HomeMy WebLinkAboutNC0020656_Inspection_20080128O`=:
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January 28, 2008
City of Laurinburg
Attn: Robert Ellis, Treatment Plants Director
P.O.Box249
Laurinburg, NC 28353
rvlicnaei r. nasiey, governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
SUBJECT: January 15, 2008 Compliance Evaluation Inspection
City of Laurinburg WWTP
Permit No: NC0020656
Scotland County
Dear Mr. Ellis:
Coleen H. Sullins, Director
Division of Water Quality
Enclosed please find a copy of the Compliance Evaluation Inspection form from the inspection conducted on
January 15, 2008. The Compliance Evaluation Inspection was conducted by Mark Brantley, Environmental
Chemist, of the Fayetteville Regional Office. The cooperation of Ricky Odom, Grade IV ORC, was greatly
appreciated. The facility was found to be in Compliance with permit NC0020656. As a reminder, preservation of
the Waters of the State can only be achieved through consistent NPDES Permit compliance.
COMMENTS
• The WWTP was clean and neat in appearance at the time of the inspection.
• It was noted during the inspection this facility is not covered under a NPDES General Stormwater Permit
(NCG110000 series). Since this facility is permitted for more than a million gallons per day flow and it has
a point source discharge for stormwater it is necessary to apply for a NPDES General Stormwater Permit.
Enclosed is an application for the permit along with its technical bulletin that contains some useful
information. Please submit a completed application no later than February 22, 2008.
• The Leith Creek WWTP analyzes a large number of the required NPDES parameters. Due to the large
amount of laboratory work that is done by Mr. Ricky Odum, Chief Operator, the city may find it beneficial
to hire someone to run the required laboratory tests. This staff member would also be available to run a
variety of process control tests that would generate data in a timely manner that would assist the plant
operators in running the plant. This would allow Mr. Ricky Odum to spend more time doing his
operational duties.
• Alarms at the influent pump station werenot tested during the inspection. A log of test dates and times of
testing the alarms are kept by plant staff.
• During the walk through part of the inspection it was noted several areas on the banks of the equalization
basin have some erosion. Please repair and establish permanent grass cover to prevent erosion and
sedimentation runoff.
• It was also noted during the inspection that the brackets that hold the baffles in the aeration basins were
being replaced. The Fayetteville Regional Office would like to encourage the city to replace the baffles at
the same time since they are beginning to age and fail. This would aid in the operation of the aeration
basin.
North Carolina Division of Water Quality/Aquifer Protection Section 225 Green St./ Suite 714 Fayetteville, NC 28301 Phone (910) 433-3300
FAX (910) 486-0707 Internet: h2o.enr.state.nc.us . Customer Service 1-877-623-6748
Nne
orthCarolina
2atarra!!i
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper
• Laboratory bench sheets for the month of November 2007 were compared to the November DMR. All data
appeared to be reported correctly.
Please refer to the enclosed inspection report for additional observations and comments. If you or your staff have
any questions, please call me at 910-433-3327.
Sincerely,
Mark Brantley
Environmental Chemist
Surface Water Protection Section
Fayetteville Regional Office
cc: Ricky Odum, ORC
Central Files
Fayetteville Files
United States Environmental Protection Agency
.E PA 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
1 I NI 2 1 51 31 NC0020656 111 121 08/01/15 117
Type . Inspector Fac Type.
1811 c1 191 s1 201 11
I I I I I I •III I I I I I I I66
Remarks
21I I I I I I 1 I I I I I I I I I I I I I I I I I I. I� I II I • I
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved I,
671 169 701 31 • 7.1 1 NI 721 NI 73 11 174 751 1 1 1 1 1 1. 1 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)
Leith Creek WWTP
Hall St Extension
Laurinburg NC 28352
Entry Time/Date
09:30 AM 08/01/15
Permit Effective Date
04/11/01
Exit Time/Date -
12:00 PM 08/01/15
Permit Expiration Date
09/08/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Robert A. Ellis/ORC/910-277-0214/
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Robert A. Ellis,PO Box 249 Laurinburg NC 28353//910-277-0214/ No
Section C:_ Areas Evaluated During Inspection (Check only those areas evaluated)
Permit • Flow Measurement • Operations & Maintenance • Records/Reports
Self -Monitoring Program Sludge Handling Disposal • Facility Site Review •.Efuent/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
Mark Brantley FRO WQ//910-433-3300 Ext.727/
/WOK -- ei 1-'8' -G g .
