Loading...
HomeMy WebLinkAboutNCG500117_Regional Office Historical File Pre 2018ATVA. NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Michael F. Easley, Governor William G. Ross, Jr., Secretary Alan W. Klimek, P.E,, Director November 15, 2006 G.L. Simmons Charlotte Pipe & Foundry Company P.O. Box 35430 Charlotte, NC 28235 Subject: NPDES Permit NCG500000 renewal Certificate of Coverage (CoC) NCG500117 Charlotte Pipe & Foundry Company Mecklenburg County Dear Permittee: The facility listed above is covered under NPDES General Permit NCG500000. NCG5C on July 31, 2007. Federal (40 CFR 122.41) and North Carolina (15A NCAC 2H.0105(e)) re la that permit renewal applications must be filed at least 180 days prior to expiration of the curre you have already mailed a renewal request, you may disregard this notice. To satisfy this requirement, the Division must receive a renewal request postmarked ru February 1, 2007. Failure to request renewal by this date may result in a civil penalty assess penalties may be assessed depending upon the delinquency of the request. This renewal notice well in advance of the due date so that you have adequate time to prepare your application. If any discharge previously covered under NCG500000 will occur after July 31 CoC must be renewed. Discharge of wastewater without a valid permit would violate North General Statute 143-215.1; unperinitted discharges of wastewater may be assessed civil penalt la- r than . Larger ng sent 0, the lina $25,000 per day. If all discharge has ceased at your facility and you wish to rescind this CoC [or if you have other questions], contact me at the telephone number or e-mail address listed below. Sincerely, A' Charles H. Weaver, Jr. NOV NPDES Unit cc: Central Files NPDES File ire j! 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 One 512 North Salisbury Street, Raleigh, North Carolina 27604 NofthCarohna Phone: 919 733-5083, extension 5111 FAX 919 733-0719 / chades.weaver@ncmail.net Aatmrallff An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper PIPE AND FoUt y_ CAhmad * tvj# 1 'RCS Wednesday, June 07, 200E -!�IAL UFFIC o TO: D. Rex Gleason 00 FROM: David Waggoner " 4) CC: Rusty Rozzelle, Don Ceccarelli SUB3EC'T: Storruwater Notice of Violation Mr. Gleason The enclosed letter is in response to the storm water Notice of Violation that Charlotte Pipe Foundry Company received on May 25, 2006. The areas of concern are being addressed and our plan of action. is written in italics under each item in the original DEIR letter. The slag water capture and routing to our treatment plant is also going to take approval from CMUD. They have been contacted and seem receptive to the idea.. Once the actual design is completed, we will contact Mr. Ceccarelli with LUESA for his review. If you have any questions or concerns please feel free to give me a call. Thank you, David Waggoner Environmental Mager April **, 2006 CERTIFIED MAIL RETURN RECEIPT REQUESTED Marshall Coble, Senior Vice President Cast Iron Division PO Box 35430 1335 S. Clarkson Street Charlotte, NC 28253 SUBJECT: NOTICE OF VIOLATION Compliance Evaluation Inspection Charlotte Pipe and Foundry Company NPDES Permit No. NCS000040 Mecklenburg County, NC Dear Mr. Coble: I-X- A --I Z IIAA-e AA- ------ 11. -r 4-1- X4-111-11--- Water Quality. The enclosed report shc th Carolina General Statt I Wif Monitoring Prograj )e self-explanatory. or a civil penalty assessment document. Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand ($25,000.00) may be assessed against any person who violates or fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S. 143-215. 1. It is requested that a written response which addresses the noted pen -nit violations, described under the Facility Site Review, Self Monitoring Program, and Stormwater/Pollution Prevention section headings, be submitted to the attention of Mr. John Lesley of this Office by no later than June. 7 2006. Additionally, please send a copy of this response to Mr. Rusty Rozzelle of the MCWQP at 700 N. Tryon St., Suite 205, Charlotte, NC 28202. Mr. Marshall Coble Charlotte Pipe and Foundry Company Page Two April **, 2006 If you have any questions concerning this report or any other matters, please do not hesitate to call Mr. John Lesley or me at (704) 663-1699. Sincerely, D. Rex Gleason, P.E. Water Quality Regional Supervisor Enclosure cc: Rusty Rozzelle, MCWQP DRG/dpc G:\WQ--Xfer\CECCADP\1ndustria1 Inspections\CharPipe&Foundry\CharPipe&FoundryReport.doe United States Environmental Protection Agency, Washington, DC 20460 Form Approved NPDES Compliance Inspection Report OMB No. 2040-0003 19 Resources A Expires North Carolina Department of Environment and Natural Resoi WDENK Approval �7 =e' Division of Water Quality, Mooresville Regional Office 7/31/85 1. Section As National Data SXstcm Coding Transaction Code NPDES Pennit No. YR/MO/DAY Inspection Type Inspector Facility Type N 5 NCS0000040 06/04/06 C C 2 Remarks: Inspector: Mecklenburg County Water ualit Program Inspection Work Days Facility Self -Monitoring Evaluation Rating BI QA __.....,Reserved. ..... 2.0 2 N N Section 8.4 Facility Data, Name and Location of Facility Inspected: Entry Time: Permit Effective Date: Charlotte Pipe & Foundry Company 09:00 am January 1, 2000 1335 S. Clarkson Street Exit Time: Permit Expiration Date - Mecklenburg County, NC 3:00 pra Date: December 31, 2004 Aril 5, 2006 Name(s) of On -Site Representative / Title(s) Phone No(s): Mr. David Waggoner / Project & Environmental Manager/ 704-332-2647 Mr. Travis Hartsell / Wastewater Operator! 