NCG150025_NOV_20200123

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
CERTIFIED MAIL:7012 3050 0001 9398 7454
RETURN RECEIPT REQUESTED
Montgomery County
Attn: Matthew Woodard, County Manager
102 East Spring Street
Troy, NC 27371
NORTH CAROLINA
Environmental Quality
January 23, 2020
Subject: NOTICE OF VIOLATION (NOV-2020-PC-0045)
NPDES Stormwater General Permit NCG150000
Montgomery County
Montgomery County Airport, Certificate of Coverage NCG150026
Montgomery County
Dear Mr. Woodard:
On January 16, 2020, Mike Lawyer, Environmental Program Consultant from the Fayetteville Regional Office of the Division
of Energy, Mineral and Land Resources (DEMLR), conducted a site inspection for the Montgomery County Airport facility
located at 262 Airport Road, Star, Montgomery County, North Carolina. A copy of the Compliance Inspection Report is
enclosed for your review. Mr. Xeith McNeill, Facility Maintenance Supervisor, along with Mr. Keith Garner and Mr. Matthew
Helms were also present dur rWOPIe 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 NCG150025. Permit coverage authorizes the discharge of stormwater from the facility to receiving waters
designated as Lick Creek, class C waters in the Yadkin 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 been developed for the facility, however it has not been updated on an
annual basis nor properly implemented in accordance with permit requirements.
2) Qualitative Monitoring
Qualitative monitoring has not been conducted and 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.
Action Items
Review and update the facility's Stormwater Pollution Prevention Plan as needed and begin incorporating documentation
pertaining to the annual update requirements of the permit. Conduct and record Qualitative Monitoring per the conditions of
the permit.
y� North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
DW ���/ Fayetteville Regional Office 1 225 Green Street, Suite 7141 Fayetteville, North Carolina 28301
Dwrbr" o,am +fd /r14f 910.433.3300

Thank you for your attention to this matter. This office requires that the violations, as noted above and detailed in the
enclosed Compliance Inspection Report, 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 [phone] or via e-mail at [e-mail].
Sincerely,
imothy L. La nty, PE
Regional Engineer
DEMLR
TL/ml
Enclosures: Compliance Inspection Report, Overdue Annual Permit Fee Invoice
VlH
ec: McNeill, Facility Maintenance Supervisor — Montgomery County
William E. (Toby) Vinson, Jr., PE, CPESC, CPM, Program Operations Chief — DEMLR
Annette Lucas, PE, Stormwater Program Supervisor— DEMLR, Stormwater Program
Alaina Morman, Environmental Specialist — DEMLR, Stormwater Program
cc:" - FRO -.DEMLR, Stormwater Files'

Permit: NCG150025
SOC:
County: Montgomery
Region: Fayetteville
Compliance Inspection Report
Effective: 09/01/17 Expiration: 08/31/22 owner: Montgomery County
Effective: Expiration: Facility: Montgomery County Airport
262 Airport Rd
Contact Person: Matthew M Woodard
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Title: County Manager
Certification:
On -site representative Kevin McNeill
Related Permits:
Inspection Date: 01/16/2020 Entry Time: 10:20AM
Primary Inspector: Mike Lawyer ,-
Secondary Inspector(s): /'�
Star NC 27356
Phone: [phone]
Phone:
910-572-1393 ext 253
Exit Time: 12:10PM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Air Transportation Stormwater Discharge COC
Facility Status: ❑ Compliant 0 Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 3

Permit: NCG150025 Owner - Fagility: Montgomery County
Inspection Date: 01/16/2020 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Met with Kevin McNeill, Facility Maintenance Supervisor, along with Keith Garner and Matthew Helms. Notified Mr. McNeill
about an overdue invoice for the annual permit fee, which was due on January 2, 2020 (copy of overdue invoice attached).
According to facility personnel, the FBO left sometime in 2014 and the airport has since been operated by the county as
essentially an unmanned airport providing only storage and fueling of aircraft with no de-icing operations. Provided overview of
permit conditions including development of a Stormwater Pollution Prevention Plan (SPPP) and semi-annual Qualitative
Monitoring of stormwater discharges. Although an SPPP could not be located at the airport, a copy was e-mailed from the
county office where it could be reviewed at the airport on a laptop computer. The facility's SPPP was prepared by a
consultant in 2011 and contains all permit -required components,, however it did not appear to have been reviewed/updated on
an annual basis or implemented as required by the NCG150000 permit. Additionally, records of the required semi-annual
Qualitative Monitoring could not be provided. Based on the facility's site map, there is only one stormwater discharge outfall
associated with "industrial activity" (i.e. fueling, maintenance). Made observations of site conditions including the fueling
station with double -walled AST and the stormwater discharge outfall. Facility personnel were informed that a Notice of
Violation would be issued for failure to review/update/implement the SPPP and failure to conduct/record monitoring as
required by the NCG150000 permit.
Page 2 of 3

