NCS000390_EPA Inspection Report_20190603

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
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o ATLANTA FEDERAL CENTER
yyF o= 61 FORSYTH STREET
�Tq4 PROII ATLANTA, GEORGIA 30303-8960
MAY 2 8 2019
CERTIFIED MAIL 7017 1450 0000 7973 8786
RETURNED RECEIPT REQUESTED
Ms. Anita Decina
Vice President, Environmental, Health, and Safety, DOT
Heritage Crystal -Clean, LLC
2175 Point Boulevard, Suite 375
Elgin, Illinois 60123
Re: Compliance Evaluation Inspections
Heritage Crystal -Clean, LLC., Concord facility
NPDES Permit No. NCS000390
Dear Ms. Decina:
JUN 0 3 2019
oENR-LAN0
Si0R1�'iUVI�fER
On March 20, 2019, the U.S. Environmental Protection Agency Region 4 and North Carolina
Department of Environmental Quality (NCDEQ) conducted a Compliance Evaluation Inspection (CEI)
at the Heritage Crystal -Clean, LLC., facility located at 2115 Speedrail Court in Concord, NC. The
purpose of the CEI was to evaluate Heritage Crystal -Clean, LLC., facility's compliance with the
requirements of Sections 301 and 402(p) of the Clean Water Act (CWA), 33 U.S.C. §§ 1311 and
1342(p); the regulations promulgated thereunder at 40 C.F.R. § 122.26; and, the State of North
Carolina's NPDES Stormwater Permit NCS000390.
The EPA and NCDEQ appreciate your cooperation in conducting this CEI. Enclosed is the EPA's CEI
report, which includes EPA's observations. Please review the report and contact Ms. Lauren Garcia at
the NCDEQ office within 14 days of receiving this letter by calling [phone] or by sending an
email to lauren. [e-mail].
There is no need to respond directly to the EPA at this time; however, please note that the EPA will
continue to closely coordinate with NCDEQ to ensure compliance at this facility. If you do happen to
have questions for the EPA, you can contact Mr. Kenneth Kwan, P.E., at the above address, by email at
[e-mail], or at [phone].
Sincerely,
Daniel J. O'Lone, Chief
Surface Water and Ground Water Section
Water Enforcement Branch
Enclosures
cc: Ms. Annette Lucas
NCDEQ
Internet Address (URL) • http://www.epa.gov
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsurnier)

1"'� U.S. Environmental Protection Agency, Region 4
61 Forsyth Street SW, Atlanta, GA 30303
o=
Water Compliance Inspection Report
FACILITY DATA
NPDES ID: NCS000390 Effective Date: 05/01/2009 Expiration Date: 04/30/14 (admin continued)
Facility Name: Hydrocarbon Recovery Service SIC Code: 5093
Address: 2115 S eedrail Court, Concord, NC 28025
On -Site Representative(s), Title, Phone Number: Responsible Official, Title, Phone Number, Mailing Address:
Greg Taylor Anita Decina
Plant Manager Vice President, Environmental, Health, and Safety, DOT
2115 Speedrail Court 2175 Point Blvd, Ste 375
Concord, NC 28025 Elgin, IL 60123
847-783-5924
INSPECTION DATES/TIMES
Entry Date/Time: 03/20/2019, 8:40 am Exit Date/Time: 03/20/2019, 1:10 pm
NAMES OF EPA AND STATE INSPECTORS
EPA Inspectors: Ahmad Dromgoole and Kenneth Kwan
NCDENR Inspectors: Holliday Keen, Seth Titley, Brandon Finch, and James Moore
AREAS EVALUATED DURING
X Permit Self -Compliance Program Pretreatment
X Records
Compliance Schedule Pollution Prevention
X Facility Site Review
Laboratory X Storm Water
X Effluent / Receiving Waters X
Operations & Maintenance Combined Sewer Overflow
Flow Measurement Sludge Handling/ Disposal Sanitary Sewer Overflow
INSPECTION NOTES
The inspection team, consisting of EPA inspectors and state inspectors from various regional offices, arrived at the facility on March
20, 2019 to perform an unannounced Compliance Evaluation Inspection (CEI). This CEI, which focused on the facility's NPDES
Industrial Stormwater permit, was performed as both a joint inspection with the state and a training opportunity for state inspectors.
Upon arrival at the facility, EPA inspectors presented credentials and facilitated an opening conference. The CEI included both a
records review portion and a facility walk through. Upon completion, an exit conference was held with Greg Taylor and Anita Decina
in which they were informed of EPA's preliminary findings and told that an actual inspection report will be sent to the facility by
EPA.
P♦ REPRESENTATIVES
Inspector Signature/Name Office/Phone Number Date
USEPA Region 4/WPD-CWEB-SRES
404-562-9212
Ahmad Dromgoole, Environmental Engineer
USEPA Region 4/WPD-CWEB-SRES
404-562-9752
Kenneth Kwan, Environmental Engineer
Management Signature/Name
Office/Phone Number
Date
USEPA Region 4/WPD-CWEB-SRES
404-562-9434
Daniel J. O'Lone, Chief
Stormwater and Residuals Enforcement Section
Pagel of 8

