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Home My WebLink AboutNCG510207_Compliance Evaluation Inspection_20190131ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Director Mr. John W. Culbreath (via email) Colonial Pipeline Company 1185 Sanctuary Pkwy Suite 100 Alpharetta, Georgia 30009 Dear Mr. Culbreath: NORTH CAROLINA Environmental Quality January 31, 2019 Subject: Compliance Evaluation Inspection Colonial Pipeline Company, Paw Creek Terminal NPDES Permit NCG510207 Groundwater Remediation Mecklenburg County On January 22, 2019, staff from the Mooresville Regional Office (MRO) performed a compliance inspection of the Groundwater Remediation system at the subject site to determine compliance with the permit. Enclosed is a copy of the inspection report. The system is online and performing at levels consist with the permit for this facility. Should you have any questions with the site inspection report or the findings list herein, I may be reached by phone at (704) 663-1699 or by email at edward.watson@ncdenr.gov, should you have questions. Sincerely, EA DocuSigned by: wNN+uft F161 FB69A2D84A3... Andrew H. Pitner, P.G. Assistant Regional Supervisor Mooresville Regional Office Water Quality Regional Operations Section Division of Water Resources, NCDEQ Attachment: Compliance Inspection Report CC: Laserfiche D Q � North Carolina Department of Environmental Quality I Division of Water Resources Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115 NOAn-icJwauNn i nwm,em of eem—woviRv 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 NCG510207 111 12 I 19/01/22 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 71 tyI� I 72 n 73 � II 74 751 u I I I I I I I80 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) 10:30AM 19/01/22 16/10/25 Charlotte Delivery Facility 7524 Kenstead Cir Exit Time/Date Permit Expiration Date Paw Creek NC 28130 12:30PM 19/01/22 20/09/30 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Gerald Beck,PO Box 1624 Alpharetta GA 30009//678-762-2498/ 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 Edward Watson MRO GW/// Signature of Management Q A Reviewer Docusigned by: Agency/Office/Phone and Fax Numbers Date *-. aW H ;P44t t4 1/31/19 EAF1611`969AMUAI.. EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type (Cont.) NCG510207 I11 121 19/01/22 117 18 ICI Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) On December 31, 2018, a fuel release estimated in the amount of 3,872 gallons was documented to have occurred at the Colonial Pipeline Paw Creek Facility. Actions have been taken to ensure that the petroleum products did not create surface water impairments as a result of the release. During the site visit, it was noticed that straw and absorbent pads were still being sporadically used for absorption of the released fuel. Temporary capture trenches and dams have been installed onsite to control flow to the on -site pond at the North end of the site and only bio-film was observed to be present in the channel during the site visit. According to John Culbreath, free product was continued to be recovered as a result of the release. However, the amount of free product remaining to be recovered is decreasing. The fuel transfer line that breached has been repaired using a sleeve to patch the damaged area of the transfer line. It is the intent of Colonial to incorporate the new recovery wells into the current on -site pump and treat system. Appropriate analytical methods were used for sampling for the petroleum constituents to determine constituent concentrations, from the period of January 2, 2019, through January 16, 2019. Analytical data was provided to MRO staff during the site visit and low hits of petroleum constituents were reported in the on -site surfacewater. The area where the highest impact occurred is near the SW-1 wastewater outfall located at the retention pond at the north end of the property on January 4, 2019. Stormwater outfall SW-3 reported a low level of the petroleum constituent hits. All other stormwater outfall locations report no petroleum fuel impacts to surface water. The MRO was informed that no product was known to have left the site as a result of the ruptured line. The ruptured line was repaired by the emplacement of a sleeve and during the site visit, the pipes were being videoed with a camera to check for the presence of addition line ruptures. On January 22, 2019, MRO staff performed a compliance inspection at the Colonial Pipeline facility under permit NCG510207. Due to the below -freezing temperature on the day of the site visit, the system was not operating and no discharge was occurring. However, the treatment system was viewed and despite the age of the treatment system, it appears to be in good condition. Final discharge of the treated effluent water is an outfall connecting to a UT to Gum Branch. This is a Class WS-IV stream associated with subbasin 03-08-34 of the Catawba River. This permit currently consists of five recovery wells. The current permit places no limits on the number of recovery wells allowed to be implemented within the treatment system. As this is considered to be an NPDES minor permit, discharge from the treatment system would not be allowed to exceed one million gallons per day without a permit modification. O&M records were reviewed during the site visit and the records appear to be up to date. The records indicated stripper tray maintenance. Also, according to John Culbreath, it appears the activated carbon may be due to be changed. MRO staff has requested that a copy of the carbon waste manifest be emailed to the MRO office when the carbon is next changed. The laboratory analytical data for 2018 was also reviewed during the site visit. A review of the analytical data also indicated reduced influent in April 2018. The reduction seems to indicate the effectiveness of the treatment system. The system is equipped to perform mid -point sampling to monitorfor breakthrough of the Activated Carbon canisters. The Oil and Water separator continues to be maintained through Legacy Page# Permit: NCG510207 Inspection Date: 01/22/2019 Owner - Facility: Charlotte Delivery Facility Inspection Type: Compliance Evaluation Environmental via a pump and haul method and this activity is recorded in the O&M records for the system. Page# Permit: NCG510207 Owner - Facility: Charlotte Delivery Facility Inspection Date: 01/22/2019 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 for review durina the site visit. The current Dermit exDires on 9/30/2020. 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 ❑ 0 ❑ ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: The permit is for a pump and treat GW remediation system. O&M records were available for review during the site visit. The records appears to be consistent and in order. 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: No flow was occurring during the site visit due to on -site air temperature being below 25 degrees F. However, the receiving waters did not appear to have any sheen present and no odors were noticed when viewing the receiving stream water. Page# 4