704-332-2647 Name and Address of Responsible Official: Title: Mr. Marshall Coble Senior Vice President, Cast Iron Division Charlotte Pipe & Foundry Company 1335 S. Clarkson Street Charlotte, NC 28253 Phone No. (704) 332-2647 Contacted No Section C: Areas Evaluated Utrr ng Inspection Permit Flow Measurement Operations & Maintenance El Sewer Overflow Records/Reports Self -Monitoring Program Sludge Handling/Disposal Z Pollution Prevention Facility Site Review El Compliance Schedules Pretreatment Program El Multimedia Effluent/Receiving Waters El Laboratory Stormwater 0 Other: Section D: Summary of Findings/Comments All areas are rated satisfactory unless otherwise indicated in Attached Sheet(s). Signature(s) of Inspector(s): Agency/Office/Telephone: Date: Donald Ceccarelli MCWQP / (704) 336-5500 April 6, 2006 Signature of Reviewer: Agency/Office Date: EPA Form 3560-3 (Revised 3-85) Previous Editions are Obsolete GEN] Street a�4-4111 1AL: rhe Charlotte Pipe & Foundry Company i Charlotte, North Carolina (refer to Figure 1). ted at 1335 South Clarkson cated on approximately 35 -veral blocks just west of (refer to Figure 2). Total impervious (parking lots, buildings, roadways, etc.) timated of 95 percent of the total site area, '1—VVv11ar5';-1 ao vaauwcaa rxFF"%-aLLv" L v"'A vy"" 015" — -- —1 --- I permit renewal deadline) and has phone logs documenting that the renewal applict received by the North Carolina Department of Environment and Natural Resource, activities, to the surface waters of the State or to the Municipal Separate Storm Sewer System, providing that the permittee treats, controls, limits and monitors the discharge as specified in the permit. Charlotte Pipe will continue to operate under the old permit, per NCDENR, until a new one is issued. RECORDS/REPORTS: CP&F provided the following documents (requested by MCWQP) for review: Stormwater Pollution Prevention Plan (SPPP), Spill Prevention, Control and Countermeasure Plan, facility drainage map, hazardous material inventory report, facility inspection records, and storm water analytical records. Compliance with the recordkeeping requirements of the permit and the SPPP is discussed under the Stormwater / Pollution Prevention section of the report. FACILITY SITE REVIEW: CP&F is located in the Irwin Creek Watershed. Irwin Creek is a Class-C water in the Catawba River Basin. REVIEW (cont.): )r operations observed during the inspection included the loading and solid materials from rail -cars and trucks, storage of raw materials, storage of mediate products, bulk above ground storage tanks, truck fueling station, ent operations, and general facility grounds. �w of the outdoor operations during the facility inspection, the following items ater from metal slag vile dischlat:ng to the storm drain syste : Wet s not currently permitted unde retaining wall to keep the slag ? channeled inside thef6undry ant where it will be treated ani ntactedfor approval. r condensate discharging to t ircels along West Palmer Stret the manufacturing plant contai I surface. This discharge of n( drain line has been moved inside into a drum ai the machine shop where the water will be collet Charlotte Pipe's water treatment plant where it thejbundr y. �rom entering the storm di i inch drain line that lead., led throughout the.foundr is scheduled to be "hardpiped d in totes so it can be deliverej ill be treated and recycled thro handles large amounts of raw materials (such as sand, oxidized metal, limestone, etc) that create dust / particulate matter on the ground surface throughout the facility. In addition, some of the dust collecting equipment (baghouses, etc.) are located near storm drains and some of the collected material is discharging to the ground surface. During rain events, this particulate matter is transported into the storm drain system and then into Irwin Creek. Facility personnel have recognized this potential issue and have instituted a street sweeper that runs 8 hrs / day during plant operation as a Best Management Practice (BMP) throughout the accessible areas of the plant. However, many outside areas of the plant are not accessible by the street sweeper. Some stormwater that collects in concrete lined foundations underneath process equipment is collected and treated in the wastewater pretreatment plant. Facility personnel have proposed to collect and treat additional stormwater from these areas in their wastewater pretreatment plant, but have been unable to gain the support of the pretreatment permitting agency, Charlotte - Mecklenburg Utility Department. Charlotte Pipe recognizes the./act that solid and other particulate matters are apart qfan�yfioundry operation and does employee a sweeper operator,full time to keep the accumulation at a minimum. The sweeper can not get under baghouses, sand silos, etc but each department is required under our 5S cleanliness guidelines to sweep these areas out so the sweeper can collect the dust. On the day of'the inspection, one of our raw silica sand silos had a malfunction, during pneumatic truck unloading, and blanketed the area around it in white sand An employee was sweeping outftom under the silofbr the sweeper as we walked by. The sand was cleaned up by the end of2 "d shift. 1he department heads, foremen, and hour�y workers ha-,,,e been reminded of requiredprocedures that must befollowed. EFFLUENT/RECEIVING WATERS: This inspection was conducted during clear, dry weather conditions. The SPPP identified five (5) stormwater discharge outfalls (SWOOI through SWO05) from the manufacturing facility. A minor discharge was observed at SWO05 during the inspection. The permittee identified the source of this discharge as non -contact cooling water being discharged under NPDES Permit No. NCG500117. The permittee indicated that this storm, drain pipe also collects stormwater ftom industrial properties southeast of the property. The discharge was clear and the flow was estimated to be less than five (5) gallons per minute, MCWQP had noted and sampled this discharge during a stream walk on March 1, 2006. The laboratory results showed an unusually high concentration (18 mg/L) of fluoride. MCWQP inquired about the use of fluoride or fluorine -containing products at CP&F. During the inspection, CP&F health and safety staff reviewed the database of Material Safety Data Sheets (MSDSs) for all products in use that contain fluoride of fluorine and CP&F identified one product (a metal brazing flux) that contains potassium fluoride at 10 to 50 percent concentration. This material, is reportedly used infrequently in small quantities in the