GPS
Coordinates
Coordinates
1. FACILITY LOCATION INFORMATION
Latitude 35020'12.19"N Longitude
80036'40.99"W
Receiving
Site
Weather
Water(s) or
Coddle Creek
Acreage
�6 acres
Condition
Clear skies
MS4
Does the site
Permit
Discharge to 303(d)
Yes,
discharge pollutants
Renewal
11/15/2013
SIC
5093
listed or
mercury,
contributing to the
Yes
Application
Code(s)
turbidity,
receiving stream
Form
waterrss
and biota
impairment.
2. BASIC STORMWATER POLLUTION PREVENT PLAN (SPPP) INFORMATION
SPPP TOPICS (Part H)
YES
NO
N/E
SPPP on -site (obtain a copy of the plan) Section A
X
The SPPP was not dated.
Site Description Section A(1)(b)
X
(storage practices, loading/unloading activities, outdoor processes, dust generating processes, and waste
processes)
Identify potential Pollutant Sources and Particular Pollutants Section A(1)(b)
X
(include inventory of materials handled at the site, information pertaining to any pollutant sources, information
pertaining to the storage and application of pest control chemicals)
Three potential pollutant sources were not identified or assessed in the SPPP:
1. Saw dust was observed in outdoor storage piles along the southside of the site. These piles, which were observed
right next to the southern drainage feature, was observed without adequate containment or identified as potential
pollutant source in the SPPP.
2. Just behind the tanker parking area, a three -sided covered area was used for the storage of tote bins, drums, and
buckets of chemicals. Although located within a covered area, no berm or containment structure was observed in
the storage area for the containment of spills and leaks. The risk potential for contaminated stormwater runoff
through spills and leaks in this area was not assessed in the SPPP.
3. The facility utilizes biological treatment unit for the removing of hydrocarbons from its air vent stream. This
concrete structure unit had a metal door on one side for the periodic servicing of the media. During the inspection,
oily water was observed discharging from the door to the ground and commingling with stormwater. This non-
stormwater discharge needs to be eliminated or identified as potential pollutant source that needs to be addressed
in the SPPP.
Site Maps (general location map and site specific map) Sections A(1)(a & c)
X
(include identification of receiving waters and/or MS4s, identification of impaired waters, lat/long of discharge
points, drainage areas to each discharge point, site boundaries, site topography, drainage features and flow
directions, impervious areas, industrial activities, and site best management practices (BMPs)
The site map did not show the outdoor storage of saw dust material, and on -site BMP structure such as rip rap.
Spill History (3 year history or spills and corrective actions) Section A(1)(d)
X
No reportable of spills was stated in the SPPP. However, it is uncleared this statement truly represent spills and
leaks during the previous 3 years since the SPPP was not dated.
SPPP Certification Section A(1)(e)
X
(Annual recertification of no evidence of non-stormwater discharging)
Certification of non-stormwater discharged was conducted on 10/31/18. However, this certification should use
the form in Appendix 7 of the SPPP with the proper certification statement in accordance with Part III, Section B.
Paragraph 3.c. of the permit.
Page 2 of 8

