NC0085359_Annual Report_20240206

RECEIVED
6 FEB 6 2024
U N I N DWRINPDES
NCDEQI
COUNTY
WATER
2023 PAR
Union County Water
Modified Program
NPDES0069841, Crooked Creek WRF
NPDES0085359, Twelve Mile WRF

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Annual IPP Summary; 2023
This report has been completed under the guidance of NCDEQ. On 1/3/2024 Union County Water received
clarification from NCDEQ that modified permits may submit partial report per 15A NCAC 02H .0908(c). This was
further clarified as"a letter to the Division giving a summary of activities during 2023 and planned work to be done
in 2024".
The Union County Water Modified Program was originally approved 1/20/1995 and was deemed inactive on
5/2/1999. The documentation for reactivation and approval was submitted to NCDEQ 9/26/2022.
The Union County Pretreatment Program was reactivated 8/23/2023. Included in the documentation provided
were the Headworks Analysis(HWA), Long Term Monitoring Plan(LTMP),Industrial Waste Survey(IWS),Sewer
Use Ordinance(SUO)and Enforcement Response Plan(ERP).
Union County Water Currently permits three(3); Non-Significant Industrial Users,zero(0);Significant Industrial
Users,and zero(0)Categorical Industrial Users;as well as monitors and inspects 343 Food Service Establishments
(FSE's)annually and provides annual training for grease haulers that service FSE's within the Union County Water
(UCW)Collection System.
Pretreatment contacts for Union County Water Include:
• Chris Clark;Water and Wastewater Division Director
• Josh Brooks;Water and Wastewater Assistant Division Director
• Jonathan Jordan;Water Reclamation Facilities Superintendent
• Kate Fleming; Industrial Pretreatment Program Manager
• Chad Green; Pretreatment Coordinator
The attached summary includes:
• Page 3: HWA and LIMP Overview
• Page 3: IWS and Dental Dischargers Overview
• Page 4-5: Narratives
• Page 6: PFAS Sampling Data
g P g
• Page 7-9: FOG Summary
• Page 10-11: Union County Projects
• Page 12-16:Special Investigations
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Pretreatment Program Requirements:
HWA and LTMP Overview:
• HWA was submitted with the program approval packet on 9/26/2022. NCDEQ required corrections to the
HWA were submitted and accepted on 9/22/2023.
• Neither basin is over allocated for any parameter other than silver. Silver over allocation is a statewide
problem due to the chronic criteria standards of 206 ug/I which is below the detection limit.
• LTMP sampling was conducted February 13-15 and 14-16;&July 20-22,2023. All results have been
entered into the HWA spreadsheet.
o LTMP sampling is scheduled to be conducted in February and July of the 2024 calendar year.
IWS and Dental Discharger Overview:
• Updated Dental Amalgam Listing 8/22/22; list is updated as new dentist offices open within the UCW
Collection System basin.
• There are currently 32 dental users;All current Dental Amalgam Forms have been received as 8/22/22.
• Consumption reports received on 1/24/23 indicated that Berry Global(Wesley Chapel Stouts Road)
consumed 25,000 GPD. Pretreatment staff conducted a site inspection on 7/2/21 and confirmed that all
process water is used for non-contact cooling and the majority of that water consumed is lost to
evaporation in the cooling towers.
o Average annual comingled domestic discharge and process flows are<10,000GPD and do not
meet the criteria of a Significant Industrial User.
o A follow-up with Berry Global will follow in 2024 to confirm that there have been no process
changes or expansions.
• IWS was last updated November 2022;at NCDEQ's request the IWS is in the process of being entered into
the new excel template.
• A full IWS will be conducted and evaluated in 2025.
o No SIU's permitted at this time.
o Three NSIU are permitted:
• Atrium Union West;#1001
• Keywell Metals,LLC#1002
• Allied Pressroom Products,#1003
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Narratives -IWS
Atrium, Union West; NSIU#1001
• Permit was issued on 9/2/21 with the effective dates of 12/1/2021 through 11/30/2026. This site is
permitted due to an onsite decontamination tank which must be sampled,and results reviewed and
approved by UCW prior to discharge if the decontamination meets the requirements set forth in Section
III-Special Conditions, D of NSIU Permit#1001.
