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HomeMy WebLinkAboutNC0046892_Inspection_20180806ROY COOPER G&V eeltw MICHAEL S. REGAL Secr�rary LINDA CULPEPPER In redm D,'rsctor Mr. Scott Dilling, Complex Manager Motiva Enterprises, LLC 410 Tom Sadler Road Charlotte, North Carolina 28214 Dear Mr. Dilling: NORTH CAROLINA frrvrrVnFh#1t1G1 (2rt2rfty 6 August 2018 Subject: Compliance Evaluation Inspection Motiva Enterprises/Charlotte South Terminal NPDES Permit No. NCO046892 Mecklenburg County On July 11, 2018, Mr. Chad Broadway of the Mecklenburg County Water Quality Program (MCWQP) conducted an inspection at the subject facility. This inspection was conducted as part of a cooperative working agreement between Mecklenburg County and the Division of Water Resources (DWR). Please inform the facility's Operator -in -Responsible Charge (ORC) of our findings by forwarding a copy of the enclosed report. It is requested that a written response be submitted to this Office by August 24, 2018, detailing the actions taken to repair the secondary containment structure for the oil/water separator holding tanks. In responding, please address your comments to the attention of Mr. Wes Bell. Additionally, please send a copy of your response to Mr. Rusty Rozzelle of MCWQP at 2145 Suttle Avenue, Charlotte, N.C. 28208. Should you have any questions concerning this letter, please do not hesitate to contact Mr. Wes Bell/Mooresville Regional Office/DWR at (704) 235-2192 and/or Mr. Broadway at (704) 280-1497, or via email at wes.bell@ncdenr.gov. and chad.broadway(kmecklenbur cg ountync.gov. Sincerely, DocuSigned by: A14CC681AF27425... W. Corey Basinger, Regional Supervisor Enclosure: Water Quality Regional Operations Section Inspection Report Division of Water Resources, NCDEQ 4:��AEQ5 ;Ns� North Carolina Department of Environmental Quality I Division of Water Resources 610 East Center Avenue I Suite 3011 Mooresville, North Carolina 28115 704.663.1699 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 IN 1 2 15 I 3 I NCO046892 111 12 I 18/07/11 I17 18 I S J 19 LG] 201 I 211111 1 1 1 1 1 111 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 111 1 1 1 1 1 166 Inspection Work Days Facility Self -Monitoring Evaluation Rating 131 QA ----------------------Reserved------------------- 67 2.0 70 71 [ I 72 I I 73 �74 751 1 1 1 1 1 1 180 u 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 oermit Number) 11:05AM 18/07/11 15/09/01 Charlotte South Terminal #058503 6851 Freedom Dr Exit Time/Date Permit Expiration Date Charlotte NC 28214 11:50AM 18/07/11 20/06/30 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Justin Chad Baker/ORC/704-399-3301/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Scott Dilling,410 Tom Sadler Rd Charlotte NC 28214/Complex Manager/704-399-3301/ No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Flow Measurement Operations & Maintenance Records/Reports Self -Monitoring Program 0 Facility Site Review 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 Water Quality Program Meckenburg County MRO WQ//704-336-5449/ Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date W. Corey Basinger MRO WQ//704-235-2194/ EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. DocuSigned by: 8/6/2018 A14CC681AF27425... Page# NPDES yr/mo/day Inspection Type (Cont.) NCO046892 111 121 18/07/11 1 17 18 JCJ Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) OPERATION & MAINTENANCE SECTION cont'd: The secondary containment dike for the oil -water separator holding tanks was observed to have two significant areas of separation, and other minor cracks and separations. This condition was also noted during inspections conducted in 2015 and 2016, and displacement of the concrete blocks appears to have increased since the previous inspections. Although there was no evidence of a discharge from the containment wall, the structure should be properly repaired to ensure adequate secondary containment is provided. Please be advised that the subject permit requires the permittee to properly operate and maintain the facility at all times [Permit Reference: Part II, Section C(2) Proper Operation and Maintenance]. Other than the secondary containment dike, the facility grounds were observed to be well kept and in good condition at the time of inspection. Page# Permit: NCO046892 Owner - Facility: Charlotte South Terminal #058503 Inspection Date: 07/11/2018 Inspection Type: Compliance Evaluation ❑ ❑ Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new ❑ ❑ 0 ❑ application? ❑ • ❑ ❑ Is the facility as described in the permit? 0 ❑ ❑ ❑ # Are there any special conditions for the permit? ❑ ❑ 0 ❑ Is access to the plant site restricted to the general public? 0 ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? 