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HomeMy WebLinkAboutNCG210432_Compliance Inspection_20210930Moore, James From: Barton, Mary <Mary.Barton@tetratech.com> Sent: Thursday, September 30, 2021 8:35 AM To: Moore, James Cc: Dalsing, Dakota Subject: [External] Request for consideration of analytical monitoring waiver CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Mr. Moore, As we discussed today by phone, my client, CHEP Services at 5808 Long Creek Park Drive appears to meet the criteria for the waiver from analytical monitoring as written in the General Industrial Stormwater Permit for the Lumber and Wood Sector, and requests an inspection to determine the validity of this claim. The facility is covered under NCG21000, with a Certificate of Coverage number NCG210432. This is a pallet recycling facility with no treated wood products and outdoor exposure is limited to a wood chipper and a general waste dumpster. When I visited the facility last week, I noted a very small amount of wood chip material adjacent to the chipper, but was told that this material is routinely cleaned up and placed into the covered wood chip bins for ultimate disposal through a third party hauler. The material is cleaned up more than once per week. Per NCG210000, Part II, Section B: SECTION B: ANALYTICAL MONITORING REQUIREMENTS A facility that retains exposed accumulations (either exposed to incident precipitation or exposed to stormwater run on) of sawdust, wood chips, bark, mulch, or other similarly sized material on site for more than seven (7) days is required to monitor and report all the site stormwater discharges for the parameters in Table 1. The permittee may petition the DEMLR Regional Office Supervisor to he excused from the required monitoring: a) upon a DEMLR Compliance Evaluation Inspection, and; b) on the basis that DEMLR concludes that taken as a whole, site -wide conditions support the assessment of very limited risk of stormwater pollution from the site. c) Among any other factors deemed relevant in his or her own considerations, the Regional Office Supervisor shall consider whether the amount of accumulated exposed materials may be deemed de minimis with respect to the potential to generate stormwater runoff pollutants. Given that all site conditions may be relevant to the determination of what constitutes a de minimis amount, such determinations shall be made on a'case-by-case basis', and shall not be assumed to be generally, or specifically, transferrable to any other permitted site, regardless of superficial similarities. d) The Regional Office Supervisor will communicate any such determination in writing, and shall state any qualifying conditions for the permittee's continuing release from monitoring. DEMLR's release letter may remain in effect through subsequent reissued versions of this permit, unless the release letter provides for other conditions or duration. e) If released from monitoring, the permittee must still continue to submit semi-annual Discharge Monitoring Reports, with the notation: 'Released from Monitoring by DEMLR Regional Office.' if at any time there are changes to DEMLR's initial site assessment, or to the initial site operating circumstances, the permittee must immediately begin analytical monitoring and reporting th accordance with Tables 1 and 2, and must immediately inform the DEMLR Regional Office that analytical monitoring has been instituted. Mr. Dakota Dalsing is the Site Safety Lead for the site and is my Stormwater Management Team contact at the site. His phone number is 803-981-3771. Could we ask you to take a look, and let us know if the site meets the criteria for a waiver from the semiannual analytical monitoring of TSS and COD? It is understood that semiannual site inspections and semiannual qualitative monitoring (visual assessment) would still be required compliance measures. If the site does meet the criteria for the waiver, please advise us on the resulting requirements pertaining to semiannual DMRs and Annual Data Summary reporting. For example, would the eDMR still need to be submitted semiannually, with a code checked for not applicable? Thank you for your consideration, Mary Mary Barton, P.E. I Environmental Compliance Specialist I Atlanta Office Cell: 770.670.9966 m a ry. ba rtonONetratech. com Tetra Tech, Inc. 1899 Powers Ferry Road SE, Suite 400 I Atlanta, GA 30339 I www.tetratech.com Compliance Inspection Report Permit: NCG210432 Effective: 08/01/18 Expiration: 07/31/23 Owner: Chep Services LLC SOC: Effective: Expiration: Facility: CHEP Charlotte County: Mecklenburg 5808 Long Creek Park Dr Region: Mooresville Charlotte NC 28269 Contact Person: Derek Anthony Title: Phone: 704-921-1928 Directions to Facility: From the intersection of WW harrison blvd & i-77 proceed east on ww harrison blvd to statesville rd and proceed south for 1.25 mi site will be on the east side of the rd System Classifications: SWNC, Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 10/13/2021 Entry Time 09:15AM Exit Time: 10:15AM Primary Inspector: James D Moore Phone: 704-663-1699 Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Technical Assistance Permit Inspection Type: Timber Products Stormwater Discharge COC Facility Status: Compliant Not Compliant Question Areas: Storm Water (See attachment summary) Page 1 of 3 Permit: NCG210432 Owner - Facility: Chep Services LLC Inspection Date: 10/13/2021 Inspection Type : Technical Assistance Reason for Visit: Routine Analytical Monitorinq Yes No NA NE Has the facility conducted its Analytical monitoring? ■ ❑ ❑ ❑ # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ ■ ❑ Comment: Based on the inspection and the limited potential to impact stormwater from the industrial activity, the site is eligible for a release from analytical monitoring. Permit and Outfalls # Is a copy of the Permit and the Certificate of Coverage available at the site? # Were all outfalls observed during the inspection? # If the facility has representative outfall status, is it properly documented by the Division? # Has the facility evaluated all illicit (non stormwater) discharges? Comment: All outfalls were observed, they are curb inlets at the rear of the site. Yes No NA NE Page 3 of 3 £ 10 Z afied •papuawwooai si liwjad 00006ZJON ay} I0 8 uoiIoaS'll fed ui sjuawaimbai 6upopow ayj jo asealai a uoi�oadsui aye uo pase8 :kewwnS uoipedsul sugnoa :;isin jol uoseaa eoue;sissy jeojuyoal: adAjL uoi;3adsul LZOZ/£6/OL :a;ep uoi;oadsul 0-1-1 saoiAieS dayo:/yijiae-A - jeumo UVOLZooN :;4waad Compliance Inspection Report Permit: NCG210432 Effective: 08/01/18 Expiration: 07/31/23 Owner: Chep Services LLC SOC: Effective: Expiration: Facility: CHEP Charlotte County: Mecklenburg 5808 Long Creek Park Dr Region: Mooresville Charlotte NC 28269 Contact Person: Derek Anthony Title: Phone: 704-921-1928 Directions to Facility: From the intersection of WW harrison blvd & i-77 proceed east on ww harrison blvd to statesville rd and proceed south for 1.25 mi site will be on the east side of the rd System Classifications: SWNC, Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 12/19/2019 Entry Time 01:30PM Exit Time: 02:30PM Primary Inspector: Water Quality Program Meckenburg County Phone: 704-336-5449 Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Timber Products Stormwater Discharge COC Facility Status: Compliant Not Compliant Question Areas: Storm Water (See attachment summary) Page 1 of 3 Permit: NCG210432 Owner - Facility: Chep Services LLC Inspection Date: 12/19/2019 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: During the recent inspection, CHEP was observed to be in compliance with the City of Charlotte Storm Water Pollution Control Ordinance and the NCG05 permit. Page 2 of 3 Permit: NCG210432 Owner - Facility: Chep Services LLC Inspection Date: 12/19/2019 Inspection Type: Compliance Evaluation Reason for Visit: Routine Stormwater Pollution Prevention Plan Yes No NA NE Does the site have a Stormwater Pollution Prevention Plan? ❑ ❑ ❑ # Does the Plan include a General Location (USGS) map? ❑ ❑ ❑ # Does the Plan include a "Narrative Description of Practices"? ❑ ❑ ❑ # Does the Plan include a detailed site map including outfall locations and drainage areas? 0 ❑ ❑ ❑ # Does the Plan include a list of significant spills occurring during the past 3 years? ❑ ❑ ❑ # Has the facility evaluated feasible alternatives to current practices? ❑ 0 ❑ # Does the facility provide all necessary secondary containment? M ❑ ❑ ❑ # Does the Plan include a BMP summary? 0 ❑ ❑ ❑ # Does the Plan include a Spill Prevention and Response Plan (SPRP)? 0 ❑ ❑ ❑ # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? 0 ❑ ❑ ❑ # Does the facility provide and document Employee Training? ❑ ❑ ❑ # Does the Plan include a list of Responsible Party(s)? ❑ ❑ ❑ # Is the Plan reviewed and updated annually? ❑ ❑ ❑ # Does the Plan include a Stormwater Facility Inspection Program? ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? ❑ ❑ ❑ Comment: Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ❑ ❑ ❑ Comment: Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? ❑ ❑ ❑ # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ ❑ Comment: Permit and Outfalls Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? ❑ ❑ ❑ # Were all outfalls observed during the inspection? ❑ ❑ ❑ # If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ M ❑ # Has the facility evaluated all illicit (non stormwater) discharges? 1111 ❑ Comment: Page 3 of 3