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HomeMy WebLinkAboutNCG200368_COMPLETE FILE - HISTORICAL_20130624STORMWATER DIVISION CODING SHEET NCG PERMITS PERMIT NO. /V ��a �cA DOC TYPE, ❑4HISTORICAL FILE ❑ MONITORING REPORTS DOC DATE ❑ a u 3 U L lj/ YYYYM M D D rWKILVED NCDENR &3 North Carolina Department of Environment and Natural Resources Division of Water Quality Pat McCrary Thomas A. Reeder Governor Actino Director June 24. 2013 CERTIFIED MAIL 7012 1640 0001 9606 3097 RETURNED RECEIPT REQUESTED Jeffery Charles, Owner J & G Recyclers of Wilson P.O. Box 1263 Wilson, NC 27894--1263 Dear Mr. Charles: John E. Skvarla, III SUBJECT: NOTICE OF VIOLATION — NOV-2013-PC-0228 Compliance Evaluation Inspection J & G Recyclers of Wilson Facility NPDES Permit NCG200000 Stormwater Permit COC NCG200368 On June 13, 2013, Mitch Hayes of the Raleigh Regional Office conducted the subject inspection. Your assistance with this inspection was greatly appreciated. Below is a list of findings and recommendations developed from the inspection: 1. The subject permit was reissued and became effective January 01, 2010 and will expire December 31, 2014. Request for permit renewal is regdred 180 days prior to permit expiration date. 2. You stated that you will be leasing the facility to another company in July, although you will retain ownership in which you will remainthe Permittee. The Permittee is responsible for maintaining all permit requirements and conditions. 3. The Facility is a buyer of scrap iron and other metals. The scrap yard has two distinct piles of metal that includes a magnetic grapple and an earth mover. These two pieces of equipment have leaked oil that has puddle on the ground. Failing to collect and remove the discharge of oil is a violation of NC General Statute 143-215.84(b) and is subject to enforcement action. The scrap yard is sloped from north to south. There is one Stormwater Discharge Outfall (SDO) 1 which discharges into the City of Wilson Municipal Separate Stormwater Sewer System. The water flowing into SDO 1 appeared clear with a sheen which may or may not be from organic material. The stormwater permit was available for inspection however, you stated you never read the permit and were unaware of any permit requirementsand conditions. The following violations were noted: 4. The Stormwater Pollution Prevention Plan has not been created andimplemented as required by General Permit NCG200000 (Certificate of Coverage) NCG200368 Part II Section A (9). 5. Analytical Monitoring had not been conducted as required by General Permit NCG200000 (Certificate of Coverage) NCG200368 Part II Section B. North Carolina Division of Water Quality 1028 Mail Service Center Raleigh, NC 2769fh28 Phone (919) 791-1200 Customer Service Internet: www.ncv aterquality.org Location: 3900 Barrett Drive Raleigh, NC 27609 Fax (919) 788-7159 1-877-623-6748 One An Equal Opportunity/Affirmative Action ErrployeF 50%Recycled110% Post Consumer Paper NorthCarolina Xatrrra!!u J & G Recyclers of Wilson CEI NOV-2013-PC-0228 6. Qualitative Monitoring had not been conducted as required by General Permit NCG200000 (Certificate of Coverage) NCG200368 Part II Section C. 7. Employee training had not been developed as required by General Permit NCG200000 (Certificate of Coverage) NCG200368 Part II Section A (5). 8. A detailed site map showing drainage and outfall location needs to be developed. 9. A permanent rain gage is required to be installed on site to record rainfall data with analytical monitoring. 10. A Spill Prevention and Response Plan will need to be developed with an oil Spill Prevention Control and Countermeasure (SPCC) plan incorporated. 11. A Stormwater Management Plan is required to be developed and implemented. 