• The Permittee does not meet the categorical criteria for Hospitals under 40 CFR 460 as it has less than
1000 beds;Atrium Union West's plans were approved with a maximum of 150 beds.
• Atrium Union West officially opened on February 22,2022.
• Site visit was conducted on March 1,2023; Kate Fleming,Shannon Bryne&Steve Geriner were present
during the site visit.The grease trap,grinder station and flume were inspected,and a walk through of the
entire facility was conducted to satisfy the UCW FOG program requirements.
• Flow records are submitted to UCW by Atrium Union West monthly.
• IWS dated 6/10/2021, received 7/15/2021.
• PFAS sampling was conducted 11/2/2022.
Keywell Metals; NSIU#1002:
• Permit was renewed with Keywell Metals effective 1/1/2022-12/31/26.
• The Permittee does not meet the categorical criteria of a Metal Finisher under 40 FR 433, nor do they
meet the criteria to be considered an SIU. Average daily flows are less than 25,000 gallons,the permittee
does not contribute more than 5%of conventional pollutants and is not considered to have potential to
impact the WRF currently.
• Permittee has pH adjustment,chemical precipitation,flow equalization,and clay absorption on site for
metals and solids removal.
• Sampling is conducted by Union County Water once per quarter. Sampling will continue throughout
2024.
o lst quarter sampling was conducted March 16-17,2023
o 2"d quarter sampling was conducted May 4-5,and 8,2023
O 3rd quarter sampling conducted July 26-27,2023
o 4th quarter sampling occurred November 16,2023.
• Annual Inspection was conducted 7/25/23.Additional Site visits occurred 2/28/23&3/23/23.
• IWS received 6/4/2021.
• PFAS sampling data was collected on 11/2/2022.
This facility receives used specialty aerospace metals millings(High Ni-Steel Alloy)for recycling. This is
achieved through resizing,crushing,and chipping,and preparation by washing with a 16-20%NaOH and KOH
solution along with well water to remove oily residues. The washing process is 2 stages,the first stage
incorporates the 16-20%NaOH/KOH solution,all water from this step goes through an oil/water separator
prior to pretreatment.The subsequent stage consists of 2 rinse tanks containing only well water;this water is
pumped to the pretreatment room. The spent NaOH/KOH soap solution is discharged at a rate of 6-8 GPM to
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pretreatment.All aqueous degreaser sludge is contained in totes and are hauled off by a third-party
environmental company.
To reduce the metal concentrations more effectively in the wastewater sent to the collection system,a
study was conducted in December 2022. 2;55 gallons drums of Polysulfide,TR-6&TR-50,for full-scale trials
were ordered and the chemicals were delivered the week of January 2"d,2023.A full-scale trial testing period
was conducted February 21st and 22"d of 2023 by Smith&Gardner comparing chemicals TR-6 and TR-50.
Parameters that were analyzed included pH,Alkalinity,TSS, HEM, BOD, Nickel,and Molybdenum.Waypoint
Analytical conducted the laboratory analysis.The report submitted to UCW on July 31,2023,showed results
that either polysulfide chemical,TR-6 or TR-50 could be used to lower the concentration of Nickel and
Molybdenum in the wash water with no negative impact. It was noted that the pH Controller onsite used only
a single point calibration and that it was recommended that a 2 or 3-point calibration be used to avoid swings
in pH measurements.As of January 2024, Keywell uses a 2-point calibration for pH adjustment and metal
precipitation.
On October 25,2023,email correspondence from Keywell Metals and Smith and Gardner communicated
an issue with the current diaphragm pump not being able to be adjusted low enough for proper treatment and
posing a safety concern to the operator due to chemical spraying out.A centrifugal pump was ordered and
installed to replace the diaphragm pump.
Allied Pressroom Products; NSIU#1003
• Permit was issued in person on 11/27/2023;effective 1/1/2024112/31/2029. This site is permitted due
to a special investigation involving released substances containing diesel and gasoline derivatives along
with trace xylenes. This location had the potential to impact due to floor drains in the chemical blending
process area and having bulk chemical onsite due to 2 sister locations shutting down in California and
Florida.
• The Permittee does not meet the criteria of an SIU. Current flows are less than 25,000 gpd with only
reverse osmosis process water being discharged from incoming water sources for purification of product.
