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HomeMy WebLinkAboutNCG500075_NOV and Intent to Assess_20190410ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Director NORTH CAROLINA Environmental Quality April 10th, 2019 RECC""�.CJEC raENR1DWR Champion Industries, Inc. APR 2 3 2019 Attn: Roddy Sugg, Facility Manager yV�+er Re+ources 3765,. Champion Blvd i'®rmii�� Section Winston-Salem, NC 27105 SUB ECT: Notice of Violation & Compliance Evaluation Inspection NOV #: NOV-2019-PC-0252 NC General Wastewater Permit NCG500000 for Discharge of Condensate & Blowdown Wastewater Certificate of Coverage: NCGS00075 for 3765 Champion Blvd, Winston-Salem, Forsyth County Dear Mr. Sugg: Ron Boone, of the NC Division of Water Resources CDWR), Winston-Salem Regional Office, met with you April 4th, 2019, to perform a compliance evaluation inspection of the general wastewater permit NCGS00075 for Champion's 3765 Champion Blvd facility in Winston-Salem. Details of that inspection are included on the attached EPAWater Compliance Inspection Report. The inspection did result in the issuance of this Notice of Violation for failure to comply with the monitoring requirements for condensate and blowdown discharges in the NCG500000 general permit. Champion may wish to consider eliminating the discharges, the volumes of which are both relatively small, and then request rescission of the permit through NC DWR's NPDES Unit in our Raleigh Central Office. Mr. Boone can assist in all these efforts. Thank you for your cooperation in this matter. If you have any questions or concerns, please contact Mr. Boone by phone at 336-776-9690, or by email at ron.boone@ncdenr.gov. You may also contact me by phone at 336-776-9700, or by email at lon.snider@ncdenr.gov. Sincerely, [DocuSigned by: o, >,adtr 14 49 25r,EA... Long'. miler, Assistant Regional Supervisor Water Quality Regional Operations Section Winston-Salem Regional Office Division of Water Resources, NCDEQ Attachments: EPA Water Compliance Inspection Report cc: NCDWR WSRO File NCDWR-NPDES Unit NCDWR Central Files North Carolina Department of Environmental Quality ; Division of Water Resources fft _E Winston.Salem Regional Office . 450 Hanes bill Road Suite 300'' Winston-Salem. North Carolina 27105 � � tee\ �✓ 336.776.9800 A United States Environmental Protection Agency Form Approved. EPA Washington, D.C. 20460 1 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/m6may Inspection Type Inspector Fac Type 1 IN 1 2 15 . 1 3 I NCG500075 111 12 19/04/04 17 18 I ,. I 19 I G I 20 LI 21111111 111111111111111111 1 111111 11111111111 r6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved 67 70 l_ 71 IJ 72 LL NJ 731 I 174 751 I I I I I I 1. 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 Dermit Number) 09:30AM 19/04/04 15/10/19 Champion Industries Exit Time/Date permit Expiration Date 3765 Champion Blvd 10:00AM 19/04/04 20/07/31 Winston Salem NC 27105 Name(s) of Onsite Representative(s)lritles(s)/Phone and Fax Number(s) Other Facility Data /// Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Roddy Snuggs,3765 Champion Blvd Winston Salem NC 27115//336-661-1556/ No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Flow Measurement Operations & Maintenance Records/Reports Self -Monitoring Program E 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 Ron Boone Docusigned by: WSRO WQ//336-776-9690/ 4/11/2019 � E11',0F8D05F2A3460... Signature of Management Q A Reviewer Docusigned by: Agency/Office/Phone and Fax Numbers Date f�oti T sMcicr 4/11/2019 EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type (Cont.) 31 NCG506075 I11 12 19/04/04 17 18 1 C I Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Both waste streams produced at this facility, boiler blowdown and AC condensate, are piped to a stormwater catch basin located in the grassy area on the south side of the facility. Analytical monitoring has not been conducted as required by the permit. The receiveing water, at the bottom of the catch basin, could not be inspected. Champion should strive to eliminate both waste stream discharges by draining the AC condensate to a grassy area in a sheetflow type manner. This is allowable as a deemed permitted discharge under NC regulations. The boiler blowdown discharge would need to be completely eliminated in some way, or, alternatively, piped to the city sanitary sewer. This cannot be done without the city's permission to