NCG510522_NOV-2022-PC-0740 and Compliance Evaluation Inspection_20221207

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS. JR.
Director
NORTH CAROLINA
Environmental Quality
December 7, 2022
CERTIFIED MAIL NO. 7020 3160 0002 0860 9468
RETURN RECEIPT REQUESTED
Mr. Alan Cubberley
Circle K Stores, Inc.
1100 Situs Court, Suite 100
Raleigh, North Carolina 27606
SUBJECT: Notice of Violation (NOV-2022-PC-0740)
Compliance Evaluation Inspection
NC General Wastewater Permit NCG510000 for Discharge of Wastewater from a
Groundwater Remediation System
Certificate of Coverage: NCG510522 for the Circle K Store #2720161, Elon,
Alamance County, North Carolina
Dear Mr. Cubberley:
Mr. Jim Gonsiewski of the North Carolina Division of Water Resources (DWR), Winston-Salem
Regional Office (WSRO), visited your facility on November 8, 2022 and met with Mr. Brad Byers,
Remediation System Technician of ATC Associates of North Carolina, P.C., to perform a
compliance evaluation inspection of your facility's groundwater remediation system. Details of that
inspection are included on the attached EPA Water Compliance Inspection Report.
The following items were noted during the inspection:
The remediation system consists of two (2) separate units. The first system is located at the gas
station has been operating since 2003. Initially the system operated as an air sparging/soil vapor
extraction system. A dual phase extraction (DPE) system was added in 2008. A second DPE system
was constructed at the former residence across NC Highway 97 in 2010. Currently forty-four (44)
groundwater monitoring wells are located on and off site. Additionally, twelve (12) DPE wells were
installed. Also, at three (3) residences, the Circle K, and the adjacent restaurant, POE (point of entry)
treatment systems, consisting of UV treatment, a particulate filter, and granulated activated charcoal
treatment, were installed to treat the water supply wells at these locations. Thirty-four (34)
monitoring wells and the DPE wells are sampled annually. The POE systems and effluent are
sampled quarterly. Laboratory analytical results for these sampling events indicated all analyzed
constituents were below laboratory reporting limits or permit standards except for lead. The system
D_E
Department oiiwiro menim Quality
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105
336.776.9800

is very well run. These systems are very well run and maintained and the buildings in which they
are located appear to be in good condition.
The outfall for the 2-inch PVC effluent pipe that transports treated water from both remediation
systems is located east of the former residence. This outfall empties into an unnamed tributary to
Travis Creek.
There were four (4) permit limit exceedances for lead noted in the 2021/2022 effluent data. It is our
understanding that your consultant, ATC Associates of NC, P.C., is actively researching options to
correct this exceedance. Currently they are evaluating a smaller micron filter and a different carbon
for the granulated activated carbon (GAC) vessels to improve the lead removal efficiency of these
vessels. The consultant is also investigating the possibility of installing an ion exchange resin vessel
to both remediation systems. Please continue to monitor this constituent and note any further
exceedances.
Part II. E 6 of the permit requires that an exceedance of any permit limitation must be reported
within 24 hours from the time the permittee becomes aware of the condition. The WSRO was not
notified of the exceedances listed above. If these exceedances occur again, please ensure that
the WSRO Water Quality Regional Operations Section is notified within 24 hours.
Please provide a response to this letter within 30 days of receipt by your office indicating the
corrective actions taken to address this violation.
Thank you for your cooperation in this matter. If you have any questions or concerns, please contact
Jim Gonsiewski by phone at 336-776-9704, or by email at [e-mail]. You may
also contact me by phone at 336-776-9700, or by email at [e-mail].
Sincerely,
DocuSigned by: L VN 1 . by'Mitkr
145B49E225C94Ek..
Lon T. Snider
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ - WSRO
Attachments:
1. NCG510000 General Wastewater Permit
2. NCG510000 Technical Bulletin
3. EPA Water Compliance Inspection Report
cc: Rick Kleinfelter — ATC Associates of NC, P.C. (Electronic Copy)
Maureen Jackson — ATC Associates of NC, P.C. (Electronic Copy)
ID_EQ�
U.p.rhnant W FavY.�aobl QwMp�
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 W. Hanes Mill Rd, Suite 300 1 Raleigh, North Carolina 27105
336.776.9800