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
Belinda S Henson FRO WQ//910-433-3300 Ext.726/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1
31
NPDES
NC0020656
I11 12I
yr/mo/day
08/01/15
17
Inspection Type
18ICI
(cont._) 1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
COMMENTS
• The WWTP was clean and neat in appearance at the time of the inspection.
• The Leith Creek WWTP analyzes a large number of the required NPDES parameters. Due to the large
•amount of laboratory work that is done by Mr. Ricky Odum, Chief Operator, the city may find it beneficial to
hire someone to run the required laboratory tests. This staff member would also be available to run a
variety of process control tests that would generate data in a timely manner that would assist the plant
operators in running the plant. This would allow Mr. Ricky Odum to spend more time doing his operational
duties.
• Alarms at the influent pump station were not tested during the inspection. A log of test dates and times
of testing the alarms are kept by plant staff.
• During the walk through part of the inspection it was noted several areas on the banks of the equalization
basin have some erosion. Please repair and establish permanent grass cover to prevent erosion and
sedimentation runoff.
• It was also noted during the inspection that the brackets that hold the baffles in the aeration basins were
being replaced. The Fayetteville Regional Office would like to encourage the city to replace the baffles at
the same time since they are beginning to age and fail. This would aid in the operation of the aeration
basin.
• Laboratory bench sheets for the month of November 2007 were compared to the November DMR. All
data appeared to be reported correctly.
Page # 2
Permit: NC0020656 Owner - Facility: Leith Creek WWTP
Inspection Date: 01/15/2008 Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ■ n n n
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ■ n n n
Judge, and other that are applicable?
Comment:
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:
Record Keeping
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?
Is a copy of the current NPDES permit available on site?
Yes No NA NE
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Yes No NA NE
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Page # 3
Permit: NC0020656 Owner - Facility: Leith Creek WWTP
Inspection Date: 01/15/2008 Inspection Type: Compliance Evaluation
Record Keeping
Facility has copy of previous year's Annual Report on file for review?
Comment:
Effluent Pipe
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:
Flow Measurement - Influent
# Is flow meter used for reporting?
Is flow meter calibrated annually?
Is the flow meter operational?
(If units are separated) Does the chart recorder match the flow meter?
Comment:
Flow Measurement - Effluent
# Is flow meter used for reporting?
Is flow meter calibrated annually?
Is the flow meter operational?
(If units are separated) Does the chart recorder match the flow meter?
Comment: The effluent flow meter was last calibrated on March 7, 2007.
Aerobic Digester
Is the capacity adequate?
Is the mixing adequate?
Is the site free of excessive foaming in the tank?
# Is the odor acceptable?
# Is tankage available for properly waste sludge?
Comment:
Drying Beds
Is there adequate drying bed space?
Is the sludge distribution on drying beds appropriate?
Are the drying beds free of vegetation?
Yes No NA NE
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Yes No NA NE
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Yes No NA NE
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Yes No NA NE
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Yes No NA NE
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Yes No NA NE
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Page # 4
Permit: NC0020656 Owner - Facility: Leith Creek WWTP
Inspection Date: 01/15/2008 Inspection Type: Compliance Evaluation
Drying Beds Yes No ;NA NE
# Is the site free of dry sludge remaining in beds? ■ n n n
Is the site free of stockpiled sludge? ■ ❑ n n
Is the filtrate from sludge drying beds returned to the front of the plant? ■ ❑ ❑
# Is the sludge disposed of through county landfill? n n ■ n
# Is the sludge land applied? Ennn
(Vacuum filters) Is polymer mixing adequate? n n ■ ❑
Comment: Approximately 800,000 gallons of sludge were land applied in Dec. 2007.
