NC0031046_Compliance Evaluation Inspection_20180810

NORTH CAROLINA
ROY COOPER Environmental Quality
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interim Director
August 10, 2018
Mr. Darren Pruitt, Operations Manager
Colonial Pipeline Company
411 Gallimore Dairy Road
Greensboro, NC 27409
SUBJECT: Compliance Evaluation Inspection
Colonial Pipeline Company— Greensboro Junction, PC-1
NPDES Permit No. NC0031046
Guilford County
Dear Mr. Pruitt:
On August 8, 2018, Jenny Graznak, of this office, met with Faron Leigh to perform
a Compliance Evaluation Inspection on the Colonial Pipeline Company — Greensboro
Junction, PC-1 stormwater/wastewater treatment system. This type of inspection
consists of two basic parts: an in-office file review and an on-site inspection of the
treatment facility. The attached EPA inspection form notes the areas that were evaluated
for this inspection. The findings and observations are outlined below:
I. Permit
The NPDES permit became effective January 1, 2017 and expires August 31,
2021. The facility had a copy of the current permit available during the inspection. The
treatment structures seen during the inspection match those listed in the permit.
II. Self-Monitoring Program
A review of the monthly discharge monitoring reports (DMRs) for the period July
2017 through June 2018 showed that the facility complied with all permit limits. Regarding
the permit monitoring requirements, it was noted that all sampling was performed per the
frequencies specified in the permit. All laboratory analysis is performed by Pace Analytical
Services, LLC. Mr. Leigh collects all the monthly and/or quarterly grab samples from the
five different outfalls, and then a representative from Pace Analytical picks them up from
the site.
One issue with the self-monitoring program was noted on the day of the inspection.
Mr. Leigh is currently collecting the upstream sample from the upstream section of the
upper retention pond. However, Ms. Graznak pointed out that he needs to collect the
DEQ
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 W.Hanes Mill Road,Suite 300 I Winston-Salem,North Carolina 27105
336-776-9800

Colonial Pipeline Company—Greensboro Junction,PC-1
August 10,2018
upstream sample from a location that is a minimum of 75 feet upstream of the influent
pipe to the settling pond, as stated in the current permit in Part I, Section A. (6).
Ill. Records/Reports
Mr. Leigh maintains a visitation log that also documents flow estimates. Chain of
custody forms and lab data sheets are in good order. All the required monitoring was
performed per the frequencies specified in the NPDES permit. Ms. Graznak noted no data
transcription discrepancies from lab sheets to DMRs in her documentation review.
IV. Flow Measurement
The permit requires episodic flow monitoring for each outfall. No meter is used for
flow measurement. Instead, the discharge volume is computed using the Rational
Method, as outlined in the current permit.
V. Operations and Maintenance
Colonial Pipeline staff perform a daily walk to inspect the ponds and the discharge
outfalls. The oil/water separator is cleaned out on an as-needed basis by Zebra
Environmental. The wash water from cleaning the aboveground storage tanks is sent off
site for disposal.
VI. Facility Site Review
The dikes around the tank farm have hand-operated control valves that are
normally closed. The tank farm has five outfalls (001 thru 005) that drain to the same on-
site pond. The only issues observed at these outfalls are as follows:
- Outfall 002: Ms. Graznak observed approximately 20 very small dead fish (all same
species) at Outfall 002. However, she also observed a larger number of live,
swimming fish in the same location. Please pay particular attention to this outfall
in the coming weeks to determine if that was a one-time incident or not.
- Outfall 004: The retention pond at Outfall 004 showed signs of erosion on its
streambanks and should be repaired.
VII. Effluent/Receiving Waters
All five outfalls were discharging, and the effluent was clear on the day of the
inspection. Effluent was being discharged into an unnamed tributary to the East Fork
Deep River, class Water Supply-IV* waters, in the Cape Fear River Basin. Ms. Graznak
did not observe solids, color, or odor associated with the effluent.
2

