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HomeMy WebLinkAboutNCG080582_NOV_20220816 (2)ROY COOPER Governor ELIZABETH S. BISER Secretary BRIAN WRENN Director CERTIFIED MAIL: 7018 0040 0000 4771 9596 RETURN RECEIPT REQUESTED Maverick Transportation, LLC Attn: Mike Jeffress, VP of Maintenance PO Box 16173 Little Rock, AR 72231 NORTH CAROLINA Environmental Quality August 16, 2022 Subject: NOTICE OF VIOLATION (NOV-2022-PC-0432) NPDES Stormwater General Permit NCGO80000 Maverick Real Estate, LLC Maverick Specialized, Certificate of Coverage NCGO80682 Scotland County Dear Mr. Jeffress: On August 10, 2022, Mike Lawyer, Environmental Program Consultant with the Fayetteville Regional Office of the Division of Energy, Mineral and Land Resources (DEMLR), conducted a site inspection for the Maverick Specialized facility located at 12801 Rocky Ford Road in Laurinburg, Scotland County, North Carolina. A copy of the Compliance Inspection Report is enclosed for your review. Mr. Mike Cadle, Service 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 NCG080000 under Certificate of Coverage NCG080582. Permit coverage authorizes the discharge of stormwater from the facility to receiving waters designated as Leith Creek (Johns Pond), class C;Sw waters in the Lumber River Basin. As a result of the site inspection, the following permit conditions violations are noted: 1) Stormwater Pollution Prevention Plan (SWPPP) Per Part B... The Stormwater Pollution Prevention Plan (SWPPP) has not been properly implemented. Per Part B-6... An annual evaluation of the stormwater discharge outfall for the presence of any non-stormwater discharges has not been documented for the past several years. Per Part B-10(f)... An updated listing of significant spills or notation that none have occurred has not been documented for the past several years. Per Part B-13... Annual employee training has not been documented for the past several years. Per Part B-15... An annual review and update of all aspects of the SWPPP has not been conducted. 2) Qualitative Monitoring of Stormwater Discharges Per Part D... Qualitative monitoring has not been conducted and/or recorded in accordance with permit requirements. 3) Analytical Monitoring of Stormwater Discharges Per Part E... Analytical monitoring has not been conducted and/or recorded in accordance with permit requirements. �W North Carolina Department of Environmental Quality 1 Division of Energy, Mineral and Land Resources .w � Fayetteville Regional Office 1 225 Green Street, Suite 7141 Fayetteville, North Carolina 28301 t.`1H71i CtS.CLina — �Q w�tmen� a1 Gmironmen6 a��a, 910.433.3300 De 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. Yourwritten 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 Immediately review and amend the facility's SWPPP in accordance with the current NCG080000 permit and begin incorporating documentation pertaining to the annual update requirements of the permit. Conduct and record Qualitative and Analytical Monitoring per the conditions of the permit. Thank you for your attention to this matter. This office requires that the violations, as detailed above and summarized in the enclosed 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 (910) 433-3394 or via email at mike.lawyer@ncdenr.gov. Sincerely, Timothy L. LaB ty, PE Regional Engineer DEMLR TL/ml Enclosure: Compliance Inspection Report ec: Mike Cadle, Service Manager — Maverick Transportation, LLC Perry Harrison, Properties Manager — Maverick Transportation, LLC Toby Vinson, Jr., PE, CPESC, CPM, Chief of Program Operations — DEMLR Brad Cole, PE, Chief of Regional Operations — DEMLR Danny Smith, Supervisor — DEMLR, Stormwater Program Brittany Carson, General Industrial Stormwater Permit Coordinator — DEMLR, Stormwater Program DEMLR NPDES Stormwater Permit Laserfiche File cc: FRO — DEMLR, Stormwater Files Compliance Inspection Report Permit: NCG080582 Effective: 07/01/21 Expiration: 06/30/26 Owner: Maverick Real Estate LLC SOC: Effective: Expiration: Facility: Maverick Specialized County: Scotland 12801 Rocky Ford Rd Region: Fayetteville Laurinburg NC 28352 Contact Person: Mike Cadle Title: Service Manager Phone: 501-955-1455 Directions to Facility: System Classifications: SWNC, Primary ORC: Secondary ORC(s): On -Site Representative(s): On -site representative Related Permits: Certification: Mike Cadle Phone: 501-955-1455 Inspection Date: 08/10/2022 nttrryTime ,1:OOPM Exit Time: 02:14PM Primary Inspector: Mike Lawyer'"'_,,' Phone: 910-433-3394 Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Transportation wNehicle Maintenance/Petroleum Bulk/Oil Water Separator Stormwater Discharge COC Facility Status: ❑ Compliant Not Compliant Question Areas: Storm Water (See attachment summary) Page 1 of 3 Permit: NCG080582 Owner - Facility: Maverick Real Estate LLC Inspection Date: 08/10/2022 Inspection Type : Compliance Evaluation Reason for Visit: Routine Inspection Summary: Met with Mike Cadle, Service Manager, who provided the facility's Stormwater Pollution Prevention Plan (SWPPP) and Spill Prevention Control & Countermeasure Plan (SPCC) for review. The SWPPP was last updated in 2013 and appears to contain all permit -required components. However, there was no documentation related to an annual review/update to include an annually updated listing of significant spills or notation that none have occurred, annual employee training, or annual evaluation of the stormwater outfall for the presence of any non-stormwater discharges. The SPCC was updated in June 2021 and contains records of inspections of the facility's ASTs and secondary containment structures. Per Mr. Cadle, monitoring of stormwater discharges per the conditions of the NCG080000 permit has not been conducted for the past several years due to some miscommunication. Monitoring records available for review at the time of inspection were from 2015. After the records review, observations were made of the facility's ASTs with secondary containment, stormwater discharge outfall, and overall site conditions. Mr. Cadle was informed that a Notice of Violation would be issued for failure to update/implement the SWPPP and failure to conduct monitoring of stormwater discharges per the conditions of the NCG080000 permit. Page 2of3 Permit: NCGO80582 Owner - Facility: Maverick Real Estate LLC Inspection Date: 08/10/2022 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? N ❑ ❑ ❑ # 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? ❑ E ❑ ❑ # Has the facility evaluated feasible alternatives to current practices? N ❑ ❑ ❑ # Does the facility provide all necessary secondary containment? M ❑ ❑ ❑ # Does the Plan include a BMP summary? 0 ❑ ❑ ❑ # Does the Plan include a Spill Prevention and Response Plan (SPRP)? ❑ ❑ ❑ # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? E ❑ ❑ ❑ # 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? ❑ N ❑ ❑ # Does the Plan include a Stormwater Facility Inspection Program? 0 ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? ❑ 0 ❑ ❑ Comment: Facility's SWPPP is dated 2013 and appears to contain all required components, but there is no documentation regarding the annual review and update requirements. Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring? ❑ 0 ❑ ❑ Comment: Based on the monitoring records available for review during the inspection, monitoring has not been conducted and recorded since 2015. Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? ❑ E ❑ ❑ # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ 0 ❑ ❑ Comment: Based on the monitoring records available for review during the inspection monitoring has not been conducted and recorded since 2015. 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? E ❑ ❑ ❑ # If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ 0 ❑ # Has the facility evaluated all illicit (non stormwater) discharges? ❑ 0 ❑ ❑ Comment: Page 3of3