44_Example Compliance Report and DEMLR Correspondence

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Interim Director
D.H. Griffin Wrecking Company, Inc.
Attn: Eric McManus
4716 Hilltop Road
Greensboro, NC 27407
Subject: Compliance Inspection:
Permit No. NCG 200420
NORTH CAROLINA
Environmental Quality
May 24, 2019
DH Griffin Wrecking Co — Hilltop Road
Guilford County
Dear Permit Holder:
On May 14th, 2019, Brandon Wise, inspector with the North Carolina Department of
Environmental Quality (NCDEQ) — Division of Energy, Minerals, and Land Resources, along
with representatives of the City of Greensboro, met with you at the facility located at 4700
Hilltop Road in Greensboro, to conduct a compliance inspection. The inspection consisted of
review of the Stormwater Pollution Prevention Plan (SWPPP) and each of its components,
review of the facility outfalls, as well as the review of the overall site conditions. The
compliance inspection was conducted to ensure all site practices and facilities are in working
order. The inspection was also conducted as part of NCDEQ's mission to inspect all permitted
facilities during each permit period and to assist any permitted municipalities in North Carolina
with any inspections.
Permit:
This facility has General Stormwater Permit NCG200420 to discharge stormwater from
industrial activity associated with Assembling, Breaking Up, Sorting, and Wholesale Trade of
Scrap Metal [SIC 5093] under the National Pollutant Discharge Elimination System (NPDES).
The permit was originally issued on February 7th, 2001 and the current version of the permit was
issued on September 291h, 2015 and expires on December 3Is', 2019.
Records/Reports:
This facility is required to develop and maintain a SWPPP in accordance with Part Il,
Section A of the permit. All qualitative and analytical monitoring records are required to be
maintained with the SWPPP for a minimum of five (5) years. Under this permit, analytical
monitoring is required under current operating procedures. The facility records were very well
maintained and kept along with the SWPPP, records were kept for the required timeline. The
facility is required to review and update the SWPPP on an annual basis in accordance with Part
II, Section A, Item 8 of the permit. The original SWPPP was written in 2012 and there were
redline changes to the permit available for review during the inspection, however, there were no
documented records of annual updates to the permit. Please note that future editions of the
E—^ North Carolina Department of Environmental Quality j Division of Energy. Mineral and Land Resources
Winston-Salem Regional Office 1450 Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27103
tJ (f I i-f , �A fGiCL. VA J�
Department of Enreonnwntaf 0-; V 336.776.9800

SWPPP should have documentation of any updates or reviews of the permit to avoid a Notice of
Violation. The facility is required to inspect outfalls for any non-stormwater (illicit) discharges
annually in accordance with Part II, Section A, Item 1, Point E. During the inspection NCDEQ
was informed that the outfalls had been inspected and due to springs on site there was always
some discharge from outfalls. This information needs to be documented and kept with the
permit, the documentation was not observed during the SWPPP review.
Facility Site Review:
This facility operates as a metal storage, sorting, and distribution yard for recycled metals
brought to DH Griffin Wrecking Company. The storage yard is separated by product
composition and given the nature of the activity is maintained well. Multiple catch basins exist
on the property allowing for sediment to settle out of the stormwater and acting as oil -water
separators. The east side of the facility is the location of the majority of truck distribution at the
site. The western side of the facility has the majority of the industrial activity that is covered by
this permit. Large amounts of metal are stored and separated based on composition. The
southernmost section of facility is some office buildings and storage of used cars and roll -off
containers. An area in the center of the facility is used to remove fluids from the vehicles
received, this area needs to be cleaned up and have a regular maintenance and inspection
schedule as there is a risk for fluids to leak and reach the stormwater system. The northern part
of the facility is large piles of scrap metal that have all been separated and are ready for removal
or sale. The majority of the facility is dirt or gravel with only small sections on the south side
and some other areas being paved. The outfalls at the facility are located on the northern side of
the facility. During the inspection all outfalls had large debris and trash in the ponding area at
the outfalls. This should be cleaned up and any potential contaminants should be removed from
the area at the outfalls. It was also recommended at outfall 1 to sample from the discharge pipe
not from the area where water was leaving the pooling area.
Effluent Receivinst Waters:
Effluent from this facility drains into an unnamed tributary of South Buffalo Creek, class
"WS-V; NSW" waters of the Cape Fear River Basin.
Self -Monitoring Program:
This facility is required to provide Qualitative and Analytical Monitoring twice annually.
The monitoring records were kept up, however, the sampling should have been placed in tier 1
with a tier 1 response kept with the SWPPP. This was not kept up and no tier 1 sampling had
been implemented. After discussion with all involved in the inspection it was determined that
DH Griffin would be placed back in tier "0" but should another high reading be discovered all
tier 1 requirements would be in required immediately.
-D E
01; rH CART 1 NA
neparm,ent a EnvaomnenW Quality f
North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
Winston-Salem Regional Office f 450 Hanes Mill Road, Suite 300 { Winston-Salem, North Carolina 27103
336,776.9800

