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HomeMy WebLinkAboutNC0071463_CEI_Letter_20230601ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality June 1, 2023 Center Point Terminal Company, LLC Attn: Bill Ransom, Vice President of Terminal Operations 8235 Forsyth Blvd, Ste 400 Saint Louis, MO 63105 SUBJECT: Compliance Evaluation Inspection Greensboro Terminal NPDES Permit #: NCO071463 Guilford County On May 17t'', 2023, Division of Water Resources staff Ron Boone conducted a routine compliance inspection at Center Point's Greensboro Terminal. Russell B. Evans, Operator in Responsible Charge, was present during the inspection. A review of records, data, treatment components, and structures was completed. This inspection reflected compliance with the subject permit. The following items of concern were noted: Prior to the inspection, Central Office personnel observed recent atypical changes in how data was being reported on discharge monitoring reports (DMR) and requested Mr. Boone to review it with Mr. Evans during the inspection. It was determined during the inspection that the previous operator was not reporting the laboratory -reported values correctly on the DMRs. Mr. Boone advised Mr. Evans that results must be reported on the DMR as they are reported by the laboratory, i.e., same units of measure. The unit of measure the laboratory measures and reports with should also match that which is required by the permit. If these conditions are not met, then the method used by the laboratory, or the laboratory itself (if it cannot measure to that degree of preciseness) must be changed. Please refer to Part II, Section D, Paragraph 4, Test Procedures, of the permit. Other observations: 1. All loading rack drainage enters a trench drain that conveys drainage to a sump which then conveys it to an oil/water separator (OWS). 2. OWS effluent is transferred to the onsite wet holding pond under normal conditions. If abnormal conditions occur, i.e. a fuel spill at the rack or if the amount of fuel spilled overwhelms the OWS, any contaminated effluent would flow to the wet holding pond and the pond would have to be cleaned up. 3. Once the wet holding pond level reaches or nears its maximum level, operators assess the condition of its contents and determine if the pond should discharge. Wet holding pond contents are manually released via a normally locked -closed gate valve to an unnamed tributary to Horsepen Creek, Class WS-III, nutrient sensitive waters in the Cape Fear River Basin. DffNorth Carolina Department of Environmental Quality I Division of Water Resources oan caaouNn Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105 M336.776.9800 oep.m.m or em�nmen� Qualm 4. Flow is calculated using a pre -established factor and based on the amount of time the valve is open. 5. Discharge monitoring reports and laboratory reports for November 2021 and April 2022 were reviewed. No discrepancies other than those noted above under "Items of Concern", were noted. No other items of concern were noted. Please be aware that pursuant to North Carolina general statute (NCGS) 143-215.6A, the Division may assess civil penalties not to exceed $25,000 per day against any person who fails to fully comply with the requirements of a permit issued pursuant to NC General Statute (NCGS) 143-215.1., as is NC0088552. If you have any questions or concerns, please feel free to contact Mr. Boone at any time by phone at 336- 776-9690, or by email at ron.boone@ncdenr.gov. Thank you for your time and attention to this matter. Sincerely, DocuSi?gned by: 945B49E225C94EA... Lon T. Snider, Regional Supervisor Water Quality Regional Operations Section Winston-Salem Regional Office Division of Water Resources, NCDEQ Attachments: Water Compliance Inspection Report REQ� North Carolina Department ofEnvironmental Quality I Division ofWater Resources Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Winston-Salem, North Carolina 27105 NORTH CAROLINA 336.776.9800 naparMeM of EmironmanW 9uallly D North Carolina Department of Environmental Quality I Division of Water Resources ✓ Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Winston-Salem, North Carolina 27105 NORTH CAROLINA 336.776.9800 onparhnem of EmironmanW 9uallly 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 1 2 u 3 I NCO071463 111 121 23/05/17 I17 18 LC] I 19 I s I 20L] 21111I I I I I I I II I I I I I I I I I I I I I I I I I I I I I I I II I I I I I r6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved ------------------- 67 I 72 I ni I 71 I 74 79 I I I I I I I80 701 I 71 I LL -1 I I LJ 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 Dermit Number) 12:OOPM 23/05/17 17/01/01 Greensboro Terminal 6900 W Market St Exit Time/Date Permit Expiration Date Greensboro NC 27409 01:OOPM 23/05/17 21/08/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Russell Brian Evan s/ORC/336-854-8556/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Rusty Evans,6900 W Market St Greensboro NC 27409/Terminal Manager/336-854-8556/ No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Flow Measurement Operations & Maintenar Records/Reports Self -Monitoring Progran 0 Facility Site Review Effluent/Receiving Wate Laboratory 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 Ron Boone DWR/WSRO WQ/336-776-9690/ DocuSigsenee�d by: 6/1/202 3 �Ori.GCG,G�. YJOOfLPi Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date DocuSigned by: 6/1/202 3 &4, F q3q,Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type NCO071463 I11 12I 23/05/17 117 18 i c i (Cont.) Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) On May 17th, 2023, Division of Water Resources staff Ron Boone conducted a routine compliance inspection at Center Point's Greensboro Terminal. Russell B. Evans, Operator in Responsible Charge, was present during the inspection. A review of records, data, treatment components, and structures was completed. This inspection reflected compliance with the subject permit. The following items of concern were noted: 1. Prior to the inspection, Central Office personnel observed recent atypical changes in how data was being reported on discharge monitoring reports (DMR) and requested Mr. Boone to review it with Mr. Evans during the inspection. It was determined during the inspection that the previous operator was not reporting the laboratory -reported values correctly on the DMRs. Mr. Boone advised Mr. Evans that results must be reported on the DMR as they are reported by the laboratory, i.e., same units of measure. The unit of measure the laboratory measures and reports with should also match that which is required by the permit. If these conditions are not met, then the method used by the laboratory, or the laboratory itself (if it cannot measure to that degree of preciseness) must be changed. Please refer to Part II, Section D, Paragraph 4, Test Procedures, of the permit. Other observations: 1. All loading rack drainage enters a trench drain that conveys drainage to a sump which then conveys it to an oil/water separator (OWS). 2. OWS effluent is transferred to the onsite wet holding pond under normal conditions. If abnormal conditions occur, i.e. a fuel spill at the rack or if the amount of fuel spilled overwhelms the OWS, any contaminated effluent would flow to the wet holding pond and the pond would have to be cleaned up. 3. Once the wet holding pond level reaches or nears its maximum level, operators assess the condition of its contents and determine if the pond should discharge. Wet holding pond contents are manually released via a normally locked -closed gate valve to an unnamed tributary to Horsepen Creek, Class WS-III, nutrient sensitive waters in the Cape Fear River Basin. 4. Flow is calculated using a pre -established factor and based on the amount of time the valve is open. 5. Discharge monitoring reports and laboratory reports for November 2021 and April 2022 were reviewed. No discrepancies other than those noted above under "Items of Concern", were noted. No other items of concern were noted. Page# Permit: NCO071463 Owner -Facility: Greensboro Terminal Inspection Date: 05/17/2023 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 ■ ❑ ❑ ❑ application? Is the facility as described in the permit? ■ ❑ ❑ ❑ # Are there any special conditions for the permit? ❑ ■ ❑ ❑ Is access to the plant site restricted to the general public? ■ ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? ■ ❑ ❑ ❑ Comment: None Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? ■ ❑ ❑ ❑ Is all required information readily available, complete and current? ■ ❑ ❑ ❑ Are all records maintained for 3 years (lab. reg. required 5 years)? ■ ❑ ❑ ❑ Are analytical results consistent with data reported on DMRs? ■ ❑ ❑ ❑ Is the chain -of -custody complete? ■ ❑ ❑ ❑ 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? ■ ❑ ❑ ❑ Is the ORC certified at grade equal to or higher than the facility classification? ■ ❑ ❑ ❑ Is the backup operator certified at one grade less or greater than the facility ■ ❑ ❑ ❑ classification? Is a copy of the current NPDES permit available on site? ■ ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review? ❑ ❑ ■ ❑ Comment: No annual report is required. Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? ■ ❑ ❑ ❑ Page# 3 Permit: NCO071463 Owner -Facility: Greensboro Terminal Inspection Date: 05/17/2023 Inspection Type: Compliance Evaluation Laboratory Yes No NA NE Are all other parameters(excluding field parameters) performed by a certified lab? 0 ❑ ❑ ❑ # Is the facility using a contract lab? ■ ❑ ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 ❑ ❑ ❑ degrees Celsius)? Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? ❑ ❑ 0 ❑ Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? ❑ ❑ 0 ❑ Comment: None 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 ❑ ❑ ❑ representative)? Comment: No composite sampling required. Lagoons Yes No NA NE Type of lagoons? # Number of lagoons in operation at time of visit? 2 Are lagoons operated in? Series # Is a re -circulation line present? ❑ 0 ❑ ❑ Is lagoon free of excessive floating materials? 0 ❑ ❑ ❑ # Are baffles between ponds or effluent baffles adjustable? ❑ ❑ 0 ❑ Are dike slopes clear of woody vegetation? 0 ❑ ❑ ❑ Are weeds controlled around the edge of the lagoon? 0 ❑ ❑ ❑ Are dikes free of seepage? 0 ❑ ❑ ❑ Are dikes free of erosion? ■ ❑ ❑ ❑ Are dikes free of burrowing animals? 0 ❑ ❑ ❑ # Has the sludge blanket in the lagoon (s) been measured periodically in multiple ❑ ❑ 0 ❑ locations? # If excessive algae is present, has barley straw been used to help control the growth? ❑ ❑ 0 ❑ Page# 4 Permit: NCO071463 Inspection Date: 05/17/2023 Owner -Facility: Greensboro Terminal Inspection Type: Compliance Evaluation Lagoons Yes No NA NE Is the lagoon surface free of weeds? 0 ❑ ❑ ❑ Is the lagoon free of short circuiting? ❑ ❑ 0 ❑ Comment: These are simply wet storage ponds. Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? ❑ ❑ 0 ❑ Is flow meter calibrated annually? ❑ ❑ 0 ❑ Is the flow meter operational? ❑ ❑ 0 ❑ (If units are separated) Does the chart recorder match the flow meter? ❑ ❑ 0 ❑ Comment: Facilitv has a preestablished factor for calculating flow based on the amount of time the valve is open. 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? ❑ ❑ ■ ❑ If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ ■ ❑ Comment: Discharge goes to an nonobservable underground stormwater vault. Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑ Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: None Page# 5