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Home My WebLink AboutNEROC PPGH Inspection 4.6.20224/20/22, 12:21 PM Print Preview - Cityworks Pollution Prevention and Good Housekeeping Inspection Inspection Item Value Inspection Id 850303 Entity Uid Northeast Remote Operations Location Northeast Remote Operations (Burwell St) Inspection Date /6/2022 10:30:07 AM Inspected By Jeltema, Stephen Recommendations Recommended they work with consultant to support SWPPP implementation. update - 4/8/22 - PO setup with consultant to support SWPPP implementation. Actual Finish /6/2022 5:00:12 PM Date Closed /7/2022 8:26:20 AM Closed By Jeltema, Stephen Status CLOSED Coordinate (State Plane) 2125356.573 Y Coordinate (State Plane) 778453.11 Initiated By Jeltema, Stephen Link ttps://cityworks.raleighnc.gov/cityworks/WorkManagement/InspectionEdit.aspx? InspectionId=850303 Observations / Results Question Answer 1. Remove feature/site from inventory? (Does the feature no No longer exist and should be permanently removed?) 2. Please add representative feature/site photo(s). CHECKED 3. Is this a no exposure site? (Does this feature qualify as a no No exposure site where materials and operations are not exposed to stormwater and should be reassessed once every permit cycle (5 years). 4.a. Does this feature/site have a NPDES Industrial Permit? Yes 4.b. Does the site have a current SWPPP? Yes 4.c. Are all requirements of the permit being followed? No 4.d. Has an inspection by SW staff been conducted at this No facility within the last 12 months with no outstanding compliance issues identified? 4.e. What actions are being taken to comply with the site's Follow up email and enforcement through internal PDES Industrial permit requirements? departmental memorandum. 5.a. Does the feature/site have a parking lot with City -owned Yes vehicles stored on the property? 5.b. Approximately how many vehicles are stored/parked long- 50 term on this property? 5.c. Are sufficient measures in place to prevent vehicle fluids Yes from coming in contact with stormwater? (Examples: drip [pans, inlet protection, covered parking areas) https://cityworks.raleighne.gov/cityworks/WorkManagement/Printing/PrintPreview.aspx?lightenform=true&I nspectionId=850303 1 /5 4/20/22, 12:21 PM Print Preview - Cityworks 5.d. What actions are being taken to address deficiencies? /A 6.a. Does the feature/site have a dumpster(s)? Yes 6.b. Is the dumpster(s) covered when not in use? Yes 6.c. Is the dumpster(s) capped to prevent discharge from inside nit? Yes 6.d. What actions are being taken to address deficiencies? /A 7.a. Does the feature/site have an outfall, storm drain, natural watercourse or stormwater conveyance directly associated with it? Yes 7.b. Add photo of outfall or point where runoff enters MS4. CHECKED 7.c. Is there any discoloration, need for maintenance or evidence of contamination at the outfall? No 7.d. What actions are being taken to address deficiencies? /A 8. Does any of the additional activities/categories listed below apply to this feature/site: Yes Chemical, pesticides, herbicides and/or fertilizer use or storage Yes Vehicle maintenance, washing and/or fueling operations Yes Pool/Aquatic center operation and maintenance No Park facilities use and maintenance No Storage building and/or storage yard operation and maintenance Yes Generator Yes This site has a SPPP No Are sufficient measures in place to prevent chemicals from coming in contact with storm -water during storage and use? (Examples: covered storage areas, secondary containment, inlet protection) Yes e chemicals stored and disposed of as directed on the product labels? Yes Does this feature/site have a pesticide, herbicide, and fertilizer application plan? Yes Does the permittee use integrated pest management (IPM)? /A Is training required and regularly conducted for chemical applicators or users? Yes If "No" to any of the above questions, what actions are being taken to address deficiencies? /A If a fire station, is the facility exempt by the NPDES permit (3 or less fire trucks) from vehicle washing requirements? /A Is washing or maintenance performed under cover and not outdoors? Yes If vehicle fueling occurs at this site, is there a stocked spill kit located near the fueling station? Yes Is there proper storage of used oil? Yes Is