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HomeMy WebLinkAboutNCG080718_Representative Status Request Letter_20190218McCoy, Suzanne From: Misenheimer, Don <dmisenhe@wm.com> Sent: Monday, February 18, 2019 3:13 PM To: Joyner, Melissa; McCoy, Suzanne; Smith, Ronald Subject: [External] Representative Outfall Status Petition (NCG080718) - Waste Management of Carolinas, Inc. - Fayetteville Hauling Attachments: Representative Status Request Letter_021819.pdf Follow Up Flag: Follow up Flag Status: Flagged External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to report.spam@nc.gov Ms. Joyner - Per our conversations, please find the attached request for Representative Outfall Status at the Waste Management of Carolinas, Inc. - Fayetteville Hauling facility. Please contact me with any questions or comments. Best regards - Don M. Misenheimer Environmental Protection Manager dmisenhe@wm.com Waste Management 10411 Globe Road Morrisville, NC 27560 Cell 984 328 0129 Recycling is a good thing. Please recycle any printed emails. W. 7 WASTE MANAGEMENT February 18, 2019 Melissa Joyner Environmental Specialist NCDEQ-DEMLR 225 Green Street, Suite 714 Fayetteville, NC 28301-5095 RE: Waste Management of Carolinas, Inc. - Fayetteville Hauling Fayetteville, North Carolina Representative Outfall Status Petition (NCGO80718) Dear Ms. Joyner: Waste Management of Carolinas, Inc. 10411 Globe Road Morrisville, NC 27560 Waste Management of Carolinas, Inc. (WM) respectfully submits this petition for representative outfall status at its Fayetteville Hauling facility (Facility) as described in Part III, Section D of the permit guidelines for Stormwater General Permit NCG080000. On January 30, 2019, a site meeting was attended by Ms. Melissa Joyner (NCDEQ-DEMLR), Mr. Ronald Smith (WM), and Mr. Don Misenheimer (WM). A historical data review and visual inspection of outfalls was performed, and subsequently, all parties determined that the Facility would benefit from submitting a Representative Outfall request. This submittal requests to reduce the number of requested Representative Outfalls from two (2) to one (1), as described below. Please note that a digital version of this letter, as well as the required attached Representative Outfall Status (ROS) request form (Attachment 1), will be emailed to Ms. Suzanne McCoy (NCDEQ-DEMLR) per the DEMLR website instructions. CURRENT OUTFALL STATUS As you are aware, the Facility currently performs outfall monitoring at two (2) Stormwater Discharge Outfall (SDO) locations. Since a Division of Water Quality inspection in September of 2010, the Facility has been gathering and reporting analytical monitoring data at both outfalls. In October 2016, a flooding event occurred at the Facility where records were destroyed, as documented in the Memorandum provided as Attachment 2. WM believes that adequate data is present to warrant "representative outfalls" at the Facility. ANALYTICAL MONITORING DATA The results of required monitoring events are summarized in the attached Table 1. This table presents all available data gathered from 2016 through 2018. WM has not included the Representative Outfall Status Petition (NCG080718) February 18, 2019 Page 2 of 3 laboratory data/reports in this request due to file size and paper considerations, but we will be happy to forward all to the DEMLR upon your request. INDUSTRIAL ACTIVITIES AND ASSOCIATED POTENTIAL POLLUTANT SOURCES The Facility operates as a commercial solid waste collection and recycling transportation facility and consists of an administrative and dispatch office/maintenance shop, customer parking area, vehicle and equipment wash area, oil storage area, container storage yard, vehicle fueling area and parking area for the refuse collection trucks (a Site Map is included as Figure 1). The facility stores and utilizes several petroleum products and other potential pollutants associated with maintenance and repair of collection vehicles and equipment. These products include diesel fuel, motor oil, hydraulic oil, used oil, ethylene glycol (antifreeze) and a limited number of detergents, cleaners, routine maintenance supplies and used and new batteries. The facility receives products via delivery tanker trucks and/or common carrier. Used oil and hydraulic fluid are stored in double walled tanks within a building adjacent to the maintenance shop for routine collection by a third -party contractor for recycling or proper disposal. The shop is equipped with a trench floor drain that connects to an oil/water separator that acts as secondary containment for the maintenance shop and the vehicle wash area. The oils and solids that accumulate in the oil/water separator are pumped on a routine basis by a third -party contractor and are transported off -site for recycling or proper disposal. The effluent water from the oil/water separator is directed to the Fayetteville Publicly Owned Treatment Works (POTW). Vehicle washing is designated in a bay on the northeast end of the maintenance shop building. The wash bay is constructed of concrete and wash waters drain into a trench drain that conveys the wash