NCS000520_Inspection Letter and Report_20220531

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
BRIAN WRENN
Director
NORTH CAROLINA
Environmental Quality
May 31, 2022
PCS Phosphate Company, Inc.
Attn: Kathryn Askew, Environmental Specialist
1530 NC Hwy 306 S
Aurora, NC 27806
Subject: NPDES Stormwater Permit No. NCS000520
Representative Outfall Status Request & Tier Sampling Relief
Morehead City Bulk Handling Facility
Carteret County
Dear Ms. Askew:
The Wilmington Regional Office staff of the Division of Energy, Mineral, and Land Resources has approved your
request for Representative Outfall Status that Outfall 001 is to represent Outfall 002. Please understand ROS
does not change the monitoring frequency required, nor does it change the required monitoring
parameters. ROS also does not reduce the qualitative monitoring (visual and odor characterization of the
discharge) required at all outfalls. If the permit requires a tiered response to benchmark exceedance's, then
an exceedance at the representative outfall may require attention to other sub -drainage areas represented
by the one outfall.
The Wilmington Regional Office staff of the Division of Energy, Mineral, and Land Resources has reviewed your
request for determination that Tler 2 status be relieved for all outfalls for the TSS, COD, and Total Phosphorus
benchmark parameters. Based on review of the sampling data 2013-2021, we are approving this request. This
approval is effective with the next sampling event. Please contact this office if there is an exceedance that is
significantly higher than the permit benchmark.
In addition, please remember that any actions you initiate in response to benchmark exceedance's as directed in
the tiered response provisions of your permit must address all drainage areas represented by Outfall 001, where
appropriate.
Please append this letter to your Stormwater Pollution Prevention Plan or permit to document that
representative outfall status has been approved. If changes in drainage areas, structures, processes, storage
practices, or other activities occur that significantly alter the basis of this approval, representative outfall status
may no longer be valid. You should either resume sampling at all storm water discharge outfalls, or reapply to
this office for representative outfall status based on updated information.
If you have any questions or concerns concerning this letter and the attached report, please contact Dan Sams
or me at [phone].
Sincerely,
Brian Lambe
Brian Lambe
Environmental Specialist
Land Quality Section
cc: SRO Files — Land Quality, LF
D�FQ North Carolina Department of Environmental Quality I Division of Energy, Mineral and land Resources
Wilmington Regional Office 1127 Cardinal Drive Extension I Wilmington, North Carolina 28405
u.w� /'V 910.796.7215

Compliance Inspection Report
Permit: NCS000520 Effective: 07/05/18 Expiration: 06/30/23 Owner : PCS Phosphate Company Inc
SOC: Effective: Expiration: Facility: Morehead City Bulk Handling Facility
County: Carteret 113 Arendell St
Region: Wilmington
Morehead City NC 28557
Contact Person: Danny Daniel Winstead Title: Phone: [phone]
Directions to Facility:
The port facility gate is on Arendell St., approx. 5.30 miles east of the intersection of US 70 and NC 24.
System Classifications: SWNC,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 05/26/2022 Entry ime 09:OOAM Exit Time: 10:OOAM
Primary Inspector: Brian P Lambe Phone:
C�
Secondary Inspector(s): /
i
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
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Permit: NCS000520 Owner - Facility: PCs Phosphate Company Inc
Inspection Date: 05/26/2022 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Request for tier releif from TSS, COD, and Total Phosporus recieved May 23, 2022.
The TSS data compiled by Nutrien since 2013 shows a period of results within the benchmark since 2014 with two
exceedances, one in 2020 and one in 2021. Nutrien has not conducted a significant amount of transport through the facility
in recent times. Other companies transport simalar materials through the permit boundaries. Nutrien contends they are a
contributing factor in the recent spikes.
Nutrien contends that the COD levels are not from thier activities, but rather from runoff from Hwy 70 adjacent to them
The total phosphorus data shows improvement from the 2008-2011 period to the current time. This improvement is indicative
to the efforts made to reduce product loss.
The sampling protocols can be returned to Tier 1 status until the permit expires. The detirmination can be re-evaluated during
permit renewal.
Request for Representative Outfall Status for Outfall 100 to represent Outfall 200. This was previously granted and continues
to be applicable for the site.
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