t S
Colonial Pipeline Company—Greensboro Junction,PC-1
August 10,2018
VIII. Requested Action
- Please correct the upstream sample location as described in this letter.
- Please pay close attention to Outfall 002 and let our office know if any more dead
fish are observed.
- Please make efforts to repair the streambank erosion at the Outfall 004 pond.
Colonial Pipeline Company's efforts to comply with the permit are appreciated. If
you have any questions regarding the inspection or this report, please contact Ms.
Graznak or me at [phone].
Siely,
4/r
Sherri V. Knight, P.E.
Regional Supervisor
Water Quality Regional Operations
Division of Water Resources
Attachments: EPA Water Compliance Inspection Report
cc: Central Files
WSRO
NPDES Unit
3

United States Environmental Protection Agency , Form Approved.
E PA 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 E 2 Li 3 I NC0031046 111 12 1 18/08/08 117 18 ,. 19 Li 201 I
21IIII I I I I I III I I I I I I N I I I I I I I I I I I I I I III I I I I Il66
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA Reserved `
67 I I 70 l��, 71 u 72 u 731 I 174 751 1 1 1 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) 09 OOAM 18/08/08 17/01/01
Greensboro Junction
Exit Time/Date Permit Expiration Date
411 Gallimore Dairy Rd
11.00AM 18/08/08 21/08/31
Greensboro NC 274099726
Name(s)of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data
///
Faron Dale Leigh/ORC/336-669-7903/
Name,Address of Responsible Official/Title/Phone and Fax Number
Contacted
Michael Cutting,411 Gallimore Dairy Rd Greensboro NC 274099726//336-931-6020/
No
Section C Areas Evaluated During Inspection(Check only those areas evaluated)
• Permit • Flow Measurement II Records/Reports • Self-Monitoring Program
• Facility Site Review • Effluent/Receiving Waters
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
Jennifer F Graznak WSRO WQ//336-771-5000/ ,
96104 zyt ja.750....,c..,
3/10/2-0 q
Signature emen`Q A Reviewer Agency/Office/Phone and Fax Numbers Date
t
EPA Form 3560-3(Rev 9-94)Previous editions are obsolete.
Page# 1

NPDES yr/mo/day Inspection Type (Cont.) 1
31 NC0031046 I11 121 18/08/08 117 18 Is.]
Section D.Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
I. Permit
The NPDES permit became effective January 1, 2017 and expires August 31, 2021.The facility had a
copy of the current permit available during the inspection.The treatment structures seen during the
inspection match those listed in the permit.
II. Self-Monitoring Program
A review of the monthly discharge monitoring reports(DMRs) for the period July 2017 through June
2018 showed that the facility complied with all permit limits. Regarding the permit monitoring
requirements, it was noted that all sampling was performed per the frequencies specified in the permit.
All laboratory analysis is performed by Pace Analytical Services, LLC. Mr. Leigh collects all the monthly
and/or quarterly grab samples from the five different outfalls, and then a representative from Pace
Analytical picks them up from the site.
One issue with the self-monitoring program was noted on the day of the inspection. Mr. Leigh is
currently collecting the upstream sample from the upstream section of the upper retention pond.
However, Ms. Graznak pointed out that he needs to collect the upstream sample from a location that is
a minimum of 75 feet upstream of the influent pipe to the settling pond, as stated in the current permit
in Part I, Section A. (6).
III. Records/Reports
Mr. Leigh maintains a visitation log that also documents flow estimates. Chain of custody forms and lab
data sheets are in good order.All the required monitoring was performed per the frequencies specified
in the NPDES permit. Ms. Graznak noted no data transcription discrepancies from lab sheets to DMRs
in her documentation review.
IV. Flow Measurement
The permit requires episodic flow monitoring for each outfall. No meter is used for flow measurement.
Instead, the discharge volume is computed using the Rational Method, as outlined in the current permit.
V. Operations and Maintenance
Colonial Pipeline staff perform a daily walk to inspect the ponds and the discharge outfalls.The
oil/water separator is cleaned out on as-needed basis by Zebra Environmental.The wash water from
cleaning the aboveground storage tanks is sent off site for disposal.
VI. Facility Site Review
The dikes around the tank farm have hand-operated control valves that are normally closed.The tank
farm has five outfalls(001 thru 005)that drain to the same on-site pond.The only issues observed at
these outfalls are as follows:
-Outfall 002: Ms. Graznak observed approximately 20 very small dead fish (all same species) at Outfall
002. However, she also observed a larger number of live, swimming fish in the same location. Please
pay particular attention to this outfall in the coming weeks to determine if that was a one-time incident
or not.
-Outfall 004:The retention pond at Outfall 004 showed signs of erosion on its streambanks and should
be repaired.
VII. Effluent/Receiving Waters
All five outfalls were discharging, and the effluent was clear on the day of the inspection. Effluent was
being discharged into an unnamed tributary to the East Fork Deep River, class Water Supply-IV*
waters, in the Cape Fear River Basin. Ms. Graznak did not observe solids, color, or odor associated
Page# 2

