NCGNE0650_COMPLETE FILE - HISTORICAL_20091104

STORMWATER DIVISION CODING SHEET
NCG PERM ITS
PERMIT NO.
DOC TYPE Cr HISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE ❑ 5(Y A I ) 0 H _
YYYYMMDD

XJA
NC®ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
November 4, 2009
Con-Way Freight
Attn: Mr. Jeff Sexton
2211 Old Earhart Road, Suite 100
Ann Arbor, Michigan 48105
Subject: No-Exposure Certification NCGNE0650
Con-Way Frieght, 438 W. Bodenhamer St, Kernersville, NC
Forsyth County
Dear Mr, Sexton:
The Division has reviewed your submittal of the No-Exposure Certification for Exclusion from NPDES Stormwater
Permitting form. Based on your submittal of signed certification of no exposure at the above referenced facility and the
site visit conducted by Ms. Jenny Graznak of the Division's Winston-Salem Regional Office on September 30, 2009, the
Division is granting your conditional exclusion from permitting as provided for under 40 CFR 126.22(g), which is
incorporated by reference in North Carolina regulations. We are also hereby rescinding your current permit Certificate of
Coverage, NCG080637, t l
Please note that by our acceptance of your no-exposure certification, you are obligated to maintain no-exposure
conditions at your facility. If conditions change such that your facility can no longer qualify for no-exposure exclusion, you
are obligated to immediately obtain NPDES permit coverage for your stormwater discharge. Otherwise,-the discharge
becomes subject to enforcement as an un-permitted discharge. Your conditional no-exposure exclusion expires in five
years (November 1, 2014). At that time you must re-certify with the Division or obtain NPDES permit coverage for any
stormwater discharges from your facility.
Your conditional exclusion from permitting does not affect your facility's legal requirements to obtain environmental
permits that may be required under other federal, state, or local regulations or ordinances.
If you have any questions or need further information, please contact Jenny Graznak at (336)(,771-5000- ort
[e-mail]. z
Sincerely, r�
for Coleen H. Sullins
cc: SWP—Winston-Salem Regional Office Stormwater Permitting Unit File NCGO80637
Stormwater Permitting Unit No Exposure Files Fran McPherson-Budget Office
SWP —Central Files NCGO80637
North Carolina Division of Water Quality,Winston-Salem Regional Office
Location:585 Waughtown St.Winston-Salem,North Carolina 27107 One
Phone:[phone] FAX:336.771A6301 Customer Service:1-877-523-6748 NorthC/arolina
w.intemet:wwncwaterquality.erg Naturally
An Equal Opportunity 1 Affirmative Action Employer

M A '
NODE R
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
November 4, 2009
Con-Way Freight
Attn: Mr. Jeff Sexton
2211 Old Earhart Road, Suite 100
Ann Arbor, Michigan 48105
Subject: No-Exposure Certification NCGNE0650
Con-Way Frieght, 438 W. Bodenhamer St, Kernersville, NC
Forsyth County
Dear Mr. Sexton:
The Division has reviewed your submittal of the No-Exposure Certification for Exclusion from NPDES Stormwater
Permitting form. Based on your submittal of signed certification of no exposure at the above referenced facility and the
site visit conducted by Ms. Jenny Graznak of the Division's Winston-Salem Regional Office on September 30, 2009, the
Division is granting your conditional exclusion from permitting as provided for under 40 CFR 126.22(g), which is
incorporated by reference in North Carolina regulations. We are also hereby rescinding your current permit Certificate of
Coverage, NCG080637.
Please note that by our acceptance of your no-exposure certification, you are obligated to maintain no-exposure
conditions at your facility. If conditions change such that your facility can no longer qualify for no-exposure exclusion, you
are obligated to immediately obtain NPDES permit coverage for your stormwater discharge. Otherwise, the discharge
becomes subject to enforcement as an un-permitted discharge. Your conditional no-exposure exclusion expires in five
years (November 1, 2014), At that time you must re-certify with the Division or obtain NPDES permit coverage for any
stormwater discharges from your facility.
