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HomeMy WebLinkAboutWQ0006060_Compliance Evaluation Inspection_20180618Water Resources Environmental Quality June 18, 2018 Mr. Bob Churchill via Email Safety and Environmental Manager Gerdau Ameristeel US, Inc. Post Office Box 481980 Charlotte, North Carolina 28269 ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Interim Director Subject: Non -Discharge Permit Inspection Wastewater Recycle System - Permit No.: WQ0006060 Gerdau AmeriSteel US, Inc. — Charlotte Steel Mill Mecklenburg County, N.C. Dear Mr. Churchill: Mooresville Regional Office (MRO) staff conducted a compliance inspection on June 13, 2018 at the referenced facility. The recycle systems appeared sufficiently maintained and operational at the time of inspection. Please note, the permit expiration date is May 31, 2020. A renewal application is due no later than six months prior to expiration, by December 31, 2019. For you convenience, an application form will be emailed along with this report, but is also available via our web -site at: https://deg.nc.gov/about/divisions/water-resources/water-resources- permits/wastewater-branch/non-discharge-permitting-unit/application. Select form "NDSR" (Non -Discharge System Renewal). The MRO would like to thank you and your staff for your time during the site visit. The attached report should be self-explanatory; however, you may contact Maria Schutte by phone (704-235-2184) or email (maria.schutte(a_)_ncdenr.gov) with questions. Sincerely, DocuSigned by: (� A14 C681AF 7425.. W. orey asinger, Supervisor Mooresville Regional Office Water Quality Regional Operations Section Division of Water Resources, NCDEQ Attachment(s): WQ0019504 Inspection Report State of North Carolina I Environmental Quality I Water Resources I Water Quality Regional Operations Mooresville Regional Office 1 610 East Center Avenue, Suite 3011 Mooresville, North Carolina 28115 704 663 1699 State of North Carolina Department of Environmental Quality Division of Water Resources Roy Cooper, Governor Michael S. Regan, Secretary Linda Culpepper, Interim Director NON -DISCHARGE COMPLIANCE INSPECTION Recycle/Reuse/Reclamation System GENERAL INFORMATION City/Town/Owner: Gerdau Ameristeel USA, Inc. County: Mecklenburg Permit No.: WQ0006060 Project Name: Charlotte Steel Mill Issuance Date: 06/30/2015 Expiration Date: 05/31/2020 Permittee: Rodrigo Canova (VP &GMS Phone: 704-596-0361 Email: rodrigo.canovaggerdau.com Facility Contact: Bob Churchill (S&EM) Cell #: 865-388-4373 Email: bob. churchill(a)gerdau.com Reason for Inspection X ROUTINE COMPLAINT FOLLOW-UP OTHER Type of Inspection Collection System Spray Irrigation Sludge X Other Inspection Date(s): June 13, 2018 Inspection Summary: (additional comments may be included on attached pales) This site visit included an inspection of the closed loop cooling systems, groundwater leachate and remediation systems and a records review. The MRO met with Bob Churchill and additional Gerdau staff. Records are well organized and documentation of internal inspections improved. All systems appeared to be maintained in accordance with permit requirements, at the time of inspection. • The permit renewal is due by December 31st, 2019 as noted in the cover letter. • The MRO should be informed of any changes to the contact information noted above. Is a follow-up inspection necessary? yes, X no Inspector Name/Title: Maria Schutte, Environmental Specialist 1 Telephone No.: 704-663-1699 Fax No. 704-663-6040 Date of Inspection: 06/13/2018 Non -Discharge Permit Inspection Page 2 WQ0006060 Gerdau-Charlotte — Recycle System Treatment Y Are treatment facilities consistent with those outlined in the current permit. Y Do all treatment units appear to be operational? If no, note below. Comment: Oil skimmers at the recycled water basins require constant maintenance. There was no visual evidence of surface oil at either location, at the time of inspection. Residuals Per previous inspection reports, this facility makes an effort to find reuse for all materials coming from their process. The mill scale is periodically removed from the basins and sold to other businesses for its high Iron Ore content. Residuals from the oil/water separator are hauled off-site for proper disposal by Safety-Kleen. Recordkeeping Y Is permit available upon request? Y Are operational logs present? Y Complete? Y Is the operation and maintenance manual present? Complete? N Has DWQ received any complaints regarding the facility in the last 12 months? Comment: System inspection logs have been improved. Other noted conditions Water from the Soil Vapor Extraction system recovery wells is plumbed to the Mill Pond for use as recycle water. This is not a typical arrangement for an SVE system; however, the recycle pond appears well mixed, is equipped with an oil water separator and does not discharge to land or surface water. This information is noted for future reference as there