All process drains have been sealed.
• This location has since plugged all floor drains, purchased onsite containment,and has begun blending
rinse water back into product. The only process water discharged to the collection system comes from an
onsite reverse osmosis unit to purify incoming water.
• No onsite sampling occurred in 2023.
• IWS received September 20, 2023.
• Annual Inspection was conducted September 26,2023.
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PFAS Sampling Data
November 2, 2023
• Sampling was conducted at 12-Mile INF, EFF,and Bio-Solids;Crooked Creek INF, EFF,and Solids; Keywell
Metals,Atrium, Union west;and Austin Chaney(Transfer Station Leachate).
• Analysis ran by Pace Analytical Labs.
PFOA PFOS GenX(HFPO) PFBS
12-Mile INF 6.41 ng/I 6.08 ng/I ND 6.92 ng/I
12-Mile EFF 14.7 ng/I 3.06 ng/I TBD 4.98 ng/I
12-Mile Residuals TBD TBD TBD TBD
Crooked INF 7.43 ng/I 7.06 ng/I TBD 11.0 ng/I
Crooked EFF 11.8 ng/I 5.47 ng/I TBD _ 20.2 ng/I
Crooked Residuals TBD TBD TBD TBD
Keywell 5.07 ng/I 4.5 ng/I TBD 2.09 ng/I
Atrium 3.47 ng/I 3.50 ng/I TBD 3.86 ng/I
Austin Chaney 110 ng/I 28.4 ng/I TBD 42.5 ng/I
May 23, 2023
• Sampling was conducted at 12-Mile INF, EFF,and Bio-Solids;Crooked Creek INF, EFF,and Solids;and
Austin Chaney(Transfer Station Leachate)on 6/9/2023.
• Analysis ran by Eurofins, Lancaster PA.
PFOA PFOS GenX(HFPO) PFBS PFNA PFHxS
12-Mile INF 9.4 ng/I 6.05 ng/I ND ND ND ND
12-Mile EFF 13.5 ng/I 2.7 ng/I ND 2.15 ng/I 1.25 ng/I 2.45 ng/I
12-Mile Residuals 4.3 ng/I 9.3 ng/I ND ND ND ND
Crooked INF 6.4 ng/I 6.85 ng/I ND 4.05 ng/I 1.2 ng/I 2.2 ng/I 1
Crooked EFF 17.5 ng/I 6.35 ng/I ND 9.15 ng/I 1.4 ng/I 3.45 ng/I
Crooked Residuals 18 ng/I 35 ng/I ND ND ND ND
Austin Chaney ND 1.7 ng/I ND ND ND ND
June 9, 2023
• Sampling was conducted at the Austin Chaney(Transfer Station Leachate).
• Analysis ran by Eurofins,Lancaster PA.
PFOA _ PFOS GenX(HFPO) PFBS PFNA PFHxS
Austin Chaney ND 1.7 ng/I ND ND ND ND
December 6, 2023
• Sampling was conducted at 12-Mile INF, EFF,and Bio-Solids;Crooked Creek INF, EFF,and Solids;and
Austin Chaney(Transfer Station Leachate).
• Samples were sent to Pace's Baton Rouge, LA laboratory; Results have not yet been received.
• PFAS will continue to be sampled at the WRF's and Transfer Station on a bi-annual frequency at minimum.
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FOG
SUMMARY:
Union County Water currently incorporates 343 total FSE's including schools.The aim of the program is to inspect
all FSE's twice annually,except for schools and low-level grease producers which are inspected once annually.
Throughout the 2024 calendar year it is our goal to extend our educational outreach efforts into the school system
and multi-family housing locations.
In August 2023 the FOG program began entering inspection data into the County's Lucity software program for
tracking purposes. The end goal is to have a heat map of problematic grease areas available on GIS to better focus
additional inspections and educational outreach. This map will cross refence FOG data along with SSO data from
the UCW collection system.
Total FSE Inspections NOD's Completed Plan Educational Mailings
Issued Reviews Delivered
662 36 283 4774
Grease Hauler Seminar:
• 15 companies attended the annual hauler training remotely on 5/25/2023.
• Emails were required from all who attended as proof of attendance.
q
• Certificates for all haulers in attendance were signed,scanned,&emailed/mailed as of 7/1/2023.