Your conditional exclusion from permitting does not affect your facility's legal requirements to obtain environmental
permits that may be required under other federal, state, or local regulations or ordinances.
If you have any questions or need further information, please contact Jenny Graznak at (336) 771-5000 or
jenny,[e-mail].
Sincerely,
for Coleen H. Sullins
cc: SWP—Winston-Salem Regional Office Stormwater Permitting Unit File NCG080637
Stormwater Permitting Unit No Exposure Files Fran McPherson-Budget Office
SWP— Central Files NCGO80637
North Carolina Division of Water Quality,Winston-Salem Regional Office
Location:585 Waughtown St.Winston-Salem,North Carolina 27107 One
Phone:[phone] FAX:[phone] Customer Service:1-877-623-6748 NorthCarolina
Internet:www.navaterquality.org Nahlrally
An Equal Opporturity�Affirmative Action Employer

FOR AC) ICY USP ONLY
Division of Water Quality I Surface Water Protection �-a; at°L"Rommh
i n�,•
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RC
DE National Pollutant Discharge Elimination System r N r ;
1 C G 1E
wo ,s q.— � NO EX;POSU E CERTMCATYON for Exclusion
NCGNF-0000
No EXPOSURE CERTIFICATION Please check,here'Iftliis�is,a,rerrawal:_p E�EIV�11�fAi
National Pollutant Discharge Elimination System application for exclusion from a Stormwater Permit based
on kO EXPOSURE:
Submission of this No Exposure Certification constitutes notification that your facility does not require a
permit for stormwater discharges associated with industrial activity in the State of North Carolina because.
it qualifies for a no exposure exclusion. A condition of no exposure at an Industrial facility means all
industrial materials and activities are protected by a storm resistant shelter(with some exceptions)to
prevent exposure to rain,snow,snowmelt,and/arrunoff.
For permitted facilities in North Carolina,.DWO must approve your application for No
Exposure Certification before this exclusion is effective. Until you are issued a No
Exposure Certification and your NPDES permit is rescinded, your facility must continue .
to abide by the.terms and conditions of the.cvrrent permit.
lndustdoi materials or activities include, but are not limited to, material handling equipment or activities.
'Industrial machinery,raw materials, intermediate products,by-products,final products,or waste products.
Material handling.activities Include the-storage,loading and unloading, transportation,or conveyance of
. . any raw material,intermediate product,final product or waste product. A storm resistant shelter is not
required for the following industrial materials and activities: drums,barrels, tanks,and similar containers
that are tightly sealed,provided those containers are not deteriorated and do not leak_ "Sealed"means
banded or otherwise secured and with locked or non-operational taps or valves;adequately maintained
vehicles used in material handling;and final products, other than products that.would be mobilized Irt
stormwater.discharges(e.g.,rock salt).
A No Exposure Certification must be provided for each tacility qualltying for the no exposure exclusion. In
addition,the exclusion from NPDES permitting is available on a facility-wine basis on"nf for individual
outfalls_ if any industrial activities or materials are,or will be,exposed to precipitation,the facility is not
eligible for the no exposure exclusion.By signing and submitting this No Exposure Certification form,you
certify that a condition of no exposure exists at this facility or site and are obligated to comply with the
terms and conditions of 40 CFR 122.26(g).
You are required to reapply for the No Exposure Exclusion once every five (5) Years.
For questions,please contact the DWO Regional Office for your area,(See.page 6)
(Please print or type)
1) Mailing address of ownerioperator address to which all certification correspondence will be mailed):
Name
Gontact yCfe(/L
Street Address v e too
City Pq
r it state ZIP Code
t h rt N 7 f.4 7 Fax-
Te ep o, e o. 5 7--
Page f of 7
SWU-NE-021309 Last revised 2/12/2009
➢0/1300B Wd5Z=l0 5001 9 Ja0 'x12� 1H313ad hWN03

NCGNE0000 No Exposure Certification
1) Location of facility producing discharge:
Facility flame C 01n- WC,
Facility Contact l a a k
Street Address H In awk e r 5 f
City v'. State C ZIP Code G
County
Telephone No. 33{,- ` {�i q Fax: L _
3) Physical location information:
Please provide a narrative description of how to get to the facil'ty(use street names, to road numbers,and
di tance and direction from a roadway intersection).Y�r n a s f 0 wf 0 W. �f cti�a�^ 1✓ 5
(A copy of a map with the facility clearly located on it should be included with the certification application.)
