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Home My WebLink AboutNC0046531_Inspection_20180810NORTH CAROLINA ROY COOPER fnvrranrh#1t1G1 QUdlfly G&V eeltw MICHAEL S. REGAL Secr�rary LINDA CULPEPPER In redm D,'rsctor 10 August 2018 Mr. Tim Fox, Director, Terminal Operations Lincoln Terminal Company 22 South Main Street Greenville, South Carolina 29601 Subject: Compliance Evaluation Inspection Lincoln Terminal Company NPDES Permit No. NCO046531 Mecklenburg County Dear Mr. Fox: On July 25, 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 31, 2018, detailing the actions taken to address the new stormwater outfall at the ethanol/biodiesel offloading area, drum storage practices, and all remedial activities undertaken to cleanup all areas (gravel, soil, etc.) impacted from previous petroleum discharges as discussed in more detail in the Operations & Maintenance/Summary Sections of the attached report. A permit modification must be requested and approved by the Division's Permitting Unit prior to any future discharges from this new stormwater outfall. The request should include a site map with the existing and new outfalls labeled (with Longitude and Latitude Coordinates), description of activities at this location and potential pollutants, and name of receiving stream. The request should be submitted to the following address: Division of Water Resources, Water Quality Permitting Section — NPDES, 1617 Mail Service Center, Raleigh, NC 27699- 1617, attention John Hennessy/Supervisor. In responding to this report, 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. EQ.:> "-mr North Carolina Department of Environmental Quality I Division of Water Resources 610 East Center Avenue I Suite 301 I Mooresville, North Carolina 28115 704.663.1699 Mr. Tim Fox Page Two 10 August 2018 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(c�r�,ncdenr.gov. and chad.broadway@mecklenbur cg ountync.gov. Sincerely, DocuSigned by: A14CC681 AF27425... W. Corey Basinger, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ Enclosure: Inspection Report Cc: Rusty Rozzelle, MCWQP (via email) 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 NCO046531 111 12 I 18/07/25 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.. I 72 I �, I 73 �74 751 I I I 1 1 1 I80 I—I 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) 09:OOAM 18/07/25 15/10/01 Lincoln Terminal Company, Inc. 7720 Mount Holly Rd Exit Time/Date Permit Expiration Date Paw Creek NC 28130 11:05AM 18/07/25 20/05/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Darcy Small/Manager Terminal/704-392-6000 /7043920249 Dillon Michael Cloninger/ORC/704-747-0336/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Tim Fox,7720 Mount Holly Rd Charlotte NC 28214//864-382-2111/ 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� 8/10/2018 A14CC681AF27425... Page# NPDES yr/mo/day Inspection Type (Cont.) NC0046531 111 121 18/07/25 1 17 18 JCJ Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) OPERATIONS & MAINTENANCE SECTION cont'd: An unlabeled 55 -gallon drum of unknown contents was missing a bung cap, leading to stormwater accumulation within the vessel. The drum had a strong solvent odor and stained soils/debris around the drum suggest that previous discharges have occurred. Numerous 5 -gallon drums of paint, methyl ethyl ketone, and other materials were stored in the same general area, with many drums accumulating stormwater that may be commingling with residual product. At the facility's loading rack, evidence of ongoing minor discharges of biodiesel was located in a gravel -covered area below the loading hose. Per facility personnel, contaminated soil/gravel is periodically removed from the area. All drums must be properly covered and secured to prevent any discharges onto the ground and/or stormwater runoff. In addition, any affected areas by previous spills must be properly remediated. The facility's biodiesel and ethanol offloading area has recently been retrofitted to plumb a trench drain to the adjacent gravel area. Per the facility ORC, the area is intended to contain the entire contents of a fuel tanker truck in the event of a release. During the inspection, the valve for this containment was open, resulting in no actual secondary containment. Evidence of minor spills/leaks was observed within the containment area and stained gravel was observed at the containment discharge. Additionally, the retrofit of the containment discharge pipe has resulted in discharges that bypass all treatment units and the facility's permitted outfall. Please be advised that the permittee must either request a permit modification to include this additional outfall (along with supporting information) or connect this discharge into the treatment system currently used for the loading rack area. Page# Permit: NCO046531 Owner - Facility: Lincoln Terminal Company, Inc. Inspection Date: 07/25/2018 Inspection Type: Compliance Evaluation Yes No NA NE Are records kept and maintained as required by the permit? 0 Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new ❑ ❑ 0 ❑ application? Are all records maintained for 3 years (lab. reg. required 5 years)? 0 ❑ ❑ 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 10/1/2015 and exDires on 5/31/2020. The last inspection of the facility was conducted by the Mecklenburg County Water Quality Program on 12/8/16. The facility and treatment measures are consistent with the description in the permit. Discharge from the facility includes stormwater that accumulates within the tank secondary containment dike and treated, filtered water from the oil -water separator. Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? 0 ❑ ❑ ❑ Is all required information readily available, complete and current? ❑ 0 ❑ ❑ Are all records maintained for 3 years (lab. reg. required 5 years)? 0 ❑ ❑ ❑ Are analytical results consistent with data reported on DMRs? 0 ❑ ❑ ❑ Is the chain -of -custody complete? 0 ❑ ❑ ❑ 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 CM 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? ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review? ❑ ❑ ❑ Page# 3 Permit: NCO046531 Inspection Date: 07/25/2018 Record Keeping Owner - Facility: Lincoln Terminal Company, Inc. Inspection Type: Compliance Evaluation Yes No NA NE Comment: Durina the inspection. DMRs were reviewed from 1/2016 throuah 6/2018. All parameters were observed to be collected and analyzed per permit specifications. No effluent limit violations were observed during the review period. A review of the laboratory analysis forms found that the date of analysis and person conducting the analysis were not documented. The permittee should request the facility's contract lab provide sufficient information to meet permit requirements. The facility's primary ORC, Dillon Cloninger, and backup ORC, Glenn Price, were both observed to have valid certifications in the 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)? ❑ ❑ 0 ❑ 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 has contracted with Research and Analytical Laboratories (NC Certification #34) to conduct analysis of all permit parameters. 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 ❑ ❑ ❑ representative)? Comment: The Dermit reauires arab samDles for all reauired parameters. The facilitv is conductin analytical monitoring for all parameters at the frequency stated; however, the facility discharges only sporadically. No discharge was documented for 8 of the previous 12 months. Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? ❑ 0 ❑ ❑ Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Page# 4 Permit: NCO046531 Inspection Date: 07/25/2018 Operations & Maintenance Owner - Facility: Lincoln Terminal Company, Inc. Inspection Type: Compliance Evaluation Yes No NA NE Comment: The facilitv utilizes an oil -water seDarator for treatment of loadina rack water. with seDarated oil discharging to a transmix tank. Contents of the transmix tank are removed by a contractor for offsite treatment and disposal; separated water treated via carbon filters and then discharges into the tank secondary containment dike. The facility ORC states that the oil -water separator levels are checked daily by site personnel. Oil -water separator maintenance is conducted on an as -needed basis. The ORC was unaware of current measures to evaluate for "breakthrough" in the carbon filters. 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: The facilitv estimates flow at 20 -minute intervals throuahout the entire discharae usina a bucket and timer to measure flow. 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