• Topics included: Regulations, Impact/Blockages/SS0's,Application Renewal,Application Requirements,
Permits, Inspections, Manifests, Reporting Requirements,&Enforcement.
• As grease haulers working within Union County were discovered remote training sessions were conducted
to issue permits accordingly.
• A Grease Hauler seminar(remote or in-person)is held annually for all grease waste haulers operating in
Union County.
Outreach Initiatives:
• IPP negotiated having 75 educational books,donated by the publisher, provided to each of the 48 public
and private elementary schools in the County,as well as to each public library within the UCW collection
system. "Winn and Doug, The Waterdrops;A water cycle and wastewater story"
o This resulted in invitations to conduct outreach events at several of the schools in the County
during the 2024 calendar year.
• Union County Waters November 2023 bill insert focused on FOG.
• 4774 FOG educational emails were sent to residents who live in communities that were recognized to be
impacted by grease&wipes.
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Notices of Deficiency Issued to FSE's:
• 1/13/23:China II Buffet located at 5850 Highway 74, Indian Trail.The existing grease trap needs to be replaced
with a 77 gpm unit or the dishwasher needs to be removed and a 37 gpm grease trap needs to be installed at
the 3-compartment sink and a 25 gpm grease trap installed at the 2-compartment sink by 4/30/23. Grease
traps were installed on 4/10/23;follow-up site visit on 4/12/23.
• 1/23/23: First China located at 6640 Old Monroe Road, Indian Trail.The existing grease trap located at the 3-
compartment sink needs to be replaced with a 40 gpm grease trap by 4/30/2023. Notification of grease trap
installation on 5/2/23;follow-up visit occurred on 5/3/23.
• 2/2/23: Pupuseria La Pasadita located at 4432 Potter Road in Stallings.The existing grease trap needs to be
replaced with a 35-gpm unit by April 30,2023.Trap has been replaced as of 6/19/23 due to shipment delays.
• 2/8/23: Noodles Kitchen located at 1369 Chestnut Lane in Matthews.The grease trap to be serviced within(3)
business days,or by Monday February 13,2023.Grease trap must remain on a quarterly service frequency.
Trap was serviced as of 2/20/23.
• 2/10/23: Bisonte Pizza located at 1381 Chestnut Lane in Matthews.The grease trap must be cleaned in (3)
business days or by 2/15/23.Trap was serviced 2/13/23.
• 2/10/23:Jersey Mike's located at 6580 Old Monroe Road in Indian Trail.The grease trap must be cleaned in (3)
business days or by 2/15/23 and remain on a monthly service frequency. Location has been serviced as of
2/23/23 and service frequency updated to monthly.
• 2/24/23:Ambriant at Austin Village located at 910 Chestnut Lane in Stallings.The grease trap needs an inlet
and outlet tee installed and ensure the proper downspouts are installed by 5/31/23.Tee's have been installed.
• 2/27/23:Wendy's at 2913 Wesley Chapel Stouts Road in Indian Trail.The grease trap needs an inlet and outlet
tee installed and ensure the proper downspouts are installed by 5/31/23.Tee's have been installed as of
7/20/23.
• 2/27/23: New Covenant CDC located at 5114 Rogers Road in Indian Trail.The grease trap needs to be serviced
within(5)business days or by March 6,2023.Shannon Bryne attended the pump out service on 3/6/23.
• 3/1/23:Waffle House located at 13727 E. Independence Boulevard in Indian Trail.The kitchen exhaust
exterior grease collection system needs to be cleaned by 3/10/23.The container was cleaned and new sand
placed inside the containment area.
• 3/15/23:Andy's Custard located at 9921 Rea Road in Waxhaw.The grease trap is to be serviced within(5)
business days,or by Wednesday March 22,2023. Trap was serviced 3/17/23.
• 3/27/23: Blue Door Deli located at 202 W. North Main Street,Waxhaw.Grease trap must be serviced within 3
days or by Thursday March 30,2023. Trap serviced om 3/29/23.
• 3/27/23: Mary O'Neils located at 116 West North Main Street,Waxhaw.Grease trap must be serviced within 3
days or by Thursday March 30,2023. Trap serviced om 3/29/23.
• 4/20/22:Culvers located at 5122 Old Charlotte Highway; had 3 business days to have the grease trap serviced.
