The URL can be used to link to this page

Home My WebLink AboutNCG520112_Benchmark_Mining_CEI_Letter_20240806ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director Benchmark Mining & Farming, LLC Attn: Stephen M. Frucht, Owner 689 Drumheller Ct Clemmons, NC 27012 NORTH CAROLINA Environmental Quality August 6, 2024 SUBJECT: COMPLIANCE EVALUATION INSPECTION & NOTICE OF DEFICIENCY NOD Tracking #: NOD-2024-PC-0139 NC General NPDES Permit: NCG520000/Certificate of Coverage: NCG520112 Facility Name: Benchmark Mine No. 1 Surry County Dear Mr. Frucht: On July 11, 2024, Division of Water Resources staff, Ron Boone and Michael Gearren, conducted a routine compliance evaluation inspection at the subject facility. We've attached a Water Compliance Inspection Report to this letter, which details the findings of the inspection. Mr. Boone and Mr. Gearren noted no areas of concern, deficiencies, or violations. If you have any questions or concerns about the inspection or this report, you may contact Mr. Boone by phone at 336.776.9690 or by email at ron.boone(&deq.nc.gov. Sincerely, DocuSigned by, OD2D3CE3F 1 B1456... Jennifer F. Graznak, Assistant Regional Supervisor Water Quality Regional Operations Section Winston-Salem Regional Office Division of Water Resources, NCDEQ Attachments: 1. Water Compliance Inspection Report 2. List of NC Certified Commercial Laboratories 3. NC General Wastewater Permit NCG520000 cc: Keith Adams, 1108 Tuckda Way, Hamptonville, NC, 27020 DffNorth Carolina Department of Environmental Quality I Division of Water Resources oan caaouNn Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105 M336.776.9800 oep.m.m or em�nmen� Qualm 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 u 3 I NCG520112 111 121 24/07/11 I17 18 LC] I 19 I s I 20L] 21111I I I I I I I II I I I I I I I I I I I I I I I I I I I I I I I II I I I I I r6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved ------------------- 67 I 72 I ni I 71 I 74 79 I I I I I I I80 701 I 71 I LL -1 I I LJ 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 Dermit Number) 10:30AM 24/07/11 21/03/31 Benchmark Mine No. 1 Old Rockford Rd Exit Time/Date Permit Expiration Date Siloam NC 27047 11:00AM 24/07/11 25/07/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Stephen M Frucht,689 Drumheller Ct Clemmons NC 27012//336-345-1345/336766363C No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Flow Measurement Operations & Maintenar Records/Reports Self -Monitoring Progran 0 Facility Site Review Effluent/Receiving Wate Laboratory 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 Ron Boone Docusigned by: DWR/WSRO WQ/336-776-9690/ Michael Gearren �p DWR/WSRO WQ/336-776-9800/ 8/6/2024 E-,0F8DD5F2A3460... Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date by: jDocuSigned if -4. DwR/WSRo 336-776-9695 8/6/2024 '--- OD2D3CE3F 197456_. EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type NCG520112 I11 12I 24/07/11 117 18 i c i (Cont.) Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) On July 11th, 2024, Ron Boone and Michael Gearren, of the Winston-Salem Regional Office of the NC Division of Water Resources, conducted a compliance evaluation inspection at the Benchmark Mine #1 located in Siloam, NC. This facility discharges to the Yadkin River and is covered by NPDES general permit NCG520000, certificate of coverage NCG520112. The assistance and cooperation of Keith Adams was greatly appreciated. Mr. Adams stated that they had not dredged at this site since the end of September 2023. The facility was clean and well maintained. Mr. Adams could not verify with certainty that the signs, required in section A of the permit, which they erected on the river as a result of the previous inspection, were still standing. He stated he would check on their condition. The permit requires that the permittee test the effluent for turbidity and measure the flow twice annually. No testing or flow measurement data was presented during the inspection. The turbidity testing must be done by a lab certified by the State of NC. Mr. Adams stated that no certified testing has been done and that he runs a turbidity test himself despite not being certified to do so. This essentially results in no valid testing data. We have attached a list of certified laboratories that you can take samples to for certified analysis. Please share the next certified test results you get with Mr. Boone. Since operations at this facility occur in batches, approximately two times per year, the permittee should attempt to run at least one analysis for each of two separate operational periods. If it is known that the facility will only open for a single operational period during the year, then the permittee may decide to take two separate samples during that single operational period to meet the permit requirement. Another option is for Benchmark to obtain their own field lab certification. Turbidity