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HomeMy WebLinkAboutNCS000391_Inspection Report_20190521ROY COOPER Governor MICHAEL S. REGAN Secretary S. DANIEL SMITH Interim Director Goodyear Tire & Rubber Company Attn: Lane Gee, Plant Manager 6650 Ramsey Street Fayetteville, NC 28311 NORTH CAROLINA Environmental Quality May 29, 2019 Subject: COMPLIANCE EVALUATION INSPECTION NPDES Stormwater Permit NCS000391 Goodyear Tire & Rubber Company — Fayetteville Plant Cumberland County Dear Mr. Gee: On May 21, 2019, I, Michael Lawyer, Environmental Program Consultant with the Fayetteville Regional Office of the Division of Energy, Mineral and Land Resources (DEMLR) along with Lauren Garcia, Environmental Specialist with DEMLR's Stormwater Program conducted a site inspection for the Goodyear Tire & Rubber Company — Fayetteville Plant facility located at 6650 Ramsey Street in Cumberland County, North Carolina. A copy of the Compliance Inspection Report is enclosed for your review. Mr. Carlton Williams, Regional Environmental Manager, and Mr. Terry Chalk, Emergency Services Coordinator, were also present during the inspection and their time and assistance is greatly appreciated. The site visit and file review revealed that the subject facility is covered by NPDES Stormwater Permit NCS000391. Permit coverage authorizes the discharge of stormwater from the facility to receiving waters designated as Carvers Creek, a Class WS-IV,B waterbody, and the Cape Fear River, a class WS-IV waterbody, both in the Cape Fear River Basin. As a result of the inspection, the facility was found to be in compliance with the conditions of NPDES Stormwater Permit NCS000391. Please refer to the enclosed Compliance Inspection Report for additional comments and observations made during the inspection. Please be advised that violations of the NPDES Stormwater Permit are subject to a civil penalty assessment of up to $25,000 per day for each violation. If you or your staff have any questions, comments, or needs assistance with understanding any aspect of your permit, please contact me at (910) 433-3394 or by e-mail at mike.lawyer@ncdenr.gov. Sincerely, Michael Lawyer, CPSWQ Environmental Program Consultant DEMLR Enclosure ec: Carlton Williams, Regional Environmental Manager — Goodyear Tire & Rubber Company cc: FRO — DEMLR, Stormwater Files DE^- North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources ,dJ}� Fayetteville Regional Office 1 225 Green Street, Suite 7141 Fayetteville, North Carolina 28301 NCRTH CAROLINA _ uiauaty /�'� 910.433.3300 Compliance Inspection Report Permit: NCS000391 Effective: 11/01/09 Expiration: 10/31/14 Owner: Goodyear Tire & Rubber Company SOC: Effective: Expiration: Facility: The Goodyear Tire & Rubber Co. - Fayetteville Plant County: Cumberland 6650 Ramsey St Region: Fayetteville Fayetteville NC 28311 Contact Person: Carlton Williams Title: Reg. Environmental Manager Phone: 330-796-0811 Directions to Facility: System Classifications: Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): On -site representative Carlton Williams 330-796-0811 On -site representative Terry Chalk Related Permits: Inspection Date: 05/21/2019 Entry Time: 02:OOPM Primary Inspector: Mike Lawye,�.�e�' Secondary Inspector(s): Lauren Garcia Reason for Inspection: Routine Permit Inspection Type: Stormwater Discharge, Individual Facility Status: Compliant ❑ Not Compliant Question Areas: Storm Water (See attachment summary) Exit Time: 04:45PM Phone: 910-433-3300 E4.7.Ir 33gY Inspection Type: Compliance Evaluation Page 1 of 3 Permit: NCS000391 Owner - Facility: Goodyear Tire & Rubber Company Inspection Date: 05/21/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine Inspection Summary: Inspection conducted as part of the permit renewal process. Met with Carlton Williams, Regional Environmental Manager, and Terry Chalk, Emergency Services Coordinator. A draft permit had previously been provided to Mr. Williams for review. A discussion was held regarding the request to remove Thiram from the discharge characteristics in the permit based on the facility's new process for receiving chemicals in pre -weigh bags instead of mixing onsite. Also discussed the monitoring of outfall 1 located at the rear of the facility, which discharges stormwater as well as process wastewater including non -contact cooling water and boiler blowdown permitted under NCG500153. According to facility personnel, they have found no practical method to separate the two discharge flows. The facility's site -specific Stormwater Pollution Prevention Plan (SPPP) was provided for review. The SPPP contains all required components and associated documentation and has been reviewed/updated on an annual basis. Monitoring has been conducted and recorded per the requirements of the permit. The Annual Summary DMR for 2018 indicates that monitoring was inadvertently conducted twice during the second half of 2018 and shows an exceedance of the benchmark value for zinc at outfall 1. There have been previous exceedances for zinc at outfall 1, which the facility attributes to the commingled process wastewater flows and has correspondence from the public utility (PWC) that they add a zinc based compound to their water system as a corrosion inhibitor. After the records review, Mr. Williams and Mr. Chalk guided inspectors through the facility's new operation for storing and processing the chemical compounds received in pre -weigh bags thereby virtually eliminating any exposure of Thiram to stormwater. Observations were then made of the facility's oil/water separator, outside chemical/liquid material storage areas that are under shelter and within secondary containment structures, waste storage areas and two stormwater outfalls. Absorbent booms have been placed at both outfalls as BMPs to aid in potential pollutant removal. Page 2 of 3 Permit: NCS000391 Owner - Facility: Goodyear Tire & Rubber Company Inspection Date: 05/21/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine Stormwater Pollution Prevention Plan Yes No NA NE Does the site have a Stormwater Pollution Prevention Plan? ❑ ❑ ❑ # Does the Plan include a General Location (USGS) map? ❑ ❑ ❑ # Does the Plan include a "Narrative Description of Practices"? ❑ ❑ ❑ # Does the Plan include a detailed site map including outfall locations and drainage areas? N ❑ ❑ ❑ # Does the Plan include a list of significant spills occurring during the past 3 years? N ❑ ❑ ❑ # Has the facility evaluated feasible altematives to current practices? 0 ❑ ❑ ❑ # Does the facility provide all necessary secondary containment? ❑ ❑ ❑ # Does the Plan include a BMP summary? ❑ ❑ ❑ # Does the Plan include a Spill Prevention and Response Plan (SPRP)? ❑ ❑ ❑ # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ❑ ❑ ❑ # Does the facility provide and document Employee Training? 0 ❑ ❑ ❑ # Does the Plan include a list of Responsible Party(s)? ❑ ❑ ❑ # Is the Plan reviewed and updated annually? ❑ ❑ ❑ # Does the Plan include a Stormwater Facility Inspection Program? ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? ❑ ❑ ❑ •.�Z 7111 iii Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? 0 ❑ ❑ ❑ Comment: Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? 0 ❑ ❑ ❑ # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ 0 ❑ Comment: Permit and Outfalls Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? 0 ❑ ❑ ❑ # Were all outfalls observed during the inspection? N ❑ ❑ ❑ # If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ N ❑ # Has the facility evaluated all illicit (non stormwater) discharges? 0 ❑ ❑ ❑ Comment: Page 3 of 3