12. A Preventative Maintenance and Good Housekeeping Program is required to be developed. Failing to comply with all permit conditions and requirements is a violation of the Clean Water Act and subject to criminal penalties up to $25,000 per day of violation. You are required to respond to the above violations within 30 days receipt of this letter. Should you have any questions concerning this letter or the inspection, please contact Mitch Hayes at 919.791.42)0. Oerely, XmithDanny S. Water Quality Regional Supervisor Raleigh Regional Office Cc: RRO permit files, Central files Permit: NCG200368 SOC: County: Wilson Region: Raleigh Compliance Inspection Report Effective: 01/01/10 Expiration: 12/31/14 Owner: J & G Recyclers Of Wilson Effective: Expiration: Facility: J & G Recyclers Of Wilson 404 Maury St Contact Person: Jeffery Charles Title: Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s) Wilson NC 27893 Phone: 252-243-3586 Certification: Phone: 24 hour contact name Jeffery Charles Phone: 252-243-3586 On -site representative Jeffery Charles Phone: 252-243-3586 Related Permits: Inspection Date: 06/13/2013 Entry Time: 01:00 PM Exit Time: 01:30 PM Primary Inspector: Mitchell S Hayes ^/I LtcC VVs,` �t�,�„n Phone: 919-791-4200 Secondary Inspector(s): /. 1 ���"""��� -/ C " / Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Wholesale Trade of Metal Waste and Scrap Stormwater Discharge COC Facility Status: O Compliant ■ Not Compliant Question Areas: E Storm Water (See attachment summary) Page:1 Permit: NCG200368 Owner - Facility: J & G Recyclers Of Wilson , Inspection Date: 0611312013 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: Owner stated he will be leasing the facility to another company in July, although he will retain ownership in which you will remain the Permittee. The Facility is a buyer of scrap iron and other metals. The scrap yard has two distinct piles of metal that includes a magnetic grapple and an earth mover. These two pieces of equipment have leaked oil that has puddle on the ground. Facility is in violation of NC General Statute 143-215.94A and is subject to enforcement action. The scrap yard is sloped from north to south. There is one Stormwater Discharge Outfall (SDO) 1 which discharges into the City of Wilson Municipal Separate Stormwater Sewer System. The water flowing into SDO 1 appeared clear with a sheen which may or may not be from organic material. The stormwater permit was available for inspection however, the owner never read the permit and was unaware of any permit requirements and conditions. Failing to comply with all permit conditions and requirements is a violation of the Clean Water Act and subject to criminal penalties up to $25,000 per day of violation. Page:2 Permit: NCG200368 Owner -Facility: J & G Recyclers Of Wilson Inspection Date: 06/13/2013 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? Cl ■ ❑ ❑ # Has the facility evaluated feasible alternatives to current practices? ❑ ■ ❑ ❑ # Does the facility provide all necessary secondary containment? ❑ ■ . ❑ # 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? Cl ■ ❑ ❑ # Does the facility provide and document Employee Training? ❑ ■ ❑ ❑ # Does the Plan include a list of Responsible Party(s)? ❑ ■ ❑ ❑ # Is the Plan reviewed and updated annually? ❑ ■ ❑ ❑ # Does the Plan include a Stormwater Facility Inspection Program? ❑ ■ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? ❑ ■ ❑ ❑ Comment: Owner is unaware of permit requirements and conditions. Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ❑ ■ ❑ ❑ Comment: There has been no monitoring. Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? ❑ ■ ❑ ❑ # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ■ ❑ ❑ Comment: There has been no monitoring. 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? ❑ ❑ ■ ❑ # Has the facility evaluated all illicit (non stormwater) discharges? ❑ ■ ❑ ❑ Page:3 Permit: NCG200368 Owner • Facility: J & G Recyclers Of Wilson Inspection Date: 06/13/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine Comment: Owner has the permit but has never read the permit and therefor unaware of permit requirements and conditions. Water flowing into SDO 1 appeared clear with a sheen which may or may not be organic. Page:4 rFR November 20, 2006 Jeffery Charles J & G Recyclers Of Wilson PO Box 1263 Wilson NC, 27893 Michael 17. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment mid Natural Resources Alan W. Klimek, P.E. Director Division of Water Quality Subject: NPDES Stormwater Permit Coverage Renewal J & G Recyclers Of Wilson CDC # NCG200368 Wilson County Dear Permittee: In response to your renewal application for continued coverage under general permit NCG200000 the Division of Water Quality (DWQ) is forwarding herewith the reissued stormwater general permit. Due to resource constraints, the Division has been unable to adequately consider appropriate modifications to the permit. Therefore, the permit has been reissued without changes from the previous permit, so all conditions remain the same. The permit term for the reissued permit is two years, expiring on September 30, 2008. The general permit may be modified and reissued prior to its expiration, The permit is reissued pursuant to the requirements of North Carolina General Statute 143- 215.1 and the Memorandum of Agreement between the stale of North Carolina and the U.S. Environmental Protection Agency, dated December 6, 1983. The following information is included with your permit package: A new Certificate of Coverage A copy of General Stormwater Permit NCG200000 Your coverage under this general permit is not transferable except after notice to DWQ. The Division may require modification or revocation and reissuance of the Certificate of Coverage. This permit does not affect the legal requirements to obtain other permits which may be required by DENR or relieve the permittee from responsibility for compliance with any other applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or decree. If you have any questions regarding this permit package please contact Bethany Georgoulias of the Central Office Stormwater Permitting Unit at (919) 733-5083, ext. 529. Sincerely, Bradley Bennett, Supervisor Stormwater and General Permits Unit cc: Central Files l III Stormwater &General Permits Unit Files � D� Raleigh Regional Office DEC 7 2ao �. DENR RALEIGH REGIONAL OFFICE ��---NAI hC Wetlands and Stonnwater Branch 1617 Mail Service Center Raleigh, NC 27699-1617 Phone (919) 733-5083 Internet: h2o.enr.state.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX (919) 733-9612 An Equal OpportunitylAKrmadve Action Employer — 50 % Recycled110°/ Post Consumer Paper STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY GENERAL PERMIT NO. NCG200000 CERTIFICATE OF COVERAGE No. NCG200368 STORMWATER DISCHARGES NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, J & G RECYCLERS OF WILSON is hereby authorized to discharge stormwater from a facility located at J & G Recyclers Of Wilson 404 Maury St Wilson Wilson County to receiving waters designated as Hominy Swamp, a class C,SW,NSW stream, in the Neuse River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, ll, III, IV, V, and VI of General Permit No. NCG200000 as attached. This certificate of coverage shall become effective November 20, 2006. This Certificate of Coverage shall remain in effect for the duration of the General Permit. Signed this day November 20, 2006 for Alan W. Klimek, P.E., Director Division of Water Quality By Authority of the Environmental Management Commission \O�CF W ATF9oG co 1 � Jeffery Charles J & G Recyclers Of Wilson PO Box 1263 Wilson, NC, 27893 Dear Permittee: Michael F. Easley, Govenua William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Alan W. Klimek, P.F. Director Division of Water Quality July 25, 2005 Subject: NPDES Stormwater Permit Coverage Renewal N J & G Recyclers Of Wilson CDC Number NCG200368 Wilson County Your facility is currently covered for stormwater discharge under General Permit NCG200000. This permit expires on October 31, 2005. The Division staff is currently in the process of renewing this permit. When a draft version is available for notice and public comment, it will be posted on our website at http://h2o.enr.state.nc.us/su/. Once the permit is reissued, your facility would be eligible for continued coverage under the reissued permit. In order to assure your continued coverage under the general permit, you must apply to the Division of Water Quality (DWQ) for renewal of your permit coverage. To make this renewal process easier, enclosed you will find a Permit Coverage Renewal Application Form. The application must be