There are no additional comments or changes to the currently operating permit. Please
continue to keep up the facility and monitor stormwater discharges. If you have any questions or
need additional information, please contact Brandon Wise at [phone] or
[e-mail].
Enclosures: Inspection Report
cc: NCDEQ — DEMLR (WSRO) w/o enclosure
Sincerely,
Brandon Wise
Stormwater Specialist
Land Quality Section
Winston-Salem Regional Office
C�JCA NC:f?i ;i^JR
Depardnent of Enyiranmental Quality
North Carolina Department of Environmental Quality j Division of Energy, Mineral and Land Resources
Winston-Salem Regional Office ( 450 Hanes Mill Road, Suite 300 f Winston-Salem, North Carolina 27103
336.776,9800

From:
White, Sue
To:
Shoffner, Debbie; White, Glen
Cc:
Schneider, Peter; Phlegar, David
Subject:
RE: DH Griffin 2016 Inspection, Permit Violations/Deficiencies
Date:
Monday, September 26, 2016 9:21:55 AM
Attachments:
imaae004.Dna
image001.pnno
Hi Debbie:
Thanks for keeping us in the loop concerning DH Griffin. It sounds like the City of Greensboro folks
are on the ball with the inspections.
I would recommend sending your inspection as a notice of discrepancies, noting all the issues you've
outlined in this email, giving them 6 months from receipt of letter to correct the issues and
scheduling a follow-up inspection at that time. If you would like for Glen or me or both to
accompany you all at that time, I'm sure that can be arranged.
I don't really see the benefit of the State conducting another inspection without giving them time to
make corrections.
Thanks!
Sue White, El
Assistant Regional Engineer
Department of Energy, Minerals and Land Resources
336-776-9661 office
[e-mail]
Winston Salem Regional Office
450 W. Hanes Mill Road
Winston Salem, NC 27106
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Shoffner, Debbie [ma iIto: Debora [e-mail]]
Sent: Friday, September 23, 2016 1:57 PM
To: White, Glen <[e-mail]>; White, Sue <[e-mail]>
Cc: Schneider, Peter <[e-mail]>; Phlegar, David
<[e-mail]>

Subject: DH Griffin 2016 Inspection, Permit Violations/Deficiencies
Glen and Sue,
As you are aware, the City of Greensboro Stormwater and NC Division of Energy, Mineral, and Land
Management planned a joint inspection of DH Griffin (NCG200420) to take place on July 27, 2016.
Due to scheduling miscommunications or other mix-ups, staff from NC DEML were unable to attend,
so this inspection was performed by City staff.
Based on the findings, we would like to request a follow-up inspection and/or meeting between NC
DEML and DH Griffin staff, with the assistance of Greensboro Stormwater staff as needed. This is
requested based on the findings of the inspection (listed below), which are direct permit
violations/deficiences.
The following issues were noted during this inspection:
• Updates are needed to the SWPPP and SPP documents. All copies of these documents
should reflect these updates. (As it stands now, the only fully updated version is a marked -up
copy kept by an individual on the yard.) These updates include, but are not limited to, the
following:
o contacting the State to obtain an accurate cover page to the current permit
o including a list of spills per permit requirements (DH Griffin has had at least three
known spills/illegal discharges in the past 18 months, though none of these were
noted.)
o changes made to the general permit in 2015
• Although monitoring has been performed as required, some benchmarks have been
exceeded one time while others have exceeded benchmarks two or more times in a row.
There is no record (nor verbal explanation) of implementation of the tiers as required by the
permit. According to our understanding of the permit, DH Griffin should be implementing, at
a minimum, Tier Two response actions for both outfalls. (See the table/info below.)

I will be sending them an inspection letter noting these items and will copy you on it as usual.
Thanks so much for your help. Let me know if you have any questions.
Debbie
Debbie Shoffner, Water Quality Analyst
Department of Water Resources, Stormwater Division
City of Greensboro
Ph: 336-373-2741; Fax: [phone]
PO Box 3136, Greensboro, NC 27402-3136
www.greensboro-nc.gov
Please note that email sent to and from this address is subject
to the North Carolina Public Records Law and may be disclosed to third parties.