4) Is the facility-located on Native American Lands?❑ Yes ;>I No
5) Is this a Federal facility? O Yes '9f No
6) Latitude Longitude (deg.,min.,seconds)
7) This NPDES No Exposure Exclusion application applies to which of the following:.
Q New or Proposed Pacility Date operation is to begin
)6 Existing Date operation began
o Renewal of existing No Exposure Certification Certification No.: NCGNE
'8)-- Was this facility or site ever covered under an NPDES Stormwater Permit? d Yes ❑ No
If yes,what is the NPDES Permit Number?_1\4 CG U �U 7
9) -Standard Industrial Classification:
Provide the 4 digit Standard Industrial Classification Code(SIC Code)that describes the primary industrial
activity at this facility
SIC Code:
10) Provide a brief descriptio at he types of Industrial activities and products produced at this facility:
11) Does this facility have any Non-discharge permits(ex:recycle Permits)?
No •.
C1 Yes
If yes, list the permit numbers for all current Non-Discharge permits for this tacility:
Page 2 of 7
SWUNE-021309 Last revised 2AM009
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NCGNE0000 No Exposure Certiftation
Exposure Checklists(12.--14.)
12) Are any of the following materials or activities exposed to precipitation, now or in the foreseeable
future?(Please check either"Yes"or"No.") if you answer"Yes"to any of these items,-you are not
eligible for the no exposure.exclusion.
a- Using, storing, or cleaning industrial machinery or equipment,and areas where 0 Yes No ❑ N/A .
residuals trorn using,storing or cleaning industrial machinery or equipment remain
and are exposed to stormwater
b. Materials or residuals on the ground or in stormwater inlets from spills/leaks ❑Yes f$[No ❑ NIA
c. Materials or products from past indus`rial activity ❑Yes No ❑N/A
d. Material handling equipment(except adequately maintained vehicles) ❑ Yes No © NIA
e. Materials or products during loadingfunloadino or transporting activities fl Yes No ❑ N/A
f.Materials or products stored outdoors (except final products intended for outside ❑Yes 9 No El WA
use[e.g., new cars]where exposure to stormwater does not result in the discharge
of pollutants)
g. Materials contained in open,deteriorated or leaking storage drums,barrels,tanks, ❑Yes l 'Na El N/A
and similar containers
h.� A• terials or products handfed/stored on roads or railways owned or maintained'by ❑Yes 'SyNo ❑ N/A
the discharger
i.Waste material (except waste in covered; non-leaking containers[e.g:,•durnpslersl) ©Yes XNo '❑ NIA
j.Application or disposal otprocess wastewater(unless otherwise permitted) ❑Yes Po ❑ NIA
k. Particulate matter or visible deposits of residuals from roof stacks and/or vents not ❑Yes ,IZNo ❑ N/A
otherwise regulated(i.e..-under an air quality control permit;and evident in the
stormwater outflow
I. Emptycontainers that previously contained materials that are not properly stored O Yes Y No © N/A
(Le-, not closed and stored upside down to prevent precipitation accumulation)
m- For any exterior ASTs,as well as drums,Barrels,tanks,and similar containers ❑Yes No ❑ NIA
stored outside, has the facility had any releases in the pass three (3)years?
13)Above Ground Storage Tanks(ASTs): If you answer"No"to any of the following items,you are not
eligible for the no exposure exclusion.
a.Are exterior ASTs or piping free of rust,damaged or weathered coating,pits,or ❑Yes ❑ No A NIA
deterioration,or evidence of leaks?
b, Is secondary containment provided for-all exterior ASTs? If so, is it free of any 0 Yes ❑ No )9 N/A
cracks, holes,or evidence of leaks,and are drain valves maintained locked shut?.