maintenance shop for machine repair. CP&F personnel did Stonnwater runoff from the main manufacturing plant property discharges via three stormwater discharge outfalls (SWOO 1, SWO02, AND SWO05) across 1-77, and ultimately to Irwin Creek, which is a Class C water in the Catawba River Basin. Please note that CP&F have identified two additional intermediate outfalls (SWO03 and SWO04) on their Site Plan for sampling purposes. CP&F personnel have mapped the storm drain system from the main manufacturing plant and have labeled stonn drains, piping and outfalls; however, the storm drain system on the adjoining parcels (along West Palmer Street, Post Street, and Summit Avenue) has not been mapped. These adjoining parcels appear to have significant materials exposed to stormwater (old core storage, material transfer areas, etc.) and should be evaluated and included as part of the SPPP and sampling regime. All of Charlotte Pipes properties will be included in the updated SPPP. The purchase order.for the update has been cut and ERM, NC conducted an initial site i4sit on June 5, 2006 The update should be completed some time in July 2006 SELF -MONITORING PROGRAM: The facility's permit (Part 11 Section Q requires that qualitative monitoring of stormwater discharge outfalls be conducted twice per year. From review of inspection records (July 2004 to March 2006), CP&F conducts monthly inspections of significant materials storage areas and stormy Sectio the pe. was n{ persor (want infom was p+ repr°es was no after I monih runof# is regi galls kept. this rt large outfalls.. ker discharge outfall is required (under Part lI snit) for various discharge characteristics annually during the first 3 years of terly the 4fh year (2003). From review of the quantitative records, sampling at all during the 4th year (2003) of the permit. This was confirmed by CP&F -ated that sampling was not performed in 2003 due to lack of rainfall events. ng was performed in June 2004; however, the data was missing required i total rainfall, event duration, and estimated flow. No quantitative sampling 005 Prism Labs performed the sampling during 2004. Charlotte Pipe also track the necessary parameters during testing going forward. Testing tit terms expire plus we did not know iwf our new permit would require different . e will monitor in 2006 rnt to be considered We perimeter o`f'the xm that ties into the gips of oil that may bypass to the stornu s ear`s rr sewer. Our, )NS & MAINTENANCE. )verall operation and maintenance strategyfor this type of facility appears to be throughout the grounds. During the inspection, liquid containers (tanks, drums, etc.) appeared to be goad condition with no sign of leaks, stains or corrosion. Large tanks were provided with secondary containment structures and the fuel island was covered with a canopy and surrounded by a blind trench drain to contain any small spills during material transfer. STO WATERCPOLLUTION PREVENTION: The permit requires the permittee to develop a Stormwater Pollution Prevention Plan, as detailed in Part II, Section A. Stormwater Pollution Prevention Plan. The permittee has developed a plan; however portions were either absent or inadequate, as detailed below. 1. Part 11, Section A. 1. Site Plan. (a) - Discharge Point(s) Location. The permit requires accurate latitude and longitude coordinates for the point(s) of discharge. There were no specific coon This will be done with, the new SPPP tA 2. Part 11, Section A. 1. Site Plan. (c) — The permit requires the site map to be drainage structures, The site map provi system for the adjoining parcels (owne( - The drawing is drawn to scale. The at from was plotted to maximize the detaij The mainfoundry drawing is what w( industrial activities take place, We hav, a buffer. The new SPPP will be update points on all of our properties. 3. Part 11, Section A. 1. Site Plan. (e) — T The permit requires that certification cal signed by the responsible party. A non but had not been completed or signed. Storm water evaporates from our contc, pumped into our water treatment plant, that CMUD would not allow into our h hauler periodicalv as needed. Therefoj - -- - --7 - - -- -- A,-,f - - - - for each outfall provided in the plan. h. P. ) scale and show locations of all s not to scale. Also, the storm drain &F) had not been mapped on the plan. 9t that Mr. Ceccarelli and I worked ire scale was not shown, ?d had to shown as this is where the scharge certification form was in the plan, 'er4fication has not been needed. anment Schedule. containment for bulk storage (single container greater than 660 gallons in capacity or multiple containers the same location exceeding 1,320 gallons in capacity total) had not been evaluated for appropriate secondary containment. Secondary containment capacity should be provided to contain the largest single storage container in a storage area plus enough freeboard to contain a 25-yr, 24-hr storm event. Additionally, there was no record of release of accumulated stonn water from diked areas. The permittee indicated that accumulated stormwater is allowed to evaporate and has never been released. The pit volumes will be calculated and compared to the standard in the SPPP. STORMWATER/POLLUTION PREVENTION (cont.): 5. Part 11, Section A. 5. Employee Training The permit requires the permittee to provide annual training and document the training for employees that have the potential to contaminate storruwater runoff. The permittee does not have training records documenting training. The pennittee indicated that employees are trained by their individual section leaders and records are not Dept in a central location. All training information should be updated and current. Also, the SPPP should be updated to include the training frequency required. This will be done in June -July. Our Safety Department will maintain the training records/signatures with all other employee turning records. SPPP will be updated to show frequency of training as annual. 