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Home My WebLink AboutNCG500198_NOV2021PC0395_Compliance Evaluation Inspection_20210804 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED August 04, 2021 James Noble, CEO President Noble Oil Services Inc Email: jim@nobleoil.com SUBJECT: NOTICE OF VIOLATION Tracking Number: NOV-2021-PC-0395 Permit No. NCG500198 Noble Oil Services Haywood County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Noble Oil Services on August 3, 2021. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in NPDES WW Permit No. NCG500198. A summary of the findings and comments noted during the inspection are provided in the enclosed copy of the inspection report. The Compliance Evaluation inspection was conducted by Division of Water Resources staff from the Asheville Regional Office. The following violations were noted during the inspection: Inspection Area Description of Violation _________________________________________________________________________________________________________________________________________________________________________ Effluent Sampling Effluent sampling (pH and flow estimate) has not been conducted as required in General Permit NCG500000, Part 1 - Section B.(1.). _________________________________________________________________________________________________________________________________________________________________________ Upstream / Downstream Change in temperature for the upstream/downstream samples exceeded 0.5 degrees Sampling Celsius for trout water classifications as required in General Permit NCG500000, Part 1 – Section B.(1.), Footnote #1. _________________________________________________________________________________________________________________________________________________________________________ DocuSign Envelope ID: A9972558-D3A3-495A-9F39-9C049237AC5D Remedial actions should have already been taken to correct this problem and prevent further occurrences in the future. The Division of Water Resources may pursue enforcement action for this and any additional violations of State law. To prevent further action, please respond in writing to this office within 30 days upon your receipt of this Notice of Violation regarding your plans or measures to be taken to address the indicated violations and other identified issues, if applicable. If you should have any questions, please do not hesitate to contact Lauren Armeni with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4667. Sincerely, Daniel Boss, Assistant Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: Laserfiche John Williams (Refined Products Manager) DocuSign Envelope ID: A9972558-D3A3-495A-9F39-9C049237AC5D EPA United States Environmental Protection Agency Washington, D.C. 20460 Water Compliance Inspection Report Form Approved. OMB No. 2040-0057 Approval expires 8-31-98 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 1 N 52 NCG500198 21/08/03 C S31112171819 20 21 66 Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved------------------- N67707172 73 74 75 80 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES permit Number) Noble Oil Services 19119 Great Smoky Mtn Expy Waynesville NC 28786 Entry Time/Date Permit Effective Date Exit Time/Date Permit Expiration Date 10:00AM 21/08/03 20/12/15 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Other Facility Data 11:00AM 21/08/03 25/11/30 Name, Address of Responsible Official/Title/Phone and Fax Number James Noble,5617 Clyde Rhyne Dr Sanford NC 273309562//919-774-8180/9197757732 Contacted No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Operations & Maintenance Records/Reports Self-Monitoring Program Effluent/Receiving Waters Laboratory Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of Inspector(s)Agency/Office/Phone and Fax Numbers Date Lauren E Armeni DWR/ARO WQ/828-296-4500/ Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page#1 DocuSign Envelope ID: A9972558-D3A3-495A-9F39-9C049237AC5D 8/4/2021 8/4/2021 NPDES yr/mo/day 21/08/03 Inspection Type C3111218 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Lauren Armeni, with the Asheville Regional Office, conducted a Compliance Evaluation Inspection of Noble Oil on August 3, 2021. The inspection was conducted to determine if the system is being operated and maintained in compliance with General NPDES Permit No. NCG500000. John Williams (Refined Products Manager) and Effram Creasman (Plant Supervisor) were present during the inspection. Noble Oil is a used oil recycling company that utlizes non-contact cooling water. No chemicals come into contact with this water. Effluent Sampling: The facility has not been estimating flow or sampling for pH semi-annually as far back as 2008. Mr. Williams and Mr. Creasman said they would add these two parameters to the sampling sheet and include them in the next sampling event. Upstream/Downstream Sampling: The change in temperature between the upstream and downstream samples exceeded the General Permit limit of 0.5 degrees Celcius for trout water classifications for 2016-2021 and prior years. During the inspection, Ms. Armeni recommended moving the upstream and downstream sampling locations because the current locations were too close to the effluent pipe. The following violations were noted during the inspection: 1. Effluent sampling (pH and flow estimate) has not been conducted as required in General Permit NCG500000, Part 1 - Section B.(1.). 2. Change in temperature for the upstream/downstream samples exceeded 0.5 degrees Celsius for trout water classifications as required in General Permit NCG500000, Part 1 - Section B.(1.), Footnote #1. Based on the above violations, the facility is in non-compliance with the requirements outlined in General Permit NCG500000. NCG500198 17 (Cont.) Page#2 DocuSign Envelope ID: A9972558-D3A3-495A-9F39-9C049237AC5D Permit:NCG500198 Inspection Date:08/03/2021 Owner - Facility: Inspection Type: Noble Oil Services Compliance Evaluation Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new application? Is the facility as described in the permit? # Are there any special conditions for the permit? Is access to the plant site restricted to the general public? Is the inspector granted access to all areas for inspection? Comment: Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? Is all required information readily available, complete and current? Are all records maintained for 3 years (lab. reg. required 5 years)? Are analytical results consistent with data reported on DMRs? Is the chain-of-custody complete? Dates, times and location of sampling Name of individual performing the sampling Results of analysis and calibration Dates of analysis Name of person performing analyses Transported COCs Are DMRs complete: do they include all permit parameters? Has the facility submitted its annual compliance report to users and DWQ? (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift? Is the ORC visitation log available and current? Is the ORC certified at grade equal to or higher than the facility classification? Is the backup operator certified at one grade less or greater than the facility classification? Page#3 DocuSign Envelope ID: A9972558-D3A3-495A-9F39-9C049237AC5D Permit:NCG500198 Inspection Date:08/03/2021 Owner - Facility: Inspection Type: Noble Oil Services Compliance Evaluation Record Keeping Yes No NA NE Is a copy of the current NPDES permit available on site? Facility has copy of previous year's Annual Report on file for review? Comment: Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? Are the receiving water free of foam other than trace amounts and other debris? If effluent (diffuser pipes are required) are they operating properly? Comment: Effluent Sampling Yes No NA NE Is composite sampling flow proportional? Is sample collected below all treatment units? Is proper volume collected? Is the tubing clean? # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type representative)? The facility has not been estimating flow or sampling for pH semi-annually. See summary for details. Comment: Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? After reviewing the past five years of temperature data, the change in temperature between the upstream and downstream samples exceeded the General Permit limit of 0.5 degrees Celsius for trout water classifications. See summary for details. Comment: Page#4 DocuSign Envelope ID: A9972558-D3A3-495A-9F39-9C049237AC5D