Page S of 7
SWU-NE-o213os Last revi8ed Viar,
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NCGNEOOOO No E.xposUre Certification
14) Secondary Containment: If you answer"No"to any of the following items,you are not eligible for the
no exposure exclusion.
a. Is secondary containment provided for single above ground storage containers ❑Yes ❑ No 0 NIA
(including drums, barrels, etc.)with a capacity of more than 660-gallons?
b. Is secondary containment provided for above ground storage containers stored ❑Yes ❑ No 'fid"N/A
in close proximity to each other with a combined capacity of more than 1,320-
gallons?
c. Is secondary containment provided for Title III Section 313 Superfund ❑Yes ❑ No NSA
Amendments and Reauthoriza ion Act(SARA)water priority chemicals`?
d. Is secondary containment provided for hazardous substances"designated in 40 Yes n No NIA
CFR§116?
e.Are release valves on all secondary containment structures looked? ❑ Yes ❑ No IF NIA
15) Hazardous Waste:
a. is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility? © Yes 1rNo ❑ NIA
b- Is this facility a Small Quantity Generator(less than 1000 k9, of hazardous waste ! r Yes ❑ No 0 N/A
generated per month)of hazardous waste?
c. is this facility a Large Quantity Generator(1000 Kg.or more of hazardous waste ❑ Yes i No ❑ N/A '
generated per month)cif hazardous waste?
If you answered yes to questions b.or c.,please provide the following information:
Types)of waste: wa44 e µ N '( 1[1 4-
How is material stored: CK jqeS0A SQtua�;z c rr +w� �
Where is material stored, 6 K
How many disposal shipments per year.: GLS IAA �e
Name of transport 1 disposal vendor: �St,
Vendor address-.
Footnotes to Questions 14)c.&d.
*Note that amounts below the 660-gallon(single) and 1,320-gallon (oombined)bulk storage minimums require
secondary containment- However, some exceptions may be made for de minimi$amounts of certain substances,
and/or other qualifiers,as described in the exemptions from reporting requirements of Title III SARA 313 in 40 CFR
§372-38.
"Note that amounts below the 660-gallon(single) and 1,320-gallon (combined)bulk-storage minimums re-quire.
secondary containment. However,some exceptions may be made for amounts less than the Reportable Quantities
of the hazardous substances listed in 40 CFR§117.3-
Page 4 of 7
SWU-NE-021309 Last revised 2I13/2o09
171-0/1,1,0d WagZ:10 60OZ S 100 :xi?j 11,1013d3 Mt-N0O

i
•NCGNEOOOO No Exposure Certifica#ion
16) Other,information:It you answer"Yes"to any of the following items..you might not be eligible for the
no exposure exclusion. A more in-depth evaluation of the site circumstances may be required.
a. Does your facility store used, recycled,or otherwise reclairned pallets outside? 0 Yes X No 0 NIA
b. Does your facility have coal piles on site? 0 Yes �No ❑ NIA
c. does your facility store oilier fuel sources outside in piles, such as wood chips, D Yes AK No ❑ NIA
sawdust,etc.?
d. Dori your facility have air emissions associated with its industrial activity(e-g., a Yes No ❑ NIA
degreasing operations,plating, painting and metal finishing)? If so,describe the
industrial activity:
e. If you answered yes to d., are those emissions permitted by an Air.Quality Permit? ©Yes ❑ No NIA
Piease specify:
f. Please list any other environmental program permits(federal, state, etc.) not
specified earlier in this application (Such as Hazardous Waste Permits,etc.);
Permit. Proaram:
Permit: Program:
Permit: Proaram:
Permit- Prograrti:
Permit: Program:
Permit: Program:
Permit: _ J Program:
Page 5of7
SWu-NE�-021302 Lest revised 2113(20010
VIOMUd 1Ud9l'l0 GOOl 9 130 'xed 11-I0118A AVA-NOD

NCGNEOOOO No Exposure Certification
17) Certification:
I certify under penalty of Jaw that I have read and understand the eligibility regl:irements for claiming a Condition:of`no
exposure"and obtaining an exclusion from NPIDES stormwater permitVng.