United States Environmental Protection Agency
E PA V1Fashington, D.C. 20460
Water Compliance Inspection Report
Form Approved.
OMB No. 2040-0057
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction
1[
21111111
Code
2 IF I
11111111111
NPDES yr/mo/day Inspection
3 I NCG510522 111 121 22/11/08 117
Type
18I Lc]
III
Inspector Fac Type
19 Ls] I 2011
1111111 1 111111
�6
IIII II I I r6
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved
671 I 70I3 I 71172 I N I 73I I I74 751 l I I I I I I I80
J 111
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to PO1W, also include
POTW name and NPDES permit Number)
Circle K Store #2720161
1031 NC Hwy 87 N
Elon NC 27244
Entry Time/Date
11:50AM 22/11/08
Permit Effective Date
21/03/22
Exit Time/Date
12:45PM 22/11/08
Permit Expiration Date
25/09/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Other Facility Data
Name, Address of Responsible Official/TitlelPhone and Fax Number
Contacted
Darrell Davis,12911 N Telecom Pkwy Tampa FL 33637NP/919-631-5473/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Records/Reports Facility Site Review Effluent/Receiving Wate
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s)
Jim J Gonsiewski
of Inspector(s) Agency/Office/Phone and Fax Numbers Date
i—Docusignedby: DWR/Division of Water Quality/336-776-9704/
�o`� 12/7/2022
‘s— E 197B66F 179D45F...
Signature of
Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
Fr oocuSiiggnedbGy: 12/7/2022
L -o, l . JMjCt
�— 4(iQ49E22 t4)Ft-r
EPA Form 3560 ev y y41 Previous editions are obsolete.
Page# 1

NPDES yr/molday Inspection Type
31 NCG510522 111 121 22/11/08 117 18 I
(Cont.)
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Mr. Jim Gonsiewski of the North Carolina Division of Water Resources (DWR), Winston-Salem
Regional Office (WSRO), visited the facility on November 8, 2022 and met with Mr. Brad Byers,
Remediation System Technician of ATC Associates of North Carolina, P.C. to perform a compliance
evaluation inspection of the facility's groundwater remediation system.
The following items were noted during the inspection:
The remediation system consists of two (2) separate units. The first system located at the gas station
has been operating since 2003. Initially the system operated as an air sparging/soil vapor extraction
system. A dual phase extraction (DPE) system was added in 2008. A second dual phase extraction
system was constructed at the former residence across NC Highway 97 in 2010. Currently forty-four
(44) groundwater monitoring wells are located on and off site. Additionally, twelve (12) DPE wells
were installed. Also, at three (3) residences, the Circle K, and the adjacent restaurant, POE (point of
entry) treatment systems, consisting of UV treatment, a particulate filter, and granulated activated
charcoal treatment) were installed to treat the water supply wells at these locations. Thirty-four (34)
monitoring wells and the DPE wells are sampled annually. The POE systems and effluent are
sampled quarterly. Laboratory analytical results for these sampling events indicated all analyzed
constituents were below laboratory reporting limits or permit standards except for lead. The systems
are very well run and maintained and the buildings in which they located appear to be in good
condition.
The outfall for the 2-inch PVC effluent pipe that transports treated water from both remediation
systems is located east of the former residence. This outfall empties into an unnamed tributary to
Travis Creek.
There were four (4) permit limit exceedances for lead noted in the 2021/2022 effluent data. It is the
DEQ's understanding that the consultant, ATC Associates of NC, P.C., is actively researching options
to correct this exceedance. Currently they are evaluating a smaller micron filter and a different
carbon for the granulated activated carbon (GAC) vessels to improve the lead removal efficiency of
these vessels. The consultant is also investigating the possibility of installing an ion exchange resin
vessel to both remediation systems.
Part II. E 6 of the permit requires that an exceedance of any permit limitation must be reported within
24 hours from the time the permittee becomes aware of the condition. The WSRO was not notified of
the exceedances listed above.
A request was made to the permittee to provide a response to this NOV within 30 days of receipt by
their office indicating the corrective actions taken to address this violation.
Page# 2

Permit: NCG510522 Owner - Facility: Circle K Store #2720161
Inspection Date: 11/08/2022
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 ❑ 0 • ❑
application?
Is the facility as described in the permit? • ❑ ❑ ❑
# Are there any special conditions for the permit? 0 •❑ ❑
Is access to the plant site restricted to the general public? 0 • ❑ ❑
Is the inspector granted access to all areas for inspection? • ❑ ❑ ❑
Comment: The remediation systems and wells are locked.
Page# 3