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ELIZABETH S.BISER
BRIAN WRENN NoRm CAROLINA
l.'zircrrn, Environmental Quality
August 13, 2021
CERTIFIED MAIL: 7017 0190 0000 2485 8121
RETURN RECEIPT REQUESTED
Renew Recycling, LLC
Attn: Gary Taylor
440 S.Tech Park Lane
Clayton, NC 27520
Subject: NOTICE OF VIOLATION (NOV-2021-PC-0404)
Renew Recycling
NPDES Storm
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CERTIFIED MAIL' RECEIPT
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440 S.Tech Park Lane.A cop a „— �� o o ❑Raft-Racelpt
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As a result of the inspection ��r� p d ata --- —
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1) Failure to Develop and I --�.� o o si.�ra>;d -t o or Ft6-6
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Pollutants accumulated �`
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complete and compreh� �,rj fe jiA.4+ -_....-__...
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2) Failure to follow the Analytical and Qualitative Monitoring Requiremen
&C) of the permit for inspecting and sampling all outfalls from the site in accordance with the
Tier Response Requirements
3) Failure to take all reasonable steps to minimize or prevent any discharge in violation of this
general permit which has a reasonable likelihood of adversely affecting human health or the
environment. Permittee has allowed pollutants to accumulate throughout the facility and
chemical tanks and liquid products from the industrial process are not being maintained. [Part
III.A-3]
North C:rrnfir,a f)Lpanmcnt of F.mironrncntai Qn.ditg I I)lvi,inn of Lncrtrg,tlincral and I-and Rr.•sc+urces
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ROY COOPERf
Governor
ELIZABETH S.BISER .. _
Secretary
BRIAN WRENN NORTH CAROLINA
Director Environmental Quality
August 13, 2021
CERTIFIED MAIL: 7017 0190 0000 2485 8121
RETURN RECEIPT REQUESTED
Renew Recycling, LLC
Attn: Gary Taylor
440 S.Tech Park Lane
Clayton, NC 27520
Subject: NOTICE OF VIOLATION (NOV-2021-PC-0404)
Renew Recycling, LLC
NPDES Stormwater General Permit NCG200000
Certificate of Coverage NCG200498
Johnston County
Mr.Taylor:
On August 4, 2021 staff from the Raleigh Regional Office of the Division of Energy, Mineral,and
Land Resources (DEMLR), conducted a site inspection for the Renew Recycle, LLC. facility located at
440 S.Tech Park Lane.A copy of the inspection report is enclosed for your review.This facility
discharges stormwater to receiving waters designated as Copper Branch,a Class C;NSW waterbody
in the Neuse River Basin.
As a result of the inspection,the following permit condition violations are noted:
1) Failure to Develop and Implement a complete Stormwater Pollution and Prevention Plan.
Pollutants accumulated across the facility are exposed to stormwater and the plan lacks a
complete and comprehensive Stormwater Pollution Prevention Plan for Part II [Section A: 1-9.)
2) Failure to follow the Analytical and Qualitative Monitoring Requirements for Part II {Sections B
&C} of the permit for inspecting and sampling all outfalls from the site in accordance with the
Tier Response Requirements
3) Failure to take all reasonable steps to minimize or prevent any discharge in violation of this
general permit which has a reasonable likelihood of adversely affecting human health or the
environment. Permittee has allowed pollutants to accumulate throughout the facility and
chemical tanks and liquid products from the industrial process are not being maintained. [Part
I I.A-3]
D�E Q�_ North Ca.ol,na Depat-t meat of Environme ntal QuakyI U.vision of Ene_g}.Mineral and Lard Resuwc.cs
��/s� Raleigh Regional Office 1 Ier18 Mail&nMcc Center 3800 ISarrett Drivc I Raleigh,Nnr sh Carti[itea 17t 09
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Notice of Violation
Gary Taylor
August 13, 2021
Page 2 of 2
Required Response
Submit an action plan with definitive steps to remove pollutants and industrial materials from the
facility and bring it back into compliance with the permit and fully develop and implement and
document all requirements of the Stormwater Pollution Prevention Plan.The action plan is due
within 30 calendar days of receipt of this notice.
Thank you for your attention to this matter.This office is considering referring these violations to
the DEMLR Director for enforcement.Your above-mentioned response to this notice will be
considered in any enforcement process.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 Thad Valentine or me at((919)791-4200.
