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Home My WebLink AboutNC0088838_Compliance Evaluation Inspection_20140523 ATP:A 1CDE Yt$ North Carolina Department of Environment and Natural Resources Pat McCrory John E. Skvarla, Ill Governor Secretary May 23, 2014 Mr. Stuart Kerkhoff, CHMM RECEIVED/DENR/DWR Environmental, Health and Safety Manager Radiator Specialty Company MAY 2 7 2014 600 Radiator Road Indian Trail, North Carolina 28079 Water Resources Permitting Section Subject: Compliance Evaluation Inspection Radiator Specialty Company Groundwater Remediation NPDES Permit No. NC0088838 Union County Dear Mr. Kerkhoff: Enclosed please find a copy of the Compliance Evaluation Inspection report for the inspection conducted at the subject facility on May 12, 2014, by Ms. Marcia Allocco of this office. Thank you for your assistance during the inspection and your efforts to comply with the requirements of your permit. The inspection report should be self-explanatory; however, should you have any questions concerning the report, please do not hesitate to contact me at (704) 235-2204 or marcia.allocco@ncdenr.gov. Sincerely, Marcia Allocco, MS; Environmental Senior Specialist Water Quality Regional Operations Section Division of Water Resources, NCDENR cc: Wastewater Branch MSC 1617 —Central files basement MA Mooresville Regional Office Location'610 East Center Ave,Suite 301 Mooresville,NC 28115 Phone.(704)663-16991 Fax:(704)663-60401 Customer Service 1-877-623-6748 Internet:http://portal.nctlenr.org/weblwq An Fnnat Onnnrtunity 1 Affirmative Actinn Fmnlover—30%Recycled/10%Post Consumer saner L1 United States Environmental Protection Agency Form Approved EPA Washington,D.C.20460 OMB No 2040-0057 Water Compliance Inspection Report Approval expires 8-31-98 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 1 I N I 2 1 51 31 NC0088838 111 121 14/05/12 1 17 181 C I "151 20H I Remarks 211111111111111111 1111 1111 11 L1 1111 111111111111 11166 Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA - 671 1.0 1 69 701 41 71 I N I 721 N I 731 I 174 751 I I I 1 1 1 180 Section B: Facility Data Name and Location of Facility Inspected(For Industrial Users discharging to POTW,also include Entry Time/Date Permit Effective Date POTW name and NPDES permit Number) 10.16 AM 14/05/12 09/10/01 Radiator Specialty Company 600 Radiator Rd Exit Time/Date Permit Expiration Date Indian Trail NC 28079 10:59 AM 14/05/12 13/10/31 Name(s)of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data /// Stuart A Kerkhoff/ORC/704-684-1815/ Name,Address of Responsible Official/Title/Phone and Fax Number Contacted Stuart Kerkhoff,600 Radiator Rd Indian Trail NC 28079//704-684-1815/7046841868 No Section C: Areas Evaluated During Inspection(Check only those areas evaluated) S Permit IN Flow Measurement ®Operations&Maintenance ®Records/Reports IN Self-Monitoring Program ®Facility Site Review IS Effluent/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 Marcia Allocco MRO WQ//704-663-1699 Ext 2204/ a2 %---0.----) cJ Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date EPA Form 3560-3(Rev 9-94)Previous editions are obsolete. Page# 1 NPDES yr/mo/day Inspection Type 1 31 N00088838 I11 12I 14/05/12 117 18I CI Section D: Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary) Page# 2 if Permit: NC0088838 Owner-Facility: Radiator Specialty Company Inspection Date: 05/12/2014 Inspection Type: Compliance Evaluation PermitYes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new application? ® n n n Is the facility as described in the permit? lei n n n #Are there any special conditions for the permit? n ® n n Is access to the plant site restricted to the general public? ® n n n Is the inspector granted access to all areas for inspection? ® n n n Comment: The subject permit expired on October 31, 2013, and a permit renewal application was received by the Division on May 7, 2013. The last compliance evaluation inspection was completed on July 1, 2010. Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? Itn n n Does the facility analyze process control parameters,for ex:MLSS, MCRT,Settleable Solids, pH, DO,Sludge It n n n Judge,and other that are applicable? Comment: Effluent data results are tracked to determine when maintenance is required on the remediation treatment system; e.g. breakthrough. The treatment system was shut down for a good portion of the previous 12 months due to required maintenance. Flow Measurement-Effluent Yes No NA NE #Is flow meter used for reporting? 