NCS000312 2008 Staff Report

NCS000312
F W A T� Michael F. Easley, Governor
Q�� RQ�i5William Ross Secretary l `� North Carolina Department of Environment and -Natural Resources
Coleen H. Sullins Director
1 Division of Water Quality
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STAFF REVIEW AND EVALUATION
NPDES Stormwater Pertnit
Facility Name:
Heritage Environmental Services, LLC
NPDES Permit Number:
NCS000312
Facility Location:
4132 Pompano Road, Charlotte, NC (Mecklenburg County)
Type of Activity:
Hazardous Waste TSD facility
SIC Code:
4953
Receiving Streams:
Stewart Creek, See Figure 1
River Basin:
Catawba River Basin, Sub -basin 03-08-34
Stream Classification: '
C
Proposed Permit Requirements:
See attached draft permit.
Monitoring Data:
See copy of renewal application.
Response Requested by (Date):
December 31, 2008
Central Office Staff Contact:
Return to: Robert Patterson, [phone]
Special Issues:
Issue
Rating Scale: 1(easy) to 10(hard)
Com fiance histo
1
Benchmark exceedance
3
Location (TMDL, T&E
species, etc)
5
Other Challenges:
1
Difficulty Rating:
10140
Description of Onsite Activities:
• This is a hazardous waste TSD facility. Hazardous and non -hazardous waste come in by truck,
unloaded, tested, and stored under cover. It is then later shipped out.
Documents Reviewed:
• NPDES Stormwater Permit Application Materials
• National Heritage Program (NHP) Threatened and Endangered Species Database
• SPU File, Central Files, EPA Sector -Specific Permit, 2008
• 303(4) List, 2008 draft, 2006 final
• 2004 Catawba Basinwide Plan
History:
• Date permit first issued: September 29, 1995
• Date permit re -issued: April 5, 2002
• Date permittee submitted renewal application: October 31, 2006
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NCS000312
NC 000 1
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Weritage Envirmimental Services, LLMC
Latitude: 350 16 41" N
Longitude: 800 52' 17"W
County: Mecklenbmg
Receiving Steam: Stewart Qeek
Stream Class: C
Sub -basin: 03-08-34 (Catawba River Basin)
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Facility Location

NCS000312
Central Office Review Summary:
1. Owner's Other Permits:
RCRA Permit
2. General Observations:
• One of the three loading/unloading areas shown on the site plan is not covered.
• Most all of the site is under cover.
• The entire site appears to drain to a single outfall at the northeast corner of the property. It is all
captured by a concrete basin with the valve closed. After a rain event the water is visually inspected before
it is released to the stream.
3. Irn aunt: Not on 3034 list. Watershed subject to a TMDL for turbidity approved February 8, 2005; and a
TMDL for fecal coliform approved March 28, 2002.
4. Threatened and Endangered: None.
5. Industrial Changes Since Previous Permit: 5 tanks that were in the building were closed. They stopped doing
ww treatment of inorganic wastewater, which eliminated the need for certain ww treatment reagents.
6. Analytical Monitoring Notes: None required in last permit term. Mecklenburg county did do some sampling in
February 2002, which is provided in the application package. Copper and Zinc were above the current
benchmark, but are hardness dependant. Iron was slightly above the benchmark. Chromium was right at the
benchmark. Copper, Zinc, Iron, and Chromium are not in the EPA Sector -Specific permit. The EPA Sector -
Specific permit includes monitoring for Ammonia, Magnesium, COD, Arsenic, Cadmium, Cyanide, Lead,
Mercury, Selenium, and Silver. Most of these were below detection limits or well below the current benchmark,
so they.are not added to the analytical monitoring. Magnesium and Cyanide were not tested for.
7. Qualitative Monitoring Notes: Performed as required. Water most of the time had a brown color, with leaves
and/or pollen floating. Suspended solids were noted to be minimal.
Revised Permit Recommendations: Analytical Monitoring:
1. Add COD, pH, and TSS to the analytical monitoring parameters. TSS added due to TMDL for turbidity. COD
added due to various possible chemicals on site and it is in the EPA sector -specific permit. Based on the site
configuration and monitoring done by the county, the other parameters in the EPA sector -specific permit are not
being added. If MRO goes out to the site and feels otherwise based on the site visit, then the parameters can be
added.