2. BASIC STORMWATER POLLUTION PREVENT INFORMATION
SPPP TOPICS (Part II)
YES
NO
N/E
Stormwater Management Strategy (Feasibility Study) Section A(2)(a)
X
(Analysis of control options like eliminating exposure or controlling runoff)
Stormwater Management Strategy (Secondary Containment) Section A(2)(b)
X
Should include a table or summary clearly inventorying the sources and procedure for making visual observations
of accumulated liquid and how to dispose of it.
Stormwater BMP Summary Section A(2)(c)
X
Include all structural and non-structural BMPs at the site
Page 16 of the SPPP regarding management of runoff should include storm drains, ditch system, rip rap structure
controls in addition to the wet detention pond.
Spill Prevention & Response Procedures (SPRP) Section A(3)
X
(Stormwater specific plan identifying the various responsible officials and their signatures)
Page 16 of the SPPP stated that spills can be isolated with value and route to the containment pond. However, no
containment pond was observed during the inspection.
Preventative Maintenance and Good Housekeeping Program Section A(4)
X
(address maintenance and cleaning schedules of control systems, outfalls, adjacent waters, handling of industrial
activities, drainage structures, and BMPs)
- Include a list of the areas incorporated in the program
Preventative maintenance schedule for oil water separator and pump seals are not discussed in the SPPP. Also,
good housekeeping practice was not evaluated in the saw dust area, wet detention pond and railroad transfer area.
Employee Training Section A(5)
X
(minimal annual training of spill response and cleanup/prevention and potential areas of industrial stormwater)
Training was conducted on 9/16/18.
Identify the Responsible Party Section (A)(6)
X
Page 5 of the SPPP designated 5 team members for implementing the SPPP. However, their specific
responsibilities and assignments for overall coordination, development, and implementation of the SPPP were
not documented.
SPPP Modified or Update to Current Conditions Section (A)(7)
X
(review and update at least annually, recertify, and include the review of most recent benchmarks samples)
The last annual review was conducted on 11/3/16.
Schedule and Procedures for Routine Inspections (minimum of semiannually) Section A(8)
X
Environmental and safety inspection perform monthly.
Page 3 of 8

Heritage -Crystal Clean conducts used oil, oily water, and waste water processing services for public and private sector clients in the
southeastern U.S. area. Operations at this site began in 1997. In 2016, the original company was purchased by Heritage -Crystal Clean
and there was a facility name change. The Concord facility currently employs approximately 35 employees at the roughly 6-acre site
which operates Monday through Friday for two 8-hour shifts. At this facility, oily wastewater is received and sent through a variety of
steps to separate and recover various constituent like used oil and antifreeze. These products are then shipped to other facilities for
recycling and/or used as asphalt material.
Heritage -Crystal Clean's Concord facility has two discharge permits: a pretreatment permit for the handling of process wastewater and
an industrial stormwater permit. For areas of the facility with the potential for wastewater sources (like the truck loadout area, processing
area, and tank storage secondary containment, runoff is captured and diverted to the wastewater treatment facility that discharges to the
city's POTW. For other areas of the facility, discharges are diverted to stormwater ditches on the north and south sides of the site and
sent to the stormwater detention pond along the west side of the site. For this inspection, the focus was on the facility's NPDES
stormwater permit (NCS000390). For this permit, there is one stormwater outfall from the detention pond.
4. RECORD REVIEW
Record Review
YES
NO
N/E
Representative on -site
X
Records of the Implementation of the SPPP Part II Section A(9), Part III Section D(6)
X
(Retain records for a minimum of 5 years)
Records of Maintenance and Housekeeping Programs Part II, Section A(9)
X
Preventative maintenance records for oil water separator and pump seals are not made available for review. Also,
good housekeeping practice records were made available for the railroad transfer area, saw dust area and the wet
detention pond.
Records of Routine Inspections Part II, Section A(9)
X
Record of routine inspections were missing from 11/17 to 10/26/18 time period
Records of Employee Training Part II, Section A(9)
X
Records for the Approval of Representative Outfalls Part III Section D(5)
X
Records of Benchmark Monitoring Part II, Section B & D, Part III Sections D, & E(1)
X
(within 30 mins of discharge, 0.1" rain event at least 72 hrs after the preceding event)
- for normal stormwater outfalls and outfalls affiliated with vehicle maintenance (with oil usage >55 gal/yr)
- include pull date, time, location, individual; analytical date, individual, method, and result
-records of report submission
Some of the benchmark samples are collected inside the wet detention pond since much of the time the pond
water level is below the discharge level during a rain event. In the future, samples collected inside the pond will
be noted in the sampling collection log. Also, the wet detection pond is a regional pond that collects stormwater
runoff from the industrial parks and other sources. In order to have an adequate representative sample of the
discharge from the facility, the sampling point near to be further upstream of the facility prior to mixing with
other sources of stormwater runoff.
Records of Qualitative Monitoring Part II Section C, Part III Section D
X
(minimum of 60 days between periodic sampling)
No records of qualitative visual observation of stormwater discharge was made available for review during the
inspection.
Records of Tiered Approach to Benchmark Exceedances Part III Sections B
X
Records of Bypasses Part III Sections E(7)
X
Page 4 of 8