Two drying beds have been rebuilt. The retaining wall on one of the drying beds needs
to be repaired.
Pump Station - Influent
Is the pump wet well free of bypass lines or structures? •nnn
Is the wet well free of excessive grease? Ennn
Are all pumps present? ❑ ■ n n
Are all pumps operable? E n ❑ n
Are float controls operable? ■ ❑ ❑ ❑
Is SCADA telemetry available and operational? • n n n
Is audible and visual alarm available and operational? ■ ❑ n n
Comment: One influent pump is out for repair. The other three pumps are in working
order.
Bar Screens
Type of bar screen
a.Manual
b.Mechanical
Are the bars adequately screening debris?
Is the screen free of excessive debris?
Is disposal of screening in compliance?
Is the unit in good.condition?
Comment:
Grit Removal
Type of grit removal
a.Manual
Yes No NA NE
Yes No NA NE
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Yes ,No NA NE
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Page # , 5
Permit: NC0020656 Owner - Facility: Leith Creek WWTP
Inspection Date: 01/15/2008 Inspection Type: Compliance Evaluation
Grit Removal Yes No NA NE
b.Mechanical •
. Is the grit free of excessive organic matter? • n n n
Is the grit free of excessive odor? • n n n
# Is disposal of grit in compliance? I. ❑ n n
Comment: Auger screw is out for repair.
Equalization Basins Yes No NA NE
Is the basin aerated? • n n n
Is the basin free of bypass lines or structures to the natural environment? • n n 11
Is the basin free of excessive grease? ■ n n n
Are all pumps present? • n El .n
Are all pumps operable? ■ n n n
Are float controls operable? ■ El n n
Are audible and visual alarms operable? n n n ■
# Is basin size/volume adequate? n n ❑ •
Comment:
Secondary Clarifier Yes No NA NE
Is the clarifier free of black and odorous wastewater? • n n n
Is the site free of excessive buildup of solids in center well of circular clarifier? • n n n
Are weirs level? • n n n
Is the site free of weir blockage? ■ n n n
Is the site free of evidence of short-circuiting? • n ❑ n
Is scum removal adequate? • El 11 n
Is the site free of excessive floating sludge? ■ ❑ ❑ ❑
Is the drive unit operational? • n ❑ n
Is the return rate acceptable (low turbulence)? ■ n n n
Is the overflow clear of excessive solids/pin floc? ■ n ❑ n
Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth) • n n n
Comment: Clarifiers 1 and 3 had a sludge blanket of 7 feet. Clarifier number 2 was
not dischargeing at the time of the inspection due to an operational change that had
been made so some maintenance work could be performed on the aeration basin.
Page # 6
Permit: NC0020656 Owner - Facility: Leith Creek WWTP
Inspection Date: 01/15/2008 Inspection Type: Compliance Evaluation
Aeration Basins Yes No NA NE
Mode of operation Ext. Air
Type of aeration system Fixed
Is the basin free of dead spots? • ❑ 0 ❑
Are surface aerators and mixers operational? I. n n. n
Are the diffusers operational? n n ■ ❑
Is the foam the proper color for the treatment process? ■ n n n
Does the foam cover less than 25% of the basin's surface? ■ n n n
Is the DO level acceptable? ■ n n n
Is the DO level acceptable?(1.0 to 3.0 mg/I) ■ n ❑ n
Comment:
Oxidation Ditches Yes No NA NE
Are the aerators operational? • n ❑ n
Are the aerators free of excessive solids build up? • n n n
# Is the foam the proper color for the treatment process? • n n n
Does the foam cover less than 25% of the basin's surface? ■ n n n
Is the DO level acceptable? ■ n ❑ n
Are settleometer results acceptable (> 30 minutes)? n n n ■
Is the DO level acceptable?(1.0 to 3.0 mg/I) • n n n
Are settelometer results acceptable?(400 to 800 ml/I in 30 minutes) n n n ■
Comment:
Disinfection -Gas Yes No NA NE
Are cylinders secured adequately? ■ n n n
Are cylinders protected from direct sunlight? • fl n n
Is there adequate reserve supply of disinfectant? ■ n n n
Is the level of chlorine residual acceptable? • n n fl
Is the contact chamber free of growth, or sludge buildup? ❑ ■ n n.