I certify under penalty of law that there are no discharges of stormvra:or contaminated by exposure to Industliai activities
or materials from the industrial facility or site identified in this document(except as allowed under 40 Cl'R 12226(g)(2)). .
I understand that t am obligated to submit a no exiaosurg Certification form once eve five 5)years to the North Carolina
Division of Water Quality and,if requested,to the operator of the local municipal separate storm sewer system(MS4)into
which the facility discharges(where applicable). l understand that I must allow the North Carolina Division of Water
Quality,or LPVIS4 operator where the discha-ge is into the local KIS4,to perform inspections io confirm the condition of no
exposure and to make such inspection reports publicly available upon request.
In the event that the site no longer qualifies for a No Exposure Exclusion, l understand that I must obtain coverage under
an NPDES permit prior to any point source discharge of stormwater from the facility-Additionally, I certify under,penalty of
law that this docurrtent and all attachments were prepared under my direction or supervision in accordance with a system
designed to assure that qualified personnel property gathered and evaluated the informationi submitted- Based on my
inquiry of the person or persons who manage the system,or those persons directly responsible for gathering the
information,the information submitted is to the best of my knowledge and belief rose,accurate and complete. I am aware
that there are significant penalties for submitting false information,including the pessibiliiy of fine and-imprisonment for
knowing violations.
I certify that I ani familiar with the information contained in this application and that to the best of my knowledge and belief
such information is true,complete,and accurate.
Printed Name of Perso Si nine: t'_ -e
pnic
F F--t `w n ixt vt r( ,,a ( ` ACl
ate ;geed)
Please Hate: This appfiratfarr for the No Exposure Exclusion is subject to approval by the
NCAENR Regional Office prior to issuance, The Regional Off" may inspect your facility for
compliance with no exposure conditions prior to that approval. The Regional Office may also
inspect your facil' at any time in the future for complldnce with the No Exposure Exclusion.
North Carolina General Statute 143-215.6 B(i) provides that:
Any person who%urowingiy makes arry false statement,representation,or certification in any appfic2tion,record,rep`r? Ftan,or oiher
document filed or required to be maintained under tis Article or a rile implementing this Article;or who knowingly makes a false
statement of a material fact in a rulernaking proceeding or contested case under this Article;or who falsifres,tampers with,or knowingly
renders inaccurate any recording or manhoring device or method required to be operated or mairiMired under this Article or rules of the
[En0ranmLmn1a1 Management)Commission implementing this Article shall be guilty of a Class 2 misdemeanor which may include a fine
not to exceed ten thausand dollars($10,000),
There is currently no fee for a No Exposure Exclusion.
Page 6of7
SWU-IYE-021309 Last revisad 211212069
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l of 1 10/28/2009 2:40 PM

NC®ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
September 30, 2009
Mr. Randy Welch, Service Center Manager
Con-Way Frieght
438 W. Bodenhamer Street
Kernersville, North Carolina 27284
Subject: NOTICE OF VIOLATION -- General Stormwater Permit Inspection
NPDES General Permit No. NCG080637 —Con-Way Freight
Forsyth County
On September 30, 2009, Jenny Graznak of this office performed a Stormwater Permit
Inspection at Con-Way Freight located at 438 W. Bodenhamer Street in Kernersville, North Carolina.
This facility holds General Stormwater Permit No. NCG80637 under the National Pollutant Discharge
Elimination System (NPDES) to discharge Stormwater associated with activities that have Vehicle
Maintenance Areas. You were present for the inspection. This type of inspection consists of two
basic parts: a review of facility files and self-monitoring data and an inspection of the facility's
discharge points. This particular inspection evaluated five (5) areas, and observations from each
area are addressed below:
1. Permit
The permit became effective November 1, 2007 and expires October 31, 2012.
