NCG080582_NOV Response_20220907

From: LaBounty, Tim L
To: Lawyer, Mike; Joyner, Melissa
Subject: FW: [External] Response to Notice of Violation NOV-2022-PC-0432
Date: Thursday, September 8, 2022 7:16:37 AM
Attachments: Response to NOV-2022-PC-0432.pdf
SWPPP.PDF
FYI.
From: Zach White <[e-mail]>
Sent: Wednesday, September 7, 2022 6:23 PM
To: La Bounty, Tim L <[e-mail]>
Cc: Doug Ford <[e-mail]>; Perry Harrison <[e-mail]>
Subject: [External] Response to Notice of Violation NOV-2022-PC-0432
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
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Mr. La Bounty,
On behalf of Maverick Transportation, attached is the response letter to Notice of Violation NOV-
2022-PC-0432 and an updated Stormwater Pollution Prevention Plan.
If you have any questions or would like to discuss, please don't hesitate to contact either me or Doug
Ford at 501-221-7122.
Respectfully,
Zach
Zachary White
Project Biologist
3512 S Shackleford Rd Little Rock, AR 72205
Office: [phone]
Cell [phone]
PM1 wy,(yu prnico.corr1

September 2, 2022
Timothy La Bounty, P.E.
North Carolina Department of Environmental Quality
Division of Energy, Minerals, and Land Resources
225 Green Street, Suite 714
Fayetteville, NC 28301
RE: Maverick Real Estate, LLC
Certificate of Coverage NCGO80582
Response to NOV-2022-PC-0432
Dear Mr. LaBounty:
Maverick Real Estate, LLC (Maverick) is in receipt of the Notice of Violation dated August 16, 2022
related to SWPPP violations at the facility located in Laurinburg, North Carolina. This letter serves
to address the violations.
Violation #1
"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 8-10(f)... An updated listing of significant spills or notation that none have occurred
has not been properly documented for the past several years."
"Pert 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."
Response
Maverick has contracted PMI to review and update the current SWPPP dated February 2013 to
be in compliance with Permit NCG080000. The review included an updated facility contact list, a
review of the feasibility of BMP's in place, and an update of the required sampling frequency at
Outfall 001. Maverick has reviewed the requirements listed in NCG080000 for spill reporting,
employee training, and sampling. The pollution prevention team named in SWPPP Section 2.0
3512 S Shackleford Rd., Little Rock, AR 72205 • 501-221-7122 • Fax [phone]
1672 E Joyce Blvd., Suite 2, Fayetteville, AR 72703 • 501-221-7122 • Fax [phone]
www.pmico.com

will be in charge of ensuring that SWPPP required annual review and training is completed in
each calendar year. The pollution prevention team will include records in the updated SWPPP to
show any corrective action, spills, or facility changes that may have happened since the
recordkeeping gap that started in 2015. Employee training will be conducted prior to the end of
the calendar year and DEQ will be notified once training is completed.
Violation #2
"Per Part D... Qualitative monitoring has not been conducted and/or recorded in accordance
with permit requirements."
Response
Maverick will implement monthly sampling at Outfall 001 as a Tier Three response. As monthly
analytical testing is completed, qualitative monitoring will also be conducted at the Outfall.
Should any qualitative parameters listed in Part D of NCG080000 be exceeded, Maverick will
immediately notify DEQ and conduct a stormwater management inspection to identify and
evaluate the source of the exceedance(s). Records of monthly qualitative monitoring will be
retained in the SWPPP.
Violation #3
"Per Part E... Analytical monitoring has not been conducted and/or recorded in accordance with
permit requirements."
Response
Maverick will implement monthly sampling at Outfall 001 as a Tier Three response and shall
continue sampling until either three samples in a row are below benchmark values for all
parameters or until DEQ is satisfied with the qualitative and analytical results. Should any
benchmark parameters be exceeded, Maverick will immediately notify DEQ and conduct a
stormwater management inspection to identify and evaluate the source of the exceedance(s). A
subsequent action plan will be submitted to DEQ will the sources identified and further action to
be implemented. Monthly analytical sampling will be included with each quarter's DMR report
and records will be retained in the SWPPP.
Please contact me at [phone] if you have any questions or comments about the responses
above.
Respectfully,
Wm. Doug Ford, PE
Principal
WDF:zdw:cfn
cc: Brent Hilton, Maverick Transportation, LLC
3512 S Shackleford Rd., Little Rock, AR 72205 • 501-221-7122 • Fax [phone]
1672 E Joyce Blvd., Suite 2, Fayetteville, AR 72703 • 501-221-7122 • Fax [phone]
www.pmico.com