completed and returned by August 19, 2005 in order to assure continued coverage under the general permit. Letters confirming our receipt of the completed application will not be sent. Failure to request renewal within the time period specified may result in a civil assessment of at least $250.00. Larger penalties may be assessed depending on the delinquency of the request. Discharge of stormwater from your facility without coverage under a valid stormwater NPDES permit would constitute a violation of NCGS 143-215.1 and could result in assessments of civil penalties of up to $10,000 per day. Please note that "no exposure exclusion" is now available to all operators of industrial facilities in any of the categories of "storm water discharges associated with industrial activity," (except construction activities). If you feel your facility can certify a condition of "no exposure", i.e. the facility industrial materials and operations are not exposed to stormwater, you can apply for the no exposure exclusion. For additional information contact the Central Office Stormwater Staff member listed below or check the Stormwater Permitting Unit Web Site at http://h2o.enr.state.nc.us/su/. If the subject stormwater discharge to waters of the state has been terminated, please complete the enclosed Rescission Request Form. Mailing instructions can be found on the bottom of the form. You will be notified when the rescission process has been completed. If you have any questions regarding the permit renewal procedures please contact Bethany Georgoulias of the Central Office Stormwater Permitting Unit at (919) 733-5083, ext. 529. Sincerely,/ Bradley Bennett Supervisor, Stormwater & General Permit Unit Cc: Central Files Raleigh Regional Office SWPU Files rn, NoyhCarolina . JAWu lly Wetlands and Stormwater I7ranch 1617 Mail Service Center Raleigh. NC 27699-1017 Phone (919) 733-5083 Internet h2o.encstate.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX (919) 733 9612 An Equal OpportunitylAffirmative Action Employer— 50% Recycled110% Post Consumer Paper State of North Carolina -- De#artment of EnvironmEe 9 and Natural Resources Division of Water Quality Michael F. Easley, Governor Sherri Evans -Stanton, Acting Secretary jo RA NCDENR Kerr T. Stevens, Director NORTH CAROLINA DEPARTMENT OF NV EIRONMENT ANRD NATURAL RESOURCES January 19, 2001P�J� JEFFERY CHARLESJ & G RECYCLERS OF WILSON JAN 2 2 20111;1' P.O. BOX 1263 i WILSON, NC 27893 — — -- -- ncykIR RAI Fh>: I Subject: Reissue - NPDES Stormwater PermiflAL OFFICE i I & G Recyclers Of Wilson COC Number NCG200368 Wilson County Dear Permittee: In accordance with your application for a discharge permit received on July 28, 1995 we are forwarding herewith the subject certificate of coverage to discharge under the subject state - NPDES general permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215 .l and the Memorandum of Agreement between North Carolina and the US Environmental Protection agency dated December 6, 1983. If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable to you, you have the right to request an individual permit by submitting an individual permit application. Unless such demand is made, this certificate of coverage shall be final and binding. Please take notice that this certificate of coverage is not transferable except after notice to the Division of Water Quality. The Division of Water Quality may require modification or revocation and reissuance of the certificate of coverage. This permit does not affect the legal requirements to obtain other permits which may be required by the Division of Water Quality or permits required by the Division of Land Resources, Coastal Area Management Act or any other Federal or Local governmental permit that may be required. Enclosed is a permit package which contains the following information * A stormwater pollution prevention plan (SPPP) implementation certification form * A copy of general stormwater permit NCG200000 * Five copies of the Analytical Monitoring form and five copies of the Qualitative Monitoring form * A copy of a Technical Bulletin for the general permit which outlines