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HomeMy WebLinkAboutNC0031038_Compliance Evaluation Inspection_20200303ROY COOPER Governor MICHAEL S. REGAN Secretary S. DANIEL SMITH Director Jeff Titus, Manager Operations Colonial Pipeline Company PO Box 87 Paw Creek, North Carolina 28130 Dear Mr. Titus: NORTH CAROLINA Environmental Quality 3 March 2020 Subject: Compliance Evaluation Inspection Colonial Pipeline Company Charlotte Delivery Facility NPDES Permit No. NCO031038 Mecklenburg County Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the subject facility on February 25, 2020, by Mr. Wes Bell of this Office. Please inform the facility's Operator -in -Responsible Charge (ORC) of our findings by forwarding a copy of the enclosed report. The report should be self-explanatory; however, should you have any questions concerning this report, please do not hesitate to contact Mr. Bell at (704) 235-2192 or at wes.belIgncdenr.gov. Sincerely, DocuSigned by: A14CCti81 AF27425... W. Corey Basinger, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, DEQ Enclosure: Inspection Report �� Office Carolina Department of Environmental Quality I Division of Water Resources Mooresville Regional 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115 NOR7H ORROLINA i kmrlaam m EnNromi Wuwi\ /`� 704.663.1699 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 15 I 3 I NC0031038 111 12 I 20/02/25 I17 18 I S I 19 I G I 201 I 211111 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 f6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved ------------------- 67 2.0 70 71 [.. I 72 73 L_LJ74 751 I I I I I I I80 u u 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) 09:20AM 20/02/25 16/03/01 Charlotte Delivery Facility 7524 Kenstead Cir Exit Time/Date Permit Expiration Date Paw Creek NC 28130 12:OOPM 20/02/25 20/06/30 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data John W. Culbreath/ORC/704-399-5259/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Jeff Titus,PO Box 87 Paw Creek NC 281300087/Manager Operations/704-399-8266/ No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Flow Measurement Operations & Maintenance Records/Reports Self -Monitoring Program 0 Facility Site Review Effluent/Receiving Waters 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 DocuSigned by: 3/3/2020 Wes Bell DWR/MRO WQ/704-663-1699 Ext.2192/ �Piy �e& A:c,96D90=437... Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date W. Corey Basinger DWR/Division of Water Quality/704-235-2194/ EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. DocuAASigned by: A14CC681AF27425... 3/3/2020 Page# NPDES yr/mo/day Inspection Type NCO031038 I11 121 20/02/25 117 18 JCJ Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) RECORD KEEPING SECTION cont'd: A "0" MGD flow was reported (for all outfalls except 010) on the days that flow was not measured. The flow column must be left blank if no flow measurements were performed for that day. In addition, the flow values reported on the eDMR for Outfall 007 in December 2019 (18th and 23rd) and Outfall 010 in November 2019 (7th, 12th, 18th, 23rd and 29th) and December 2019 (12th) will need to be revised. Page# Permit: NCO031038 Owner - Facility: Charlotte Delivery Facility Inspection Date: 02/25/2020 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: The Division had received the facilitv's Dermit renewal aDDlication Dackaae on 12/27/19. The last compliance evaluation inspection at the facility was performed by Charlotte -Mecklenburg Stormwater Services/Water Quality Program staff on 9/7/17. 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 ❑ ❑ 0 ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: Overall. the site arounds were well maintained. The facilitv is staffed 24/7 with the entire site being inspected on a daily basis (once per 12-hour shift). The free product in the oil/water separator (manifold area/Outfall 010) is removed by a contracted company (Legacy Environmental) and disposed at Heritage -Crustal Clean in Concord, N.C. The ground between the secondary containment structures for Outfalls 007 and 009 was significantly disturbed due to the ongoing cleanup efforts to address a pipeline leakage (petroleum) that occurred in late December 2018. Approximately 8,000-9,000 tons of soil have been removed to date. The disturbed areas of soil and associated remediation activities have contributed to the turbidity and TSS limit violations reported at Outfalls 007 and 009. Silt fencing has been installed and facility staff are investigating the usage of chemical addition and filtration to address the turbidity and TSS issues at these outfalls. 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 Page# 3 Permit: NCO031038 Owner - Facility: Charlotte Delivery Facility Inspection Date: 02/25/2020 Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Are DMRs complete: do they include all permit parameters? 0 ❑ ❑ ❑ 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: The records reviewed durina the inspection were oraanized and well maintained. Discharae Monitoring Reports (eDMRs) were reviewed for the period January 2019 through December 2019. All monitoring frequencies were correct. Daily maximum effluent turbidity violations were reported in November 2019 (Outfalls 007 and 009) and December 2019 (Outfalls 007, 008 and 009). A daily maximum effluent TSS violation was also reported in December 2019 (Outfall 007). Monthly average effluent TSS violations were reported in December 2019 for Outfalls 007 and 009. The Division has previously addressed these limit violations through the issuances of either a NOV or NOV/civil penalty assessment. See "Summary" Section for additonal comments. Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? ❑ ❑ 0 ❑ Are all other parameters(excluding field parameters) performed by a certified lab? 0 ❑ ❑ ❑ # Is the facility using a contract lab? 0 ❑ ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees ❑ ❑ 0 ❑ 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: Waypoint Analytical, LLC has been contracted to perform all effluent analyses except toxicity. ETT Environmental performs the toxicity tests. Effluent Sampling Yes No NA NE Is composite sampling flow proportional? ❑ ❑ 0 ❑ Is sample collected below all treatment units? 0 ❑ ❑ ❑ Is proper volume collected? 0 ❑ ❑ ❑ Is the tubing clean? ❑ ❑ 0 ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees ❑ ❑ 0 ❑ Celsius)? Page# 4 Permit: NCO031038 Owner - Facility: Charlotte Delivery Facility Inspection Date: 02/25/2020 Inspection Type: Compliance Evaluation Effluent Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type 0 ❑ ❑ ❑ representative)? Comment: The subject permit requires effluent grab samples. 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: The flows for all outfalls are based on the Rational Eauation criteria (area of drainaae area total rainfall, etc.). 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? ❑ ❑ 0 ❑ Comment: The effluent beina discharaed from Outfall 010 appeared sliahtiv turbid with no Detroleum sheens or odors. The remaining outfalls were not discharging at the time of the inspection; however, the accumulated stormwater inside the secondary containment structures for Outfalls 007 and 009 was significantly turbid due to the disturbed soil/runoff from the ongoing remediation activities. Page# 5