discharge the boiler blowdown into the sanitary sewer. Champion may contact the city's pretreatment coordinator, Joel Freeman, at 336-397-7621. If and when the discharges of the two waste streams to surface waters are eliminated, Champion may request rescission of the discharge permit by letter to the Division. You may contact Ron Boone for additional information on this process. Until the discharges are eliminated and the permit is rescinded, or Champion begins to abide by the conditions of the permit, Champion is technically in violation of the permit. Page# Permit: NCG500075 Owner - Facility: Champion Industries Inspection Date: 04/04/2019 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 ❑ ❑ M ❑ application? Is the facility as described in the permit? 0 ❑ ❑ ❑ # Are there any special conditions for the permit? ❑ ❑ ❑ Is access to the plant site restricted to the general public? M ❑ ❑ ❑ Is the inspector granted access to all areas. for inspection? 0 ❑ ❑ ❑ Comment: None Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? ❑ M ❑ ❑ Is all required information readily available, complete and current? ❑ 0 ❑ ❑ Are all records maintained for 3 years (lab. reg. required 5 years)? ❑ ❑ ' ❑ 0 Are analytical, results consistent with data reported on DMRs? ❑ ❑ 0 ❑ Is the chain -of -custody complete? ❑ ❑ M ❑ Dates, times and location of sampling ❑ Name of individual performing the sampling ❑ Results of analysis and calibration ❑ Dates of analysis ❑ Name of person performing analyses ❑ Transported COCs ❑ Are DMRs complete: do they include all permit parameters? ❑ ❑ 0 0 Has the facility submitted its annual compliance report to users and DWQ? ❑ ❑ 0 ❑ (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator ❑ ❑ M ❑ on each shift? Is the ORC visitation log available and current? ❑ ❑ 0 ❑ Is the ORC certified at grade equal to or higher than the facility classification? ❑ ❑ 0 ❑ Is the backup operator certified at one grade, less or greater than the facility classification? ❑ ❑ 0 ❑ Is a copy of the current NPDES permit available on site? ❑ M ❑ ❑ Facility has copy of previous year's Annual Report on file for review? ❑ ❑ 0 ❑ Comment: Facility has not conducted the effluent monitoring required by the permit. Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? ❑ ❑ 0 ❑ Are all other parameters(excluding field parameters) performed by a certified lab? ❑ ❑ 0 ❑ Page# 3 Permit: NCG500075 Owner -Facility: Champion Industries Inspection Date: 04/04/2019 Inspection Type: Compliance Evaluation Laboratory Yes No NA NE # Is the facility using a contract lab? ❑ ❑ N ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees ❑ ❑ 0 ❑ Celsius)? Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? ❑ ❑ M ❑ Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? ❑ - ❑ M ❑ Comment: Facility has not conducted the effluent monitoring required by the permit.' Effluent Sampling Yes No NA NE Is composite sampling flow proportional? ❑ ❑ 0 ❑ Is sample collected below all treatment units? ❑ ❑ 0 ❑ Is proper volume collected? ❑ ❑ M ❑ Is the tubing clean? ❑ ❑ 0 ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees ❑ ❑ ❑ Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type 0 ❑ representative)? Comment: Facility has not conducted the effluent monitoring required by the permit. Flow Measurement - Effluent Yes No NA NE. # Is flow meter used for reporting? ❑ M ❑ ❑ Is flow meter calibrated annually? ❑ ❑ N ❑ Is the flow meter operational? ❑ ❑ 0 ❑ (If units are separated) Does the chart recorder match the flow meter? ❑ ❑ M ❑ Comment:' Facilitv has not conducted the effluent monitoring required by the permit. Only flow estimation is required. 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? ❑ ❑ ❑ If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ ❑ Comment: Both waste streams produced at this facility, boiler blowdown and AC condensate, are piped to a stormwater catch basin located in the grassy area on the south side of the facility. Monitoring has not been conducted as required by the permit. The receiveing water, at the bottom of the catch basin, could not be inspected. Page# 4 Permit: NCG500075 Owner - Facility: Champion Industries Inspection Date: 04/04/2019 Inspection Type: Compliance Evaluation Operations '$ Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? M ❑ ❑ ❑ Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ M ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: - None Page# 5