4n n n Is flow meter calibrated annually? 4n n n Is the flow meter operational? Itn n n (If units are separated)Does the chart recorder match the flow meter? 0 0 f+ n Comment: A flow totalizer is used to report flow on the monthly discharge reports and is calibrated once per year. Johnston, Inc. completed the most recent calibration on October 4, 2013; the maximum deviation from the true discharge was <10%. Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? r, 0 0 0 Are the receiving water free of foam other than trace amounts and other debris? 4n n n If effluent (diffuser pipes are required) are they operating properly? n n ® n Comment: The outfall runs through Radiator Specialty Company property (leased as agricultural fields) and discharges to an unnamed tributary to the South Fork Crooked Creek. The discharge was clear with no foam and did not appear to impact the receiving stream. Effluent Sampling Yes No NA NE Page# 3 V Permit: NC0088838 Owner-Facility: Radiator Specialty Company Inspection Date: 05/12/2014 Inspection Type: Compliance Evaluation Effluent Sampling Yes No NA NE Is composite sampling flow proportional? 0 0 i 0 Is sample collected below all treatment units? F1n n n Is proper volume collected? L 0 0 0 Is the tubing clean? n n E n #Is proper temperature set for sample storage(kept at less than or equal to 6.0 degrees Celsius)? in n n Is the facility sampling performed as required by the permit(frequency,sampling type representative)? I 0 0 0 Comment: The permit requires grab samples for all required parameters. All effluent samples are kept on ice in a cooler until transfer to the contracted analytical laboratory is completed. Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? Lin n n Are all other parameters(excluding field parameters)performed by a certified lab? 0 0 0 #Is the facility using a contract lab? E 0 0 0 #Is proper temperature set for sample storage(kept at less than or equal to 6 0 degrees Celsius)? ® n n n Incubator(Fecal Coliform)set to 44.5 degrees Celsius+/-0.2 degrees? n n E n Incubator(BOD)set to 20.0 degrees Celsius+/-1.0 degrees? 0 0 0 Comment: Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? 0 0 0 Is all required information readily available, complete and current'? li n n n Are all records maintained for 3 years(lab reg. required 5 years)? ® n n n Are analytical results consistent with data reported on DMRs? Ii n n n Is the chain-of-custody complete? Lln n n Dates,times and location of sampling I.; Name of individual performing the sampling RE Results of analysis and calibration Eg Dates of analysis fiii Name of person performing analyses RI Transported COCs EN Are DMRs complete:do they include all permit parameters? 0 E 0 0 Page# 4 Permit: NC0088838 Owner-Facility: Radiator Specialty Company Inspection Date: 05/12/2014 Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE 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? n ® n n Has the facility submitted its annual compliance report to users and DWQ? n n ® n (If the facility is=or>5 MGD permitted flow)Do they operate 24/7 with a certified operator on each shift? n 0 r Is the ORC visitation log available and current? gin n n Is the ORC certified at grade equal to or higher than the facility classification? ® n n n Is the backup operator certified at one grade less or greater than the facility classification? 0 0 0 Is a copy of the current NPDES permit available on site? ® n n n Facility has copy of previous year's Annual Report on file for review? n n ® n Comment: The permittee has contracted Prism Laboratories, Inc. (NC certification #402)to conduct all analyses. Prism Laboratories, Inc. subcontracts with Environmental Testing Solutions, Inc. to complete the quarterly toxicity tests (please add ETS as a certified lab on the applicable DMRs). Discharge Monitoring Reports (DMRs)were reviewed for the period February 2013 through February 2014. The reports indicate that the permittee was meeting permit effluent limits and monitoring frequency requirements during the review period with the following exception. A tetrachloroethene concentration of 5.8 ppb was reported on Nov. 14, 2013, which exceeded the daily maximum permit limit of 3.0 ppb. This exceedance was handled under separate cover through the issuance of a Notice of Violation (NOV-2014-LV-0121). Additional analyses were conducted on the effluent in Nov. and Dec. 2013 but were not reported on the respective DMRs; all effluent analyses must be reported to the DWR as per Section E, 5(b) of NC0088838 Page# 5