NCG081023_NOD_20240524

ROY COOPER
Governor
j '
ELIZABETH S.BISERa;n �
Secretary
WILLIAM E.TOBY VINSON,JR. NORTH CAROL-INA
Interim Director Environmental Quality
May 24, 2024
CERTIFIED MAIL 7022 0410 7791 5577
RETURN RECEIPT REQUESTED
Carvana LLC
Attn: Jessica Tierney
1930 W Rio Salado Pkwy
Tempe, Arizona 85281
Subject: NOTICE OF DEFICIENCY (NOD-2024-PC-0085)
NPDES Stormwater General Permit NCG080000
Carvana,LLC
Concord Inspection Center, Certificate of Coverage NCG081023
Cabarrus County
Dear Ms. Tierney:
On May 15, 2024, Matthew Gigante from the Mooresville Regional Office of the Division of Energy,
Mineral and Land Resources (DEMLR), conducted a site inspection for the Concord Inspection Center
facility located at 3035 New Town Rd SW, Cabarrus County, North Carolina. A copy of the Compliance
Inspection Report is enclosed for your review. Michael Patterson 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 NCGO80000 under Certificate of Coverage
NCG081023. Permit coverage authorizes the discharge of stormwater from the facility to receiving waters
designated as Coddle Creek, class C waters in the Yadkin Pee-Dee River Basin.
As a result of the site inspection, the following deficiencies are noted:
1) Analytical and Qualitative Monitoring was not being conducted on site.
2) The Stormwater Pollution Prevention Plan (SWPPP)has not been reviewed since Augst 2022.
Other Observations
Please refer to the enclosed Compliance Inspection Report for additional comments and observations
made during the inspection.
North Carolina Department of Environmental Quality I Division of Energy,Mineral,and Land Resources
Mooresville Regional Office 1610 East Center Avenue,Suite 3011 Mooresville,North Carolina 28115
704-235-2100

NOTICE OF DEFICIENCY
Carvana LLC
May 24, 2024
Page 2 of 2
Requested Response
A written response is not requested at this time.
Action Items
1) Immediately begin analytical and qualitative monitoring beginning with the next measurable storm
event.
2) Within 30 days of receiving this Notice of Deficiency, conduct a review of the SWPPP and note
this review date in the SWPPP. Email a copy of the reviewed SWPPP with the updated review date
to Matthew Gigante with the NCDEQ Mooresville Regional Office.
Thank you for your attention to this matter. This office requires that the deficiencies, as noted above
and detailed in the enclosed inspection report, be properly resolved. Failure to address the
deficiencies could result in the issuance of a Notice of Violation, which is subject to a civil penalty
assessment of up to $25,000 per day for each violation. Should you have any questions or concerns,
please contact Matthew Gigante or myself at [phone].
Sincerely,
Docu Signed by:
er"
4A35D6B02BO2438...
Jerry W. Eplin, PE
Regional Engineer
Land Quality Section
cc: Michael Patterson, Carvana LLC, 3035 New Town Way, SW, Concord,NC 28027
JWE/cys/KSP
Enclosure: Compliance Inspection Report
c: Mike Lawyer, CPSWQ, Stormwater Program Supervisor—DEMLR
Brad Cole, PE, Chief of Regional Operations—DEMLR
DEMLR NPDES Stormwater Permit Laserfiche File
North Carolina Department of Environmental Quality I Division of Energy,Mineral,and Land Resources
Mooresville Regional Office 1610 East Center Avenue,Suite 3011 Mooresville,North Carolina 28115
704-235-2100

Compliance Inspection Report
Permit:NCG081023 Effective: 08/18/22 Expiration: 06/30/26 Owner: Carvana LLC
SOC: Effective: Expiration: Facility: Concord Inspection Center
County: Cabarrus 3035 New Town Rd Sw
Region: Mooresville
Concord NC 28027
Contact Person:Eric Gless Title: Phone: [phone]
Directions to Facility:
System Classifications: SWNC,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 05/15/2024 Entry Time 09:45AM Exit Time: 11:40AM
Primary Inspector:Matthew J Gigante Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Transportation w/Vehicle 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: NCG081023 Owner-Facility:Carvana LLC
Inspection Date: 05/15/2024 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
An inspection was conducted alongside Michael Patterson with Carvana LLC. The stormwater pollution prevention plan
(SWPPP)was present on site at the time of the inspection. All sections of the plan were present, however there was no
date indicating the SWPPP had been reviewed in the last year. The most recent date located on the SWPPP was August
2022.
Analytical and Qualitative monitoring data was not present on site at the time of the inspection.Staff notified that this was
not being completed as they had not yet received an approval letter or certificate of coverage.A review of available
documents related to this permit indicates an approval letter and certificate of coverage for the facility was sent to Jessica
Tierny on August 18, 2022.
All outfalls were observed with no visual issues at the time of the inspection.
This facility must:
- Immediately begin analytical and qualitative monitoring beginning with the next measurable storm event.
-Within 30 days, conduct a review of the SWPPP and note this review date in the SWPPP. Email a copy of the reviewed
SWPPP with the updated review date to Matthew Gigante with the NCDEQ Mooresville Regional Office.
Page 2 of 3

Permit: NCG081023 Owner-Facility:Carvana LLC
Inspection Date: 05/15/2024 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? ❑ ❑ ❑
#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? 0 ❑ ❑ ❑
#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: All portions of the stormwater pollution prevention plan were present with the exception of a
review date within the last year. The most recent date located on the stormwater pollution
Prevention plan was August 2022.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring? ❑ 0 ❑ ❑
Comment: Qualitative monitoring data was not present on site at the time of the inspection.
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? ❑ 0 ❑ ❑
Comment: Analytical monitoring data was not present on site at the time of the inspection.
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? ❑ ❑ 0 ❑
#Has the facility evaluated all illicit(non stormwater)discharges? 0 ❑ ❑ ❑
Comment: All outfalls were observed on site with no visible issues at the time of the inspection.
Page 3 of 3