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
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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
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TABLE
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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
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ATTACHMENT 1
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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
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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
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