NCS000595_NOV_20220401

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
BRIAN WRENN
Director
CERTIFIED MAIL: 7018 0040 0000 4771 9589
RETURN RECEIPT REQUESTED
Pasture Management Systems, Inc.
Attn: David Hill, President
PO Box 1120
Mt Pleasant, NC 28124
NORTH CAROLINA
Environmental Quality
April 1, 2022
Subject: NOTICE OF VIOLATION (NOV-2022-PC-0167)
NPDES Stormwater Permit NCS000595
Pasture Management Systems, Inc.
Anson County
Dear Mr. Hill:
On March 29, 2022, Mike Lawyer and Penny Markle with the Fayetteville Regional Office of the Division of Energy, Mineral
and Land Resources (DEMLR), conducted a site inspection for the Pasture Management Systems, Inc. facility located at
375 Little Creek Road in Anson County, North Carolina. A copy of the Compliance Inspection Report is enclosed for your
review. We greatly appreciate your time and assistance during the inspection. The site visit and file review revealed that the
subject facility is covered by NPDES Stormwater Permit NCS000595. Permit coverage authorizes the discharge of
stormwater from the facility to receiving waters designated as North Prong Buffalo Creek, a class C stream in the Yadkin -
Pee Dee River Basin.
As a result of the site inspection, the following permit conditions violations are noted:
1) Analytical Monitoring
Per Part Il, Section B... Analytical Monitoring has not been conducted and/or recorded in accordance with permit
requirements.
2) Qualitative Monitoring
Per Part II, Section C ... Qualitative Monitoring has not been conducted and/or recorded in accordance with permit
requirements.
Other Observations
Please refer to the enclosed Compliance Inspection Report for additional comments and observations made during the
inspection.
Requested Response
You are asked to respond to this office, in writing, within 30 calendar days from receipt of this notice. Your written response
should include a reasonable explanation as to why the aforementioned violations have occurred as well as a Plan of Action
to prevent these violations from recurring.
.--—.
++
RR North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
D Q :)f Fayetteville Regional Office 1 225 Green Street, Suite. 714 ( Fayetteville, North Carolina 28304
oe�nrtmentat Pmlronmenli Ity vv 910.433.3.300

Action Items
Conduct and record Analytical and Qualitative Monitoring per the conditions of the permit. Submit monitoring data in
accordance with permit requirements.
Thank you for your attention to this matter. This office requires that the violations, as detailed above, be properly
resolved. These violations and any future violations are subject to a civil penalty assessment of up to $25,000 per
day for each violation. Should you have any questions regarding these matters, please contact Mike Lawyer at (910) 433-
3394 or via e-mail at [e-mail].
Sincerely,
imothy L. La B PE
Regional Engineer
DEMLR
TL/ml
Enclosure: Compliance Inspection Report
ec: Toby Vinson, Jr., PE, CPESC, CPM, Chief of Program Operations — DEMLR
Brad Cole, PE, Chief of Regional Operations — DEMLR
Alaina Morman, Environmental Specialist — DEMLR, Stormwater Program
DEMLR NPDES Stormwater Permit Laserfiche File
cc: FRO — DEMLR, Stormwater Files

Compliance Inspection Report
Permit: NCS000595
SOC:
County: Anson
Region: Fayetteville
Contact Person: David Hill
Directions to Facility:
Effective: 08/01/19 Expiration: 07/31/24 Owner: Pasture Management Systems Inc
Effective: Expiration: Facility: Pasture Management Systems Inc
375 Little Creek Rd
System Classifications: SWNC,
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
On -site representative
Related Permits:
Title: President
Certification:
David Hill
Inspection Date: 03/29/2022 Entry Time 09:33AM
Primary Inspector: Mike Lawyer
Secondary Inspector(s):
Penny Markle t7 y
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Wadesboro NC 28170
Phone: [phone]
Phone:
704-436-6401
Exit Time: 12:06PM
Phone: [phone]
Inspection Type: Compliance Evaluation
Page 1 of 3

Permit: NCS000595 Owner - Facility: Pasture Management Systems Inc
Inspection Date: 03/29/2022 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Inspectors met with Mr. David Hill, President of Pasture Management Systems, Inc. to conduct a compliance evaluation
inspection regarding the facility's coverage under Individual Stormwater Permit NCS000595. Individual permit coverage was
required due to the wood treatment process. Facility treats various sizes of wood fence posts with a solution of CCA
(Copper, Chromium, Arsenic), which is conducted inside a building. Once the posts are treated and sufficiently dried on a
drip pad under shelter, bundles are stored outside in a graveled area until shipped to retail suppliers. Vehicle and equipment
maintenance is conducted onsite by a third -party contractor, however less than 55 gallons of new motor oil and/or hydraulic
oil is used per month. Facility has one stormwater discharge outfall, which is a ditch starting at the rear of the property and
continuing between two of the graveled storage areas along the side of the property before connecting with the roadside
ditch. A review of the facility's Stormwater Pollution Prevention Plan was conducted, which appeared to contain all required
components and has been recently updated. Monitoring of stormwater discharges per the conditions of the permit was not
conducted in 2019, 2020, or 2021. Mr. Hill stated that he has contacted a lab to coordinate a stormwater
sampling/monitoring event for the first half of 2022.
After inspection of the wood treating facility, observations were made at a facility located directly across the road at 380
Little Creek Road. This "post -mill" facility is also owned/operated by Pasture Management Systems, Inc and according to
Mr. Hill, was constructed in 2021. The facility receives logs from the field, which are debarked, cut to various size fence
posts and then stored in bundles outside to be air-dryed before being sent across the road to the treating facility. Two
stormwater discharge outfalls were observed. Mr. Hill was informed that since this facility does not conduct any treating of
the wood, he could apply for coverage under the NCG210000 Stormwater General Permit for Lumber and Wood Products. A
copy of the Notice of Intent application for NCG210000 coverage was provided to Mr. Hill via e-mail on March 30, 2022. The
application needs to be completed and submitted to our Raleigh Central Office no later than April 30, 2022.
Page 2 of 3

Permit: NCS000595 Owner - Facility: Pasture Management Systems Inc
Inspection Date: 03/29/2022 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?
0
❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
N
❑ El ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
0
❑ El ❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
0
❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
0
❑ ❑ ❑
# Does the facility provide all necessary secondary containment?
0
El ❑ ❑
# 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?
N
❑ ❑ ❑
# Does the facility provide and document Employee Training?
0
❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
0
❑ n ❑
# Is the Plan reviewed and updated annually?
N
❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
N
❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
E
❑ ❑
Comment:
Qualitative Monitoring
Yes No NA NE
Has the facility conducted its Qualitative Monitoring? ❑ 0 El ❑
Comment: Qualitative Monitoring has not been conducted per the conditions of the permit
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? ❑ 0 ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? El ❑ E ❑
Comment: Analytical Monitoring has not been conducted per the conditions of the permit
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? N El ❑
# Were all outfalls observed during the inspection? N ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ 0 ❑
# Has the facility evaluated all illicit (non stormwater) discharges? E ❑ ❑ El
Comment:
Page 3 of 3