NC0089087_NOD-2020-PC-0108_20200312

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ROY COOPER
covernor .
MICHAEL S.REGAN
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Secretary *�awsv�•
S.DANIEL SMITH NORTH CAROLINA
Director Environmental Quality
March 12", 2020
Ramon L.Callahan
Ergon Asphalt& Emulsion Inc.
PO Box 1639
Jackson, MS 39215
Subject: Notice of Deficiency NOD-2020-PC-0108
Compliance Evaluation Inspection
Ergon Asphalt& Emulsion
Permit NC0089087
Wilson County
Dear Mr.Callahan:
On Wednesday, March i 1'l',2020,Josh Brigham of the Raleigh Regional Office of the Division of Water
Resources,conducted a compliance evaluation inspection of the subject facility.The purpose of this
inspection was to ensure compliance with the subject permit. During the inspection, the presence and
cooperation of Sean Randall was helpful and appreciated.
This compliance evaluation inspection consisted of the following:
• Review of the permit requirements; .
• Review of lab data, eDMRs and associated documents;
• Review of the owner/facility information;
• And on-site inspection of the facility.
Findin s during the inspection and rile review were as follows:
1. Ergon Asphalt& Emulsion, Inc. is permitted to discharge treated stormwater and related
wastewater runoff(s) into an unnamed tributary to Contentnea Creek in the Neuse River Basin.
The wastewater treatment system consists of the following components: railroad offloading
facilities for liquid asphalt with spill-prevention secondary containment, above ground heated
asphalt storage tanks, a truck-loading rack with spill-prevention secondary containment, a
stormwater retention pond, an 8-inch diameter discharge line with manually operated discharge
valve, an effluent surface-spreader/diffusor, and a sample point that is up gradient of vegetative
filter.
2. A review of eDMRs for 2019 revealed several errors with reporting. Monitoring results were not
reported for the quarters starting in January 2019 and October 2019 despite there being discharge
events. There also appears to be no evidence of Acute WET Toxicity being performed in January
or April. Lab results were present on site,and no discrepancies were found for data that had been
D ��� North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office 3800 Barrett Drive I Raleigh.North Carolina 27609

reported for eDMRs. However,we recommend revising and resubmitting your eDMRs for
2019 to include missing parameters.Since flow measurement is episodic,we also
recommend leaving the No Reporting Reason column blank in the future instead of putting
NOFLOW.
3. Gary Fischer(ORC) and Frederick Ammons(bORC)currently perform pH testing on effluent
during discharge events and transport samples to a certified lab. As stated in Subchapter 08G of
the North Carolina Administrative Code and Statutes,Grade 1 physical/chemical systems
should have weekly visitations by operators(15A NCAC 08G .0204 (2)(h)(i).The operator
should come and view the treatment system at least once a week,even during no discharge.
4. At the time of inspection,the various facility components were found to be well maintained.
5. At the time of inspection,the retention pond and outfall were found to be well maintained.
However,it is recommended that you remove woody vegetation and weeds from the banks
of the pond.
Please respond in writing within the next 30 days as to how you have addressed items 2,3,and 5 or
how you plan to address them.
If you have questions or comments about the inspection,this report, or the requirements to take corrective
action(if applicable), please contact:
Josh Brigham at 919-7914251 or via email at [e-mail].
Sincerely,
icoLuV`inson,Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office, Division of Water Resources,NCDEQ
Attachments: Compliance Inspection Report
Cc: Sean Randall, Facility Manager, Ergon Asphalt& Emulsions, Inc., sean.randallaergon.com
NCDWR Aquatic Toxicology Branch, Cindy Moore
RRO Files
Laserfiche

United Stales Environmental Proledion Agency Form Approved.
EPA Washington,D C 20460 OMB No.2040-0057
Water Compliance Inspection Report Approval expires B-31-98
Section A National Data System Coding(i.e.. PCS)
Transaction Code NPDES yr/mo,day Inspection Type Inspector Fac.Type
1 u 2 Ia 1 3 1 N00089087 I l i 12 20/03111 17 18 I r IJ I 19 I G I 201 I
21 J LJ LJ 6
Inspection Work Days Facility Self-Monitoring Evaluation Rating 81 QA Reserved
67 70I IJ I 71 Lj 72 I Lry I 731 I I74 7 80
Section B- Facility Data J I I J
Name and Location of Facility Inspected(For Industrial Users discharging to POTW,also°nclude Entry Time/Date Permit Effective Date
POTW name and NPDES nermit.Numberl 09.30AM 20/03/11 19/01/01
Ergon Asphalt&Emulsion
2520 Wilco Blvd S Exit rime/Date Permit Expiration Date
Wilson NC 27893 11:30AM 20/03/11 23/12/31
Name(s)of Onsite Representative(5)ti itles(s)lPhone and Fax Number(s) Other Facility Data
u1
Name,Address of Responsible Officialffitle/Phone and Fax Number
Austin Moody,PO Box 23028 Jackson MS 39225302811601-933-352116019333369 Contacted
No
Section C Areas Evaluated During Inspection(Check only those areas evaluated)
Permit E Operations&Maintenar E Records/Reports Self-Monitoring Progran
Facility Site Review N Effluent/Receiving Wate N Laboratory Other
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
Joshua S Brigham DWFURRO WQ1919-79142001
/+2/2ozv
Signature of Management O A Reviewer Agency/OfficelPhone and Fax Numbers Date
311,z/2v 2-0
EPA Form 3560-3(Rev 9-94)Previous editions are obsolete.
Page# I