Record Review
Records of 24 hr Reporting
(and/or other noncompliance reporting)
Part III Sections E(8 &9)
YES I NO I N/E
X
Pollutant Sources
Note location, quantitative description, design issue, O&M deficiencies (including the nature and
extent), and pollutants off -site
Loading and unloading operations at the site occur at the truck unloading area on the east side of the site (seen
in photos DSCN1880-DSCN1881) and in the railcar loading area near the west side of the site (seen in photo
Loading/Unloading
DSCN1902). The tanker trucks received at the facility enter the shed covered area in the middle of the site.
Areas
Here the trucks can be sampled, connected to a pump system, and have their material sent to the holding tanks.
In this area, the drainage system discharges to the wastewater treatment system. In the railcar loading area, a
pumping station was observed in a bermed shed covered area (see photo DSCN1903).
Saw dust was observed in outdoor storage piles along the southside of the site. These piles, which were
observed right next to the southern drainage feature, were observed without adequate containment (see photos
Outdoor Storage
DSCN1895-DSCN1896). During the inspection, saw dust in this pile was observed as only having containment
Areas
structures in place on three of the four sides. The unprotected side, which was the side along the drainage
feature, was observed with saw dust running into the stormwater drainage ditch. Additionally, these storage
piles were not identified in the facility's SPPP.
Storm drain inlets and curbed areas were observed throughout the site for directing either stormwater or process
wastewater to the appropriate treatment area. Storm drain inlets were observed in the tanker truck unloading
area. These storm drains, seen in photos DSCN1880-DSCN1881, discharge to the secondary containment
structure for the tanks which is pumped to the wastewater treatment plant. Along the south side of the paved
Storm drains
area of the site, a concrete curb was observed. The curb helped collect stormwater runoff and directed it to the
storm drain inlet leading to the oil/water seperator and eventually to the drainage conveyance. A portion of the
berm, seen in photo DSCN1897, runs along the front of the chemical storage shed.
An unidentified pipe was observed on the south side of the site discharging to the hill leading to the west side
of the property. The origin of this pipe, seen in DSNC 1890, was unknown by the facility.
During the inspection, some areas of the site were observed with housekeeping and maintenance deficiencies.
Housekeeping and
The saw dust storage pile, seen in photo DSCN1895-DSCN1896, was observed in need of additional
Maintenance
housekeeping measures to minimize the loss of the saw dust to the drainage ditch. In the waste bin storage
area, the facility was observed as having belt press plates on the ground outside of the bins. According to
facility personnel, these plates were just temporarily being stored in this area while they were being cleaned.
The majority of the above ground storage tanks at the facility are located within the primary secondary
containment structure. This structure, seen in photos DSCN1882-DSCNI884, captures accumulated fluids and
directs them to the wastewater treatment plant. In the northeast corner of the containment structure, a pvc pipe
was observed through the side of the containment structure (see photo DSCN1883). This pipe diverted
stormwater from the roof down pipes to the stormwater ditch on the north side of the site. According to facility
personnel, the secondary containment structure is periodically inspected to assure that the containment meets
Liquid Storage
the necessary standards and that there was no commingling of wastewater into the stormwater pipe.
Tanks
A few of the tanks at the site were located within a separate secondary containment structure. The evaporator
tanks, seen in photo DSCN1884, were located within a separate secondary containment structure. This structure
had a sump pump that could be used to pump accumulated liquid to the primary secondary containment
structure for treatment. Another storage tank, seen in photo DSCN1893, was also located within a separate
secondary containment structure which requires accumulated liquid to be manually pumped out to the primary
secondary containment area tied to the wastewater treatment plant.
Page 5 of 8