No service records were onsite. Trap was serviced,follow-up inspection on 5/2/23.
• 3/27/23: Pizza Hut located at 6732 Old Monroe Road, Indian Trail. Grease Interceptor outlet tee must be
installed by 6/30/23. Tee installed on 6/30/23.
• 4/10/23: Popeye's located at 13800 East Independence Blvd., Indian Trail. Grease cleanout cap must be
replaced by 4/24/23.Cap replaced on 4/19/23.
• 5/2/23: Bill and Bob's Coffee Bar located at 2701 Old Monroe Road in Stallings.A(10)gallon grease trap needs
to be installed at the(3)compartment sink by July 31,2023.GT installed;follow-up on 8/1/23.
• 5/4/23:Taco Bell located at 3021 Wesley Chapel Stouts Road in Indian Trail.The grease trap service records
need to be available on site for a period of 3 years. Follow-up on 5/11/23, new management. Records are
onsite as of 12/14/23.
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• 5/9/23:Jimmy John's located at 6405 Old Monroe Road in Indian Trail.The grease trap needs to be serviced
within(5) business days or by May 16,2023.The location must remain on a monthly service frequency.GT
serviced on 5/12/23.
• 5/11/23:Charanda located at 6437 Old Monroe Road in Indian Trail.The grease interceptor needs to install
both Inlet and Outlet Tees with downspouts by 7/31/23. This location was reinspected on 7/20/23 and
1/12/24;the tees were not present. Due to IPP not conducting a follow-up in a reasonable timeframe after
the deadline, a new NOD has been issued and will be followed-up on within 30 days.
• 5/16/23: El Tecate Mexican Restaurant located at 1615 Providence Road located in Waxhaw.The grease trap
must be on a monthly service. Each service invoice must remain on site-available.Grease trap serviced
5/16/23.
• 5/30/23:Tap and Vine located at 6443 Old Monroe Road in Indian Trail.The grease trap must be on a monthly
service.The grease trap service manifest must be available for inspection.The used fryer oil container area
needs to be cleaned by June 6,2023. Grease trap service scheduled for 6/14/23;trap cleaned on 6/28/23.
• 6/1/23:Andy's Frozen Custard located at 9917 Rea Road in Waxhaw.The grease trap must remain on an 8-
week service frequency.The grease trap service records must be available for future inspections and retained
for(3)years.Trap serviced on 6/5/23.
• 6/9/23: Union Day located at 3000 Tilley Morris Road in Weddington.This location must have the grease
interceptor serviced by 7/7/23.The location needs to remain on an annual grease trap service frequency.The
location had the grease trap serviced on 2/13/23,service invoice was never forwarded.Closed 6/9/23.
• 6/28/23: Rock Store Express-Shell located at 13801 Providence Road,Weddington. Location must provide
grease trap records by 7/5/23. Records were received 7/14/23.
• 6/29/23: 701 Main located at 701 W.South Main Street,Waxhaw.Grease trap must be serviced within the
next 7 days or by 7/10/23.Trap was serviced 7/19/23.
• 7/25/23: Food Lion located at 7868 Idlewild Road, Indian Trail. Tee and downspout must be installed by
10/31/23.Tee's were installed 10/18/23.
• 8/4/23: Food Lion located at 1301 N. Broome Street,Waxhaw. A baffle inlet tee needs to be reattached by
9/30/23. Tee's installed;verification 1/12/24.
• 8/17/23: Ming Fu located at 8139 Kensington Drive,Waxhaw.The(3)interior grease traps must be serviced
within(3)business days or by 8/22/23. Trap serviced 8/23/23.
• 9/11/23:The Peach Cobbler Factory located at 1310 Wesley Chapel Road, Indian trail.Grease trap service was
previously skipped at must be cleaned within 10 days. Trapped serviced on 9/21/23;follow-up on 9/25/23.
• 9/15/23:Children's Lighthouse NC-4 located at 9918 Rea Road, Marvin.Grease trap service skipped;trap must
be cleaned within 10 days. Trap serviced 9/25/23.
• 11/17/23: Dunkin Donuts located at 14055 W Hwy 74, Indian Trail. Excessive solids trap must be serviced
within 10 days. Follow-up on 11/27/23 trap back in compliance.