Sincerely,
William H. Denton IV, PE
Regional Engineer
Land Quality Section
Enclosure: Inspection Report(August 4, 2021)
ec: Sill Denton-Engineering Regional Supervisor
Annette Lucas, PE-Stormwater Program Supervisor
Alaina Morman- Environmental Specialist
Compliance Inspection Report
Permit:NCG200498 Effective: 08/01/19 Expiration: 05/31124 Owner: Renew Recycling LLC
SOC: Effective: Expiration: Facility: Renew Recycling LLC
County: Johnston 440 S Tech Park Ln
Region: Raleigh
Clayton NC 27520
Contact Person:Luke Bryant Title: Phone:865-335-5574
Directions to Facility:
take hwy 70 a to pony farm rd turn rt on pny farm rd proceed 2 mi
System Classifications: SWNC,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 08/04/2021 Entry Time 10:OOAM Exit Time: 11:05AM
Primary Inspector:Thaddeus W Valentine Phone:
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Wholesale Trade of Metal Waste and Scrap Stormwater Discharge COC
Facility Status: ❑ Compliant 0 Not Compliant
Question Areas:
■ Storm Water
(See attachment summary)
Page 1 of 3
Permit: NCG200498 Owner-Facility:Renew Recycling LLC
Inspection Date: 08/04/2021 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
The stormwater pollution prevention plan (SP3) has some of the requirted information, but much is not available.
They have an orginizational chart that shows positions, but doesn't list the names for the positions.
The spill history was incomplete and after walking the site and seeing the numerous spills it is lacking much information.
There are spill reports but nothing has been filled out
There are good housekeeping checklist, but none have been filled out, nor has it been implemented
There are preventive maintenance logs but none are filled out, nor has it been implemented
There are spill prevention and prevention logs that haven't been filled out or implemented.
Much of the preventive maintenance plan is descriptive of what it is, but is not site specific with details for implementing the
different measures at this site.
The facility has many spills throughout the site and improperly stored materials.
Batteries are outside on pallets and on the ground
55 gallon drum and 5 gallon buckets are out in the open around the facility and in some cases without lids or caps.
There are piles of small vessels with hydrolic or some type of petroleum fluids leaking onto the ground
Ther are equipment and work areas with large accumulations of hydrolic fluids and oils that have obviousely have not been
cleaned up in a very long time.
There are many 55 gallon drums that were being pumped out with no type of containment or spill prevention devises.
The sample point was identified as the ditch next to the scales and scale house. The basin that drains much of the site
runoff is located outside of the fence and in an inaccessible area.The outfall to the basin should be one outfall area,
whatever it takes to access it.
From the sample data found in laserfiche,the facility is in Tier III and must follow Tier III protocals and sampling requirements
and has not been.All requirements of the Tier III protocal should be implemented immediately
Page 2 of 3
Permit: NCG200498 Owner-Facility:Renew Rw.ycling LLC
Inspection Date: 08/04/2021 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? 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? ❑ 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? ❑ E ❑ ❑
#Does the facility provide all necessary secondary containment? E ❑ ❑ ❑
#Does the Plan include a BMP summary? 0 ❑ ❑ ❑
#Does the Plan include a Spill Prevention and Response Plan (SPRP)? ❑ 0 ❑ ❑
#Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ❑ 0 ❑ ❑
#Does the facility provide and document Employee Training? E ❑ ❑ ❑
#Does the Plan include a list of Responsible Party(s)? ❑ 0 ❑ ❑
#Is the Plan reviewed and updated annually? ❑ 0 ❑ ❑
#Does the Plan include a Stormwater Facility Inspection Program? ❑ 0 ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented? ❑ 0 ❑ ❑
Comment: The permittee has some parts of the stormwater pollution Prevention glan, but most was not
available
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? 0 ❑ ❑ ❑
Comment: There was qualitative monitoring for (1) outfall for (1) period. 5/29/2021, According to
monitoring reports submitted the facility should be in Tier 3 and sampling monthly
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? ❑ ❑ ❑
#Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ 0 ❑ ❑
Comment: There was analytical monitoring for(1) outfall for(1) period 7/21/2021. According to DMR's
submitted and entered into laserfiche, the facility„should be in Tier 3 and be sampling monthly.
Permit and Outfalls Yes No NA NE
#Is a copy of the Permit and the Certificate of Coverage available at the site? 0 ❑ ❑ ❑
#Were all outfalls observed during the inspection? ❑ 0 ❑ ❑
#If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ M ❑
#Has the facility evaluated all illicit(non stormwater)discharges? ❑ 0 ❑ ❑
Comment: One outfall was observed beside the scale and scale house in the ditch. No samples have
been taken from the outlet of the basin on he West side of the property
Page 3 of 3