6. Part Il, Section A. 7. Plan Amendment. The permit requires the permittee to review and update the SPPP on an annual basis. The Plan Amendment Signatory page indicated that the plan had not been updated. since 1998. All information should be updated and current. This is being done this month and will be done each year in the, f utre. 7. Part Il, Section B. Analytical Monitoring Requirements. The permit requires analytical monitoring annually the first three years and quarterly the 4�h year. Section 4.0 of the SPPP indicates the sampling should be done annually. The SPPP should be updated to reflect the required monitoring schedule. This will be clone this month in the updated SPPP. TING: Unsatisfactory NWN A T t- ot d May 23, 2006 CERTIFIED MAIL 7003 RETURN RECEIPT REQUESTED Charlotte Pipe & Foundry Company PO Box 35430 1335 S. Clarkson Street Charlotte, NC 28253 Subject: C( Cl M M Dear Mr. Coble: Enclosed is a copy of the sample analysis result Michael F. Easley, Govemor)' William G. Ross Jr,, Secretary North Carolina Department of Environment and Natural Resources Alan W. Klimek, P,E, Director Division of Water Quality 1260 00013493 9214 ipliance Sampling Inspection Results rlotte Pipe & Foundry Company )ES PeitNo. NCS000040 �klenburg County, NC iality. Sincerely, D. Rex Gleason, P.E. Surface Water Protection Regional Supervisor Attachment cc: Rusty Rozzelle, MCWQP DRG/dpe IrM AFile- M:\EPIC\WQ\NPDES\CharPipe&Fndty(2006-00379),doe ON MA NroCarolina ,a, HMEW WUMAY Mooresville Regional Office Division of Water Quality Phone 704-663-1699 Customer Service Internet: )YAW—,flRLAAt—eLqqJajt�L,,or- 610 East Center Ave, Suite 301 Mooresville, NC 28t 15 Fax 704-663-6040 1-877-623-6748 An Equal OpportunitylAffirmative Action Employer — 50% Recycled/10% Post Consumer Paper ANALYTICAL RESULTS SHEET NAME OF FACILITY: Charlotte Pipe & Foundry Grab: ® Composite: Sample Date(s): April 26, 2006 NPDES Permit No. NCS000040 Sample Location: SWO02 County: Mecklenburg BOD5, mg/I Phenols, ug/1 < 50 COD: High, mg/1 26.7 Sulfate, mg/1 COD: Love, mg/1 Sulfide, mgtl Coliform: Fecal, #/100 nd Biomass: Dry Weight Coliform: "Total, #I100 ml Biomass: Peri Ash Free Coliform: Tube Fecal, MPN 3-N, mg/1 < 0A0 Coliform: Tube Total, MPN TKN, mg/1 0.5 Residue: Total, mg/1 287 NO2 + NO3, mg/1 L8 Volatile;, mg/1 PO4, mg/1 Fixed, mg/1 P. Total, mg/1 0.028 Residue: Suspended, mg/1 4.8 P: Dissolved, mg/1 Volatile, mg/I Ag-Silver, u'I < 5.O Fixed, mg/I Al -Aluminum, ug/1 Settleable Solids, mitt Be -Beryllium, ug/1 < 2.0 PH, s.. Ca -Calcium, ug/1 TOC/, mg/I Cd-Cadmium, ug/1 < 1.O Turbidity, NTU Co -Cobalt, ug/1 Chloride, mg/I Cr-Chromium: 'Total, ug/1 < 5.0 Oil and Grease, mg/1Cu-Copper, ug/l 17 Cyanide, ug/1 Fe -Iron; mg/1 0.600 Fluoride, mg/1 0.22 Pb-Lead, ugfl < 5.O Hardness. Total, met Hg-Mercury, ug/I < 0. AS, ug/1 Ni-Nickel, ug/l < 5.0 Conductivity, umhos/cm Semivolatiles SEE ATTACHED SHEET(s) Dissolved Oxygen, mg/1 VOC SEE ATTACHED SHEET(s) Temperature, °C 1&5 Selenium, ugll < 5.O Silver, ugfl < 5.0 Thallium, ug/l < 5.O Zinc, ugll 100 denotes a violation of a permit limitation. tc/at> denotes that sample was collected by grab method, ANALYTICAL RESULTS SHEET NAME OF FACILITY: Charlotte Pipe & Foundry Grab: [D Composite: Cl Sample Dates}: April 26, 2006 NPDES Permit No. NCS000040 Sample Location: SW005 County: Mecklenburg BOD5, mg/1 Phenols, ug/l < 50 COD: High, mg/l 39.6 Sulfate, mg/l COD: Low, mg/l Sulfide, mg/l Coliform: Fecal, #/100 ml Biomass: Dry Weight Coliform: Total, #/100 ml Biomass: Peri Ash Free Coliform: Tube Fecal, MPN NH3-N, mg/1 Coliform: Tube Total, MPN TIN, mg/l 2.4 Residue: Total, mg/l 395 NO2 + NO,, mg/1 1A Volatile, mg/1 PO4, Mg/1 Fixed, mg/l P: Total, mW1 0.17 Residue: Suspended, mg/l 13 P: Dissolved, mg/l Volatile, mg/1 Ag-Silver, ug/l < 5.0 Fixed, mg/l Al -Aluminum, ug/l Settleable Solids, ml/1 Be -Beryllium, ug/1 < 10 pH, sx. Ca -Calcium, ug/l TOC, mg/1 Cd-Cadmium, ug/1 < Lo Turbidity, NTU Co -Cobalt, ug/l Chloride, mg/l Cr-Chrornium: Total, ug/1 < 5.0 Oil and Grease, mg/1 Cu-Copper, ug/1 10 Cyanide, ug/1 Fe-lron, mg/l L4 Fluoride, mg/1 133 Pb-Lead, ug/l 13 Hardness: Total, mg/1 Hg-Mercury, ug/l < 01 MBAS, ug(I Ni-Nickel, ug/l 10 Conductivity, umhos/cm Sernivolatiles SEE ATTACHED SHEET(s) Dissolved Oxygen, mg/1 VOC SEE ATTACHED SHEET(s) Temperature, OC 193 Selenium, ug/l 13 Silver, ug/l < 5,0 Thallium, ug/l < 5.0 Zinc, ug/l 1500 denotes a violation of a permit limitation. denotes that sample was collected by grab method. NWN A *r � it&/, Ad, 0� Michael F. Easley, Governor William G. Ross Jr., Secretary .. I— North Carolina Department of Environment and Natural Resources Alan W. Klimek, P , Director Division of Water Quality May 8, 2006 CERTIFIED MAIL RETURN RECEIPT,REQUESTED 7003 2260 0001 3493 9085 Marshall Coble, Senior Vice iPresident Gast Iron Division Charlotte Pipe & Foundry Company PCB Box 3430 1335 S. Clarkson Street Charlotte, NC 28253 SUBJECT: NOTICE OF VIOLATION Tracking No. NOV-2006-PC-017 Compliance Sampling Inspection Charlotte Pipe and Foundry Company NPES Permit No. NCS000040 Mecklenburg County, NC Dear Mr. Coble. n April 5, 2006, Mr. Donald Ceccarelli of the Mecklenburg County Water Quality e ' • ' a • t • +; _ # e ' R •i ! r s, 1- Mr. Marshall Coble Charlotte Pipe and Foundry Company Page Two May 8, 2006 If you have any questions concerning this report or any other matters, please do not hesitate to call Mr. John Lesley or me at (704) 663-16 9. Sincerely, �71"�,"' 1 . Rex Gleason, P.E. Surface Water Protection Regional Supervisor Enclosure cc. Rusty Rozzelle, MCWQP dp M:\EPIC\WQtNOV1NOV-CharPipe&Foundry-0- 0348 do Form Approved 40-0003 spires Section A: National Data System Coding Transaction Code NPDES Permit No. YR/MO/DAY Inspection Type Inspector Facility Type S NCS0000040 06/04/06 C C Remarks: Ins ector: Mecklenbur Coon Water nails Prci ram Inspection Work Days Facility Self -Monitoring Evaluation Rating BI ;QA ...........Reserved„......... 