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.
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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.'
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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
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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
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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:
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,O. Bost 29535, Raleigh, North Carolina 27626-0535 Telephone 919- -7015 FAX 919- -2496
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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
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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
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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