NCS000339_NOV with Response Letter_20191002

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
CERTIFIED MAIL:
RETURN RECEIPT REQUESTED
Durable Wood Preservers Inc.
Attention: Bevo Barksdale
Post Office Box 25825
Charlotte, North Carolina 28229
NORTH CAROLINA
Environmental QuaUty
October 2, 2019
7017 2620 0000 6783 2718
Subject: NOTICE OF VIOLATION (NOV-2019-PC-0667)
NPDES Stormwater Permit NCS000339
Durable Wood Preservers Inc.
Mecklenburg County
Dear Mr. Barksdale:
On September 18, 2019, Isaiah Reed from the Asheville Regional Office of the Division of
Energy, Mineral and Land Resources (DEMLR), conducted a site inspection for the Durable
Wood Preservers Inc. facility located at 7901 Pence Road, Charlotte, North Carolina. A copy of
the Compliance Inspection Report is enclosed for your review. The site visit and file review
revealed that the subject facility is covered by NPDES Individual Stormwater Permit
NCS000339. Permit coverage authorizes the discharge of stormwater from the facility to
receiving waters designated as an unnamed tributary to McAlpine Creek, a Class C waterbody in
the Catawba River Basin. However, during the inspection, it was observed that stormwater from
the site appears to be discharging to an unnamed tributary of Reedy Creek, a Class C waterbody
in the Yadkin Pee -Dee River Basin.
As a result of the site inspection, the following permit conditions violations are noted:
1) Stormwater Pollution Prevention Plan (SPPP)
A Stormwater Pollution Prevention Plan (SPPP) has not been maiatained and properly
implemented.
2) Qualitative Monitoring
Qualitative monitoring has not been conducted and recorded in accordance with permit
requirements.
3) Analytical Monitoring
Analytical monitoring has not been conducted and recorded in accordance with permit
requirements.
D_E
North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
Mooresville Regional Office 1 610 East Center Avenue, Suite 301 I Mooresville, North Carolina 28115
704.663.1699

Durable Wood Preservers Inc.
Notice of Violation
October 2, 2019
Page 2 of 2
Action Items
Immediately begin efforts to comply with the NPDES Individual Stormwater Permit
NCS000339, including but not limited to:
1. Review and update the Stormwater Pollution Prevention Plan
2. Immediately resume monitoring and documentation efforts at all outfalls.
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 violation(s)
from recurring.
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 Isaiah Reed at [phone] or myself at
[phone].
Sincerely,
Zahid Khan, CPM, CPESC, CPSWQ
Regional Engineer
Land Quality Section
Mooresville Regional Office
Enclosure: Inspection Report
ec: Alaina Morman- Environmental Specialist Alaina.mormannncdenr.gov
Stan Aiken- Regional Engineer Stan. aikenaa,ncdenr.goT
Lauren Garcia- Lauren.garcia@)nedenr.gov
cc: Mooresville File Copy

Compliance Inspection Report
Permit: NCS000339 Effective: 09/01/03 Expiration: 08/31/08 Owner: Durable Wood Preservers Inc
SOC: Effective: Expiration: Facility: Durable Wood Preservers Incorporated
County: Mecklenburg 7901 Pence Rd
Region: Mooresville
Charlotte NC 28229
Contact Person: B E Barksdale Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 09/18/2019
Primary Inspector: Isaiah L Reed
Secondary inspector(s):
EntryTime: 10:OOAM
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ❑ Compliant 0 Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Certification: Phone:
Exit Time: 11:3DAM
Phone: [phone]
Inspection Type: Compliance Evaluation
Page 1 of 3

Permit: NCS000339 Owner - Facility: Durable Wood Preservers Inc
Inspection Date: 09/18/2019 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On September 18, 2019 this facility was inspected for compliance. I met Bevo Baksdale on site. During the inspection, the
following violations were noted:
1) A Stormwater Pollution Prevention Plan has not been maintained and properly implemented. The Permittee is directed to
review and update the pollution prevention plan, and immediately begin efforts to reach compliance with all SWPPP
requirements as outlined in the NCS000339 Individual Stormwater Permit.
2) Qualitative monitoring has not been conducted in accordance with the permit requirements. The permittee is directed to
immediately resume monitoring and documentation efforts in accordance with the NCS000339 Individual Stormwater Permit.
3) Analytical monitoring has not been conducted in accordance with the permit requirements. The permittee is directed to
immediately resume monitoring and documentation efforts in accordance with the NCSOOD339 Individual Stormwater Permit.
The following observations were noted during the inspection:
1) The location and applicability of some of the outfall points may need to be reviewed. The number of outfalls to be
monitored may be able to be reduced. It is recommended that the permittee evaluate the potential for a reduced number of
outfalls based on observations discussed during the inspection.
2) Hazardous waste is still being handled/stored/removed on site.
3) Sawmill activity and production has been reduced, and no active production was observed on site.
4) Coverage under an industrial stormwater permit is necessary until all hazardous waste removal efforts have been
completed.
Please refer to the enclosed Notice of Violation for additional information.
If you have any questions, please contact this office at [phone]
Page 2 of 3

Permit: NCS000339 Owner - Facility: Durable Wood Preservers Inc
Inspection Date: 09/18/2019 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?
0 ❑ ❑ ❑
# Does the Plan include a General Location (USGS) map?
N ❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
0 ❑ ❑ ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
N ❑ ❑ ❑
# 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 ❑ ❑ ❑
# 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?
E ❑ ❑ ❑
# 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?
❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
0 ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
❑ 0 ❑ ❑
Comment: A Stormwater Pollution Prevention Plan has not been maintained and
properly implemented.
Qualitative Monitoring yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ❑ N ❑ ❑
Comment: Qualitative monitoring has not been conducted in accordance with the permit requirements.
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? ❑ N ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ 0 ❑
Comment: Analytical monitoring has not been conducted in accordance with the permit requirements.
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? ❑ ❑ ❑
# Were all outfalls observed during the inspection? ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ E ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ❑ 0 ❑ ❑
Comment:
Page 3 of 3

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