10 2 N N Section B: Facility Data Name and Location of Facility Inspected: Charlotte Pipe & Foundry Company 1335 S. Clarkson Street Mecklenburg; County, NC Entry Time: 09:00 am Exit Time: 3:00 pm Date: April 5, 2006 Permit Effective Date: January 1, 2000 Permit Expiration Date: December 31, 2004 Name(s) of On -Site Representative / Title(s) / Phone No(s). Mr. David Waggoner /.Project & Environmental Manager/ 704-33 -2647 Mr. Travis Hartsell /Wastewater Operator / 704-332-2647 Name and Address of Responsible Official. Marshall Coble Charlotte Pipe & Foundry Company 1335 S. Clarkson Street Charlotte, NC 28253 Title: Senior Vice President, Cast Iron Division Phone No. (704) 332-2647 Contacted? No Section C: Areas Evaluated During Inspection Permit El Flow Measurement E Operations & Maintenance E] Sewer Overflow Records/Reports Self -Monitoring Program ® Sludge Handling/Disposal Pollution Prevention Facility Site Review [ Compliance Schedules E] Pretreatment Program D Multimedia Effluent/Receiving Waters ❑ Laboratory 0 Stormwater El Other: Section D Summary of Findings/Comments All areas are rated satisfactory unless otherwise indicated in Attached eet(s). Signatures) -of Inspector(s): Donald Ceccarelli Agency/Office/Telephone: MCWQP / (704) 336-5500 Date: April 6, 2006 Signature of Reviewer: John Lesley Agency/Office: S / Mooresville Regional Office (704-66 -1699 Date: May 8, 2006 EPA Form 35 0-3 (Revised 3-85) Previous Editions are Obsolete GENERAL: aria, uistrioures cne roe owing major raw materials: cast iron scrap, coke, coal, limestone, quartz, sand., silicon, bentonite, petroleum -asphalt, gasoline and diesel fuel. The Mecklenburg County Water Quality Program (MCWQP) has historically conducted NPDES inspections of the Charlotte Pipe & Foundry Company (CP&F). PERMIT: CP&F holds an individual NPDES Stormwater Permit, NCS000040. The permit became effective on January 1, 2000 and expired on December 31, 2004. CP&F has documentation that the Permit Coverage Renewal Application Form was completed and signed on June 20 2004 (prior to the permit renewal deadline) and has phone logs documenting that the renewal application was received by the North Carolina .Department of Environment and Natural Resources. CP F continues to operate under the conditions of the expired permit. The permit authorizes the permittee to discharge stormwater associated with industrial activities, to the surface waters of the State or to the Municipal Separate Storm Sewer System, providing that the permittee treats, controls, limits and monitors the discharge as specified in the permit. CPF provided the fallowing documents to MCWQP for review. Stormwater Pollution Prevention Plan (SPPP), Spill Prevention, Control and Countermeasure Plan, facility drainage map, hazardous material inventory report, facility inspection records, and storm water analytical records. Compliance with the recordkeeping requirements of the permit and the SPPP'is discussed under the Stormwater / Pollution Prevention section of the report. FACILITY SITE VIEW: The facility is located in the Irwin Creek.. Watershed. Irwin Creek is a Class-C water i the Catawba River Basin. 0 1,111111 ! & ILI ttU.A In. F!"MMIMITMINTUMMM"I _-MMUMMEMI process metal slag is conveyed outdoors to a storage pile.During the inspection, N from the slag pile was flowing into the storm drain system. This discharge of non- stormwater is not currently permitted under a separate NPDES permit and is not a] by the Stormwater NPDES permit. EFFLUENT/RECEIVING WATERS (cont.): CP&F personnel have mapped the storm drain system from the main manufacturing plant and have labeled storm drains, piping and outfalls; however, the storm drain system on the adjoining parcels (along West Palmer Street, Post Street, and Summit Avenue) has not been mapped. These adjoining parcels appear to have significant materials exposed to stormwater (old core storage, material transfer areas, etc.) and should be evaluated and included asp of the SPPP and sampling regime. MCWQP collected grab samples from stormwater outfalls SWO05 and SWO02 at the point of discharge into Irwin Creek on April 26, 2006. The sample temperature was recorded and the samples transported under ice to the Charlotte -Mecklenburg Utilities Laboratory at approximately 3:30 pm. Analytical results from the sampling will be sent under separate cover. SELF-MONITORJNG PROGRAM: The facility's permit (Part 11 Section Q requires that qualitative monitoring of stormwater outfalls be conducted twice per year. From review of records (July 2004 to March 2006), CP&F conducts monthly inspections of significant materials storage areas and stormwater outfalls. RIB _U '"too] • The overall operation and maintenance strategy for this type of facility appears to be adequate with the exception of the accumulated particulate matter on the impervious areas throughout the grounds. During the inspection, liquid containers (tanks, drums, etc.) appeared to be in good condition with no sign of leaks, stains or corrosion. Large tanks were provided with secondary containment structures and the fuel island was covered with a canopy and surrounded by a blind trench drain to contain any small spills during material transfer. STfl ATE OLLUTION PRI 'NTION: The permit requires the permittee to develop a Stormwater Pollut detailed in Part II, Section A. Stoaer Pollution Prevention Plan.' . p .. w FA"Ixi I'mvva v%.1 FW11.1V11a vv%,Vl , G1IUV�1 i1UJGIR U1 11mucquate, US uetunea Mow. 1. Part II, Section A. 1. Site Plan. (a) —Discharge Point(s) Location. The permit requires accurate latitude and longitude coordinates for the point(s) of discharge. There were no specific coordinates for each outfall provided in the plan. . Part II, Section A.1. Site Plan. (c) — Site Map. The permit requires the site map to be drawn to scale and show locations of all drainage structures. The site trap provided i was not to scale. Also, the storm drain system for the adjoining parcels (owned by CPF) had not been mapped on the plan. 3. Part II, Section A.1. Site Plan. (e) - Non-Storwater Discharge Certification. The permit requires that certification of note-stormwater discharges be made and signed by the responsible party. A non -discharge; certification form was in the plan, but had not been completed or signed. . Part II, Section A. 2. (h) — Secondary Containment Schedule. The SPCC plan identified numerous above ground petroleum storage tanks that meet the permit criteria for required secondary containment; however, secondary containment for bulk storage (single container greater than 660 gallons in capacity or multiple containers the same location exceeding 1,320 gallons in capacity total) had not been evaluated for appropriate secondary containment. Secondary containment capacity should be provided to contain the largest single storage container in storage area plus enough freeboard to contain a 25-yr, 24-r storm event. Additionally, there was no record of release of accumulated storm water from diked areas. The permittee indicated that accumulated stormwater is allowed to evaporateand has never been released. 