• 11/20/23:Tap&Vine located at 6443 Old Monroe Road, Indian Trail. Grease Trap not being serviced on the
correct frequency; must be cleaned within 10 days. Follow-up on 12/13/23,trap back in compliance.
• 11/28/23:Crossroads Grill located at 112 N. Broome Street,Waxhaw. Excessive solids,grease trap not being
maintained properly. Must have grease trap cleaned within 10 business days. Follow-up on 12/13/23;trap in
back in compliance.
• 11/29/23: East Coast Wings located at 5410 Old Charlotte Hwy, Monroe. Excessive solids need to have grease
trap cleaned within 10 days,decreased frequency to 8-week service. Folow-up on 12/13/23,trap in
compliance.
• 12/28/23: Moochie's Tavern located at 15060 Idlewild Road, Matthews. No records on site,grease trap not
being properly maintained,no floor sink strainers. Follow-up on 1/2/24,location is back in compliance.
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Union County Activities; Other Projects:
Austin Chaney; Union County Solid Waste Transfer Station:
• The Crooked Creek ORC noticed a drop in DO after receiving a load of approximately 3,000
gallons from the Union County Solid Waste Transfer Station in late 2022;After looking at SCADA
trends it became apparent that there had historically been repetitive impact to the DO at the
Crooked Creek WRF from the transfer station leachate.
• Each hauled load is currently being sampled for NH3-N &COD.The below results are indicative
of why the DO drops after offloading.
• UCW is currently working with UC Solid Waste to lessen the impact to the Crooked Creek WRF.
• UCW received notice that the landfill transfer station is currently receiving poultry processing
waste(blood,tissue,etc.)due to Valley Proteins shutting down this portion of their rendering
process after being sold to Darling Ingredients. UC Solid Waste has been instructed by the
Board of County Commissioners to continue accepting poultry waste until the facilities are able
to purchase and install onsite grinders for the poultry waste material(expected June 2024).
• Meeting with Solid Waste on 12/5/23 resulted in a discussion of trial period where the poultry
processing waste would be segregated from the domestic trash and that it would be landfilled
without being placed on the tipping floor. No notice if this process has yet begun.
Date NH3-N COD
Domestic Level in SUO;25 mg/I Domestic Level in SUO;500 mg/I
9/20/23 385 mg/I 50,000 mg/I
10/6/23 350 mg/I 49,400 mg/I
10/24/23 1080 mg/I 62,200 mg/I
11/27/23 293 mg/I 64,300 mg/I
12/12/23* 372 mg/I 35,300 mg/I
12/13/23* 139 mg/I 39,400 mg/I
12/26/23 267 mg/I 37,200 mg/I
12/28/23* 114 mg/I 23,700 mg/I
1/4/24 141 mg/I 36,300 mg/I
1/10/24* 112 mg/I 53,900 mg/I
1/12/24* 100 mg/I 27,100 mg/I
* Significant rain event, 1.5"on 12/10/23, 2.6"on 12/26/23, 1.83"on 1/9/24
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Eastside I; Lift Station:
• Eastside l's heavy accumulation of trash was initially brought to IPP's attention on 5/2/22;a site visit was
conducted at Eastside I on 5/4/22. The source was identified as the Union County Jail.
• Meetings with Union County Sheriff's Office personnel were held on 7/22/22,9/7/22,&9/21/22,
where the following information has been communicated and continues to be discussed:
o The trash that is being discharged from the jail is causing issues for our collections system.
o This is a prohibited discharge as per our sewer use ordinance and we want to work with the
Sheriff's Office to correct the issues but that it needs to be corrected.
o UCW is expected to spend$40,000 annually on quarterly cleaning of this station. Cost Recovery
is something we may need to look down the road.
o What we are asking is what would be asked of other entities causing impact and that those
locations would be permitted,and civil penalties would be assessed if not corrected.
o The best option is to address the issue at the current flume&grinder station.
• 10/14/22:Discussions with Union County upper management resulted in a decision that the UC Jail
grinder station would be replaced with a mechanical bar screen set-up and that general funds would be
used to cover the cost.
• A plan to construct a new jail facility was passed by the Board of County Commissioners.
Thus,halting the project to install a mechanical bar screen at the current jail location.