Is there chlorine residual prior to de -chlorination? • n ❑ 11
Does the Stationary Source have more than 2500 lbs of Chlorine (CAS No. 7782-50-5)? n n ■
El
If yes, then is there a Risk Management Plan on site? n n ■ n
Page # 7
Permit: NC0020656 Owner - Facility: Leith Creek WWTP
Inspection Date: 01/15/2008 Inspection Type: Compliance Evaluation
Disinfection -Gas
If yes, then what is the EPA twelve digit ID Number? (1000- - )
If yes, then when was the RMP last updated?
Comment: One side of the chlorine contact chamber was being cleaned at the time of
the inspection. The other side of the chamber had 18 inches of sludge and was
scheduled to be cleaned as soon as the other side was back in service.
De -chlorination
Type of system ?
Is the feed ratio proportional to chlorine amount (1 to 1)?
Is storage appropriate for cylinders?
# Is de -chlorination substance stored away from chlorine containers?
Comment:
Are the tablets the proper size and type?
Are tablet de -chlorinators operational?
Number of tubes in use?
Comment:
Standby Power
Is automatically activated standby power available?
Is the generator tested by interrupting primary power source?
Is the generator tested under load?
Was generator tested & operational during the inspection?
Do the generator(s) have adequate capacity to operate the entire wastewater site?
Is there an emergency agreement with a fuel vendor for extended run on back-up power?
Is the generator fuel level monitored?
Comment:
Pumps-RAS-WAS
Are pumps in place?
Are pumps operational?
Are there adequate spare parts and supplies on site?
Comment: One return pump was out for repair but the other pumps were in working
order.
Laboratory
Yes No NA NE
Yes No NA NE
Gas
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Yes No NA NE
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Yes No NA NE
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Yes No NA NE
Page # 8
Permit: NC0020656 Owner - Facility: Leith Creek WWTP
Inspection Date: 01/15/2008 Inspection Type: Compliance Evaluation
Laboratory
Are field parameters performed by certified personnel or laboratory?
Are all other parameters(excluding field parameters) performed by a certified lab?
# Is the facility using a contract lab?
Is proper temperature set for sample storage (kept at 1.0 to 4.4 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?
Comment:
Influent Sampling
# Is composite sampling flow proportional?
Is sample collected above side streams?
Is proper volume collected?
Is the tubing clean?
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
Is sampling performed according to the permit?
Comment: The influent sampler was at 3degrees Celsius.
Effluent Sampling
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 1.0 to 4.4 degrees Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
Comment: The effluent sampler was at 2 degrees celsius.
Upstream / Downstream Sampling
Yes No NA NE
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Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? ■ 0 0 n
Comment:
Page # 9
FOR AGENCY USE ONLY
ATI
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Division of Water Quality /Water Quality Section
National Pollutant Discharge Elimination System
NCG110000
NIClGl
Date Received
Year
Month
Day
Certificate ofCoverage
Check #
Amount
Permit Assigned to
NOTICE OF INTENT
National Pollutant Discharge Elimination System application for coverage under General Permit
NCG110000:
STORMWATER DISCHARGES associated with activities classified as:
Treatment Works treating domestic sewage or any other sewage sludge or wastewater treatment
device or system, used in the storage, treatment, recycling, and reclamation of municipal or
domestic sewage, with a design flow of 1.0 million gallons per day or more, or required to have an
approved pretreatment program under Title 40 Code of Federal Regulations (CFR) Part 403,
including lands dedicated to the disposal of sewage sludge that is located within the confines of
the facility.