is one of several parameters known as field parameters for which a permittee can become certified to run themselves. If you wish to do so, you can initiate the process by going to our website here and follow the provided instructions: https://www.deq.nc.gov/about/divisions/water-resources/water-sciences/chemistry-laboratory/laborato ry-certification-bran ch/field-lab-certification Please send Mr. Boone photographic evidence of the signs required in Section A of the permit. Please ensure it is discernable in the photos the side of the river that each sign is on. Also, please inform Mr. Boone, within 10 business days of receiving this report, of your plan to attain and maintain future compliance with the monitoring requirements of the permit, i.e. turbidity testing and flow measurement. If you have any questions or concerns regarding the inspection or this report, please contact Mr. Boone by phone at 336.776.9690, or by email at ron.boone@deq.nc.gov. Page# Permit: NCG520112 Inspection Date: 07/11/2024 Owner - Facility: Benchmark Mine No. 1 Inspection Type: Compliance Evaluation 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: None Record Keeping Are records kept and maintained as required by the permit? Is all required information readily available, complete and current? Are all records maintained for 3 years (lab. reg. required 5 years)? Are analytical results consistent with data reported on DMRs? Is the chain -of -custody complete? 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? (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator 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? Facility has copy of previous year's Annual Report on file for review? Yes No NA NE ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ El El ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ Page# 3 Permit: NCG520112 Inspection Date: 07/11/2024 Owner - Facility: Benchmark Mine No. 1 Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Comment: Facility is not required to submit DMRs and does not require an operator in responsible charge. Keith Adams is the individual who manages operation and maintenance of the facility. Mr. Adams is currently running field turbidity samples himself but is NOT certified to do so by the NC DWR Laboratory Certification Branch, as required. This is a violation of the permit and can be remedied by becoming field certified to run the turbidity samples himself or taking the samples to a certified laboratory. More information about this is in the Summary section of this report. Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? ❑ ■ ❑ ❑ 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 Celsius)? Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? ❑ ❑ ■ ❑ Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? ❑ ❑ ■ ❑ Comment: Mr. Adams is currently running field turbidity samples himself but is NOT certified to do so by the NC DWR Laboratory Certification Branch, as required. This is a violation of the permit and can be remedied by becoming field certified to run the turbidity samples himself or taking the samples to a certified laboratory. More information about this is in the Summary section of this report. Effluent Sampling Yes No NA NE Is composite sampling flow proportional? ❑ ❑ 0 ❑ Is sample collected below all treatment units? ❑ ❑ ❑ Is proper volume collected? ❑ ❑ ❑ ■ Is the tubing clean? ❑ ❑ ■ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 ❑ ❑ ❑ degrees Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type ❑ 0 ❑ ❑ representative)? Comment: All samples are qrab. No sampling was done durinq the inspection so a full evaluation of sampling procedures was not conducted. Two samples per year are required but no sampling results, certified or not, were provided during the inspection. More information about this is also in the Summary section of this report. Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? ❑ ❑ 0 ❑ Is flow meter calibrated annually? ❑ ❑ 0 ❑ Is the flow meter operational? ❑ ❑ 0 ❑ Page# 4 Permit: NCG520112 Owner - Facility: Benchmark Mine No. 1 Inspection Date: 07/11/2024 Inspection Type: Compliance Evaluation Flow Measurement - Effluent Yes No NA NE (If units are separated) Does the chart recorder match the flow meter? ❑ ❑ 0 ❑ Comment: There is no flow meter. Flows are estimated, if anvthinq. Flows should be estimated at the same time that turbidity samples are taken. No turbidity or flow information was provided during the inspection. Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? 0 ❑ ❑ ❑ Are the receiving water free of foam other than trace amounts and other debris? 0 ❑ ❑ ❑ If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ 0 ❑ Comment: There was no discharge during the inspection. Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑ Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ 0 ❑ ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: None Page# 5