r
Permit: NCG150025 Owner - Facility: Montgomery County
Inspection Date: 01/16/2020 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"?
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?
❑ N ❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
❑ ❑ ❑
# Does the facility provide all necessary secondary containment?
E❑ ❑ ❑
# Does the Plan include a BMP summary?
❑ ❑ ❑
# 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?
❑ 0 ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
N ❑ ❑ ❑
# Is the Plan reviewed and updated annually?
❑ E ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
0 ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
❑ 0 ❑ ❑
Comment: Facility's Stormwater Pollution Prevention Plan does not appear to have been reviewed or
updated since initially developed by consultant in 2011.
Qualitative Monitorinq Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ❑ 0 ❑ ❑
Comment: No monitoring records available for review at the time of inspection.
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? N ❑ ❑ ❑
# Were all outfalls observed during the inspection? 0 ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ❑ ❑ ❑
Comment:
Page 3 of 3

NORTH CAROLINA DEPARTMENT OF
ENVIRONMENTAL QUALITY
INVOICE
Stormwater Annual Permit Fee
IIIPnIIInI�PIIIIIIRIIIIIIIIIIIIIIrlllll
`:Overdue
This Stormwater annual fee is required by the North Carolina Administrative Code 143-215.13(a). It covers the administrative
costs associated with your permit. It is required of any person holding a permit for any time during the annual fee period,
regardless of the facility's operating status. Failure to pay the fee by the due date will subject the permit to revocation.
Operating without a valid permit is a violation and is subject to a $10,000 per day fine. If the permit is revoked and you later
decide a permit is needed, you must reapply, with the understanding the permit request may be denied due to changes in
environmental, regulatory, or modeling conditions.
Invoice Number: 2019PROl1274
Permit Number; NCG150025
Montgomery County
Montgomery County Airport
Chris L. Hildreth
Montgomery County
102 E Spring St
Troy, NC 27371
Annual Fee Period: 2020-01-01 to 2020-12-31
Invoice Date: 12/03/2019
Due Date: 01/02/2020
Annual Fee: $100.00
Payment Options:
1. Electronic payment is convenient and quick. To pay by ePayment, type "hops://deq.nc.gov/epayments/stormwatee' into your
browser. If you select eCheck, there will be no convenience fee. The convenience fee for a credit card is 2.65% and the
convenience fee for a debit card is $3.95.
2. To pay by mail, please make your check payable to "DEMLR Stormwater Program" and include the invoice number on the check.
Then, detach the invoice below and write the check number on the invoice. A $25.00 processing fee will be charged
for returned checks in accordance with N.C. General Statute 25-3-512.
Remit payments by mail to:
NCDEQ - Division of Energy, Mineral and Land Resources
Attn: Stormwater Billing
512 N. Salisbury Street
1612 Mail Service Center
Raleigh, NC 27699-1612
3. Non-payment of this fee by the payment due date will initiate the permit revocation process.
4. Please include your permit number in all correspondence.
5. Should you have any questions, please contact the Fee Coordinator at [phone].
(Return This Portion With Check)
ANNUAL PERMIT INVOICE
IIII'MIIIN��I91111111111NIIIIIiIII!IIIIIIIVI'IV
Overdue
Invoice Number: 2019PROl1274 Annual Fee Period: 2020-01-01 to 2020-12-31
Permit Number: NCG150025 Invoice Date: 12/3/2019
Montgomery County
Montgomery County Airport Due Date: 1/2/2020
Annual Fee: $100.00
Chris L. Hildreth
Montgomery County
102 E Spring St Check Number:
Troy, NC 27371