NPDES yrlmolday Inspection Type (Cont.) 1
31 NC0089087 +11 1 20/03/11 17 18{r•I
Section D;Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
1. Ergon Asphalt& Emulsion, Inc. is permitted to discharge treated stormwater and related
wastewater runoff(s) into an unnamed tributary to Contentnea Creek in the Neuse River Basin. The
wastewater treatment system consists of the following components: railroad offloading facilities for
liquid asphalt with spill-prevention secondary containment, above ground heated asphalt storage tanks
a truck-loading rack with spill-prevention secondary containment, a stormwater retention pond, an
8-inch diameter discharge line with manually operated discharge valve, an effluent
surface-spreader/diffusor, and a sample point that is up gradient of vegetative filter.
2. A review of eDMRs for 2019 revealed several errors with reporting. Monitoring results were not
reported for the quarters starting in January 2019 and October 2019 despite there being discharge
events.There also appears to be no evidence of Acute WET Toxicity being performed in January or
April. Lab results were present on site, and no discrepancies were found for data that had been
reported for eDMRs. However, we recommend revising and resubmitting your eDMRs for 2019 to
include missing parameters. Since (low measurement is episodic, we also recommend leaving the No
Reporting Reason column blank in the future instead of putting NOFLOW.
3. Gary Fischer(ORC) and Frederick Ammons (bORC) currently perform pH testing on effluent
during discharge events and transport samples to a certified lab. As stated in Subchapter 08G of the
North Carolina Administrative Code and Statutes, Grade 1 physical/chemical systems should have
weekly visitations by operators (15A NCAC 08G .0204 (2)(h)(i). The operator should come and view the
treatment system at least once a week, even during no discharge.
4. At the time of inspection, the various facility components were found to be well maintained.
5. At the time of inspection, the retention pond and outfall were found to be well maintained. However,
it is recommended that you remove woody vegetation and weeds from the banks of the pond.
Page# 2

Permit: NCO089087 Owner-Facility: Ergon Asphalt&Emulsion
Inspection Date: 03111/2020 Inspection Type: Compliance Evaluation
Other Yes No NA NE
Comment:
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:
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:
Laboratory Yes No NA NE
Are field parameters performed by certified personnel or laboratory? M ❑ ❑ ❑
Are all other parameters(excluding field parameters)performed by a certified lab? ■ ❑ ❑ ❑
#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 ❑ ❑ M ❑
Celsius)?
Incubator(Fecal Coliform) set to 44.5 degrees Celsius+/-0.2 degrees? ❑ ❑ ❑
Incubator(BOD) set to 20.0 degrees Celsius +1- 1.0 degrees? ❑ ❑ M ❑
Comment:
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? ❑ ❑ ❑
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 M
Page# 3

Permit: NCO089087 Owner-Facility: Ergon Asphalt&Emulsion
Inspection Date: 03/11/2020 Inspection Type: Compliance Evaluation
Record Keeping Yes No NA NE
Name of person performing analyses ■
Transported CM ■
Are DMRs complete: do they include all permit parameters? ❑ ■ 1113
Has the facility submitted its annual compliance report to users and DWQ? ❑ ❑ ■ ❑
(If the facility is=or>5 MGD permitted flow) Do they operate 2417 with a certified operato ❑ ❑ ■ ❑
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' ■ ❑ ❑ ❑
1s a copy of the current NPDES permit available on site? ❑ ❑ ❑
Facility has copy of previous year's Annual Report on file for review? ❑ ❑ ■ ❑
Comment: A review of eDMRs for 2019 revealed several errors with reporting. Monitoring results were
not reported for the quarters starting in January 2019 and October 2019 despite there being
discharge events.There also appears to be no evidence of Acute WET Toxicity being
performed in January or April. Lab results were present on site, and no discrepancies were
found for data that had been reported for eDMRs.The operator should come and view the
treatment system at least once a week, even during no discharge.
Lagoons Yes No NA NE
Type of lagoons?
#Number of lagoons in operation at time of visit? 1
Are lagoons operated in?
#Is a re-circulation line present? ❑ ❑ ■ ❑
Is lagoon free of excessive floating materials? ■ ❑ ❑ ❑
#Are baffles between ponds or effluent baffles adjustable? ❑ ❑ ■ ❑
Are dike slopes clear of woody vegetation? ❑ ■ ❑ ❑
Are weeds controlled around the edge of the lagoon? ❑ ■ ❑ ❑
Are dikes free of seepage? ■ ❑ ❑ ❑
Are dikes free of erosion? ■ ❑ ❑ ❑
Are dikes free of burrowing animals? ■ ❑ ❑ ❑
#Has the sludge blanket in the lagoon (s) been measured periodically in multiple ❑ ❑ ■ ❑
locations?
#If excessive algae is present, has barley straw been used to help control the growth? ❑ ■ ❑ ❑
Is the lagoon surface free of weeds? ■ ❑ ❑ ❑
Is the lagoon free of short circuiting? ■ ❑ ❑ ❑
Page# 4

Permit: NCO089087 owner-Facility: Ergon Asphalt&Emulsion
Inspection Date: 03/11/2020 Inspection Type: Compliance Evaluation
Lagoons Yes No NA NE
Comment: Some woody vegetation and weeds surrounding la oon. Algae is treated with copper sulfate
crystals.
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? N ❑ ❑ ❑
#Are there any special conditions for the permit? ❑ ❑ M ❑
Is access to the plant site restricted to the general public? 0 ❑ ❑ ❑
Is the inspector granted access to all areas for inspection? ■ ❑ ❑ ❑
Comment:
Page# 5