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HomeMy WebLinkAboutNC0022187_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 frrvrraArh#1t1G1 (2rt2rfty 6 August 2018 Subject: Compliance Evaluation Inspection Motiva Enterprises/Charlotte North Terminal NPDES Permit No. NCO022187 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 prevent any future discharges from the monitoring well and all remedial activities undertaken to cleanup all areas (gravel, soil, etc.) impacted from previous monitoring well discharges. 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��QEQ5 ;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 I 2 15 I 3 I NCO022187 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 Id I 71 [ I 72 I I 73 �74 751 1 1 1 1 1 1 180 I—I I� 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) 08:30AM 18/07/11 15/09/01 Paw Creek Terminal 410 Tom Sadler Rd Exit Time/Date Permit Expiration Date Paw Creek NC 28130 11:05AM 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: e� 8/6/2018 A14CC681AF27425... Page# NPDES yr/mo/day Inspection Type (Cont.) NC0022187 111 121 18/07/11 1 17 18 JCJ Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) OPERATIONS & MAINTENANCE SECTION cont'd: During an inspection of the facility grounds, evidence of a discharge from one of the facility's monitoring wells was observed. The discharge appeared to have resulted in staining of the surrounding gravel. Facility staff also indicated the monitoring well occasionally discharges following periods of heavy rainfall. Please be advised that the monitoring well should be properly capped to prevent any future discharges. In addition, any areas impacted by previous discharges of petroleum must be properly remediated. Page# Permit: NCO022187 Owner - Facility: Paw Creek Terminal ❑ ❑ ❑ 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 facility's current permit 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 facilitv is as described in the permit. with treatment units that include a bermed secondary containment for the bulk liquid storage area, an oil/water separator (referred to on site as an SPCC tank) that collects and treats runoff from the loading rack area, an additional lower detention pond where discharge ultimately occurs at outfall #001, and an intermittently active dual phase ground water remediation system with carbon filters. Discharge from this facility includes stormwater collected in the dike containment area, intermittent discharge from the groundwater remediation system, and water discharged from the loading rack area after treatment through the oil / water separator. 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 COCs 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? Yes No NA NE ❑ ❑ ❑ Page# 3 ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ 0 ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Page# 3 Permit: NCO022187 Owner - Facility: Paw Creek Terminal Inspection Date: 07/11/2018 Inspection Type: Compliance Evaluation Yes No NA NE Are field parameters performed by certified personnel or laboratory? ❑ ❑ Record Keeping Yes No NA NE Is the backup operator certified at one grade less or greater than the facility classification? 0 ❑ ❑ ❑ Is a copy of the current NPDES permit available on site? M ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review? ❑ ❑ 0 ❑ Comment: Durina the inspection. DMRs were reviewed from 6/2017 throuah 5/2018. No effluent limit violations were observed during the review period. Collection dates and analysis results documented on DMRs 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? ❑ ❑ 0 ❑ 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 all permit parameters except the toxicity analysis, which is analyzed by ETT Environmental (NC Certification #022). Effluent Sampling Yes No NA NE Is composite sampling flow proportional? ❑ ❑ 0 ❑ Is sample collected below all treatment units? 0 ❑ ❑ ❑ Is proper volume collected? ❑ ❑ 0 ❑ Is the tubing clean? ❑ ❑ 0 ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees ❑ ❑ 0 ❑ Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type M ❑ ❑ ❑ representative)? 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: NCO022187 Owner - Facility: Paw Creek Terminal 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 inspects the oil / water separator. which collects and treats flow from the loadin rack, twice per week. Separated water from the treatment unit flows into the containment dike. No evidence of petroleum contamination was observed where the tank discharges into the containment area. Accumulated petroleum waste is removed from the oil / water separator by STAT Environmental Services or HEPACO 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? ❑ ❑ 0 ❑ Comment: A 6" SDarlina inline flow meter. located at outfall #001. is used to measure discharae from the facility. The meter was last calibrated on 3/13/2018 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