NCG510543_NOV-2018-PC-0209_20180626

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ROY COOPER
Governor
MICHAEL S.REGAN
Secretary
Water Resources LINDA CULPEPPER
Environmental Quality Interim Director
June 26, 2018
CERTIFIED MAIL#7016 3560 0000 4428 3290
RETURN RECEIPT REQUESTED
Mr. Brandon Moore
Paragon Environmental Consultants, Inc. RECEIVED/DENRIDWR
P.O. Box 157
Thomasville,NC 27361-0157 JUL 10 2018
Water Resources
Subject: Compliance Evaluation Inspection Permitting Section
Notice of Violation
NOV-2018-PC-0209
Allen's Exxon GW Remediation System
NPDES Certificate of Coverage NCG510543
Orange County
Dear Mr.Moore,
Jeremiah Dow of the Raleigh Regional Office conducted a compliance evaluation inspection of the above
referenced facility on June 20,2018. The assistance of Mr. Ben Robinson was appreciated. Please find
the attached Basin Wide Information Management System(BIMS) inspection checklist summarizing the
inspection.
During the inspection,the following items and permit violations were noted:
1. The subject Certificate of Coverage(COC)under General Permit NCG510000 was issued and
became effective December 12, 2014 and will expire September 30,2020.
2. The facility is authorized to operate and discharge water(<0.05 MGD)from a groundwater
remediation system for"combined gasoline and diesel fuel, aviation fuel,kerosene, or fuel oil
contaminated groundwater." The discharge flows to an ephemeral channel and into a pond that is
part of an unnamed tributary to Cane Creek(WS-V;NSW).
3. The facility consists of the following units: Five (5)groundwater recovery wells, a four(4)tray
air stripper rated at 25 gpm with an air-to-water ratio of 12:1,two (2)bag filters rated for 100
gpm,two (2)carbon adsorption drums rated at 20 gpm, each 200 lbs., effluent discharge line with
flow meter, and a discharge outfall.
4. Recovery wells 1, 3, and 4 were operating at the time of the inspection with recovery wells 2 and
—5 being-inactive due to-a reduction in the size of the contaminant plume. All other treatment units
were operating. The area around the effluent pipe was free of solids.
- Notl�in Compares_ •�._
State of North Carolina I Environmental Quality I Water Resources I Raleigh Regional Office
1628 Mail service Center I Raleigh,North Carolina 27699-1628
919 791-4200

5. The effluent observed at the sampling port upon startup of the pumps was slightly turbid
and contained a petroleum odor believed to be a result of carbon adsorption tanks and/or
bag filters in need of maintenance or replacement. Mr. Robinson indicated that the effluent is
typically clear and free of odor, and that he intended to replace one(or both) of the carbon
adsorption drums and check the bag filters upon receiving approval from the UST section to
perform system maintenance for this quarter. He believes that this will resolve the issue of turbid,
odorous effluent at startup.
This is a violation of Part II, Section C, Condition 2 of General Permit NCG510000,"The
permittee shall at all times properly operate and maintain all facilities and systems of
treatment and control(and related appurtenances)which are installed or used by the
Permittee to achieve compliance with the conditions of this permit."
6. A review of laboratory results indicates that all parameters are being monitored and analyzed
according to the permit.
The TSS effluent limit is 30.0 mg/L. On May 26, 2017 the effluent had a TSS value of 74 mg/L
which Mr. Robinson indicated was caused by a failure of Recovery Well 4,which has since been
repaired. On February 27,2018 an effluent TSS value of 40 mg/L was documented. The
February 27 exceedance is believed to be a result of the carbon adsorption tanks requiring
maintenance and/or replacement.
This is a violation of Part II, Section C, Condition 2 detailed above and Part 1,Table A.(3)
which establishes a TSS daily maximum limit of 30.0 mg/L.
The lead limit is 25 µg/1, and on August 31,2017 a lead value of 67 µg/1 was returned by the
laboratory(Meritech,Inc.). Mr.Robinson contacted Meritech and was told that the value was a
result of laboratory error. An additional lead sample was collected the following month and was
below the method detection limit.
7. The only field parameter collected at the site is pH, and when questioned,Mr. Robinson was
unsure of the frequency or method of meter calibration. Please ensure that meters are
calibrated properly ad on a regular schedule. We highly recommend that you maintain a
log for meter calibration.
Requested Response:
You are requested to address the below items in writing within 30 days of receipt of this letter.
1. Please explain the steps you will undertake to ensure that the facility is properly operated and
maintained to achieve compliance with your NPDES permit, and prevent turbid, odorous effluent
from discharging as detailed in Item 5 above. Please note that maintenance of treatment systems
associated with your NPDES permit are not conditional on receipt of payment/approval from the
UST Trust Fund. Treatment units must be maintained at all times.
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2. Explain how you will prevent continuing exceedances of your TSS daily maximum limit of 30.0
mg/L as detailed in Item 6 above.
3. Please submit to this office quarterly lab results for a minimum of two (2)consecutive quarters
beginning with the next sampling event. If additional permit limit exceedances occur,then
additional lab results may be requested.
4. Field parameter pH–Please detail in your written response: 1) how you are ensuring pH is
properly collected using US EPA standard methods, 2)the pH meter is properly calibrated, and 3)
the data is collected at the appropriate frequency, in keeping with the NPDES permit.
This office requires that the violations,as detailed above,be abated immediately and properly
resolved. Environmental damage and violations of North Carolina Administrative Codes have been
documented for the subject site as stated above. Your efforts to undertake activities to bring the subject
site back into compliance is not an admission, rather it is an action that must be taken in order to begin to
resolve ongoing'environmental issues.
These violations and any future violations are subject to a civil penalty assessment of up to $25,000.00
per day for each violation. Your response to this letter will be considered with any Enforcement
Action recommendation or Civil Penalty Assessment. Should you have any questions regarding these
matters,please contact Jeremiah Dow at(919)791-4248 or via email at jeremi [e-mail].
Sincerely,
—
Danny Smith
Water Quality Regional Operations
Raleigh Regional Office
Attachment: Inspection Report
cc: Charles Weaver
RRO File
Mark Powers,Regional Supervisor,Underground Storage Tanks Section
;-.,. 1$4;144
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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(l e,PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 1J 2 u 3 I NCG510543 111 12 I 18/06/20 117 18 1,.I 19 I S I 20 11
211111 1 1 1 1 1 1II 1 I 1 1 1 1 1 1 1 1 1 1 1 1 I 1 1 1 I 1 1 1 111 1 l I I 1166
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA -------------Reserved----------
671 1 70I I 71 1 1 72i 1 731 I 174 7511 1 1 1 1 1 1 180
Section B Facility Data L-1
Name and Location of Facility Inspected(For Industrial Users discharging to POTW,also include Entry Time/Date • Permit Effective Date
POTW name and NPDES permit Number) 09 51AM 18/06/20 16/10/13
Allen's Exxon remediation site
5402 NC Hwy 54 W Exit Time/Date Permit Expiration Date
Chapel Hill NC 275167506 12 52PM 18/06/20 20/09/30
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
Brandon Moore,P0 Box 157 Thomasville NC 273610157//336-669-6037/3366696037
No
Section C Areas Evaluated During Inspection(Check only those areas evaluated)
Permit Records/Reports Self-Monitoring Program 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
Jeremiah J Dow RRO WQ//919-791-4248/
7 ignatulie of Managements ° -ev ewer ger—ncy/Office/Phone and Fax Numbers Date r
EPA Form 356A-3(Rev 9-94)Previous editions are obsolete
Page# 1