5. Part II, Section A. S. Employee Training The permit requires the permittee to provide annual training and document the training for employees that have the potential to contaminate stormwater runoff: The permittee does not have training records documenting training. The permittee indicated that employees are trained by their individual section leaders and records are not kept in a central location. All training information should be updated and current. Also, the SPPP should be updated to include the training frequency required. 6. Part II, Section A. 7. flan Amendment. The permit requires the permittee to review' and update the SPPP on an annual basis. The Flan Amendment Signatory page indicated that the plan had not been updated since 1998. All information should be updated and current. 7. Part II, Section B. Analytic The permit requires analytic the fourth year. Section 4.0 annually. The SPPP should RATING: Unsatisfactory MENTION (coat. al Monitoring Requirements. al monitoring annually the first three years and quarterly of the SPPP indicates the sampling should be done be updated to reflect the required monitoring schedule. ig information is included with your permit pack Df the Certificate of Coverage for your treatment of General Wastewater Discharge Permit NCG51 ity arge Permit NCG500000 after notice to DWQ. The Division may r( and General Perm its Unit at{919) 533-5683, ext. 578- ' Sincerely, NIC E)"111"HPI, Cl,- Al 4, for Alan W. Klimek, P.E. t"I 7 4 nA cc: Central Files Stormwater & General Permits Unit Files Mooresville Regional Office 1 ul t mait tiervice t;emer, Halleign, Norm uaroiina z f ovts- i t) i f ieiepnoneviv-f,:ij-ovo,5 r/AA An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consu State of North Carolina Department of Environment, Health and Natural Resources 0 Division of Water 'Quality JUL 1998 James B. Hunt, Jr., Governor Wayne McDevitt, Secretary A. Freston Howard, Jr. P.E., Director July 24, 1997 G. L. Simmons Charlotte Pipe 8r Foundry Company P.O. Box 35430 Charlotte, NC 28235 Subject: Certificate of Coverage No. NCG50011 Renewal of General Permit Charlotte Pipe & Foundry Company Mecklenburg County Dear Per ittee: In accordance with your application for renewal of the subject Certificate of Coverage, the Division is forwarding age sball'be final and binding. nental permit that may be required. ave any questions concerning this permit, please contact the NPDES Group at the address belay Central Files PlS Filc �, r Sincerely, A. Preston Howard., Jr., P.P. Facility Assessment Llnit P.O. Box 29535, Raleigh, worth Carolina 7626-0 (919) 73 -5083 FAX (1 733-0719 p&eOdem.ehnr An Equal Opportunity Affirmative Action Employer 50°l recycled / 1011/6 pest -consumer paper STATE CAP NORTH CA: OLINA w&TWOM101 :- .. - W. - • lilt[ a Otte i regut Lions promulgatea ana aaoptecx Dy the i-4orm %-aroiuia rnvirviuiteiitcu ivic td eittcitt Commission, and the Federal Water Pollution Control Act, as amended, Charlotte ripe & Foundry Company is hereby authorized to discharge non -contact cooling water, condensate and rather similar wastewaters from a facility located at Charlotte Pipe; & :Foundry Company 135 South: Clarkson Street Charlotte Mecklenburg County to receiving waters designated as subbasin 30834 in the Catawba River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts 1 11,111 and IV of General Pe t No. NCG500000 as attached. This certificate of coverage shall become effective August 1,197. This certificate of coverage shall remain in effect for the duration of the General Permit. Signed this day July 24,1997. ��. Preston Howard, Jr., `.E., Director IjDivision of Water Quality By Authority of the Environmental Management Commission of North Carolina p.rtrn nt of Environment, w 1th and Natural Resources ,� �► ision of Environmental Management ns B. Hunt, Jr., Governor Lathan B. Howes, Secretary PrestonHoward, Jr., P.F., Director X. C DEPT. OF NA7(TRAL RESOURCES AIND August 13, 193 COMMUNITY DEVELOPNIVNT A',J 11993 P 0 Box 35430 MOREZ' ltLt RENKAI OFfICE Charlotte, SIC 28235' Subject: general Permit No. NCG500000 Charlotte lotte Pipe &:Foundry COC NCG50011 Mecklenburg County Dear Mr. Simmons: In accordance with your application for discharge permit received on Jane 8, 1993, we are forwarding herewith the subject certificate of coverage to discharge under the subject state - NPDES general permit. This permit is issued pursuant to the requirements of North ;Carolina General Statute 1 -215 .1 and the Memorandum of Agreement between North Carolina and. the US Environmental Protection agency dated December 6, 1983. If any parts, measurement' frequencies or sampling requirements contained in this permit are unacceptable to you, you have the right to request an individual permit by submitting an individual permit application.' Unless such demand is made,: this certificate of coverage shall be final and binding. Please take notice that this certificate of coverage is not transferable except after notice to the :Division of Environmental` Management. The Divsion of Environmental Management may require modification or revocation and reissuance of the certificate of coverage. Division of Environmental Management or permits its required by the Division of Land Resources, Coastal' Area Management Act or any other Federal or Local governmental pennit that may be required. If you have any questions concerning this permit, please contact Ms. Susan Robson at telephone number 919/733-5083. Sincerer, Original Signed By Coleen H. Sullins A. Preston Howard, Jr., P. E. cc: <w ,O. Bost 29535, Raleigh, North Carolina 27626-0535 Telephone 919- -7015 FAX 919- -2496 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper PPPPPP'_ STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT, N AL , AND R RESOURCES DIVISION OF ENVIRONMENTAL MANAGEMENT E GENERAL PERMIT CEBI:IFICATE COVERAGE Ng, NQU500117 TO DISCI) NON -CONTACT COOLING WATER, COOLING TOWER AND BOILER R BLC CONDENSATE AND SIMILIAR WASTEWATERS UNDER TBE In compliance with the provision of North Carolina General Statute 14 - 15.