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Home My WebLink AboutNCG150011_Notice of Deficiency_20191023ROY COOPER Governor MICHAEL S. REGAN Secretary S. DANIEL SMITH Director CERTIFIED MAIL: 7015 0640 0007 8168 5628 RETURN RECEIPT REQUESTED NORTH CAROLINA Environmental Quality October 23, 2019 City of Clinton Attn: Chris Medlin P. O. Box 199 Clinton, NC 28329 Subject: NOTICE OF DEFICIENCY (NOD-2019-PC-0229) NPDES Stormwater General Permit NCG150000 City of Clinton Clinton Sampson Airport Certificate of Coverage NCG150011 Sampson County Dear Mr. Medlin: On September 24, 2019, Melissa Joyner from the Fayetteville Regional Office of the Division of Energy, Mineral and Land Resources (DEMLR), conducted a site inspection for the Clinton Sampson Airport facility located at 115 Sampson Airport Road, Sampson County, North Carolina. A copy of the Compliance Inspection Report is enclosed for your review. Mr. Lynn Reynolds, Public Works Director, Mark Turlington, Assistant Public Works Director, Jim Naylor, FBO and Benjamin Bothell, PE, Senior Project Engineer with W.K. Dickson & Co., Inc. 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 NCG150000 under Certificate of Coverage NCG150011. Permit coverage authorizes the discharge of stormwater from the facility to receiving waters designated as Great Coharie Creek (Blackmans Pond), a Class C;SW waterbody in the Cape Fear River Basin. As a result of the site inspection, the following deficiency is noted: The Stormwater Pollution Prevention Plan (SPPP) has not been properly implemented. Other Observations: Please refer to the enclosed Compliance Inspection Report for additional comments and observations made during the inspection. Requested Response: A written response is not requested at this time. Thank you for your attention to this matter. This office requires that the deficiency noted above and detailed in the enclosed inspection report, be properly resolved. Failure to address the deficiency could result in the issuance of a Notice of Violation, which is subject to a civil penalty.assessment of up to $25,000 per day for each violation. Should you have any questions or concerns, please contact Melissa Joyner or myself at (910) 433-3300. North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources Fayetteville Regional Office 1 225 Green Street. Suite 7141 Fayetteville, North Carolina 28301 NORTIa gAFipL.INA aewLoraw mawa� /'�� 910.433.3300 Sincerely, Timothy L. L unty, PE Regional Engineer DEMLR TLL/maj Enclosure: Compliance Evaluation Inspection ec: Lynn Reynolds, Public Works Director — County of Sampson (via email) Mark Turlington, Assistant Public Works Director — County of Sampson (via email) Benjamin Bothell, PE, Senior Project Engineer— W.K. Dickson & Co., Inc. (via email) William E. (Toby) Vinson, Jr., Section Chief — DEMLR (via email) Annette Lucas, PE, Program Manager — DEMLR, Stormwater Program (via email) Alaina Morman, Environmental Specialist — DEMLR, Stormwater Program (via email) cc: FRO - DEMLR, Stormwater Files Permit: NCG150011 SOC: County: Sampson Region: Fayetteville Compliance Inspection Report Effective: 09/01/17 Expiration: 08/31/22 Owner: City of Clinton Effective: Expiration: Facility: Clinton Sampson Airport 115 Sampson Airport Rd Contact Person: Lynn Reynolds Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Title: Public Works Director Certification: Clinton NC 28328 Phone: 910-592-0188 Phone: On -site representative Lynn Reynolds 910-592-0188 Related Permits: Inspection Date: 09/24/2019 Entry Time: 09:40AM Exit Time: 10:45AM Primary Inspector: Melissa A Joyner Phone: Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Air Transportation Stormwater Discharge COC Facility Status: ❑ Compliant Not Compliant Question Areas: Storm Water (See attachment summary) Page 1 of 3 Permit: NCG150011 Owner - Facility: City of Clinton Inspection Date: 09/2412019 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: Melissa Joyner met with Mr. Lynn Reynolds, Public Works Director, Mark Turlington, Assistant Public Works Director, Jim Naylor, FBO and Benjamin Bothell, PE, Senior Project Engineer with W.K. Dickson & Co., Inc. The Stormwater Pollution Prevention Plan (SPPP) was reviewed. It was very detailed and well -organized. There were no records for significant spills or leaks during the previous three years or the notation that no spills had occurred. The stormwater outfalls had not been evaluated for the presence of non-stormwater discharges. Annual training of employeees had not been conducted. Facility inspections were being done annually, not semi-annually. The facility had also not evaluated feasible alternatives to current practices. The Qualitative Monitoring records were reviewed. The facility has a total of 6 outfalls, three of which were determined during the previous inspection on June 27, 2011 to be non -industrial outfalls, which is still true. Outfalls 2, 5 and 6 were inspected as well as the facility's fuel storage/fueling area, which were in good condition. The facility grounds appeared orderly. Page 2 of 3 Permit: NCG150011 Owner - Facility: City of Clinton Inspection Date: 09/24/2019 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? ❑ ❑ ❑ # Does the Plan include a "Narrative Description of Practices"? ❑ ❑ ❑ # 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 ❑ ❑ # Has the facility evaluated feasible alternatives to current practices? ❑ E ❑ ❑ # Does the facility provide all necessary secondary containment? 0 ❑ ❑ ❑ # Does the Plan include a BMP summary? 0 ❑ ❑ ❑ # Does the Plan include a Spill Prevention and Response Plan (SPRP)? 0 ❑ ❑ ❑ # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? N ❑ ❑ ❑ # Does the facility provide and document Employee Training? ❑ ❑ ❑ # Does the Plan include a list of Responsible Party(s)? 0 ❑ ❑ ❑ # Is the Plan reviewed and updated annually? ❑ 0 ❑ ❑ # Does the Plan include a Stormwater Facility Inspection Program? ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? ❑ ❑ ❑ Comment: The Stormwater Pollution Prevention Plan is not being fully implemented. Qualitative Monitoring Yes nio NA NE Has the facility conducted its Qualitative Monitoring semi-annually? E ❑ ❑ ❑ Comment: Analytical Monitorina Yes No NA NE Has the facility conducted its Analytical monitoring? ❑ ❑ 0 ❑ # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ N ❑ Comment: Analytical Monitoring is not required per General Permit NCG150000. Permit and Outfalls Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? M ❑ ❑ ❑ # Were all outfalls observed during the inspection? M ❑ ❑ ❑ # If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ M ❑ # Has the facility evaluated all illicit (non stormwater) discharges? ❑ M ❑ ❑ Comment: Page 3 of 3