Pollutant Sources
Note location, quantitative description, design issue, O&M deficiencies (including the nature and
extent), and pollutants off -site
In addition to the above ground storage tanks, a chemical storage area was observed near the southeast corner
of the site. During the inspection, the outdoor storage of tanker trailers was observed (seen in photo
DSCN1899). Just behind the tanker parking area, there was a shed covered area for chemical storage. These
three -sided covered areas were used for the storage of tote bins, drums, and buckets of chemicals (seen in
photos DSCN1897 and DSCN1899). Although located within a covered area, no berm or containment structure
was observed in the storage area for the containment of spills.
Wastewater from the facility is directed to the secondary containment structure for the storage tanks. Two
sumps were in place in the containment structure with pumps to direct the accumulated liquid to the treatment
plant (see photo DSCN1882).
Stormwater conveyances were in place along the north and south sides of the property. The conveyance on the
south end of the property can be seen in photos DSCN1891, DSCN1894-DSCN1896. This conveyance collects
stormwater from the facility, some collected in storm drains throughout the site and sent through an oil/water
seperator and directs it west towards the wet detention pond. An oil sheen was observed in the portion of the
conveyance immediately down gradient of the outlet from the oil/water seperator (seen in photo DSCN1896).
Along the conveyance, near the middle of the site, there a small basin area for additional sediment removal
(see photo DSCN1892). Past the small basin, there was no longer a clear conveyance leading west.
Best Management
Practices (BMPs)
Near the warehousing area, the conveyance reemerges and continues west towards the pond (see photos
DSCN1900 and DSCN1906). Photo DSCN1901 shows the area upgradient of the western continuation of the
stormwater ditch. Although shown in the SPPP as being a continuous conveyance, there was no clear flow path
connecting the eastern portion of the drainage ditch to the western portion (which led to the wet detention
pond). At the west end of the conveyance, it connects with wet detention pond. The inlet to the pond can be
seen in photos DSCN1905 and DSCN1908.
At the end of the conveyances on the west side of the site, there is a wet detention pond. This pond can be seen
in photo DSCN1907. The outlet structure for the pond was located near the western corner of the pond and is
seen in photo DSCN1909. During the inspection, the wet detention pond was observed as being significantly
overgrown with vegetation and lacking maintenance. The pond was seen with trees and bushes of significant
size resulting in a loss of retention volume and potential loss of integrity of the sides of the berms.
Although the majority of the manufacturing processes were located indoors, a few were observed outdoors
with exposure to stormwater. The facility utilizes biological treatment unit for removing hydrocarbons from
its air vent stream. This unit, which was an open top absorption cell, can be seen in photos DSCN1885-
DSCN1886. This concrete structure unit had a metal door on one side for the periodic servicing of the media.
During the inspection, oily water was observed discharging from the door to the ground and commingling with
Processes Operations
stormwater.
Next to the biological treatment unit, the site was observed operating a cooling unit. This unit was observed
discharging significant amounts of the cooling water to ground. This was process water, seen in photos
DSCN1887-DSCN1889, was observed commingling with the oily water from the biological treatment unit.
This runoff then ran down the hill towards the warehousing area on the west side of the property. Pools of this
commingled water were observed during the inspection with an oily sheen (see photos DSCN1889).
Spills/Leaks Handing
Any leaks and spill in the secondary containment area are treated on -site prior to discharge to a POTW.
Disposal/Waste
Roll off waste dumpsters were observed along the south side of the site. The onsite dumpsters observed during
Handling Areas
the inspection (seen in photo DSCN1898) were located in an inclined bermed area to help collect and manage
spilled materials.
Page 6 of 8

Pollutant Sources Note location, quantitative description, design issue, O&M deficiencies (including the nature and
extent), and pollutants off -site
Vehicle Maintenance A maintenance shop was observed near the west side of the facility. The storm drain inlets in the area around
and Washing Areas the maintenance shop (seen in photo DSCN1904) are tied into the wastewater treatment system.
6. OUTFALL,
STORMWATERDISCHARGE
Outfall, Stormwater
Discharge &
YES
NO
Receiving Water
Number & location
of stormwater
discharge(s)/outfall(s)
X
Describe:
consistent with the
SPPP
Evidence of off -site
accumulation of
pollutants observed
X
Describe: No discharge of stormwater was observed during the inspection.
in receiving water
Describe: Along the conveyance, near the middle of the site, there a small basin area for
Other potential
additional sediment removal. Past the small basin, there was no longer a clear conveyance
discharges off -site
leading west. Although shown in the SPPP as being a continuous conveyance, there was no clear
(through outfalls not
X
flow path connecting the eastern portion of the drainage ditch to the western portion (which led
included in the
to the wet detention pond). The flow path has a potential to flow offsite into an industrial park
SPPP)
area. It is uncleared whether the stormwater runoff from the industrial park next door is re-
channel back to the wet detention pond.
Non-stormwater
Describe: During the inspection, process waste water from the cooling unit and the bioretention
served
X
unit (seen in photos DSCN1885-DSCN1889) was observed discharging to the ground and
tt
commingling with stormwater runoff.
Additional inspection summary, narrative, findings, comments, photos, and schematic diagram of the facility area as
necessary:
An exit conference was held with Greg Taylor and Anita Decina (by phone) where the following observations were relayed:
• SPPP Observations:
o The SPPP provided during the inspection was not dated and had not been updated since 11/3/16
o The spill records at the site should be dated for each annual update
o The site map did not show the outdoor storage of saw dust material, and on -site BMP structures such as rip rap
o Page 5 of the SPPP designated 5 team members for implementing the SPPP. However, their specific responsibilities
and assignments for overall coordination, development, and implementation of the SPPP were not documented
o The PE certification date of 7/3/13 in the SPCC was out of date
o Preventative maintenance schedule for oil water separator are not discussed in the SPPP. Also, good housekeeping
practice was not evaluated in the saw dust area, wet detention pond, and railroad transfer area
Page 7 of 8