1) Mailing address* of owner/operator:
Name
Street Address
(Please print or type)
City State ZIP Code
Telephone No. Fax:
Address to which all permit correspondence will be mailed
2) Location of facility producing discharge:
Facility Name
Facility Contact
Street Address
City State ZIP Code
County
Telephone No. Fax:
3) Physical Location Information:
Please provide a narrative description of how to get to the facility (use street names, state road numbers, and
distance and direction from a roadway intersection).
(A copy of a county map or USGS quad sheet with facility clearly located on the map is required to be submitted with this application)
4) This NPDES Permit Application applies to which of the following :
❑ New or Proposed Facility Date operation is to begin
❑ Existing
5) Standard Industrial Classification:
Provide the 4 digit Standard Industrial Classification Code (SIC Code) that describes the primary industrial
activity at this facility
SIC Code:
Page 1 of 3
SWU-226-101701
NCG110000 N.O.I.
6) Provide a brief narrative description of the types of industrial activities and products manufactured at
this facility:
7) Discharge points / Receiving waters:
How many discharge points (ditches, pipes, channels, etc.) convey stormwater from the property?
What is the name of the body or bodies of water (creek, stream, river, lake, etc.) that the facility stormwater
discharges end up in?
If the site stormwater discharges to a separate storm sewer system, name the operator of the separate storm
sewer system (e.g. City of Raleigh municipal storm sewer).
8) Does this facility have any other NPDES permits?
❑ No
❑ Yes
If yes, list the permit numbers for all current NPDES permits for this facility:
9) Does this facility have any Non -Discharge permits (ex: recycle permits)?
❑ No
❑ Yes
If yes, list the permit numbers for all current Non -Discharge permits for this facility:
10) Does this facility employ any best management practices for stormwater control?
❑ No
❑ Yes
If yes, please briefly describe:
11) Does this facility have a Stormwater Pollution Prevention Plan?
❑ No
El Yes
If yes, when was it implemented?
12) Are vehicle maintenance activities occurring at this facility?
❑ No ❑ Yes
13) Hazardous Waste:
a) Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility?
❑No ❑Yes
b) Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous waste generated per month) of
hazardous waste?
❑ No ❑ Yes
c) Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste generated per month) of
hazardous waste?
El No ID Yes
d) If you answered yes to questions b. or c., please provide the following information:
Type(s) of waste:
Page2of3
S W U-226-101701
NCG110000 N.O.I.
4
S W U-226-101701
How is material stored:
Where is material stored:
How many disposal shipments per year:
Name of transport / disposal vendor:
Vendor address:
14) Certification:
North Carolina General Statute 143-215.6 b (i) provides 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 any
recording or monitoring device or method required to be operated or maintained under Article 21 or regulations of the
Environmental Management Commission implementing that Article, shall be guilty of a misdemeanor punishable by a
fine not to exceed $10,000, or by imprisonment not to exceed six months, or by both. (18 U.S.C. Section 1001 provides
a punishment by a fine of not more than $10,000 or imprisonment not more than 5 years, or both, for a similar offense.)
I hereby request coverage under the referenced General Permit. I understand that coverage under this permit
will constitute the permit requirements for the discharge(s) and is enforceable in the same manner as an
individual permit.
I certify that I am familiar with the information contained in this application and that to the best of my
knowledge and belief such information is true, complete, and accurate.
Printed Name of Person Signing:
Title:
(Signature of Applicant) (Date Signed)
Notice of Intent must be accompanied by a check or money order for $100.00 made payable to:
NCDENR
Final Checklist
This application will be returned as incomplete unless all of the following items have been included:
❑ Check for $100 made payable to NCDENR
❑ This completed application and all supporting documents
❑ Copy of county map or USGS quad sheet with location of facility clearly marked on map
Mail the entire package to:
Stormwater Permitting Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Note
The submission of this document does not guarantee the issuance of an NPDES permit.
