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Home My WebLink AboutNC0088838_Compliance Evaluation Inspection_20200928ROY COOPER Governor MICHAEL S. REGAN Secretary S. DANIEL SMITH Director NORTH CAROLINA Environmental Quality September 28, 2020 Mr. Stuart Kerkhoff (via email) Environmental Health and Safety Manager Radiator Specialty Company 600 Radiator Road Indian Trail, North Carolina 28079 Subject: Compliance Evaluation Inspection Radiator Specialty Company NPDES Permit #NC0088838 Groundwater Remediation Union County Dear Mr. Kerkhof£ Thank you your time and assistance during the September 23, 2020, inspection. Enclosed you will find the report for the compliance inspection. It is our understanding that a change of ownership form was submitted to the NPDES Central Office Permitting Group in Raleigh and that a property transfer is due to happen soon. The new property owner name has been listed as 600 Radiator Road, LLC. Please contact our office if this information is not correct. On April 13, 2020, a severe lighting strike disabled multiple remediation system components. The MRO received notification of this Process Unit Failure via email on May 13, 2020. Please note that Process Unit Failures are to be reported to the Division as soon as possible, but no later than 24 hours or the next working day following the occurrence or first knowledge of the occurrence. This issue is addressed further in the inspection report. Should you have further questions or concerns, please contact Edward Watson at 704-235-2198 or edward. watsongncdenr. gov. Sincerely, DocuSigned by: A w H pul- ► F161 FB69A2D84A3... Andrew H. Pitner, Assistant Regional Supervisor Water Quality Regional Operations Section Mooresville Regional Office Division of Water Resources, NCDEQ Attachment: Compliance Inspection Report CC: Laserfiche file North Carolina Department of Environmental Quality I Division of Water Resources Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115 m )ry rN cxl40:. itiA o.,"ro^•m or a""w^^�•"mow°•r� /� 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 2 u 3 I NCO088838 111 121 20/09/23 I17 18 L� ] 19 I s I 201 211IIIII 111111III II III III1 I I IIIII IIIIIIIII II r6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved ------------------- 67 I 72 L r., � 71 I 74 79 1.0 70IL� J I 71 [� L -1 I I I I I I I I I80 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) 10:OOAM 20/09/23 18/07/01 Radiator Specialty Company 600 Radiator Rd Exit Time/Date Permit Expiration Date Indian Trail NC 28079 11:48PM 20/09/23 23/03/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Stuart A Kerkhoff/ORC/704-684-1815/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Stuart Kerkhoff,600 Radiator Rd Indian Trail NC 28079//704-684-1815/7046841868 No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Records/Reports 0 Facility Site Review 0 Effluent/Receiving Wate 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 Edward Watson DWR/MRO WQ/ / DocuSigned by: 9/28/2020 Signature of ManagementlQs�4�5.... �s y�ed by: Agency/Office/Phone and Fax Numbers Date �t r� Ar�aw H P 9.28.2020 F161 FB69AMUA3... EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type (Cont.) NCO088838 I11 12I 20/09/23 117 18 i c i Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) On 9/23/2020, Staff from the Mooresville Regional Office (MRO), Division of Water (DWR), performed a Compliance Evaluation Inspection (CEI) at the Radiator Specialty facility under permit NC0088838. Staff met with Mr. Stuart Kerkhoff, ORC. A facility ownership change is in the closing process. The new property owner will be 600 Radiator Road, LLC. However, ORC and Back-up ORC are not expected to change. The corporation name change paperwork has been filed with Central Office NPDES permitting Group. The closing date for the sale is expected to occur before the end of September 2020. Two new monitoring wells were added to the monitoring well network to provide additional plume delineation. GW sampling results indicate there is no presence of elevated constituents present in the new wells, reducing the plume's estimated footprint. MRO has been made aware of the system being operating sporadically since January 2020. The system is currently only partially operational due to multiple systems being out of service as the result of a severe lighting strike that occurred on April 13, 2020. Damaged system components are in the process of being replaced. PART II STANDANDARD CONDITIONS FOR NPDES PERMITS SECTION E Reporting Requirements: Item 9 Noncompliance Notification (b): Any process unit failure, due to known or unknown reasons, that render the facility incapable of adequate wastewater treatment such as mechanical or electrical failures of pumps, aerators, compressors, etc. The MRO did not receive notification of the lightning strike to the facility until May 13, 2020. In the future, please remember that timely notification of a Process Unit Failure is a permit requirement. During the site visit, MRO staff were informed that the system is expected to be returned to normal operations after the completion of the property transfer, but before the end of October 2020. MRO staff requested to be notified the day the system is returned to service. During the month of March 2020, the system indicated flow averaging slightly above 54,000 gal./day, (GPD). During this period, elevated 1,4-Dioxane was recorded at 99.8 ug/I. The elevated 1,4 Dioxane is being attributed to the liquid in the 6,000-gallon equalization tank being allowed to concentrate. The fluid was recirculated back through the Air -stripper to allow for volatilization of the 1,4, Dioxane before being released through the outfall. eDMR records also indicate flow during for the last 20 days of the month of June 2020,with an average daily flow of 24,000GPD. The system displayed sporadic flow during the month of July. As the system is currently not in service, there is no discharge occurring at the outfall. Page# Permit: NC0088838 Owner -Facility: Inspection Date: 09/23/2020 Inspection Type: Radiator Specialty Company 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? M ❑ ❑ ❑ Comment: There are no restrictions on the permit. There are continuous monitoring requirements for 1 A Dioxane and Tetrachlorethene chemical constituents. Page# 3