• Records Observations:
o The inspection records provided did not clearly address the pollutant sources identified at the site
o Routine inspection records from 11/2017 to 10/26/2108 were not available
o The records of qualitative monitoring were not clear as to whether samples are being pulled from the pond itself or
from the outfall
o Certification of non-stormwater discharge was conducted on 10/31/18. However, this certification should use the
form in Appendix 7 of the SPPP with the proper certification statement in accordance with Part III, Section B.
Paragraph 3.c. of the permit
• Site Observations:
o No BMPs were in place in the saw dust pile area
o The wet detention pond was observed as being significantly overgrown with vegetation and lacking maintenance
o It was unclear as to whether the stormwater drainage ditch along the south side of the property effectively routed
stormwater from the east side of the site to the wet detention pond on the west side
o The wet detetention pond is a regional pond that collects stormwater runoff from the industrial parks and other
sources. In order to have an adequate representative sample of the discharge from the facility, the sampling point
needs to be further upstream of the facility prior to mixing with other sources of stormwater runoff
o The biological treatment system used to control air emissions was discharging oily water that commingled with
stormwater
o Cooling water, which is not an allowable non-stormwater under the permit, was observed discharging to the ground
and commingling with stormwater
o Good housekeeping practices were not implemented in the wet detention pond and railroad transfer area
Page 8 of 8

SW-NCS000390-032019
Heritage -Crystal Clean, LLC
2115 Speedrad Court
Concord, NC 28025
Overview Map
\\I
0
W-NCS000390-032019 Page 1 of 33

DSCN1880.JPG
or —
4
+ a F-V #
f.
Attributes
File Name
DSCN1880.JPG
Description
Photograph of the truck handling area. This area is covered and graded towards the middle where
a drain inlet is located which directs collected fluids to the wastewater treatment plant.
Latitude
N 35° 20' 12.37"
Longitude
W 80' 36' 41.09"
SW-NCS000390-032019 Page 2 of 33

DSCN 1881.J PG
Attributes
File Name
DSCN1881.JPG
Description
Photograph of the truck handling area. An overflow grate can be seen in the back of this area
used to carry any overflow from this area to the storage tank secondary containment which is also
directed to the wastewater treatment facility.
Latitude
N 35' 20' 12.68"
Longitude
W 80' 36' 41.20"
SW-NCS000390-032019 Page 3 of 33

DSCN 1882.J PG
Attributes
File Name
DSCN1882.JPG
Description
Sump for the pump inside of the secondary containment for the storage tanks.
Latitude
N 35' 20' 12.94"
Longitude
W 80' 36' 41.70"
SW-NCS000390-032019 Page 4 of 33

DSCN1883.JPG
11
Attributes
File Name
DSCN1883.JPG
Description
Photograph of the plastic drainage pipe from the building roof gutters. The pipe routed into the
tank secondary containment structure and then through one of its sidewalls to a drainage ditch.
Latitude
N 35' 20' 12.38"
Longitude
W 80' 36' 42.21"
SW-NCS000390-032019 Page 5 of 33

DSCN 1884.J PG
Attributes
File Name
DSCN1884.JPG
Description
Photograph of the evaporator tanks inside of a secondary containment structure. Between the
tanks is a sump pump which can direct accumulated water to the wastewater treatment system.
Latitude
N 35' 20' 11.51"
Longitude
W 80' 36' 43.48"
SW-NCS000390-032019 Page 6 of 33