is no effluent sampling requirement as is typical with most SVE systems. In addition, Mr. Churchill discussed potential closure of the SVE system and removal of the recovery wells from this permit, to be addressed at renewal. Permit: WQ0006060 SOC: County: Mecklenburg Region: Mooresville Contact Person: Bob Churchill Compliance Inspection Report Effective: 06/01/15 Expiration: 05/31/20 owner: Gerdau Ameristeel US Inc Effective: Expiration: Facility: Charlotte Steel Mill 6601 Lakeview Rd Title: Charlotte NC 28269 Phone: 704-596-0361 Ext.3128 Directions to Facility: From Charlotte, take State Highway 115 North past the Brockenbrough Airport approximately 2 miles. Turn left onto Lakeview Road. The facility is the first property on your right. System Classifications: Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 06/13/2018 Entry Time: 10:02AM Primary Inspector: Maria Schutte Secondary Inspector(s): Reason for Inspection: Routine Permit Inspection Type: Closed -Loop Recycle Facility Status: Compliant ❑ Not Compliant Question Areas: 0 Miscellaneous Questions Record Keeping (See attachment summary) DS _ C,5 6/18/2018 Exit Time: 11:52AM Phone: 704-663-1699 Inspection Type: Compliance Evaluation 0 Storage Page: 1 Permit: WQ0006060 Owner - Facility: Gerdau Ameristeel US Inc Inspection Date: 06/13/2018 Inspection Type : Compliance Evaluation Reason for Visit: Routine Inspection Summary: This site visit included an inspection of the closed loop cooling systems, groundwater leachate and remediation systems and a records review. The MRO met with Bob Churchill and additional Gerdau staff. Records are well organized and documentation of internal inspections improved. All systems appeared to be maintainted in accordance with permit requirements, at the time of inspection. • The permit renewal is due by December 31st, 2019 as noted in the cover letter. • The MRO should be informed of any changes to the contact information. Additonal Comments: Oil skimmers at the recycled water basins require constant maintenance. There was no visual evidence of surface oil at either location, at the time of inspection. Per previous inspection reports, this facility makes an effort to find reuse for all materials coming from their process. The mill scale is periodically removed from the basins and sold to other businesses for its high Iron Ore content. Residuals from the oil/water separator are hauled off-site for proper disposal by Safety-Kleen. Water from the Soil Vapor Extraction system recovery wells is plumbed to the Mill Pond for use as recycle water. This is not a typical arrangement for an SVE system; however, the recycle pond appears well mixed, is equipped with an oil water separator and does not discharge to land or surface water. This information is noted for future reference as there is no effluent sampling requirement as is typical with most SVE systems. In addition, Mr. Churchill discussed potential closure of the SVE system and removal of the recovery wells from this permit, to be addressed at renewal. Page: 2 Permit: WQ0006060 Owner - Facility: Gerdau Ameristeel US Inc Inspection Date: 06/13/2018 Inspection Type : Compliance Evaluation Reason for Visit: Routine Type Yes No NA NE Activated Sludge Spray, LR ❑ Activated Sludge Spray, HR ❑ Single Family Spray, LR ❑ Reuse (Quality) ❑ Activated Sludge Drip, LR ❑ Infiltration System ❑ Single Family Drip ❑ Lagoon Spray, LR ❑ Recycle/Reuse Record Keeping Yes No NA NE Is a copy of current permit available? 0 ❑ ❑ ❑ Are monitoring reports present: NDMR? ❑ ❑ 0 ❑ NDAR? ❑ ❑ 0 ❑ Are flow rates less than of permitted flow? ❑ ❑ 0 ❑ Are flow rates less than of permitted flow? ❑ ❑ 0 ❑ Are application rates adhered to? ❑ ❑ 0 ❑ Is GW monitoring being conducted, if required (GW -59s submitted)? ❑ ❑ 0 ❑ Are all samples analyzed for all required parameters? ❑ ❑ 0 ❑ Are there any 2L GW quality violations? ❑ ❑ 0 ❑ Is GW -59A certification form completed for facility? ❑ ❑ 0 ❑ Is effluent sampled for same parameters as GW? ❑ ❑ 0 ❑ Do effluent concentrations exceed GW standards? ❑ ❑ 0 ❑ Are annual soil reports available? ❑ ❑ 0 ❑ # Are PAN records required? ❑ ❑ 0 ❑ # Did last soil report indicate a need for lime? ❑ ❑ 0 ❑ If so, has it been applied? ❑ ❑ 0 ❑ Are operational logs present? ❑ ❑ ❑ Are lab sheets available for review? ❑ ❑ ❑ Do lab sheets support data reported on NDMR? ❑ ❑ ❑ Do lab sheets support data reported on GW -59s? ❑ ❑ ❑ Are Operational and Maintenance records present? ❑ ❑ ❑ Were Operational and Maintenance records complete? ❑ ❑ ❑ Has permittee been free of public complaints in last 12 months? ❑ ❑ ❑ Is a copy of the SOC readily available? ❑ ❑ 0 ❑ Page: 3 Permit: WQ0006060 Owner - Facility: Gerdau Ameristeel US Inc Inspection Date: 06/13/2018 Inspection Type : Compliance Evaluation Reason for Visit: Routine No treatment units bypassed since last inspection? Comment: This is a closed loop recycle system for industrial process cooling water. ❑■❑❑ Page: 4