NCG100241_NOV Response_20200706

PYRAM �'�
ENVIRONMENTAL & ENGINEERING, P.C.
Mr. Tim LaBounty
NC Department of Environmental Quality
Division of Energy, Mineral and Land Resources
225 Green Street, Suite 714
Fayetteville, NC 28301
RE: Response to NOV Letter Dated 6/12120
Sandhills Pick-N-Pull
561 S. King Street, Fayetteville, NC 28301
Dear Ms. LaBounty:
July 2, 2020
JUL - 6 2020
3: o2f11-f
DEQ-FAYETTEVILLE REGIONAL OFFICE
On behalf of Sandhills Pick-n-Pull, Pyramid Environmental & Engineering, P.C. is responding to
the Notice of Violation letter date June 12, 2020 in response to a site inspection that was
performed by Melissa Joyner on June 3, 2020.
As a result of the site inspection the following permit conditions violations were 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.
The following action items are required to correct the violations.
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 NCGl00000
permit requirements, conduct and record monitoring for the parameter Total Toxic
Organics.
Response to Action Items
1. After the DEQ inspection on 6/12/20, Sandhills Pick-N-Pull immediately updated the
Pollution Prevention Team and Emergency Contact personnel in the SPPP. The facility
will now plan to conduct an annual review of the SPPP in January of every year and
include documentation of annual spill awareness training in the SPPP.
P.O. Box 16265 • Greensboro, NC 27416
503 Industrial Ave • Greensboro, NC 27406
Phone [phone] • Fax [phone] • Toll Free [phone]
Email: [e-mail]
www ovramidenvironmental.com

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2. Total Toxic Organics analyses have been added to the required laboratory parameter list
for all future sampling events. On June 16, 2020, the stormwater samples were
successfully collected during a representative rain event by Thomas Cantrell, General
Manager of Sandhills Pick-N-Pull. The samples were analyzed for total toxic organics
(TTO) using EPA Methods 608.3, 624.1 & 625.1 in addition to the other standard
parameters required in General Permit NCG10000. The lab results were received and the
TTO concentration was below the benchmark level of 1 mg/L. A bottle kit for the 2"d half
of 2020 has been delivered to the facility and includes the laboratory prepared containers
for all the required parameters including TTO.
If you have any question or need additional information, please contact me [phone] or
[e-mail].
Sincerely,
mftm�rm
Brett S. Higgins
Senior Project Manager
Cc: Marc Vanover & Thomas Cantrell
Sandhills Pick-n-Pull, Fayetteville, NC —Response to NOV 710212020
Pyramid Project # 2020-169 2