NCG100241_NOV_20200612

ROY COOPER
Governor
MICHAEL S„REGAN
Secretary
BRIAN WRENN
Acting Director
CERTIFIED MAIL: 7018 0040 0000 4771 9923
RETURN RECEIPT REQUESTED
Carolina Pick-N-Pull
Attn: Marc Vanover, Owner
555 S. King Street
Fayetteville, NC 28301
NORTH CAROLINA
Environmental Quality
. June 12, 2020
Subject: NOTICE OF VIOLATION (NOV-2020-PC-0290)
NPDES Stormwater General Permit NCG100000
Carolina Pick-N-Pull
Sandhills Pick-N-Pull, Certificate of Coverage NCG100241
Cumberland County
Dear Mr.Vanover:
On June 3, 2020, Melissa Joyner from the Fayetteville Regional Office of the Division of Energy, Mineral and Land
Resources (DEMLR), conducted a site inspection for the Sandhills Pick-N-Pull facility located at 555 S. King Street,
Fayetteville, Cumberland County, North Carolina. A copy of the Compliance Inspection Report is enclosed for your review.
Mr. Tom Cantrell, General Manager, was also present during the inspection and his time and assistance is greatly
appreciated. The site visit and file review revealed that the subject facility is covered by NPDES Stormwater General
Permit NCG100000 under Certificate of Coverage NCG100241. Permit coverage authorizes the discharge of stormwater
from the facility to receiving waters designated as the Cape Fear River, class C waters in the Cape Fear 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 properly recorded and implemented.
2) Analytical Monitoring
Analytical 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
1. Immediately review and amend the facility's Stormwater Pollution Prevention Plan as needed and begin
incorporating documentation pertaining to the annual update requirements of the permit.
2. Unless a Solvent Management Plan is implemented in accordance with NCG100000 permit requirements,
conduct and record monitoring for the parameter Total Toxic Organics.
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
910.433.3300

Thank you for your attention to this matter. This Office is considering sending a recommendation for enforcement to the
Director of the Division of Energy, Mineral & Land Resources regarding these issues. Your above -mentioned response to
this correspondence will be considered in this process. 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 Melissa
Joyner or myself at [phone].
Sincerely,
T othy L. La ty, PE
Regional Engineer
DEMLR
TLL/maj
Enclosure: Compliance Inspection Report
ec: Tom Cantrell, General Manager (via email)
William E. (Toby) Vinson, PE, CPESC, CPM, Program Operations Chief — DEMLR (via email)
Annette Lucas, PE, Stormwater Program Supervisor— DEMLR, Stormwater Program (via email)
Alaina Morman, Environmental Specialist — DEMLR, Stormwater Program (via email)
CC] FRO — DEMLR, Stormwater Files

Permit: NCGl00241
SOC:
County: Cumberland
Region: Fayetteville
Compliance Inspection Report
Effective: 11/01/18 Expiration: 05/31/21
Effective: Expiration:
Contact Person: Marc Vanover
Title:
Owner: Carolina Pick-N-Pull
Facility: Sandhills Pick-N-Pull
555 S King St
Fayetteville NC 28301
Phone: [phone]
Directions to Facility:
business 95 (a. eastern blvd) to bell street, bell street to s. king street, right on s. king street, site is on the left.
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
On -site representative
Related Permits:
Tom Cantrell
Inspection Date: 06/03/2020 Entry Time 09:OOAM Exit Time: 11:10AM
Primary Inspector: Melissa A Joyner !NAT
Secondary Inspector(s):
843-8554114
Phone:
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Used Motor Vehicle Parts Stormwater Discharge CDC
Facility Status: ❑ Compliant E Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 3

Permit: NCGl00241 Owner- Facility: Carolina Pick-N-Pull
Inspection Date: 06/03/2020 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Melissa Joyner met with Mr. Tom Cantrell, General Manager, at the Sandhills Pick-N-Pull facility. The facility was inspected
due to a complaint received by this Office. There were no issues in regards to this complaint. The Stormwater Pollution
Prevention Plan (SPPP) was reviewed and appeared well -organized. Michael Fulgum, Jr. no longer works at this facility and
his name will need to be removed from the SPPP. The site map should be updated, indicating the percentage of each
drainage area which is impervious and the location of Outfall #2. The facility documented that there were no spills in 2018,
but there was no documentation for 2019. The stormwater outfalls have not been annually evaluated for the presence of
non-stormwater discharges. Documentation of annual employee training has also not occurred. A Best Management
Practices (BMP) summary needs to be developed, including the permanent basin, riprap outlet protection, berm, drop inlet
protection and wattles utilized near the double -walled Above Ground Storage Tank (AST). This summary should be reviewed
and updated annually. It is recommended that the facility's 'Weekly Inspection" form be modified to include these BMPs.
The facility has not conducted a feasability study.
The Analytical and Qualitative Monitoring forms were reviewed. No exceedances of the benchmark values for the parameters
was noted. The parameter Total Toxic Organics has not been monitored. This will need to be initiated for the next sampling
event. Analytical Monitoring had not occurred for Period 1, in 2020, at the time of the inspection.A Solvent Management
Plan may be developed which will waive this requirement but until this plan has been developed and approved, Total Toxic
Organics will need to be monitored. New motor oil or hydraulic oil usage (gal/month) has not been recorded. During the
facility grounds inspection a second outfall was located which will need to be monitored during Period 1. There were no
issues with the outfalls and other BMP's inspected except that the berm, which was partially disturbed, will need to be
stabilized with permanent groundcover. The facility grounds appeared orderly.
Page 2 of 3

permit: NCGl00241 Owner -Facility: Carolina Pick-N-Pull
Inspection Date: 06/03/2020 Inspection Type: Compliance Evaluation Reason for visit: Routine
Stormwater Pollution Prevention Plan
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?
# 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?
# 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?
Yes No NA NE
■❑❑❑
■❑❑❑
■❑❑❑
❑ ❑ ❑
❑ ❑ ❑
❑ N ❑ ❑
N ❑ ❑ ❑
❑ ❑ ❑
■❑❑❑
■❑❑❑
❑■❑❑
■❑❑❑
❑■❑❑
■❑❑❑
❑■❑❑
Comment: The Stormwater Pollution Prevention Plan has not been properly recorded and implemented.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? 0 ❑ ❑ ❑
Comment:
Analytical Monitoring 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 has not been conducted for the parameter Total Toxic Organics.
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? E ❑ ❑ ❑
# Were all outfalls observed during the inspection? N ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ 0 ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ❑ M ❑ ❑
Comment:
Page 3 of 3