DSCN1885.JPG
Attributes
File Name
DSCN1885.JPG
Description
Photograph of the access door to the biological treatment cell. This cell is used to control oil and
other materials in the facility's waste gas stream. The door to the cell was observed leaking oily
water during the inspection which had the potential to commingle with discharged stormwater.
Latitude
N 35' 20' 11.78"
Longitude
W 80' 36' 43.84"
SW-NCS000390-032019 Page 7 of 33

DSCN1886.JPG
Attributes
File Name
DSCN1886.JPG
Description
Photograph of the access door to the biological treatment cell. This cell is used to control oil and
other materials in the facility's waste gas stream. The door to the cell was observed leaking oily
water during the inspection which had the potential to commingle with discharged stormwater.
Latitude
N 35° 20' 11.71"
Longitude
W 80' 36' 43.93"
SW-NCS000390-032019 Page 8 of 33

DSCN 1887.J PG
Attributes
File Name
DSCN1887.JPG
Description
Photograph of the discharged water from the cooling unit. This water discharged down the hill
towards the truck staging and warehousing area.
Latitude
N 35' 20' 11.72"
Longitude
W 80' 36' 44.14"
SW-NCS000390-032019 Page 9 of 33

DSCN 1888.J PG
Attributes
File Name
DSCN1888.JPG
Description
Photograph of the discharged water from the cooling unit. This water discharged down the hill
towards the truck staging and warehousing area.
Latitude
N 35' 20' 11.68"
Longitude
W 80' 36' 44.27"
SW-NCS000390-032019 Page 10 of 33

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DSCN 1891.J PG
Attributes
File Name
DSCN1891.JPG
Description
Photograph of the drainage ditch along the south side of the site. The intent of this drainage ditch
was to direct stormwater runoff from the processing plant area, by way of an oil/water seperator,
to the wet detention pond on the west side of the property. A noticeable oily trail was observed
along this ditch which is down gradient of the oil/water seperator.
Latitude
N 35' 20' 11.06"
Longitude
W 80' 36' 43.99"
SW-NCS000390-032019 Page 13 of 33

DSCN 1892.J PG
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Attributes
File Name
DSCN1892.JPG
Description
Photograph of a small retention area along the drainage ditch on the south side of the site. This
retention area was believed to discharge back into a drainage ditch leading to the wet detention
pond on the west side of the site.
Latitude
N 35' 20' 10.99"
Longitude
W 80' 36' 43.93"
SW-NCS000390-032019 Page 14 of 33

DSCN 1893.J PG
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Attributes
File Name
DSCN1893.JPG
Description
Photograph of standing water in the secondary containment around one of the storage tanks. This
specific containment structure was not connected to the primary retention area (which is connect
by pump to the treatment system). Accumulated water in this catchment is periodically pumped
out by truck and sent through the treatment system.
Latitude
N 35' 20' 10.67"
Longitude
W 80' 36' 43.30"
SW-NCS000390-032019 Page 15 of 33

DSCN 1894.J PG
Attributes
File Name
DSCN1894.JPG
Description
Photograph of the drainage ditch along the south side of the site. The intent of this drainage
ditch was to direct stormwater runoff from the processing plant area, by way of an oil/water
seperator, to the wet detention pond on the west side of the property. A noticeable oily trail was
observed along this ditch which is down gradient of the oil/water seperator.
Latitude
N 35' 20' 10.48"
Longitude
W 80' 36' 43.25"
SW-NCS000390-032019 Page 16 of 33

DSCN1895.JPG
Attributes
File Name
DSCN1895.JPG
Description
Photograph of a saw dust storage on the south end of the site. This storage pile is located along
the primary drainage ditch on the south side of the site. On the side closest to the ditch, there
was not a continuous containment structure and saw dust was observed spilling over into the
drainage ditch.
Latitude
N 35' 20' 10.52"
Longitude
W 80' 36' 42.80"
SW-NCS000390-032019 Page 17 of 33

DSCN1896.JPG
Attributes
File Name
DSCN1896.JPG
Description
Photograph of the beginning of the drainage ditch on the south side of the site. Two outfalls (one
from the storm drains by way of the oil/water seperator and one from roof drains) were seen
discharging into the ditch. The saw dust storage pile along the ditch can be seen spilling over into
the ditch due to the lack of a containment structure.
Latitude
N 35' 20' 10.37"
Longitude
W 80' 36' 42.15"
SW-NCS000390-032019 Page 18 of 33

