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Home My WebLink AboutNC0089702_Compliance Evaluation Inspection_20210415ROY COOPER Governor DIONNE DELLI-GATTI Secretary S. DANIEL SMITH Director Richard Rivitz Brightleaf Durham Associates LLC 22730 Fairview Center Dr. Ste. 200 Fairview Park, OH 44126 NORTH CAROLINA Environmental Quality April 15, 2021 Subject: Compliance Evaluation Inspection Brightleaf on Main NPDES Permit No NCO089702 Durham County Dear Mr. Rivitz: On March 3, 2021, Cheng Zhang of the Raleigh Regional Office (RRO) conducted a Compliance Evaluation Inspection at the subject facility. The assistance provided by Mr. Gary Fischer, Operator in Responsible Charge (ORC), was appreciated. The inspection report is attached. Findings during the inspection were as follows: 1. The facility is currently permitted to discharge 0.0065 MGD of treated groundwater into an unnamed tributary (UT) to Ellerbe Creek, a waterbody currently Classified WS- V; NSW within the Neuse River Basin. Original permit was issued on November 18, 2018. Current permit was modified on July 16, 2020, and became effective on September 1, 2020. 2. The plant is classified as a PC-1 wastewater facility. Mr. Gary Fischer is designated as the ORC; Mr. Fred Ammons is designated as the backup ORC. Operation log books are detailed and are kept onsite going back since starting operation in December 2018. 3. Field lab parameter (Certificate No. 5730) calibration and analysis records were reviewed during the inspection. Please be reminded of new rules that require field labs to have Standard Operating Procedures (SOPs) and develop and implement a documented training program. January and July 2020 DMR data was compared to bench sheets and lab reports; no data transcription errors were noted. Lab results, chain -of -custody forms, and DMRs were complete and organized. 4. The permit lists the following units: • Subgrade collection/ settling sump • Submersible pumps (primary and backup) • Ion -exchange resin filters • Liquid phase carbon filters • Influent and effluent sample ports D QZ� North Carolina Department of Environmental Quality I Division of Water Resources Raleigh Regional Office 1 3800 Barrett Drive I Raleigh, North Carolina 27609 NORTH CCAROI INA ^P.�,^+^ro^m•^�� /'� 919.791.4200 • Totalizing flow meter • Appurtenant discharge piping to local storm -sewer At the time of inspection, one bag filter, one resin filter, and four carbon filters were in service. Influent was pumped from the sump (vault) and treated by the treatment units. 5. The inspector noticed the following issues during the inspection: • The effluent flow meter has not been calibrated since it was installed in 2018. Permit requires that the flow meter be calibrated at least once a year. There is an overflow pipe in the sump, water flows through the pipe would bypass the treatment system. This pipe needs to be plugged/sealed. It was unknown whether the telemetry unit at the sump/vault was operational or not. Please verify the status of the telemetry. 6. Since starting operation in December 2018, the facility has experienced multiple monitoring and limit violations, including late DMR submission, missing flow records, limit violations for copper, lead, and flow. The facility exceeded flow daily maximum limit three times in 2020, due to increased aquifer recharge and runoff inflow to the vault. Action was taken to reduce the infiltration to the pump vault by sealing the vault doors with tapes, which was noted during the inspection. Please response in writing to RRO within 30 days regarding issues listed in Item 5. If you have any questions regarding the attached report, please contact Cheng Zhang at 919-791-4200 (or email: cheng. zhang@ncdenr. gov). Sincerely, DocuSigned by: I WVU,SSA, f . hA�dAd,�, B2916EMB32144F... Vanessa E. Manuel, Assistant Regional Supervisor Water Quality Regional Operations Section Raleigh Regional Office Division of Water Resources Attachments: Compliance Inspection Report Cc: Central Files w/attachment (Laserfiche) Raleigh Regional Office w/attachment Daniel Nielsen, Mid -Atlantic Associates Inc. (electronic copy only) North Carolina Department of Environmental Quality I Division of Water Resources Raleigh Regional Office 1 3800 Barrett Drive I Raleigh, North Carolina 27609 NORTH CCAROI INA ^P.�,^+^ro^m•^�� /'� 919.791.4200 United States Environmental Protection Agency Form Approved. EPA Washington, D.C. 20460 OMB No. 2040-0057 Water Compliance Inspection Report Approval expires 8-31-98 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 1 IN 1 2 15 I 3 I NCO089702 I11 121 21/03/03 I17 18I� I 191 S I 201 211IIIII IIIIIIIIIII IIIIIII I111111 IIIIIIIIIII �66 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved ------------------- 67 70 J 71 I 72 LnJ 73 74 79 I I I I 80 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date POTW name and NPDES permit Numbed 09:OOAM 21/03/03 20/09/01 Brightleaf on Main 1001 W Main St Exit Time/Date Permit Expiration Date Raleigh NC 27603 11:00AM 21/03/03 23/06/30 Name(s) of Onsite Representative (s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Gary A Fischer/ORC/919-250-9918/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Richard S Rivitz,22730 Fairview Center Dr Ste 200 Fairview Park OH 44126//404-348-1850/ NO Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Flow Measurement Operations & Maintenar N Records/Reports Self -Monitoring Progran 0 Facility Site Review Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date Cheng Zhang Docusignedby: DWR/RRO WQ/919-791-4200/ 4/15/2021 cx2 u.