Page3of3
Technical Bulletin
For STORMWATER GENERAL PERMITS
AA
�r
NCDENR
NORTH CAROLINA DIVISION OF WATER QUALITY
April 16, 2003, rev. 1/9/08
NCG050000, NCG070000, NCG110000, NCG130000, NCG170000, and NCG210000
The stormwater permitting
program's objective is to reduce the
pollutant load in stormwater runoff
1- Educating the permitted
community about stormwater
pollutants,
2- Encouraging the use of Best
Management Practices (BMPs)
to minimize the entry of
pollutants into stormwater, and
3- Using collected analytical data to
assess stormwater's contribution
to water pollution to help
prioritize controls in problem
areas.
Key Permit Requirements
❑ Implementation of a Stormwater
Pollution Prevention Plan (SPPP)
(Part II, Section A).
O Provide secondary containment
for all bulk storage of liquid
materials. (Part II, Section A: 2.
(b)).
O Perform and document semi-
annual qualitative monitoring.
(Part II, Section B).
❑ Perform annual analytical
monitoring for vehicle
maintenance area, if present, and
submit the results on the
monitoring report forms
provided with the permit. (Part
II, Section C).
Obtaining Representative Outfall
Status
If a facility has more than one
stormwater outfall from the vehicle
maintenance area(s) then the permit
requires that all such outfalls be
monitored. However, the permit also
allows for the facility to request
"Representative Outfall Status".
Representative outfall status allows
the facility to perform analytical
monitoring at a reduced number of
outfalls. Application is made by a
letter to the Stormwater and General
Permits Unit clearly explaining which
outfall(s) is/are to be considered
representative of other discharges
from the site. A copy of the site map
used in the SPPP that delineates
drainage areas, industrial activities,
and any other potential stormwater
pollutant exposures shall be included
with the letter to support the
application.
BMP's
The Stormwater Pollution Prevention
Plan should include the use of Best
Management Practices (BMP's) to
control the discharge of pollutants"
from a facility's stormwater outfalls.
BMP's include a variety of things
that the industrial facility can do in
order to minimize the potential for
pollutants to get into the stormwater
draining from a facility. The
following outlines some potential
types of BMP's.
Non -Structural BMP's
Some examples of non-structural
(practices or activities) BMP's are as
follows:
• Eliminate exposure of materials
and equipment wherever possible
by moving materials and
equipment to indoor locations.
• A very effective and cost
effective BMP is to practice
good housekeeping on -site.
Keep materials handled and
stored at the facility in an orderly
fashion.
• Examine process and exchange
hazardous materials for non-
hazardous ones wherever
possible.
• Establish routine leak and
maintenance checks to minimize
the chance of spills before they
occur. When spills do occur,
clean them up immediately.
• Establish bulk storage tank
protocols that minimize the risk
of spills during loading and
unloading procedures.
• Store used pallets and process
waste dumpsters inside or under
a roof where water cannot flow
on or around them.
Structural BMP's
Some examples of structural
(equipment or devices) BMP's are as
follows:
• Build containment dikes around
the loading areas of bulk liquid
storage containers.
• Where practical, change painting
operations from liquid systems to
powdered systems that don't
generate solvent wastes.
• Build roofs and secondary
containment around any
materials stored outside so that
stormwater doesn't run onto them
and carry pollutants away with it.
No Exposure Certification
A facility with an industrial activity
subject to the NPDES Stormwater
regulations that eliminates all
potential stormwater exposure on
site is now eligible for a No
Exposure Exclusion from a
stormwater permit (the exemption is
no longer restricted to Category 11
activities). A facility that meets
these conditions may fill out a No
Exposure Certification application
form (see NC DWQ's Stormwater
Permitting Unit's website:
http://h2o.enr.state.nc.us/su. ) to
apply for a No Exposure Exclusion
and to request recission of the
existing permit (if applicable). If
approved, the facility must re-
certify No Exposure every five (5)
years.