the oil water separators maintained with records? Yes Are street sweepers, trash trucks and other vehicles/equipment washed out properly No e chemicals stored and disposed of as directed on the Yes https://cityworks.raleighnc.gov/cityworks/WorkManagement/Printing/PrintPreview.aspx?lightenform=true&lnspectionId=850303 2/5 4/20/22, 12:21 PM Print Preview - Cityworks product labels? Is there a spill kit and spill SOP for the facility? Yes If "No" to any of the above questions, what actions are being wash wastewater is not being properly contained due to taken to address deficiencies? construction design and some tracking. Addressed through email. Does the pool backwash discharge to sanitary sewer? No If pool backwash discharges to the storm sewer or natural /A watercourse, does the facility have a dichlorination procedure prior to discharge with records? e chemicals stored and disposed of as directed on the No product labels? If "No" to any of the above questions, what actions are being /A - No pool taken to address deficiencies? Does the park have trash enclosures that are emptied regularly? /A Does the park have pet waste disposal stations equipped with /A bags and signs? e all parking lots clear and free of debris? /A o all of the stormwater BMPs throughout the site appear to be Yes properly functioning with no apparent deficiencies? (Examples: stream buffers, stormwater conveyances, SCMs) If there a boat house and/or are operations conducted over /A water with proper/adequate BMPs and precautions in place to prevent impact to surface waters? If "No" to any of the above questions, what actions are being /A taken to address deficiencies Is there an opportunity to incorporate a vegetated buffer along No any natural watercourses throughout the park property? (if yes, describe location in Section 9 - Additional Observations) Are parking lots clear of debris and regularly maintained? Yes If spill kits are needed on site, are they present, accessible, and Yes stocked? Are stockpiles properly contained? Yes e sufficient measures in place to protect storm drains, inlets No and natural watercourses throughout and adjacent to the site? (Examples: grass buffers, secondary containment, inlet protection, construction entrance or temporary perimeter measures) If "No" to any of the above questions, what actions are being /A taken to address deficiencies? 9.a. Are there any other deficiencies that need to be addressed Analytical Sampling and Inspections/Training need to be throughout the site? current per SWPPP requirements. This program is beginning implementation in 2022 due to pending permit with State. 9.b. Optional - Please add any additional photos. Is there secondary containment around the generator? Yes if "No" is secondary containment recommended and possible? Is there a hard -copy of the SPPP available on site? No Is the SPPP current with no updates required? No https://cityworks.raleighnc.gov/cityworks/WorkManagement/Printing/PrintPreview.aspx?lightenform=true&lnspectionId=850303 3/5 4/20/22, 12:21 PM Print Preview - Cityworks Have all components of SPPP been implemented as required? No No No Has the Spill and Release Log been maintained and current? Has the SPPP On -Site Training Log been maintained and current? There are there no features at this facility that are need to be No addressed by the current SPPP If "No" to any of the above questions, what actions are being /A - SWPPP, not SPPP, is being implemented at this site. taken to address deficiencies? Implementation has not occurred since February, 2022 due to anagement and role turnover for facility. Map Placeholder Image https://cityworks.raleighnc.gov/cityworks/WorkManagement/Printing/PrintPreview.aspx?lightenform=true&lnspectionId=850303 4/5 4/20/22, 12:21 PM Print Preview - Cityworks Northeast R emotE is Opeiatons ente i� 2 A t https://cityworks.raleighnc.gov/cityworks/WorkManagement/Printing/PrintPreview.aspx?lightenform=true&lnspectionId=850303 5/5 Raleigh Union Station Inspection Date: March 6, 2022 1 Wet Pond -Facing East Washstation -Facing East -Containment needed Fuel ASTs;DEF Tank, Remote Fill Port, Facing South Dispensing Area and Adsorbent Application, Facing West Raleigh Union Station Inspection Date: March 6, 2022 2 TFS Emergency Generator with Subbase Tank (Diesel), Facing East Covered Treated