key requirements and addresses frequently asked questions * A Certificate of Coverage If you have any questions concerning this permit, please contact Bill Mills at telephone number (919) 733-5083 ext. 548. Sincerely tJPlG7RAUSlGMFC, i"•; RUN C.14 (1181 for Kerr T. Stevens cc: Central Files Stormwater and General permits Unit Files Raleigh Regional Office 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone 919-733-5083 Fax 919-733-9919 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper a TATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY GENERAL PERMIT NO. NCG200000 CERTIFICATE OF COVERAGE No. NCG200368 STORMWATER DISCHARGES NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, J & G RECYCLERS OF WILSON is hereby authorized to discharge stormwater from a facility located at J & G RECYCLERS OF WILSON WILSON COUNTY to receiving waters designated as HOMINY SWAMP & CITY OF WILSON STORM SEWER SYSTEM, a class C SW NSW stream, in the River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III, IV, V, and VI of General Permit No. NCG200000 as attached. This certificate of coverage shall become effective January 19, 2001. This Certificate of Coverage shall remain in effect for the duration of the General Permit. Signed this day January 19, 2001. OMM-SIGNL-'? "Y ft"C. NA_! S for Kerr T. Stevens, Director Division of Water Quality By Authority of the Environmental Management Commission j- CH CAROLINA -NATURAL RESOURCES ITY DEVELOPMENT R DRTH CAROLINA 5455 /V Sw PAD CROSSROADS/ '35 /, a pas \ \N \>. IG�\ 7" IIh d Jeia\d4: • `' J Cent. an,, ^7 �. / \ VFI I' J�'`\ 1z 1 it�WI'LS0 �0 J & G ® WILSON 0 • NORTH CAROLIN: Clers Ol T Wilson 7.5 MINUTE SERI NW/4 WILSON 5 '38 2 330 000 FEET '39 z /� - •t b \ Toisnot j ' r , 'Park, � l I I. �\ 0, Substa Radio OT) IW�TI z z � 'ratio" Trade Parks T oiler Park NES S BUS 26 / �� ✓.. \ �eri\ -I.; � IIISCNttl�� e L + NC A Y Eastern NC �+ VQF ,D Frre �' \ How 3/ xh I. —_--1 a Ir v �/ 'y/ �� m 7 I '�� �� Flemin II_'� ! •�' 4T r�� I l � Stadiu���� �i �.',A� :-.� Fie r t\//��.� IhI�'IIV ..,�eoA% • \ ��� \ /y��. i � ���la I���� lam,/ ��r�// � w A A. r \ l qq .�,.. c 1 1 Le \s`.• 37 %- 1y n /� r L �, v L r �� �� Rest Haven 26 \ l �,i•5 / Radlo Towers .. � �� � ��� � �'�/���+� _L�/ ' .. � Imo. � ♦ a �\J(—Ii �. r" B .� / P ,•� Grave •� � ► Drive m 1 l � / Th ale-- :"! ! ��o �• , '! J • r J Y L 2 4 2013 July 23, 2013 1300922.100 Mr. Danny S. Smith North Carolina Department of Environment and Natural Resources Division of Water Quality 1628 Mail Service Center Raleigh, North Carolina RE: RESPONSE TO JUNE 13, 2013 COMPLIANCE EVALUATION INSPECTION J & G RECYCLERS OF WILSON WILSON, NORTH CAROLINA Dear Mr. Smith: On behalf of J & G Recyclers of Wilson, Golder Associates of NC, Inc. (Golder) is submitting this letter in response to findings and violations noted in the compliance evaluation inspection performed by the North Carolina Department of Environment and Natural Resources (NC DENR) Division of Water Quality (DWQ) on June 13, 2013, at the J & G Recycling Facility located in Wilson, North Carolina. As a result of the inspection, twelve items were recorded that require a response from the facility owner. The owner/operator of J & G Recyclers of Wilson is taking the following actions to address the findings and violations noted in the compliance evaluation inspection report from your office dated June 24, 2013. Each finding and/or violation noted in the June 24, 2013, inspection report is listed below in bold/italics followed by the facility owner's response to each. Findinqs #1 & #2 • Request for permit renewal is required 180-days prior to permit expiration date. The Permittee is responsible for maintaining all permit requirements and conditions. Response to #1 & #2 J & G Recyclers will submit a Notice of Intent and applicable fees for coverage under the General Permit No. NCG200000 to discharge stormwater under the National Pollution Discharge Elimination System within two weeks and intends to implement and maintain permit requirements and conditions under this permit. Findinq #3 Two pieces of equipment have leaked oil that has puddled on the