NCG080927_XPO Logistics NOV_20240112

ROY COOPER
Governor - � .-Li , NSSIF
ELIZABETH.'S.BISER :„too
Secretaryµ
WILLIAM E,TOBY VINSON,JR NORTH CAROLINA
Enter m Director ,Environmental Quality
January 12, 2024
CERTIFIED MAIL: 7020 3160 0000 3835 2367
RETURN RECEIPT REQUESTED
XPO Logistics Freight, Inc. -NLB
Attn: Jeff Sexten
2211 Old Earhart Boulevard, Suite 100
Ann Arbor, MI 48105
Subject: NOTICE OF VIOLATION(Case#NOV-2024-PC-0022)and
NPDES Stormwater General Permit NCG080000
XPO Logistics Freight Inc.
XPO Logistics Freight, Inc. -NLB,Certificate of Coverage NCG080927
Robeson County
Dear Mr. Sexten;
. On December 7, 2023, Ms. Kelly Jonas and Ms. Melissa Joyner from the Fayetteville Regional Office of the
Division of Energy, Mineral and Land Resources (DEMLR), conducted a site inspection for the XPO
Logistics Freight Inc. NLB facility located at 4715 West Fifth Street, Lumberton, Robeson County, North
Carolina; A copy of the.Compliance Inspection Report is enclosed for your review. Mr. Brad Lutz and Mr.
Riley Anderson were also present during the inspection and their time and assistance is greatly appreciated.
The site visit and file review revealed that the subject facility is covered by NPDES Stormwater General
Permit NCG080000 under Certificate of Coverage NCG080927. Permit coverage authorizes the discharge
of stormwater from the facility to receiving waters designated as an unnamed tributary,Jacob Swamp,class
C waters in the Lumber River Basin.
As a result of the site inspection, the following permit conditions violation(s)are noted:
1)Stormwater Pollution Prevention Plan(SWPPP)
Per Part B...A Stormwater Pollution Prevention Plan (SWPPP) has not been properly implemented.
2) Qualitative Monitoring
Per Part D, Section D-1...Qualitative monitoring has not been conducted and/or recorded in accordance
with permit requirements.
3)Analytical Monitoring
Per Part E, Section E-1 -E-4...Analytical 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.
ANorth Carolina Department of Environmental Quality I Division of Energy,Mineral and Land Resources
..,DEFayetteville Regional Office 1225 Green Street,Suite 7141 Fayetteville,North Carolina 2S301.
NORM,CAR9JMA
Dermtnentet EmdrowneatatC1.1 �/ 910,433.3300

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 violation(s) have
occurred as well as a Plan of Action to prevent these violations from recurring.
Action Items
Include actions permittee should take along with reasonable timeframes.
Example: Immediately review and amend the facility's SWPPP as needed and begin incorporating
documentation pertaining to the annual update requirements of the permit. Conduct and record monitoring
per the conditions of the permit.
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 Kelly Jonas or myself at(910) 433-3300.
Sincerely,
• Timothy L. LaBou PE
Regional Engineer
DEMLR
TL/kbj
Enclosure: Compliance Inspection Report
ec: Brad Lutz, Service Center Manager
Toby Vinson, Jr., PE, CPESC, CPM, Chief of Program Operations—DEMLR
Brad Cole, PE, Chief of Regional Operations DEMLR
Michael Lawyer, CPSWQ — Stormwater Program Supervisor --DEMLR
Kieu Tran, Environmental Specialist, Stormwater Program—DEMLR
DEMLR NPDES Stormwater Permit Laserfiche File
cc: FRO—DEMLR

Compliance inspection Report
Permit:NCG080927 Effective: 08/30/21 Expiration: 06/30/26 Owner: Xpo Logistics Freight Inc
SOC: Effective: Expiration: Facility: XPO Logistics Freight,Inc.-NLB
County: Robeson 4715 W Fifth St
Region: Fayetteville
Lumberton NC 28358
Contact Person:Jeff Sexten Title: Phone:[phone]
Directions to Facility:
System Classifications: SWNC,
Primary ORC: Certification: Phone:Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 12/07/2023 Entry Time 01:30PM Exit Time: 03:30PM
Primary Inspector:Kelly Jonas Phone: [phone]
Secondary Inspector(s):
MelissaAJoyner fra Phone :
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Transportation wNehicle Maintenance/Petroleum Bulk/Oil Water Separator Stormwater Discharge COC
Facility Status: 0 Compliant 1111 Not Compliant
Question Areas: -
II Storm Water -
(See attachment summary)
Pagel of