Lumber Storage, Facing East Parks Emergency Generator with Subbase Tank (Diesel), Facing West Waste Recepticle Area, Parks, Facing West Raleigh Union Station Inspection Date: March 6, 2022 3 SDO_001 Mouth from Pond, Facing North Proxy Outfall Location -SDO-001, Facing West Proxy Outfall -SDO-002 Location within Catchment, Facing North Proxy Outfall -Outfall-002 -Location, Facing North 1 Jeltema, Stephen From:Jeltema, Stephen Sent:Thursday, April 7, 2022 8:25 AM To:Dickerson, Patrick K Cc:Harcum, Justin; Poole, Zachary Subject:Industrial PPGH Inspection - Internal Audit - NEROC Patrick: Thanks for taking the time today to participate in the Pollution Prevention and Good Housekeeping self-audit inspection. You’ve recently been established as the site manager for the NEROC facility’s Stormwater Pollution Prevention Plan. This position should oversee the implementation of the Industrial NPDES required SWPPP document for the facility. First action item that should be completed is checking that your facility is up to date with your NPDES permit compliance. Please contact Jim Frei with Stormwater Services Group, LLC, whom you had a previous relationship with, and see if they have been performing the required inspections, training, stormwater discharge monitoring for 2021. Please let us know if this is the case. If they have not, then your facility is out of compliance since this SWPPP was implemented early 2021 and this should be addressed as soon as possible. Stormwater Services Group, LLC 8916 Oregon Inlet Ct. Raleigh, North Carolina 27603 Phone: (919) 661-9954 Fax: (919) 661-8108 As for this inspection, we have been seeing recurring issues: please see our pollution prevention recommendations below in review of your facility. Please note that several of these concerns have been noted during previous site visits over the last year:  We observed some oil dripping at your fuel dispensers where this absorbent was applied, but not collected and disposed of. Your oil absorbent should be utilized and disposed of in agreement with the product application and disposal guidelines and the MSDS. Typically, this material is collected and disposed of directly, and is not allowed to sit and degrade. Either way, it is not an allowable discharge if it was to be transported into a receiving water or the City’s MS4.  There are oil stains throughout the facility in multiple areas. These can be mitigated by drip pans and remediating the oil stains with adsorbent. If the material is persistent – you can use power washing techniques or equivalent and capture the wastewater.  The vehicle wash facility shows a steady stream of excess waste water that drains directly into a catchment that bypasses any stormwater control measure. We performed a test onsite and identified that this discharge is caused by the wash station not containing the fluids at the exit point as a whole, versus just overspray and tracking from the vehicles. This has been a persistent issue and we recommend attempting to contain this wash wastewater utilizing a containment curb to redirect the wash wastewater to its internal collection system that pumps directly to the adjacent O&W separator, versus attempting to treat it downstream.  Your records are not kept onsite and logs are not kept up to date in the SWPPP document, nor can we point to an online repository. Please see note above in the beginning of this email and make sure that there is a system in place, either through a contractor, or in house personnel, that is complying with the requirements of this NPDES permit. 2  We recommend providing cover to your metal scrap bins to avoid exposure to stormwater. This may include moving your bins under existing cover or covering these bins when not in use. Please reach out once the SWPPP records for 2021 and the first quarter of 2022 have been located so that Stormwater staff can review and provide any necessary feedback. We are requesting a follow-up site visit once the containment curb has been installed at the exit of the vehicle wash facility. Please let me know how we can further assist you in these efforts. Thank you! Stephen Jeltema Engineer I City of Raleigh Engineering Services Department Stormwater Management 127 West Hargett Street | 8th Floor Raleigh, NC 27601 (p) 919-996-3961 (m) 984-265-9809 raleighnc.gov