0 ❑ ❑ ❑ Comment: The facilitv's current Dermit became effective on 9/1/2015 and expires on 6/30/2020. The last inspection of this facility was conducted by the Mecklenburg County Water Quality Program on 8/16/2016. The facility no longer operates equipment listed in the permit as being associated with groundwater remediation activities, including the oil / water separator, carbon filters and air stripper. An air sparging system, or in-situ air stripper, is currently active for ground water remediation efforts. Other elements of the facility are consistent with the description in the permit. Discharge from the facility includes stormwater that accumulates within the tank containment dike and surrounding areas. Record Keeping Are records kept and maintained as required by the permit? Is all required information readily available, complete and current? Are all records maintained for 3 years (lab. reg. required 5 years)? Are analytical results consistent with data reported on DMRs? Is the chain -of -custody complete? Dates, times and location of sampling Name of individual performing the sampling Results of analysis and calibration Dates of analysis Name of person performing analyses Transported CDCs Are DMRs complete: do they include all permit parameters? Has the facility submitted its annual compliance report to users and DWQ? (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift? Is the ORC visitation log available and current? Is the ORC certified at grade equal to or higher than the facility classification? Is the backup operator certified at one grade less or greater than the facility classification? Is a copy of the current NPDES permit available on site? Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Page# 3 Permit: NCO046892 Inspection Date: 07/11/2018 Owner - Facility: Charlotte South Terminal #058503 Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Facility has copy of previous year's Annual Report on file for review? ❑ ❑ 0 ❑ Comment: During the inspection, MRS were reviewed from 6/2017 through 5/2018. All parameters were observed to be collected and analyzed per permit specifications. No effluent limit violations were observed during the review period. Collection dates and analysis results documented on MRS matched collection times and analysis results in the chain -of -custody forms. The facility's primary ORC, Justin Baker, and backup ORC, Colin Parker, were both observed to have valid certifications in the Division's Basinwide Information Management System (BIMS) database. Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? ❑ ❑ M ❑ Are all other parameters(excluding field parameters) performed by a certified lab? 0 ❑ ❑ ❑ # Is the facility using a contract lab? 0 ❑ ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees ❑ ❑ 0 ❑ Celsius)? Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? ❑ ❑ 0 ❑ Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? ❑ ❑ 0 ❑ Comment: The facility contracted with Biota Diagnostics (NC Certification #683) from June 2017 to December 2017 and Test America (NC Certification #64) from January 2018 to May 2018 to conduct analysis of permit parameters except acute toxicity, which is analyzed by ETT Environmental (NC Certification #022). Effluent Sampling Is composite sampling flow proportional? Is sample collected below all treatment units? Is proper volume collected? Is the tubing clean? # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type representative)? Yes No NA NE ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ Comment: The permit requires grab samples for all required parameters. The facility is conducting analytical monitoring for all parameters at the frequency stated in the permit. Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑ Page# 4 Permit: NCO046892 Owner - Facility: Charlotte South Terminal #058503 Inspection Date: 07/11/2018 Inspection Type: Compliance Evaluation Operations & Maintenance Yes No NA NE Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: The facilitv utilizes an oil -water separator for treatment of loadina rack water. which is then discharged to two holding tanks. Contents of the holding tanks are removed by STAT Environmental Services or HEPACO for offsite treatment and disposal. Facility personnel inspect the oil -water separator twice weekly for levels and maintenance needs. The facility ORC states that the contents of the oil -water separator and holding tanks are removed on an as -needed basis. See "Summary" Section for additional comments. Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? 0 ❑ ❑ ❑ Is flow meter calibrated annually? 0 ❑ ❑ ❑ Is the flow meter operational? 0 ❑ ❑ ❑ (If units are separated) Does the chart recorder match the flow meter? ❑ ❑ M ❑ Comment: A 6" SDarlina inline flow meter. located at outfall #001. is used to measure flow from the facility. The flow meter was last calibrated on 1/17/2018 by Sparling Instruments. Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? 0 ❑ ❑ ❑ Are the receiving water free of foam other than trace amounts and other debris? 0 ❑ ❑ ❑ If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ 0 ❑ Comment: The facility was not discharging at the time of inspection. No visual signs of pollution were observed below the outfall. Page# 5