DSCN 1897.J PG
Attributes
File Name
DSCN1897.JPG
Description
Photograph of the drainage ditch along the front of the chemical storage shed. Some sediment
accumulation was observed in this ditch. This ditch leads to the oil/water seperator discharging to
the main drainage ditch on the south side.
Latitude
N 35° 20' 10.12"
Longitude
W 80' 36' 41.26"
SW-NCS000390-032019 Page 19 of 33

DSCN 1898.J PG
Attributes
File Name
DSCN1898.JPG
Description
Photograph of a roll off dumpster in an unloading area near the processing area. In this area,
which drained down into a catchment, the facility was temporarily staging filter presses which it
planned to send to another facility. The site was cleaning these filters in this area prior to shipping
them to the other facility.
Latitude
N 35' 20' 10.83"
Longitude
W 80' 36' 41.17"
SW-NCS000390-032019 Page 20 of 33

DSCN1899.JPG
Attributes
File Name
DSCN1899.JPG
Description
Photograph of the chemical storage area on the south side of the site. This storage area was
covered but did not have secondary containment for the various drums and totes nor was there a
berm in place along the outside to contain potential spills.
Latitude
N 35' 20' 10.82"
Longitude
W 80' 36' 41.10"
SW-NCS000390-032019 Page 21 of 33

DSCN1900.JPG
Attributes
File Name
DSCN190O.JPG
Description
Photograph of the continuation of the drainage ditch along the south side leading to the wet
detention pond. This portion of the drainage ditch reappears near the railcar loading area.
Although the facility believed this ditch connected to the ditch on the southeast side of the facility
near the processing plant, there was no clear path connecting the drainage ditch in the southeast
corner of the site to the ditch on the southwest corner of the site.
Latitude
N 35' 20' 12.01"
Longitude
W 80' 36' 45.95"
SW-NCS000390-032019 Page 22 of 33

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DSCN1902.JPG
Attributes
File Name
DSCN1902.JPG
Description
Photograph of the railcar loading area. Some oil staining was observed in this area.
Latitude
N 35' 20' 11.87"
Longitude
W 80' 36' 46.06"
SW-NCS000390-032019 Page 24 of 33

DSCN 1903.J PG
Attributes
File Name
DSCN1903.JPG
Description
Photograph of a covered pump near the railcar loading area. The containment area around the
pump had accumulated water which according to facility personnel is pumped out and sent to the
treatment system.
Latitude
N 35' 20' 13.67"
Longitude
W 80' 36' 47.09"
SW-NCS000390-032019 Page 25 of 33

DSCN 1904.J PG
Attributes
File Name
DSCN1904.JPG
Description
Photograph of the drainage area near the maintenance shop. This drainage area is connected to
the facility's treatment system.
Latitude
N 35° 20' 13.18"
Longitude
W 80' 36' 46.12"
SW-NCS000390-032019 Page 26 of 33

DSCN1905.JPG
Attributes
File Name
DSCN1905.JPG
Description
Photograph of the pipe connecting the stormwater drainage ditch along the southwest side of
the site to the wet detention pond.
Latitude
N 35' 20' 12.38"
Longitude
W 80' 36' 48.31"
SW-NCS000390-032019 Page 27 of 33

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DSCN1907.JPG
Attributes
File Name
DSCN1907.JPG
Description
Photograph of the wet detention pond at the west side of the property. The pond was observed
to be dry at the time of the inspection. There was significant overgrowth in the pond which
appeared to be in need of maintenance.
Latitude
N 35° 20' 12.97"
Longitude
W 80' 36' 48.55"
SW-NCS000390-032019 Page 29 of 33

DSCN 1908.J PG
Attributes
File Name
DSCN1908.JPG
Description
Photograph of the pipe connecting the stormwater drainage ditch along the southwest side of
the site to the wet detention pond.
Latitude
N 35' 20' 13.26"
Longitude
W 80' 36' 48.71"
SW-NCS000390-032019 Page 30 of 33

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DSCN1910.JPG
Attributes
File Name
DSCN191O.JPG
Description
Photograph of the southwest corner of the paved area around the warehouse area. The area
appears to drain to a drainage feature leading to the pond.
Latitude
N 35' 20' 12.77"
Longitude
W 80' 36' 48.28"
SW-NCS000390-032019 Page 32 of 33

DSCN1911.JPG
Attributes
File Name
DSCN1911.JPG
Description
Photograph of the southwest corner of the paved area around the warehouse area. The area
appears to drain to a drainage feature leading to the wet detention pond.
Latitude
N 35' 20' 12.84"
Longitude
W 80' 36' 48.28"
SW-NCS000390-032019 Page 33 of 33