ground. Failing to collect and remove the discharge of oil is a violation of NC General Statute 143-215.84(b) and is subject to enforcement action. Response to #3 J & G Recyclers will remove soils associated with the oil leaks from the on -site equipment and properly dispose of the collected materials. The oil contaminated soil is scheduled to be excavated and removed gipralecls\j& g recyclerstresponse letterUesponse letter fire.docx Golder Associates NC, Inc. ,S 5B Oak Branch Drive Greensboro, NC 27407 USA � ' Tel: (336) 852-4903 Fax: (336) 852-4904 w .golder.com Golder Associates: Operations in Africa, Asia, Australasia, Europe, North America and South America Golder, Golder Associates and the GA globe design are trademarks of Golder Associates Corporation Mr. Danny Smith July 23, 2013 NC DENR. Division of Water Qualitv 2 1300922.100 from the facility by the end of August 2013. J & G will also implement a spill prevention and response plan as required by the General Permit to assist in preventing future releases of oil at the facility. Violations #4 - #12 • The Stormwater Pollution Prevention Plan has not been created and implemented as required by General Permit NCG200000 (Certificate of Coverage). • Analytical monitoring had not been conducted as required by General Permit NCG200000. • Qualitative monitoring had not been conducted as required by General Permit NCG200000. • Employee Training had not been developed as required by General Permit NCG200000. • A detailed site map showing drainage and outfall locations needs to be developed. • A permanent rain -gauge is required to be installed on site to record rainfall data related to analytical monitoring. • A Spill Prevention and Response Plan will need to be developed with oil Spill Prevention Control and Countermeasure (SPCC) Plan incorporated. • A Stormwater Management Plan is required to be developed and implemented. • A preventative maintenance and Good Housekeeping Program is required to be developed. Response to #4 - # 12 J & G Recyclers has hired Golder to prepare a Stormwater Pollution Prevention Plan (SWPPP) that will comply with the requirements listed in the General Permit NCG200000. The SWPPP will include all required components listed in the General Permit NCG20000, including but not limited to, the analytical and qualitative monitoring requirements, employee training, detailed site map, spill prevention and response plan, site specific stormwater management BMPs, and outline a preventative maintenance and good housekeeping program. J & G Recyclers will also purchase a permanent rain -gauge and install it in an appropriate location at the facility to document rainfall totals as required by the General Permit. J & G Recyclers intend to complete and implement the SWPPP by the end of August 2013. J & G Recyclers has assessed the volume of oils stored at the Wilson facility and have determined that the total above -ground storage capacity is less than 1,320 gallons. Non -transportation related on -shore facilities that have less than 42,000 gallons of completely buried storage capacity and the aggregate above -ground storage capacity of the facility is 1,320-gallon or less are not required to have a SPCC Plan per 40CFR 112.1(d)(2). If you have any questions or concerns related to J & G Recyclers response to the findings and violations listed in the June 24, 2013 compliance evaluation inspection report feel free to contact the undersigned at (333) 852-4903. gaarojects4 & g recyclersbesponse letWVesponse lette• final.Oocx VilGolder Associates Mr. Danny Smith July 23, 2013 NC DENR, Division of Water Quality 3 1300922.100 Sincerely, GOLDER ASSOCIATES NC, INC. Ken Sizemore, CHMM Project Environmental Scientist vaolA� Rachel P. Kirkman, P.G Associate and Senior Geologist cc: Jeff Charles, Owner, J & G Recyclers of Wilson, P.O. Box 1263 Wilson, NC 27894. 919-920-0856. Yard. doo69(aDhotmail.com Dennis Gehle, General Manager, Goldsboro Metal Recyclers, 801 North Johns Street, Goldsboro, NC 27530. 919-731-5600. doehle(aa)goldsboroscraometalrecycling.com g;�projectsy & g recyclers4esponse leue esponse lever final. doi 9 Golder Associates