• The County Manager placed it back on Union County Water to come up with an alternative solution in the
interim and those options are currently being explored.
o 3rd party contractor to service manual bar screen.
o Rental screening equipment.
o Hire additional Sheriff's Office or Facilities staff.
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SPECIAL INVESTIGATIONS:
Commercial Drive,Greenbriar Drive;Accumulation
Crooked Creek Basin
Background:October 21, 2022; Notification that contractors doing work off Greenbriar Drive discovered heavy
sludge with oily components that had a metallic smell. Keywell Metals and the properties off Commercial Drive
discharge to Green Briar Drive.
A site visit to Keywell Metals was conducted by IPP along with a phone call to Rich Polinski with Keywell Metals
explaining the issue. Composite samples were collected November 3,4,&11 at Keywell Metals;the results
indicated:
November 10,2022-IPP arrived on site at Keywell at 1330;samples were collected out of the larger cleanout that
is suspected to receive flows from Keywell's domestic flows.A visual site inspection was conducted;no noticeable
spills or evidence of a spill was noted. Multiple totes containing"dirty wash water"from the wash line are housed
in the warehouse area.There are no floor drains in this area.All totes are held until a truck load is accumulated
and then all totes are sent off as Haz-Waste to STAT Environmental.
• A sample was collectedfrom one ofthese totes chosen at random byIPP.
p
• A copy of the most recent manifest has been received.
• The pretreatment area was clean and was in working order.
January 17,2023-Engineering provided drawings showing ne line with three tanks which ties into Green Briar and
that it was approved.
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►i�� F3 f ( (�rl caunn es eereo
February 1,2023—A letter mailed to the owner of Davis Steel&Iron who owns the parcel that the 3 tank are on.
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February 17,2023 @ 1731-Phone Call with Weston Davis confirmed that the letter was received. Davis provided
photo documentation of previous exhaust stack with faulty gaskets.Weston believed the issue may have been
metal dust accumulation from the roof gutters that was somehow entering the sewer.There was a previous issue
with the gaskets on the exhaust stack on the roof along with a previous roof leak that lead to the discovery of the
accumulation sometime around 2013.Weston also stated that there was an agreement regarding the easement
that was recorded when the property was sold.According to Weston there was a clause in the agreement that
would relieve Davis Steel&Iron of any responsibility of the cleaning up the sludge or another issue causing
environmental impact. I expressed that we have been able to find very little documentation and requested that he
send any records and information he had.
February 21,2023-Weston Davis provided Sanitary Sewer easement agreement between Davis Steel&Iron and
property owner(s)at 1035 Commercial Drive.
February 28,2023 @ 1102am—Site Visit at Keywell Metals with Tony Tyson&Chuck Griffin. A site inspection
showed that the majority of the gutters now discharge to daylight.A few still discharged to storm.It was requested
that they look in to having someone smoke test the line for verification.While onsite UCW was provided with a
flash drive of the some of the lines at Keywell that were inspected and recorded in December of 2022.
March 13,2023 @ 0851: Email was received from Weston Davis containing 4 photos of lines that had been
unearthed previously and a rough schematic of a proposed water line addition.
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IPP received written notification on 3/17/23 from Weston Davis, representative of Davis Steel and Iron,that
"Keywell has indicated they are fully cooperating with Union County Water in addressing this issue.Additionally,
Keywell Metals has expressed their intention to continue sole use of this tank located on the property of Davis
Steel&Iron Company for their business operations.Although Davis Steel&Iron maintains ownership of the tank,
Keywell has acknowledged all responsibility for maintaining this tank and ensuring compliance with Union County.
Therefore, Davis Steel&Iron Company provided Keywell Metals temporary access to the property expressly and
solely to resolve any deficiencies determined by Union County Water until resolution is reached.
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As of 4/3/23 this project was resolved/closed.
• Scott Oliver at Keywell and a contracted with Aqua Doc to dye test the storm lines at 1035 Commercial
Drive;this testing was completed on 3/23/23 and confirmed that the gutters and storm lines from 1035
Commercial Drive are not attached to sanitary and are attached to storm.
• Stevens Septic in conjunction with Carolina Plumbing pumped out the lower tank located on the Vickie
drive parcel on 3/23/23.The pump out showed that the tank was mostly free of solids at the time of
cleaning.