NPDES yr/mo/day Inspection Type 1
31 NCG510543 I11 121 18/06/20 17 18 LI
Section D Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
Page# 2

Permit. NCG510543 Owner-Facility Allen's Exxon remediation site
Inspection Date. 06/20/2018 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 ® 0
application'?
Is the facility as described in the permit'? ® 0 0 0
#Are there any special conditions for the permit'? ❑ •? 0 0
Is access to the plant site restricted to the general public'? 0 0 0
Is the inspector granted access to all areas for inspection'? - 0 0 0
Comment
Effluent Pipe Yes No NA NE
Is right of way to the outfall properly maintained'? 0 0 0
Are the receiving water free of foam other than trace amounts and other debris'? 0 0 0
If effluent (diffuser pipes are required) are they operating properly'? 0 0 ® ❑
Comment Effluent pipe not discharging at time of observation. No solids or soil discoloration observed
at discharge. Effluent was observed at sampling port and was slightly turbid with a
petroleum odor. Mr. Robinson indicated that the turbidity/odor was likely caused by the
system sitting idle and allowing sediment to settle Typically effluent is clear and odor free
The carbon adsorption tank(s) may need replaced.
Record Keeping Yes No NA NE
Are records kept and maintained as required by the permit'? Di 0 0 0
Is all required information readily available,complete and current'? • 0 0 0
Are all records maintained for 3 years(lab. reg. required 5 years)? El 0 ❑ 0
Are analytical results consistent with data reported on DMRs? 0 0 ❑
Is the chain-of-custody complete'? ❑ ❑ 0
Dates,times and location of sampling
Name of individual performing the sampling El
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete do they include all permit parameters'? 0 0 0 ❑
Has the facility submitted its annual compliance report to users and DWQ'? 0 0 0
(If the facility is=or>5 MGD permitted flow) Do they operate 24/7 with a certified operator 0 0 El ❑
on each shift?
Is the ORC visitation log available and current'? ❑ 0 El 0
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N
Permit. NCG510543 • Owner-Facility: Allen's Exxon remediation site
Inspection Date: 06/20/2018 Inspection Type: Compliance Evaluation
Record Keeping ' Yes No NA NE
Is the ORC certified at grade equal to or higher than the facility classification? El ❑ ❑
Is the backup operator certified at one grade less or greater than the facility classification? 0 0 ® ❑
Is a copy of the current NPDES permit available on site? • 0 0 0
Facility has copy of previous year's Annual Report on file for review? 0 0 ❑
Comment. There are sample collection and analysis requirements and effluent limitations for the site.
However, DMRs are not required to be submitted. There have been two TSS exceedances.
One was a result of a recovery well failure which has been addressed, and on is believed to
be a result of needed maintenance to carbon adsorption system
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional? 0 0 WE El
Is sample collected below all treatment units? ER 0 0 0
Is proper volume collected? 0 0 0
Is the tubing clean? ❑ ❑ E ❑
#Is proper temperature set for sample storage(kept at less than or equal to 6 0 degrees 0 0 ❑
Celsius)?
Is the facility sampling performed as required by the permit(frequency,sampling type 0 0 0
representative)?
Comment' Grab samples are collected quarterly. Flow is measured continuously with an in-line flow
meter and the value recorded monthly
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