NCS000616_Inspection Report_20240502

Compliance Inspection Report
Permit:NCS000616 Effective: Expiration: Owner: Braven Environmental LLC
SOC: Effective: Expiration: Facility: Braven Environmental, LLC
County: Wake 517 N Industrial Dr
Region: Raleigh
Wendell NC 27591
Contact Person:Christopher Serrati Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 05/02/2024 Entry Time 10:20AM Exit Time: 11:50AM
Primary Inspector:Thaddeus W Valentine Phone:
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Storm Water
(See attachment summary)
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Permit: NCS000616 Owner-Facility:Braven Environmental LLC
Inspection Date: 05/02/2024 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Site Review
There are 35-40 220 gallon poly tanks with petroleum or petroleum residue along the side and back of the building located
outside exposed to stormwater. At least one has been hit and crushed by a lift or some other heavy equipment. These tanks
and containers must be stored in secondary containment if situated outside or be stored inside in an area that cannot reach
the outside if ruptured or spilled.A standard operating procedure(SOP)should be developed for storage practices
Along with the poly tanks there are drums of petroleum and petroleum residue placed along the back and side of the facility.
Some are closed with petroleum residue accumulated on the lids and running down the sides onto the ground with some
completely to partially open to the weather. Some have accumulated rainwater inside.
All of these containers/vessels require secondary containment to be stored outside exposed to stormwater or in an area that
can flow or be tracked outside and exposed to stormwater. Additionally, these containers/vessels cannot be brought outside
to be pumped down unless they are placed in a secondary containment area while they are pumped down. All drums should
have secured lids with plugs in all plug holes. No drums can be stored outside unless they have secure lids and zero residue
on the top or sides. The handling of drums outside is limited to the loading or unloading of drums and a detailed (SOP) must
be in place and reviewed by personnel with that duty.
There are gas cans and buckets of petroleum with rainwater in different areas around the facility as well. These gas
containers must be stored inside when not in use
There are wood pallets and used secondary containment pallet for drums and small vessels along the North side of the
facility, most of which are covered with or having visible petroleum residue spilled on and around the sides. These wood and
used secondary containment pallets must be stored inside or under a shelter that stormwater cannot reach or run through.
The Oil Water Separator(OWS)on site is being used to pump down the secondary containment area for the large chemical
storage tanks. (OWS's)are not able to function as required when water/product is being pumped to it at a high velocity,
which is the case with this setup. The (OWS)should be used to remove oil only. The other chemicals in the tanks will
require specific methods of removal depending on the chemical being removed from the secondary containment. This should
be researched and an acceptable method for removing all the different chemicals found in the secondary containment will
need to be approved by DEQ's different divisions before water is pumped from the secondary containment through a system.
Until that is achieved, the water accumulated in the secondary containment must be disposed of properly off site.
The same is true for the secondary containment for the (OWS). Accumulated water/product should be disposed of properly,
off site, until an approved method of onsite disposal is approved
There are drums of Glycol, startup oil and hazardous materials stored inside alongside the loading dock. There are 20+ poly
tanks of liquids, from the secondary containment areas, stored indoors in a bunched, stacked manner. Any liquid materials
stored inside will need some type of secondary containment due to the close proximity to doors and the construction of the
building. The walls of the building are sheet metal that rest on the concrete floor. That type of construction allows for liquids
to seep out of the building if there is a spill or leak. Some type of secondary containment, or other approved method, is
required to store liquid chemicals indoor in large quantities.
Documentation
Standard operating procedure (SOP's)should be developed for all processes at the facility that have the potential for
exposure to stormwater. This will include the transporting of char materials to the outside containers. Be sure to cover all
processes at the facility.
Train all employees that work in material handling areas proper spill prevention and proper material handling procedures,
maintenance and inspections
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Permit: NCS000616 Owner-Facility:Braven Environmental LLC
Inspection Date: 05/02/2024 Inspection Type:Compliance Evaluation Reason for Visit: Routine
There should always be someone on site that can provide any documents requested or answer basic questions related to
stormwater procedures and awareness.
Site specific inspection documents should be developed for all areas of the facility with the potential for spills or leaks. They
should also know the outfall types and locations
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Permit: NCS000616 Owner-Facility:Braven Environmental LLC
Inspection Date: 05/02/2024 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? ❑ ❑ ❑
#Does the Plan include a list of significant spills occurring during the past 3 years? ❑ ❑ ❑
#Has the facility evaluated feasible alternatives to current practices? ❑ ❑ ❑
#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? ❑ ❑ ❑
#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? ❑ ❑ 0 ❑
Comment: Documents for the permit are being developed
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