NCG130084_Compliance Report_20190904

Ploy COOPER,
Governor
MICHAEL S. PEGAN
Secretary
S. D NIEL SMITH
Director
Covanta Environmental Solutions
2503 North Fayetteville Street
Asheboro, NC 27203
NORTH CAROI INA
Environmental Quality
September 4, 2019
Subject : Compliance Inspection Report:
Permit No. NCG 130084
Covanta Environmental Solutions - Asheboro
Randolph County
Dear Permit Holder:
On August 30, 2019, Brandon Wise, inspector with the North Carolina Department of
Environmental Quality (NCDEQ) — Division of Energy, Minerals, and Land Resources, and other
inspectors with NCDEQ, met with site contacts at the facility located at 2503 North Fayetteville Street in
Asheboro. The purpose of this visit was to conduct a compliance inspection per a request to inspect
facilities that could have contact with compounds deemed high priority by NCDEQ. The inspection
consisted of review of the Stormwater Pollution Prevention Plan (SWPPP) and each of its components,
review of the facility outfalls, as well as the review of the overall site conditions.
Permit:
This facility has General Stormwater Permit NCG130084 to discharge stormwater from industrial
activity associated with Non -Metal Waste Recycling Industry [SIC 5093] under the National Pollutant
Discharge Elimination System (NPDES). This version of the permit was issued on June 1, 2018 and the
permit will expire on May 31, 2023.
Records/Reports:
This facility is required to develop and maintain a SWPPP in accordance with Part Il, Section A
of the permit. All qualitative and analytical monitoring records are required to be maintained with the
SWPPP for a minimum of five (5) years. Under this permit, analytical monitoring is not required under
current operating procedures. The facility records are kept up to date and kept with the SWPPP in the
main office. The facility previously had a permit under NCGO80000 and this permit did require analytical
monitoring, these records were kept with the new updated SWPPP. The SWPPP for this facility had been
put together and implemented prior to the inspection. The SWPPP was well put together and a new
SWPPP for the 2019 calendar year had been created and was there for review. Please note on the site
maps, that a universal naming system should be used for tanks on site. The lack of a universal naming
system made it hard for even site contacts to be able to inform NCDEQ which tanks were which. The
SPCC was also reviewed and a new version of it had been created as well. The facility is required to
amend and update the SWPPP at a minimum of annually in accordance with Part II, Section A, Item 8 of
the permit. Please note that as long as changes were not made to the permit it can be signed off that the
SWPPP was reviewed with no changes and a whole new SWPPP does not have to be created each year.
North Carolina Department of Environmental Quality Division of Energy. Mineral and Land Resources
E 1 Winston-Salem Regional Office ( 450 Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27103
Department of Envimnmentaf Quality 336,776.9800

Facility Site Review:
This facility operates as an environmental recycling facility. The facility receives products that
cannot go to landfills or need to be modified prior to going to landfills. The facility is graded in a way
that stormwater in the east (front) portion of the facility all drains to a single stormwater pipe that
discharged in the front of the facility near the road. The western (rear) portion of the facility either drains
overland or drains to outlets that then discharge to a pond in the northwestern corner of the facility. This
pond was full and appeared to be working during the inspection, however some issues were observed with
the pond. The pond had evidence of overtopping the banks on both sides of the designed outfall. While
some overtopping can be attributed to an "emergency spillway" of sorts, the evidence during the
inspection was that water would typically discharge over the banks prior to or during discharging to the
designed outfall. This should be fixed by building up the banks otherwise these areas of discharge could
be considered extra outfalls. The outfall from this pond was not observed as it was overgrown and
difficult to reach, please ensure that the qualitative monitoring is being performed at the location where
stormwater leaves the pond and not the pond itself. The pond should be inspected during facility
inspections however the stormwater outfall is the location the water leaves the facility not the pond. The
overall housekeeping of the facility was good however some areas could use clean-up. The middle
section of the facility where sawdust was stored to be mixed with waste should be cleaned up. The area
had deposits of sawdust and while it appeared to be primarily clean sawdust that had not yet been used in
the actual recycling process, the potential exists for impacts from the waste mixing to be present. There
was also an area to the south of the waste mixing area where trucks could pull through in order to be
loaded with waste product. This area needs to be clean and should be an area of regular inspection. Due
to the location of this area there is high potential for waste impacts to make it to this area as the shredder
where waste is shredded and added to the mixing pit is in this area and trucks pulling through could carry
impacted sawdust into this area. There were two locations that needed spill kits, one being the attached
building where the shredder was located and another being the rear storage area. This was pointed out
during the inspection and before the inspection was over the site contacts were working on ordering more
spill kits. Some secondary containment around the tank farm north of the office building showed some
evidence of cracking, however it did not appear as though these cracks went through the secondary, this
should be monitored to ensure the secondary containment works as designed.
At this facility almost all industrial activity is performed under cover or is performed inside of an
enclosed building. The primary risk for contamination comes from the mixing area as discussed
previously, however the mixing area is graded so any liquid from that location should flow towards the
mixing pit. Throughout the inspection spill kits were observed in many locations to help address any
issues that could arise during the waste mixing process.
Effluent Receiving Waters:
Effluent from this facility drains into an unnamed tributary of Haskett Creek, class "C" waters of
the Cape Fear River Basin. Please note that this area is part of the Cape Fear River Basin so the potential
exists for future changes to the class of waters or additional nutrient testing requirements.

Self -Monitoring Program:
This facility is required to provide qualitative monitoring twice annually. The outfalls where
stormwater is discharged from the facility are expected to be properly maintained and monitored. At the
time of the inspection monitoring was being done, however there was no obvious maintained access to the
western outfall. Please ensure that regular maintenance is being performed to keep the outfall clear and
maintained. Monthly inspections of the facility are required to ensure the facility is meeting the
housekeeping requirements in the permit. At the time of the inspection these regular inspections were
being completed as required.
There are no additional comments or changes to the currently operating permit. Please continue
to keep up the facility and monitor stormwater discharges. If you have any questions or need additional
information, please contact Brandon Wise at [phone] or [e-mail].
Sincerely,
Brandon Wise
Stormwater Specialist
Land Quality Section
Winston-Salem Regional Office
Enclosures: Inspection Report
cc: NCDEQ — DEMLR (WSRO) w/o enclosure
NCDEQ — Air Quality (WSRO) w/o enclosure

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