inspection Date: 11/03/2021 Inspection Type : Compliance Evaluation Reason for Visit: Routine Are there access restrictions and/or signs? Is the application site free of odors or vectors? Have performance requirements for application method been met? For injection? For incorporation? Does permit require monitoring wells? Have required MWs been installed? Are MWs properly located w/ respect to RB and CB? Are MWs properly constructed (including screened interval)? Is the surrounding area served by public water? If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted? Are soil types consistent w/ Soil Scientist report/evaluation? Is the water table greater than 1'/3' bls. Is application occurring at the time of the inspection? Comment: No application has occurred since 2014. ❑ ❑ • ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ • Page 4 of 4 DWR Division of Water Resources State of North Carolina Department of Environmental Quality Division of Water Resources WATER QUALITY REGIONAL OPERATIONS SECTION NON -DISCHARGE PERMIT RESCISSION REQUEST FORM October 6, 2021 To: WSRO-WQROS: Lon Snider / Jenny Graznak From: Nathaniel D. Thornburg, Water Quality Permitting Section - Non -Discharge Branch Permit Number: WQ0005809 Permittee: Colonial Pipeline Company Facility Name: Colonial Pipeline Company RLAP Comments: Please see the attached rescission request. Permit Type: Land Application of Residual Solids (503 Exempt) Date Rescission Requested: October 5, 2021 Date of Last Inspection: August 8, 2018 Please complete this form and return to the Central Office within 30 days of receipt. ® Site visit performed. ® Permit rescission approved. ❑ Permit rescission denied. Comments: A site visit was completed. Inspection report is attached. MWs have been repaired and photos provided. Photos are attached. Pleftoecigspection report for additional comments. WQROS Reviewer: C,AAtubL (AAA. �8B834968199D49D... Date: 1/4/2022 FORM: WQROSNDPRR 08-17 Page 1 of 1