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Charlotte Pipe and Foundry is hereby authorized to continue operation of a cooling water system for the generation of non -contact cooling water with the discharge of wastewater from a facility located at Clarkson Street Charlotte Mecklenburg County to receiving waters designated as an unnamed tributary to Irwin Creek in the Catawba.. River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, IT, III d IV of General Permit No, NCG500000 as attached. This certificate of coverage shall become effective August 13, 1993 This Certificate of Coverage shall remain in effect for the duration of the General Permit. Signed this day August 13, 1993 ri i at Signed By Coleen H. Sullins A. Preston Howard, Jr., P,E.,Director Division of Environmental Management By Authority of the Environmental Management Commission M . GAST-ON7A 20 "nrar. t d MJ. TOtht7"ERS tATE" 85 ti4+tLLE 7 MI, =` `' .-,. ti�trVi k R $ 1 � �� ;� ,�`�� ( '° �-� �,r_ ,; `" i * ` . i � ~`ter k y �r ;;,y ' �x �� %" � • � .:.,f#" _ It ..:..�%[1� �t L� �— '" "1:! w �,��: e�' ! �i a t yx' � r ` w,w, ' ,r �' -1' •,�" y ,y `� o ii v, ( ca`'"� �� c>�y401, SOC Priority Project,: Yes —No X If Yes, SOC No, To: Permits and Engineering Unit Water Quality Section Attention: Susan Robson Date. Jule' 27, 1993 NPDES STAFF REPORT AND RECOMMENDATION County`. Mecklenburg Permit No. NCG500117' PART - I - GENERAL INFORMATION 1. Facility and Address: Charlotte Pipe and Foundry Post Office Box 35430 Charlotte, North Carolina 28235 2. Date of 'Investigation: July 21, 1,993 . Report Prepared by Kim H. Colson, Environmental Engineer, 1 4> Persons Contacted and Telephone Number: Greg Simmons,;(704) 332-2647. 5> Directions to Site: From the intersection of Morehead Street and Clarkson Street in central Charlotte, travel south on Clarkson Street approximately 0.3 male. Charlotte Pipe and Foundry is located on the left side of the road. . Discharge Po nt:(s), List for all discharges points: Latitude. 35' 13' 28" LLongitude: 800 51' 42" Attach a USGS map extract and indicate treatment facility site and discharge point on map. U, .G.S. Quad No.: 015NE U<S.G.S. Quad. Name Charlotte East, NC 7. Site size and expansion area consistent with application? Yes, 8. Topography (relationship to flood plain_ included): Flat slopes the facility is not located within the 1,00 year flood plain. 9. Location of nearest dwelling': Several commercial facilities are located within 500 feet of the manufacturing facility, 10. Receiving stream or affected surface waters: UT to Irwin Creek a: Classification: C at �W Page Two b. River Basin and Subbasin No.: Catawba 030834 C. Describe receiving stream features and pertinent downstream uses: The receiving ;stream is a storm drain which flows into a wet weather ditch-. General rrry classification uses downstream. PART II — DESCRIPTION OF DISCHARGE AND TREATMENT WORKS 1. a. Volume- of wastewater to be permitted: 0.003 M G D (ultimate design capacity) b. Current permitted capacity of the wastewater treatment facility: N/A C. Actual treatment capacity of the current facility (current design capacity): N/A d. Date(s) and construction activities allowed by previous Authorizations to Construct issued in the previous two years`: N/A e. Please provide a descript.ion of existing or substantially constructed wastewater treatment facilities: N/A f. Please provide a description of proposed wastewater treatment facilities: There is no proposed treatment. g. Possible toxic impacts to surface waters: N/A h. Pretreatment Program (POTWs:only): NSA ?. Residuals handling and utilization/disposal scheme: N/A a. If residuals are being land applied, please specify DPM Permit No.: Residuals Contractor`. Telephone No.: b. Residuals stabilization" PSRP PFRP" Other C. Landfill d. Other disposal/utilization scheme (Sp-ecify): 3. Treatment plant classification (attach completed rating sheet)_: N/A 4. SIC Code(s): 3321 Wastewater Code(s) Primary: 14 Secondary: Main Treatment Unit Code: 00000 . Page Three PART III - OTHER PERTINENT INFORMATION 1. Is this facility~ being constructed with Construction Grant Funds or are any public monies involved (municipals only)? N/A 2. Special monitoring or limitations (including toxicity) requests: /A . Important SOC, JOC or Compliance Schedule dates (Please indicate): N/A Via. Alternative Analysis Evaluation: Spray Irrigation: N/: Connection to Regional Sewer System: N/A Subsurface: N/A Other disposal options; N/A . Air quality and/or groundwater concerns or hazardous materials utilized at. this facility that may impact water quality, air quality, or groundwater: There are ,no known air quality, groundwater, or hazardous materials concerns. . Other Special Items: N/A PART IV - EVALUATION AND RECOMMENDATION The applicant., Charlotte Pipe and Foundry, has applied for coverage under General Permit. NCG500000 for the discharge of non - contact cooling water. All contact cooling water and other industrial process wastewater is discharged into the CMUD 's collection system. It is recommended that coverage under the General Permit, be granted and a Certificate of Coverage be issued as requested. Signature of report prepares r �• �r Water Quality R9441onal Supervisor Date 80, 35'1E 3epp�rnoa 