• The upper septic tank located on the 1035 Commercial Drive parcel was pumped out by Stevens Septic on
4/3/23.
• A rough plumbing schematic below was provided by Weston Davis on 3/13/23.
o Updated redlines to this schematic and a statement of accuracy from Keywell Metals was
received on 4/3/23.
• Downstream lines off Greenbriar Drive were visually inspected by K. Fleming;there was no evidence of
solids build-up in the downstream lines at that time.
• Accumulation discovered was determined to be residual in the line from previous operations. Active 1
accumulation is not present in the tanks or downstream lines after cleaning and is not a result of
processes at Keywell Metals.
Helmsville Lift Station,Crooked Creek WRF;Illicit Fuel Discharge
Crooked Creek Basin
8/5/23
• Kate Fleming received notification from Rick Mareth at 1619 that Amy Molina-McCarley had reported a
strong fuel odor and that the gas alarm at the Crooked Creek wet well had alarmed at 1433. It was
reported that they couldn't detect the odor at the influent MH.
• Amy Collected samples for TPH, DRO&GRO at 1710.
• Kate Fleming arrived onsite and collected samples for TPH, DRO,&GRO at 1750.
• Kate Fleming arrived at Helmsville LS and collected samples for TPH,GRO&DRO at 1830. It was at the
time that it became apparent that a large amount of fuel had been illegally disposed of and that it was
largely present in the LS.
• Kate Fleming notified Matt Ferrell at 1837; Kevin Edgarton was on call and for me to reach out to Matt
Hargett regarding someone with a CDL. Matt Ferrell offered up the maintenance vac truck for the
containment of the fuel product from the Helmsville LS.
• Chad Green and Ray Davis arrived on site at 1900 at Helmsville with the Maintenance Vac Truck at and
began pumping out the LS.They were onsite until 2100 and the truck was full;around 1300 gallons.
o All contents of the truck were held until flash point sampling results were obtained. All contents
were taken to Haz-Mat for treatment and disposal.
• Upstream trace was conducted by IPP; results did not produce an indication of where the source may
have been coming from.
• Samples were collected at 2029 at Helmsville and confirmed that active inflow of fuel was no longer
occurring.
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The chart below indicates the results from the sampling event:
Location DRO(mg/I) GRO(mg/I)
Crooked Creek @ 1710 27.0 13.6
Crooked Creek @ 1740 49.8 18.8
Helmsville @ 1830 215000 701000
Helmsville @ 2030 17600 780
8/6/23
• Received a text on 8/6/23 at 1512 from Crooked Creek that the Gas alarm was going off at 1514.
• IPP contacted Maintenance and requested that the LS be kept at a higher level so that the fuel would be
less likely to pump to the plant as it is lighter and stays at the top of the water level.
• IPP arrived on site at Helmsville and collected a sample for visual confirmation at 1644. The sample
appeared normal and agreed that the odor was a fraction of what it was the day prior;that there was not
an additional active fuel discharge.
` 111/4
-4010*
1835 on 8/5/23; KF 1649 on 8/6/23; KF
8/7/23
• MH-5658, MH-5654, MH-5778,&MH-5664 were rechecked to see if a fuel odor could be detected. The
checks were inconclusive.
• Visited seven upstream sites that were potential contributors.
8/17/23
• Ten upstream sites were inspected,of these locations Allied Pressroom Products was identified as a
possible source.
o Allied Pressroom Products: Chemical Blender.This site has floor drains with plugs that may*
have been replaced before I walked into the process area as everyone seemed to be scrambling.
Various chemicals including kerosene,xylene and glycol ether were onsite in bulk.They were
instructed to improve their housekeeping and to have unused waste product and totes properly
disposed of and/or hauled offsite.
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8/23/23
• Kate Fleming revisited Allied Pressroom Products and completed a walk-through of the facility. The floor
drain has been replaced with a screwed in permeant plug.They have begun working on housekeeping,
chemical labeling,and organization. Rick Sures was provided with a long IWS/permit application and was
verbally informed that it was our intent to issue a general permit to the facility and that the application
needed to be returned within 30 days. Everyone seemed receptive and willing to cooperate. The NSIU for
Allied Pressroom products was effective as of 1/1/24.
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