Permit: NC0031046 Owner-Facility: Greensboro Junction
Inspection Date: 08/08/2018 Inspection Type: Compliance Evaluation
with the effluent.
VIII. Requested Action
-Please correct the upstream sample location as described in this letter.
-Please pay close attention to Outfall 002 and let our office know if any more dead fish are observed.
-lease make efforts to repair the streambank erosion at the Outfall 004 pond.
Page# 3

Permit: NC0031046 Owner-Facility: Greensboro Junction
Inspection Date: 08/08/2018 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 0 II 0
application?
Is the facility as described in the permit'? • ❑ ❑ ❑
#Are there any special conditions for the permit'? 0 • 0 0
Is access to the plant site restricted to the general public'? • 0 0 0
Is the inspector granted access to all areas for inspection'? • 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'? • 0 0 0
Are all records maintained for 3 years(lab. reg. required 5 years)? • 0 0 0
Are analytical results consistent with data reported on DMRs? • 0 0 0
Is the chain-of-custody complete? • ❑ ❑ 0
Dates,times and location of sampling U
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis U
Name of person performing analyses U
Transported COCs
Are DMRs complete:do they include all permit parameters? • 0 0 0 •
Has the facility submitted its annual compliance report to users and DWQ? 0 0 U ❑
(If the facility is=or>5 MGD permitted flow) Do they operate 24/7 with a certified operator 0 0 II 0
on each shift'?
Is the ORC visitation log available and current'? • 0 0 0
Is the ORC certified at grade equal to or higher than the facility classification? 0 0 U 0
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? • 0 0 0
Facility has copy of previous year's Annual Report on file for review'? 0 0 • 0
Comment:
Effluent Pipe Yes No NA NE
Is right of way to the outfall properly maintained'? • ❑ ❑ ❑
Are the receiving water free of foam other than trace amounts and other debris'? • 0 0 0
Page# 4

Permit: NC0031046 Owner-Facility: Greensboro Junction
Inspection Date: 08/08/2018 Inspection Type: Compliance Evaluation
Effluent Pipe Yes No NA NE
If effluent (diffuser pipes are required) are they operating properly? 0 0 • 0
Comment:
Flow Measurement-Effluent Yes No NA NE
#Is flow meter used for reporting'? 0 • 0 0
Is flow meter calibrated annually'? 0 0 • 0
Is the flow meter operational'? 0 0 • 0
(If units are separated)Does the chart recorder match the flow meter'? 0 0 • 0
Comment: The permit requires episodic flow monitoring for each outfall. No meter is used for flow
measurement. Instead, the discharge volume is computed using the Rational Method, as
outlined in the current permit.
Upstream/ Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit(frequency,sampling type,and 0 • 0 0
sampling location)'
Comment: Mr. Leigh is currently collecting the upstream sample from the upstream section of the
upper retention pond. However, Ms. Graznak pointed out that he needs to collect the
upstream sample from a location that is a minimum of 75 feet upstream of the influent pipe
to the settling pond, as stated in the current permit in Part I, Section A. (6).
Page# 5