water to the onsite oil water separator. Discharge to the sanitary sewer is allowed under an agreement with the Fayetteville Public Works Commission. The following industrial activities are conducted at the facility and are shown on the site map (Figure 1): Industrial Activity Associated Pollutants PPS #1— Maintenance Shop Ethylene Glycol (Antifreeze), Used Oil, Battery Acid Parts Cleaner —various hydrocarbons, solvents PPS #2 — Fueling Station Diesel Fuel PPS #3 — AST 10,000 Gallon Diesel Fuel Diesel Fuel PPS #4 — Oil Storage Area Used Oil, Motor Oil, Hydraulic Fluid PPS #5 — Truck Parking Various Hydrocarbons PPS #6 — Truck Wash Area Various Hydrocarbons, Detergents PPS #7 — Emergency Generator Diesel Fuel Representative Outfall Status Petition (NCG080718) February 18, 2019 Page 3 of 3 PPS #8 — A/C Unit Condensate, allowable non -storm water discharge PPS #9 — Container Storage Various Hydrocarbons,Paint PPS #10 — Scrap Metal Storage Metals POTENTIAL POLLUTANT EXPOSURE The following is the site Potential Pollutant Summary Table: Location SDO Locations Maintenance Shop Outfall 1 Vehicle Refueling Outfall 1,2 Oil Storage Area Outfall 1 Truck Parking Outfall 1,2 Truck Wash Area Outfall 1 Material Storage Outfall 1,2 PROPOSED REPRESENTATIVE OUTFALL 1. Outfall 1 represents the drainage area with the highest potential pollutant exposure originating from all potential site pollutants. WM proposes that Outfall 1 be representative for Outfall 2. We appreciate your attention in this matter and are prepared to promptly respond to any questions or concerns regarding this request. Should you have any questions or require clarification, please contact me at (984) 328-0129 or by email below. Sincerely, Waste Managero;nt of Carolinas, Inc. — Fayetteville Hauling /64rx — Don Mi enheimer Environmental Protection Manager dmisenhe@wm.com Attachments Cc: Suzanne McCoy, DEMLR Ronald Smith, Waste Management C:\Users\dmisenhe\Waste Management\South Atlantic - NC Sites Permanent Operating Records\Fayetteville Hauling\NPDES Stormwater\Representative Outfall Status\2019\Representative Status Request Letter_021819.docx This page is left intentionally blank. TABLE This page is left intentionally blank. wwrift, WASTE MANAGEMENT By: DMM Date: 2/18/19 TABLE 1 WM - FAYETTEVILLE HAULING - CDC #: NCGO80718 OUTFALL MONITORING DATA Dec-1G Jun-17 Dec-17 Jun-18 Secont Semi -Annual 2D18 (No Sampleable Events) OUTFALL TSS OGG pH TSS OGG pH I TSS OGG pH TSS OGG pH TSS OGG pH Dutfall1 120 2.4 7.3 27 2.4 7.3 12 2.4 7.3 9.2 2.4 7.3 N/A N/A N/A Outfall2 53 2.4 7.3 23 2.85 7.3 9.8 2.4 7.3 18 2.4 7.3 N/A N/A N/A BOLDE1-Exceedance in benchmark value NA -Not Applicable Parameters Benchmark Value Fecal Caliform IDDD Colonies/100 ml TSS 100 Mg/1 COD 1120 mg/L ** all values reported are in the above units This page is left intentionally blank. 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S ; z z- rnm ocnoLn O r 0 O O r Ln L � cn cn a z O O N O m z D O r C Z u Q C7 Z7 Z m Z7 O r N m D C W m� O O X D m X U L/7 C7 2 D X G) m O C Ti D r r 0 O C -M (n z r- -c 0 O F= m 0 r O C D z z �D z 0 N m m TI r O m n O z M D Z n ° M 0 O r x m D m �D O D m Z77 r z rri c �a c 0 c v c v �_ v a.o �a Q t ATTACHMENT 1 This page is left intentionally blank. Division of Energy, Mineral & Land Resources Stormwater Program National Pollutant Discharge Elimination System Environmental REPRESENTATIVE OUTFALL STATUS (ROS) r71Jnlitz1 FOR AGENCY USE ONLY Date Received Year Month Day --_ KEVUENI NUK1Vl If a facility is required to sample multiple discharge locations with very similar stormwater discharges, the permittee may petition the Director for Representative Outfall Status (ROS). DEQ may grant Representative Outfall Status if stormwater discharges from a single outfall are representative of discharges from multiple outfalls. Approved ROS will reduce the number of outfalls where analytical sampling requirements apply. If Representative Outfall Status is granted, ALL outfalls are still subject to the qualitative monitoring requirements of the facility's permit —unless otherwise allowed by the permit (such as NCG020000) and DEQ approval. The approval letter from DEQ must be kept on site with the facility's Storm water Pollution Prevention Plan. The facility must notify DEQ in writing if any changes affect representative status. For questions, please contact the DEQ Regional Office for your area (see page 3). (Please print or type) 1) Enter the permit number to which this ROS request applies: Individual Permit (or) Certificate of Coverage N I C S N c G 0 8 0 7 1 8 2) Facility Information: Owner/Facility Name Waste Management of Carolinas - Fayetteville Hauling Facility Contact Street Address City County Telephone No. Ronald Smith 691 Tom Starling Road Fayetteville Cumberland 910-480-4024 State NC E-mail Address Fax: ZIP Code 28206 rsmith15@wm.com 3) List the representative outfalls) information (attach additional sheets if necessary): Outfall(s) outfall 1 is representative of Outfall(s) Outfall 2 Outfalls' drainage areas have the same or similar activities? Outfalls' drainage areas contain the same or similar materials? Outfalls