NC0090093_Respose to NOV-2024-LV-0682_20240826

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ONE ENVIRONMENTAL GROUP
August 23, 2024
Ms. Vanessa Manuel AUG 2 6 20?4
Deputy Regional Supervisor
Water Quality Regional Operations Section
NCDEQ Raleigh Regional Office
3800 Barrett Dr.
Raleigh, NC 27609
Attention: Cheng Zhang
Re: NPDES Permit # NCO090093
Written Response to:
NOV-2024-LV-0682
Dear Ms. Manuel:
AP Peabody & Gregson LP received a Notice of Violation (NOV) and Intent to Assess Civil Penalty
from the North Carolina Department of Environmental Quality (NCDEQ) on August 13, 2024,
concerning an exceeded flow value through the treatment system located at 810 West Peabody
Street in Durham, North Carolina ("the property').
The NOV is outlined as follows:
Sample
NOV Tracking
Limit Value
Reported
Location
Number
parameter
Date
d
Value d
001 Effluent
NOV-2024-LV-0682
Flow
5 31 2024
455
14,380.13
The property was recently redeveloped with a two-story commercial structure occupied by BioLabs
North Carolina, a biotech co-worldng facility. The property is located at the former Durham Dry
Cleaners (DCSA Site ID DC320026), which provides a historical source of groundwater
contamination. Groundwater is recovered through a gravity -fed French drain system around the
building's perimeter to prevent interior flooding. Recovered groundwater is sent through a bag
filter and two activated carbon (GAC) fiberglass treatment vessels connected in series prior to
discharge into the City of Durham stormwater system.
Following the completion of the new construction, significant rainfall occurred in Durham during
December 2023, recharging the area water table which had been in severe to extreme drought
conditions. The aquifer has since returned to a steady-state discharge volume that is significantly
higher than the volume estimated during the initial NPDES permit application and the start of
system operation.
Based on the higher discharge rate, a major modification to minor source NPDES Permit #
NCO090093 was submitted to the NCDEQ Division of Water Resources on May 1, 2024. AP Peabody
& Gregson LP received a draft copy of the permit modification with a revised flow rate of 0.072
MGD on July 30, 2024. The draft permit was available for public comment until August 22, 2024.
ONE Environmental Group of Carolina, PLLC
www.oneenv.com

On behalf of AP Peabody & Gregson LP, ONE requests that a letter of no further action be issued as
AP Peabody & Gregson is continuing to comply with all other NPDES permit conditions and a
revised draft permit has been received prior to the receipt of this NOV.
If you have any questions or comments or require any additional information, please do not
hesitate to contact me at [phone], or by e-mail at [e-mail].
Sincerely,
ONE Environmental Group of Carolina, PLLC
Mary Kennamer, P.E.
Project Manager
cc: Forrest Cherry, AP Peabody & Gregson
ONE Environmental Group of Carolina, PLLC
www.oneenv.com