2. All analytical monitoring has been set to semi-annually during a representative storm event as defined in Part H
Section B. The permittee must also document the total precipitation for each event. If no discharge occurs
during the sampling period, the permittee must submit a monitoring report indicating "No Flow" within 30 days
of the end of the six-month sampling period. Additionally, samples must be taken a minimum of 60 days apart,
as specified in Table 2.
3. Benchmarks for analytical monitoring have been added to this draft permit. Exceedances of benchmark values
require the permittee to increase monitoring, increase management actions, increase record keeping, and/or
install stormwater Best Management Practices (BMPs) in a tiered program. If the sampling results are above a
benchmark value, or outside of the benchmark range, for any parameter at any outfall then the facility shall
follow the Tier 1 guidelines which require a facility inspection within two weeks and implementation of a
mitigation plan within two months. If during the term of this permit, the sampling results are above the
benchmark values, or outside of the benchmark range, for any specific parameter at a specific discharge outfall
two times in a row (consecutive), then the facility shall follow the Tier 2 guidelines which require a repetition of
the steps listed for Tier I and also immediately institute monthly monitoring for all parameters at every outfall
where a sampling result exceeded the benchmark value for two consecutive samples.
4. The permittee is required to collect all of the analytical and qualitative monitoring samples during representative
storm events as defined in Part II Section B. Qualitative monitoring is required regardless of representative
outfall status.
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NCS000312
5. The permittee is responsible for all monitoring until the renewal permit is issued. See Footnote 1 of Tables 1, 4,
and 5.
6. The flow reporting requirement has been removed per DWQ revised strategy. (The total rainfall parameter is in
this permit, however.)
7. Vehicle maintenance monitoring has been revised to semi-annually in order to coincide with analytical and
qualitative monitoring.
Other Proposed Changes to the Previous Permit:
I . Additional guidance is provided about the Site Plan requirements. The site map must now identify if the
receiving stream is impaired and if it has a TMDL established. It must also describe potential pollutants in each
outfall. The map requirements are stated more explicitly. And, the site plan must contain a list of significant
spills that have occurred in the past three years and also must certify that the outfalls have been inspected to
ensure that they do not contain non-stormwater discharges. Additional information is provided in Part II Section
A.
2. Additional requirements for the Stormwater Management Plan have been specified in Part II Section A. More
details regarding secondary containment are provided.
3. Additional requirements for the Stormwater Pollution Prevention Plan have been specified in Part II Section A.
The plan must also be updated annually to include a list of significant spills and to certify that the outfalls do not
contain non-stormwater discharges.
4. The facility must now implement a semi-annual Facility Inspection Program of the site's stormwater
management controls as specified in Part II Section A.
5. Information regarding the No Exposure Exclusion has been added to this draft permit. If industrial materials and
activities are not exposed to precipitation or runoff as described in 40 CFR §122.26(g), the facility may qualify
for a No Exposure Exclusion from NPDES stormwater discharge permit requirements. Additional information
is provided in Part I Section A.
Discussions with permittee: Craig Hogarth, 317-486-2783, November 21, 2008
Confirmed general observations.
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NCS000312
Recommendations: Based on the documents reviewed, the application information submitted on October 31, 2006
sufficient to issue an Individual Stormwater Permit.
./ "
Prepared by (Signatur�kl U«e) � � Date l! 2cbg'
/oe)Stormwater Permitting Unit Supervisor Date I i
for radley nnett
Concurrence by Regional
Date
RO Water Quality Supervisor Date
Regional Office Staff Comments
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NCSU00312Rot�/b�"
Recommendations., Based on the documents reviewed, the application information submitted on October 31, 2006
sufficient to issue an Individual Stormwater Permit.
Prepared by (Signature) Date ! 2 t b
Stonnwater Permitting Unit Supervisor Date I d
for mApy ett
Concurrence by Regional
RO Water Quality
Date
Date,%3�C.7T_
Regional Office Staff Comments
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