Permit: NCG080927 Owner-Facility:Xpo Logistics Freight Inc
Inspection Date: 12/0i/2023 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Kelly Jonas and Melissa Joyner met with Mr. Brad Lutz, Service Center Manager, and Mr.Riley Anderson,Area Safety
Manager, to conduct an industrial stormwater inspection at the XPO Logistics facility in Lumberton, NC.The facility is
currently XPO Logistics. The Stormwater Pollution Prevention Plan(SWPPP)was reviewed per the conditions of the
National Pollutant Discharge Elimination System (NPDES) General Permit NCG080000.The current SWPPP was dated
July 1,2023. There were several omissions noted in the plan.The detailed Site Map needs to include topographic contours,
the pipes that connect the onsite retention ponds and adjusting the location of the outfall. No spills were noted in the plan,
though none had occurred within the last three years.A best management practices(BMP)summary and annual review,
and feasibility study and annual review were not noted in the plan, Employee Training has not been conducted per the
conditions of the General Permit NCG080000.A list of responsible parties was included in the plan; however,signatures of
the responsible parties was not included. Solvents are not utilized at the facility, however a certification statement was not
included in the plan.The SWPPP that was reviewed was current; however,an annual review indicating any changes from the
previous year was not included, as well as being signed and dated.A copy of the Certificate of Coverage was left at the
facility.
The facility does not conduct any vehicle maintenance or cleaning at the facility. Fleetwash comes to the facility,which
collects the water during the process.Any necessary vehicle maintenance is conducted offsite. The facility has one 15,000
diesel aboveground storage tank(AST), which is locked with a system login system, and has a secondary wall.
Qualitative and Analytical Monitoring has not been conducted per the conditions of the General Permit NCG080000.
Additionally the facility needs to get registered on eDMR in order to submit Analytical Monitoring results electronically.
The facility grounds were inspected, including the AST and the outfalls. The facility appeared to be well-maintained.Two
retention ponds are located onsite in series, which then discharges to a spillway near the property line. It was discussed
that the pipes between the ponds need to be added to the detailed Site Map.Additionally,the spillway should be the
location of the outfall that should be monitored. This location should be added to the detailed Site Map.
The following corrective actions are required: 1. Update the detailed Site Map to include topographic contours,the pipes
connecting the onsite retention ponds and adjusting the location of the outfall; 2.Implement all the sections in the SWPPP
per the conditions of the General Permit NCG080000, including the annual spill summary,BMP summary and annual review,
feasibility study and annual review, signatures of all responsible parties, and certification statement regarding lack of use of
solvents; 3. Conduct awareness training for all facility employees per the conditions of the General Permit NCG080000; 4.
Conduct Qualitative Monitoring per the conditions of the General Permit NCG080000; 5.Conduct Analytical Monitoring per
the conditions of the General Permit NCG080000; 6. Register on eDMR; 7. Update facility information online.
Page 2 of 3

Permit: NCG080927 Owner-Facility:Xpo Logistics Freight Inc
Inspection Date: 12/07/2023 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? • 0 0 ❑
#Does the Plan include a General Location(USGS)map? • 0 0 0
#Does the Plan include a"Narrative Description of Practices"? • 0 0 0
#Does the Plan include a detailed site map including outfall locations and drainage areas? • ❑ ❑ ❑
#Does the Plan include a list of significant spills occurring during the past 3 years? 0 • ❑ 0
#Has the facility evaluated feasible alternatives to current practices? ❑ ■ ❑ ❑
#Does the facility provide ail necessary secondary containment? • 0 0 0
#Does the Plan include a BMP summary? ❑ • 0 0
#Does the Plan include a Spill Prevention and Response Plan (SPRP)? MOOD
#Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? • ❑ ❑ 0
#Does the facility provide and document Employee Training? 0 • 0 0
#Does the Plan include a list of Responsible Party(s)? • 0 0 0
#Is the Plan reviewed and updated annually? ❑ ■ ❑ ❑
#Does the Plan include a Stormwater Facility Inspection Program? MOOD
•
Has the Stormwater Pollution Prevention Plan been implemented? ❑ ❑ ❑
Comment: The Stormwater Pollution Prevention Plan has not been fully implemented.
Qualitative Monitoring
Yes No NA NE
Has the facility conducted its Qualitative Monitoring? ❑ • 0 0
Comment: Qualitative Monitoring has not been conducted per the conditions of the NPDES Stormwater
General Permit 080000.
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? 0 • 0 ❑
#Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ 0 • 0
Comment: Analytical Monitoring has not been conducted per the conditions of the NPDES Stormwater
General Permit 080000.
Permit and Outfalls
Yes No NA NE
#Is a copy of the Permit and the Certificate of Coverage available at the site? IN ❑ ❑ 0
#Were all outfalls observed during the inspection? MOOD
#If the facility has representative outfall status, is it properly documented by the Division? ❑ 0 • ❑
#Has the facility evaluated all illicit(non stormwater)discharges? • ❑ ❑ ❑
Comment:
Page 3 of 3