12 r IFI r *. RESOURCES=A" June 24, 1993 U "1 93 Greg Simmons Charlotte Pipe & Foundry MOD',, 1r , te,®*) �. P. . Boas 343 Charlotte, NC 28235 Subject: NCI Application NPDES; NCG50011' Charlotte Pipe & Foundry Mecklenburg County Dear Mr. Simmons: This letter is to acknowledge receipt of your application dated May 2, 1993 for coverage under General Pertnit for non -contact cooling water. The permit number ber highlighted above has been assigned to the subject facility. By copy of this later, we are requesting g that our regional Office ice Supervisor prepare a staff report and recommendations regarding this discharge. If you have questions regarding this matter, please contact Susan Robson at (919 733-83. Sincerely, Coleen Sullins, P.E. Supervisor, NP )ES group Permits d Engineering Unit Central Files P.O. Box 29535, Raleigh, North Carolina 76 6-0535 Telephone 919-733-5083 FAX 91 -733- 919 n Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper 00. h the duration d frequency of the discharge, per each separate discharge point: 1. Continuous. X 2, It ttent (Pl describe): 3. Seasonal (check month(s) the discharge occurs): January (); February (): March (}, April ( ) May ( ); June ( ) P July ( ); August ( ); September ) ; October ( ), November ( ); December (}. 4. How many days per week is there a discharge? (Check the days the discharge occurs) Monday (:0, Tuesday (, Wednesday (, Thursday (It, Friday () Saturday W, Sunday %. . :Flow much of the volume discharged is treated? (state in percents D. What type of wastewater is discharged, per separate discharge point (place check next to correct ). 1. Non -contact cooling water; . Boiler blowdo . Cooling;toer blowdo 4. Condensate; 5. Other (please describe); Please list any known pollutants that are present in the discharge, per each separate discharge point (if applicable): None known E. Please describe the type of process the cooling water is being discharged from, per separate discharge point (i.e. compressor, boiler blowdown, cooling tower blowdown, air conditioning unit, etc.): furnace ail cooler P. Please check the type of chemical added to the wastewater for treatment or other, per separatedischarge point: 1. Biocides; . Corrosion inhibitors; 3. Chlorine; . Algae control; 5. tither (please describe): 6. None: g If 1,2,3,4 or 5 was checked please state the name and manufacturer of the chemical =additive. Also include a completed Biocide 10 form), and manufacturers' information on the additive with the application for theDivision's review. G. Is there any type of treatment being provided to the wastewater before discharge (i.e. retention, ponds,; settling ponds, etc.), if yes, please describe. Give design specifics (i.e. design volume, retention time, surface area, etc.). Existing treatment facilities should be described In detail and design criteria or operational data should be provided (including calculations) to ensure that the facility can comply with requirements of the General Permit None NOTE Construction of any wastewater treatment facilities require submission of three (3) sets of plans d specifications along with their application. Design of treatment facilities must comply with requirement 15A NCAC 2H .0138. If construction applies to the discharge, include the three sets of plans d specifications with the application. . What is the nature of the business applying for this permit? Foundry production of oast iron soil pip d fittings. 6. Name of receiving water: Irwin Creek Classification: (Attach a USGS topographical map with all discharge point(s) clearly marked) ]Page directly to the receiving wate : learly the pathway to thqj�tial �e DoinL )�Iiik site map. s includes tracing the pathway of the storm sewer to its discharge point, if a storm sewer is the only viable to of discharge.) See attachment S. please 3ddr= possible non -discharge alternatives for the following options: See attachment A. Connection to a Regional Sewer Collection System; B. Subsurface Disposal; C. Spray Irrigation; 9. 1 certify that I am familiar with the information contained in the application and that to the best of my knowledge and belief such information is true, complete, and accurate. Printed Name of Person Signing Title A Date Application Signed Signature of Applicant AHOLINA UENERALi 1 (D P" FS THAT: Any person who knowingly makes any false statement, representation, or certification in any application, record, report, plan or other document filed or required to be maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, or who falsifies, tampers with or knowingly renders inaccurate * ths, or by ; ORT it not more d= 5 yews, or y a check or money order for $400.00 made payable to the North Carolina, Natural Resources. Mail three (3) copies of entire package to: ,sion of Envirotunental Management )ES Permits Group •MI 0=1 . •1. Attachment to Notice of Intent Application for coverage under General Permit NCG500000 Charlotte Pipe & Foundry Company Charlotte, North Carolina NCD980 4731 Item 7>. Specification of Discharge Point Cooling water discharge is to site stormwater collection system. ultimate discharge is to Irwin Creek via City of Charlotte stormwater collection system. Item S. Non --discharge Options A. Connection to a Regional Sewer Collection System Giventhat a pre --treatment permit is held for other process wastewater streams, this was an early consideration.. However, the location and elevation of the cooling water discharge relative to the sewer collection system presents a technical hurdle for making a tie-in. Likewise, disruption of operations and maintenance of the tie-in would he: significant economic hardship. S .' Subsurface Disposal Subsurface disposal via a leeching field type system is not .feasible clue to the fully developed nature of this urban, industrial site. Permitting and energy requirements of injection well(s) ;render such disposal methods economically unfeasible. C. Spray Irrigation As mentioned above, the fully developed nature of this site does not offer space for an irrigation field or infiltration gallery. 13486