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Home My WebLink AboutNC0082970_Compliance Evaluation Inspection_20210820DocuSign Envelope ID:2DD62FB8-B7A8-4D22-B2E6-C7F1BD7102AC ROY COOPER GaVPIiiGY ELIZABETH S. BISER.@�. Se�mrary S. DANIEL SMITH NORTH CAROLINA Dh tc Envero—tal Quality August 23, 2021 Pratt Summers, VP CTI of North Carolina Inc PO Box 576 Savannah, GA 31402-0576 SUBJECT: NOTICE OF DEFICIENCY Tracking Number: NOD-2021-PC-0442 Permit No. NCO082970 Wilmington Terminal Facility New Hanover County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Wilmington Terminal Facility on August 20, 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. NC0082970. A summary of the findings and comments noted during the inspection are provided in the enclosed copy of the inspection report. The following deficiency was noted during the inspection: Inspection Area Description of Deficiency Record Keeping Facility does not have a back-up ORC designated and been that way since 6-2020. Please note a new backup in required to be designated within 120 days of a vacancy, thus new one needs to designated ASAP. 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, carefully review these deficiencies and address the causes of non-compliance to prevent the recurrence of similar situations. If you should have any questions, please do not hesitate to contact Dean Hunkele with the Water Quality Regional Operations Section in the Wilmington Regional Office at 910-796-7215. Sincerely, DocuSigned by: 7F141E73B6F345IS_ Tom Tharrington, Asst. Regional Supervisor Water Quality Regional Operations Section Wilmington Regional Office Division of Water Resources, NCDEQ ATTACHMENT Cc: Upload to Laserfiche ANmf. bdlra Oepartimnot£nvhm mmlal QualLLyl �IrlslondWater &smeces m.v-D IQ�� Vrlminptcn Repima[Oface 103 N-ID,1re Ext mmI Mntm, Nonhl lm2WS 1 90.I9hR15 DocuSign Envelope ID: 2DD62FB8-B7A8-4D22-B2E6-C7F1 BD7102AC United States Environmental Protection Agency Form Approved. EPA Washington, D.C. 20460 OMB No. 2040-0057 Water Compliance Inspection Report Approval expires 8-31-98 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 1 IN I 2 u 3 I NCO082970 I11 121 21/08/20 I17 18I � I 19 I s I 201 211IIIII 111111III II III III1 I I IIIII IIIIIIIII II r6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved ------------------- 67 701L—I a I 71 [n LI 72 I ni I 71 I 74 79 I I I I I I I80 L-1 I I Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date POTW name and NPDES Dermit Number) 10:OOAM 21/08/20 17/01/01 Wilmington Terminal Facility 1002 S Front St Exit Time/Date Permit Expiration Date Wilmington NC 28401 11:30AM 21/08/20 21/12/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Anndell Barefoot-Ottaway//910-762-6615 ext 6111/9107626154 Philips Watts//910-251-1020 /9107622359 Thetis Anndella Ottaway/ORC/910-762-6615/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Matt Miller,PO Box 576 Savannah GA 314020576/EHS Specialist/912-236-1331/ Yes Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Flow Measurement Operations & Maintenar Records/Reports Self -Monitoring Progran 0 Facility Site Review Compliance Schedules Effluent/Receiving Wate 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 Dean Hunkele Docusignedby. DWR/WIRO WQ/910-796-7215/ L8/23/2021 E1D9294C4D3746E... Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date Doc Signed by: Tom TharriFgt�nµ�� WQ/ - - / 8/23/2021 ��DWR/WIRO 7F141 E73136F3456... EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# DocuSign Envelope ID: 2DD62FB8-B7A8-4D22-B2E6-C7F1 BD7102AC NPDES yr/mo/day Inspection Type NC0082970 I11 12I 21/08/20 117 18 i c i Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Overall, the site is doing fine with compliance even though turbidity from the O&W separators is difficult at times given the characteristics of the site. Only main issue noted is the facility lacks having a back-up ORC designated which is about 8 months past due to do so. Page# DocuSign Envelope ID: 2DD62FB8-B7A8-4D22-B2E6-C7F1 BD7102AC Permit: NCO082970 Inspection Date: 08/20/2021 Owner - Facility: Wilmington Terminal Facility Inspection Type: Compliance Evaluation Permit (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: Compliance Schedules Is there a compliance schedule for this facility? Is the facility compliant with the permit and conditions for the review period? Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Yes No NA NE ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ Comment: Since last inspection in 5-2016, the facility has had some simple Notices issued for effluent violations and been assessed civil penalties 3 other times (twice for BOD and once for missed sampling). No additional notices have been issued in some time for turbidity limit violations unless it impacts the river via reported data which is highly unlikely to occur. 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? ■ ❑ ❑ ❑ Page# 3 DocuSign Envelope ID: 2DD62FB8-B7A8-4D22-B2E6-C7F1 BD7102AC Permit: NCO082970 Owner - Facility: Wilmington Terminal Facility Inspection Date: 08/20/2021 Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Is the backup operator certified at one grade less or greater than the facility ❑ 0 ❑ ❑ classification? Is a copy of the current NPDES permit available on site? M ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review? ❑ ❑ 0 ❑ Comment: Facility does not have a back-up ORC designated and been that way since 6-2020. Please note a new backup in required to be designated within 120 days of a vacancy, thus new one needs to designated ASAP. Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? ■ ❑ ❑ ❑ Are all other parameters(excluding field parameters) performed by a certified lab? 0 ❑ ❑ ❑ # Is the facility using a contract lab? 0 ❑ ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 ❑ ❑ ❑ ■ degrees Celsius)? Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? ❑ ❑ ■ ❑ Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? ❑ ❑ 0 ❑ Comment: Grease Removal Yes No NA NE # Is automatic grease removal present? 0 ❑ ❑ ❑ Is grease removal operating properly? 0 ❑ ❑ ❑ Comment: Water within O&W separators appeared murky which could be the inside color of the steel tank, but there was some floating algae -like material in at least one. If its the tank that is colored/rusted, then could consider coating inside of tank with a lighter color to show clarity or lack thereof water better. Water leaving or set to leave O&W separators appeared to have better clarity. Effluent Sampling Yes No NA NE Is composite sampling flow proportional? ❑ ❑ 0 ❑ Is sample collected below all treatment units? 0 ❑ ❑ ❑ Is proper volume collected? ❑ ❑ ❑ Is the tubing clean? ❑ ❑ 0 ❑ # 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)? Comment: Page# 4 DocuSign Envelope ID: 2DD62FB8-B7A8-4D22-B2E6-C7F1 BD7102AC Permit: NCO082970 Inspection Date: 08/20/2021 Upstream / Downstream Sampling Owner - Facility: Wilmington Terminal Facility Inspection Type: Compliance Evaluation Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? Yes No NA NE ■ ❑ ❑ ❑ Comment: Very difficult to obtain representative samples from site due to extent of marsh, its depth, and influences of tidal activity. Operations & Maintenance Is the plant generally clean with acceptable housekeeping? Does the facility analyze process control parameters, for ex: MLSS, IVICRT, Settleable Solids, pH, DO, Sludge Judge, and other that are applicable? Yes No NA NE ■ ❑ ❑ ❑ ❑ ❑ ❑ Comment: This site is somewhat wetter and muddier than others inspector has been on; facility should examine if any improvements near drains feeding the O&W separators can be made to reduce or eliminate its entry into system if its occurring. Page# 5