� D6171508E1EC41F... Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date DocuSigned by: 4/15/2021 Vatn t,SS& . Ill 4 a 2 PA 2916W6Y EPA �orm S50U lKev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type (Cont.) 31 NCO089702 I11 12I 21/03/03 117 18 ICI Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) The treatment consists of subgrade collection/settling sump, submersible pumps (primary and secondary), ion -exchange resin fileters, liquid phase carbon filters, influent and effluent sample ports, totalizing flow meter, and appurtenant discharge piping to local storm -sewer. At the time of inspection, one bag filter, one resin filter, and four carbon filters were in service. The flow meter has not been calibrated since it was installed. An overflow pipe was noted in the sump, water flows through the pipe would bypass the treatment system. The pipe needs to be plugged/sealed. It was unknown whether the telemetry at the sump was operational or not. Since starting operation in 12/2018, the facility experienced the following violations: Late submission of DMRs in 12/2018 and 1/2019. Limit violations for copper and frequency violations for flow in 2/2019. Limit violations and frequency violations for flow in 4/2019. Limit violations for lead in 9/2019. Frequency violations for flow in 11/2019 and 12/2019. Limit violations for flow in 2/2020, 9/2020, and 12/2020. Page# Permit: NCO089702 Inspection Date: 03/03/2021 Operations & Maintenance Is the plant generally clean with acceptable housekeeping? Owner -Facility: Brig htleaf on Main Inspection Type: Compliance Evaluation Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: Permit (If the present permit expires in 6 months or less). Has the permittee submitted a new application? Is the facility as described in the permit? # Are there any special conditions for the permit? Is access to the plant site restricted to the general public? Is the inspector granted access to all areas for inspection? Comment: Permit was issued 11/8/2018, and was modified on 7/16/2020. Flow Measurement - Effluent # Is flow meter used for reporting? Is flow meter calibrated annually? Is the flow meter operational? (If units are separated) Does the chart recorder match the flow meter? Yes No NA NE ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ Yes No NA NE ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Yes No NA NE Comment: Water meter type flow meter has not been calibrated since it was installed. Pump Station - Influent Is the pump wet well free of bypass lines or structures? Is the wet well free of excessive grease? Are all pumps present? Are all pumps operable? Are float controls operable? Is SCADA telemetry available and operational? Is audible and visual alarm available and operational? ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ Yes No NA NE ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ Comment: There is an overflow pipe that needs to be plugged. It was unknown whether the telemetry was operational. Record Keeping Are records kept and maintained as required by the permit? Yes No NA NE ■ ❑ ❑ ❑ Page# 3 Permit: NCO089702 Owner -Facility: Brig htleaf on Main Inspection Date: 03/03/2021 Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Is all required information readily available, complete and current? 0 ❑ ❑ ❑ Are all records maintained for 3 years (lab. reg. required 5 years)? 0 ❑ ❑ ❑ Are analytical results consistent with data reported on DMRs? 0 ❑ ❑ ❑ Is the chain -of -custody complete? 0 ❑ ❑ ❑ Dates, times and location of sampling Name of individual performing the sampling Results of analysis and calibration Dates of analysis Name of person performing analyses Transported COCs Are DMRs complete: do they include all permit parameters? ❑ ❑ ❑ Has the facility submitted its annual compliance report to users and DWQ? ❑ ❑ 0 ❑ (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operato ❑ ❑ ❑ on each shift? Is the ORC visitation log available and current? ❑ ❑ ❑ Is the ORC certified at grade equal to or higher than the facility classification? ❑ ❑ ❑ Is the backup operator certified at one grade less or greater than the facility classification' ❑ ❑ ❑ Is a copy of the current NPDES permit available on site? 0 ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review? ❑ ❑ 0 ❑ Comment: Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? 0 ❑ ❑ ❑ Are all other parameters(excluding field parameters) performed by a certified lab? 0 ❑ ❑ ❑ # Is the facility using a contract lab? 0 ❑ ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees 0 ❑ ❑ ❑ Celsius)? Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? ❑ ❑ 0 ❑ Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? ❑ ❑ 0 ❑ Comment: The operators analyzes effluent pH, all other parameters are analyzed by contract lab. Page# 4