J
Other sources of information on
North Carolina's Stormwater
Permitting Program
The following documents are
available through the stormwater
permitting group by calling (919)733-
5083.
• Summary of Federal National
Pollutant Discharge Application
Regulations for Stormwater
Discharges Associated with
Industrial Activities.
• Stormwater Pollution Prevention
Plans for Stormwater Runoff at
Industrial Activities.
• Stormwater Pollution Prevention
Plan Guidance Document.
• Stormwater Management
Guidance Manual.
The Unit can be found on the World
Wide Web at
1-1ttn:l/h2o.enrst ate.nc.us/su/storm
water.html. Another source of
information is the DENR Customer
Service Center. They may be reached
at 1-877-NC ENR 4 U (1-877-623-
6748) or http://www.envhelp.org/.
An additional source of information
is the Division of Pollution
Prevention and Environmental
Assistance. They have lots of
specific information on how to
minimize pollutants at various types
of industries. They may be reached
at (919) 571-4100 or
http://www.p2pays.org/.
Commonly asked questions
1) Do all stormwater outfalls need
to be analytically monitored?
Only those outfalls that drain areas of
the facility where vehicle
maintenance activities using over 55
gallons of new motor oil per month
need to be analytically monitored.
Also, see previous discussion on
representative outfall status.
2) What happens if when I pull
samples for my annual
analytical monitoring I'm
unable to get a sample for one
of the parameters?
If this happens it is fine to go ahead
and just sample for the missing
parameter during the next
representative storm event, just be
sure to note the total rainfall, event
duration, and totalflow apart from
the initial monitoring data.
3) Does a certified lab need to be
used to analyze stormwater
samples?
Monitoring under all NPDES permits
must be conducted in accordance to
test procedures approved under
federal regulations in 40 CFR § 136.
All labs certified by North Carolina
perform analysis in accordance with
those procedures. So, while facilities
that are not considered Water
Pollution Control Systems under
T15A NCAC 8G .0306 do not need
to meet and maintain certification
requirements, any data gathered
under an NPDES permit must
conform to federal requirements.
Using a North Carolina certified lab
is often the easiest way to ensure
compliance with NPDES Program
requirements.
Note that pH is a special case (a field
parameter) and must be measured
within 15 minutes. You must either
train on -site staff to conduct pH
measurements in accordance with
approved methods or contract with
commercial services that can monitor
pH properly at your site. All labs
with N.C. wastewater field parameter
certification as per 15A NCAC 2H
.0800 can perform pH analysis in
accordance with federal procedures.
A list of labs with field parameter
certification is available from DWQ's
Laboratory Certification Branch at:
http://h2o.enr.state.nc.us/lab/cert.htrn
4) How do you average the first
year's analytical monitoring
results?
The measured concentration of a
particular pollutant collected during
the first year's analytical monitoring
is the average value for that
parameter since dividing it by one
gives the same value for cut-off
purposes.
5) What If I Sell My Business Or
The Name of My Business
Changes ?
The Division views changes of
name or ownership as a minor
modification and requires the
Director's approval. Name and
ownership changes require you to
complete a Name/Ownership
Change Form SWU-239. The form
is downloadable from our website.
Changes in Reissued General
Permits
These permits include some
clarifying and updated language
throughout the permit. In addition
language has been added to address
coverage under these permits for
discharges to waters with approved
TMDLs (Part I Section A).
Language has also been added to
Part I Section B in reference to
water quality standards.
Other Information
Additional Technical Bulletins will
be available in the future from the
Division. Contact us at:
http://h2o.enr.state.nc.us/su/stor
mwater.html
N.C. Division of Water Quality
Water Quality Section
Stormwater and General Permits Unit
1617 Mail Service Center
Raleigh, N.C. 27699-1617
Phone 919-733-5083
Fax 919-733-0719
Please make us aware of any
issues you feel should be
addressed in future Technical
Bulletins.