have similar monitoring results? Outfall(s) is representative of Outfall(s) Outfalls' drainage areas have the same or similar activities? Outfalls' drainage areas contain the same or similar materials? Outfalls have similar monitoring results? Outfall(s) is representative of Outfall(s) Outfalls' drainage areas have the same or similar activities? Outfalls' drainage areas contain the same or similar materials? Outfalls have similar monitoring results? ❑ Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No ❑ No data* ❑ Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No ❑ No data* ❑ Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No ❑ No data* *Non-compliance with analytical monitoring prior to this request may prevent ROS approval. Specific circumstances will be considered by the Regional Office responsible for review. Page 1 of 3 SWU-ROS-2009 Last revised 12/30/2009 Representative Outfall Status Request 4) Detailed explanation about why the outfalls above should be granted Representative Status: (Or, attach a letter or narrative to discuss this information.) For example, describe how activities and/or materials are similar. PLEASE SEE ATTACHED LETTER REQUEST. 5) Certification: North Carolina General Statute 143-215.6 B(i) provides that: Any person who knowingly makes any false statement, representation, or certification in any application, record, report, plan, or other document filed or required to be maintained under this Article or a rule implementing this Article; or who knowingly makes a false statement of a material fact in a rulemaking proceeding or contested case under this Article; or who falsifies, tampers with, or knowingly renders inaccurate any recording or monitoring device or method required to be operated or maintained under this Article or rules of the [Environmental Management] Commission implementing this Article shall be guilty of a Class 2 misdemeanor which may include a fine not to exceed ten thousand dollars ($10,000). I hereby request Representative Outfall Status for my NPDES Permit. I understand that ALL outfalls are still subject to the qualitative monitoring requirements of the permit, unless otherwise allowed by the permit and regional office approval. I must notify DEQ in writing if any changes to the facility or its operations take place after ROS is granted that may affect this status. If ROS no longer applies, I understand I must resume monitoring of all outfalls as specified in my NPDES permit. I certify that I am familiar with the information contained in this application and that to the best of my knowledge and belief sucVinformation is true, complete, and accurate. Printed Name o J onSlgning: Don Misenheimer Title: E ronment rtion Manager (Signature qrf Applicant) 2/18/19 (Date Signed) Please note: _ This application for Representative Outfall Status is subject to approval by the NCDEQ Regional Office. The Regional Office may inspect your facility for compliance with the conditions of the permit prior to that approval. Final Checklist for ROS Request This application should include the following items: ❑ This completed form. ❑ Letter or narrative elaborating on the reasons why specified outfalls should be granted representative status, unless all information can be included in Question 4. ❑ Two (2) copies of a site map of the facility with the location of all outfalls clearly marked, including the drainage areas, industrial activities, and raw materials/finished products within each drainage area. ❑ Summary of results from monitoring conducted at the outfalls listed in Question 3. ❑ Any other supporting documentation. Page 2 of 3 SWU-ROS-2009 Last revised 12/30/2009 ATTACHMENT 2 This page is left intentionally blank. wwpvto WASTE MANAGEMENT To: Fayetteville Hauling SPCC and SWPP File From: Shawn Carroll 691 Tom Starling Rd Address Pages: 1 (including cover) Fayetteville, NC 28306 Phone: Date: 11 /14/2016 Re: Loss of Plans and Records cc: 3920 River Road Wilmington, NC 28412 (910) 798-1230 (910) 799-2826 scarrol3@wm.com ❑ Urgent ❑ For Review ❑ Please Comment ❑ Please Reply ❑ Please Recycle Pat: As you are aware, on October 8, 2016, Hurricane Matthew made landfall along the South Carolina and North Carolina coast. The storm resulted in a large amount of rainfall which heavily impacted the interior counties of North Carolina. The Cape Fear River crested at historical highs, and the Fayetteville Hauling facility was flooded with over five feet of water entering the office, shop and parking lot. Due to the flooding, the site's entire office contents were lost, including the SPCC Plan and records, SWPPP plan and records, and all other environmental -related files. EP is assisting the site with rebuilding and re -implementation of the plans and records, this will likely be an ongoing process through Q1 of 2017. Please place a copy of this memo into your forthcoming SPCC and SWPPP files. Regards, Shawn Shawn P. Carroll Environmental Protection Manager WASTE MANAGEMENT - South Atlantic 3920 River Road Wilmington, NC 28412 910 274 8869 (c) 910 798 1230 (w) scarroQ3( wm. com This page is left intentionally blank.