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HomeMy WebLinkAboutNC0088838_Compliance Evaluation Inspection_20181012NORTH CAROLINA ROY COOPER ErrVfr "Fh#1trdf Qrtorrry Govwnw MICHAEL S. REGAN 54hT ary LI DA CULPEPPER October 12, 2018 lnrerfm &'rea w Mr. Stuart Kerkoff (via email) Environmental Health and Safety Manager Radiator Specialty Company 600 Radiator Road Indian Trail, North Carolina 28079 Subject: Compliance Evaluation Inspection Radiator Specialty Company NPDES Permit #NC0088838 Groundwater Remediation Union County Dear Mr. Kerkoff: Thank you your time and assistance during the October 10, 2018, inspection. Enclosed you will find the report for the compliance inspection. The treatment and disposal system appears to be performing well. There are, however, a few items that should be addressed should a permit modification be required for system re- location and potential additional required treatment: • Please keep the MRO informed of changes in the location of the treatment system and collection tank. • Please advise the MRO if additional treatment is planned to be added to the system to aid in the reduction of the new 1 A Dioxane constituent. • Please advise the MRO if the buyer is able to obtain a Brownfield Status. The report should be self-explanatory. Should you have any questions regarding this report, feel free to contact Ed Watson at edward.watson(a)ncdner.gov, or 704-235-2198. Attachment: Compliance Inspection Report Sincerely, DocuSig ned by: Loti ? .5_'J �T For An reW94E� tt ' P.G., Assistant Regional Supervisor Water Quality Regional Operations Section Mooresville Regional Office Division of Water Resources QE 3 North Carolina Department of Environmental Quality I Division of Water Resources Mooresville Regional Office 1 610 East Center Avenue, Suite 301 I 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 IF I 3 I NCO088838 111 12 I 18/10/10 I17 18 I S J 19 L G] 201 I 211111 I I I I I I II I I I I I I I I I I I I I I I I I I I I I I I II I I I I I f6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved ------------------- 67 1.0 70 I z I 71 I p JI 72 I I 73 I I I74 751 I I I I I I I80 I —I I I i Section B: FacilityDataI� 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) 10:OOAM 18/10/10 18/07/01 Radiator Specialty Company 600 Radiator Rd Exit Time/Date Permit Expiration Date Indian Trail NC 28079 11:30AM 18/10/10 23/03/31 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) Permit Flow Measurement Operations & Maintenance Records/Reports Facility Site Review Compliance Schedules 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 Maria Schutte Division of Water Quality//704-663-1699) Edward Watson MRO GW/// Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date DocuSigned by: Lon Snider Lam- 'r S'ac, 1-- EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type (Cont.) NCO088838 I11 12, 18/10/10 117 18 JCJ Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) This permit recently renewed with new permit conditions for monitoring 1,4 Dioxande to be maintained at a level of 80ug/L or below. The newly installed RW is being pumped on 10 minute cycles to avoid exceeding the 80ug/I requirement. Alternate additional treatment may be required to maintain the 1,4 Dioxane parameter. The facility ceased production at the end of August 2018. The property is in the process of being sold and is currently under contract. The buyer may wish to have the tank farm removed and have the treatement system and recovery tank re -located. The possibility of additional treatment and the re -location of the tank and air stripper will likely require a permit modification. These changesd are yet to be determined, but likely to occur. The cost to re -locate the treatement system has to be negotiated between the two parties. Being aware of the presence of the chlorinated solvent plume, the buyer has applied for a Brownfield classification. The buyer is also aware that the treatment system will be required to be maintained. However, Radiator Specialty is retaining ownership of the contaminant and will continue to maintain the treatment system. Page# Permit: NCO088838 Owner - Facility: Radiator Specialty Company Inspection Date: 10/10/2018 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 current Dermit was Dresent onsite and available for review. There is a sDecial condition of monitoring 1 A Dioxane as this chemical is considered to be an emerging contminant. Compliance Schedules Yes No NA NE Is there a compliance schedule for this facility? M ❑ ❑ ❑ Is the facility compliant with the permit and conditions for the review period? 0 ❑ ❑ ❑ Comment: The first Dart of the October 2018 Chronic Toxicitv sample was collected on 10/09/2018 This facility historically Passes Chronic Toxicity testing. 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? Comment: The facility ceased manufactoring operations on August 31, 2018. The facility is currently going through a slow shut -down phase as there is a significant quantity of manufactored product that needs to be shipped or stored elseware. The 2018 O&M records were reviewed during the sitie visit. The records are current and complete. Page# 3