2. Records/Reports
During the inspection, it was determined that your facility has developed a Stormwater Pollution
Prevention Plan (SPPP), which was updated in February 2009, as required by the permit. The
SPPP appeared to be thorough and complete, including a location map of the outfalls and a site plan
listing potential Stormwater pollutants and best management practices used at the site. Employee
Training of the SPPP occurs on an annual basis with the most recent event taking place an March
16, 2009.
3. Facility Site Review
The maintenance shop was closed in December 2008 at this location. All truck maintenance occurs
at the Charlotte location. A vendor visits the facility regularly to do light maintenance such as tire
changes and light bulb replacements. No new or used motor oils are stored on site. The facility
does have three underground storage tanks for diesel fuel.
Therefore, it was determined during the visual inspection of the property that a condition of No
Exposure exists at this facility. All chemicals and materials at the facility are covered by a storm
resistant shelter to prevent exposure to rain, snow, snowmelt, and runoff. Therefore, it is
recommended that you apply for a No Exposure Certification for Exclusion from NPDES Stormwater
Permitting. A No Exposure application is attached to this letter should you choose to proceed in that
direction. If you wish to proceed in this route, please complete and send the application to:
North Carolina Division of Water Quality,Winston-Uem Regional Office
Location:585 Waughtown St.Winston-Salem,North Carolina 27107 One
Phone:[phone] FAX:336-771 A6301 Customer Service:1-877-623-6748 NorthC arol i na
Internet:www,ncwaterquality.org )Vatumlly
An Equal Opportunity lAffirmative Action Employer

The Stormater Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
4. Effluent/Receiving Waters
The SPPP lists three outfalls at the site. However, Ms. Graznak determined during the inspection
that these were not outfalls but were actually storm water inlets. Although the storm water outfall for
the inlets was never discovered, it is most likely located in the stream across Bodenhamer Street.
You should make an effort to locate the storm water discharge outfall for your site. According to the
permit, stormwater from the property discharges to an unnamed tributary to the Abbots Creek in the
Cape Fear River Basin.
5. Self-Monitoring Program
It was determined during the inspection that you have not performed the analytical self-monitoring
requirements of the General Permit since 2007. The stormwater permit requires semi-annual
qualitative and analytical monitoring of stormwater discharge outfalls and effluent. Qualitative
monitoring was performed as required by the permit, with the last monitoring event occurring on
June 4, 2009. The last analytical monitoring event took place on June 11, 2007. All results were
within permit limits: pH 5.2, Total Suspended Solids 54 mgll, and Oil and Grease <5 mgll. You
explained that your consultant (Blymyer Engineering) assured you that Con-Way did not need to do
analytical monitoring, which was incorrect guidance. However, should you apply for and receive No
Exposure Certification; your facility would be exempt from these monitoring requirements.
Please be aware that the failure to comply with monitoring requirements is a violation of the
General Permit. Therefore, this inspection report is being sent as a Notice of Violation. According to
permit text Part Ili Section A (2), "the permittee must comply with all conditions of this permit. Any
permit noncompliance constitutes a violation of the Clean Water Act and is grounds for enforcement
action; for permit termination, revocation and reissuance, or modification; or denial of a permit upon
renewal application." Under state law, a daily civil penalty of not more than twenty-five thousand
dollars ($25,000) per violation may be assessed against any person who violates or fails to act in
accordance with the terms, conditions, or requirements of a permit. [Ref: NC General Statutes 143-
215.6A]
You-are required to either apply for a No Exposure Certification for Exclusion from
NPOES Stormwater Permitting or comply with the permit requirements as stated above.
Please respond to this office in fifteen (15) days alerting our office to your decision.
You may refer to the attached report for further details from the inspection. If you have any
questions concerning this report, please contact Mrs. Graznak or me at [phone].
Sincerely,
Steve W. Tedder
Regional Supervisor,
Surface Water Protection Section
cc: NPS Assistance & Compliance Oversight Unit
SWP—Central Files
SW 17---WSRO

Compliance Inspection Report
Permit: NCGO80637 Effective: 11/01/07 Expiration: 10/31/12 Owner: Con-Way Freight
SOC: Effective: Expiration: Facility: Con-Way Freight-Nwn
County: Forsyth 438 Bodenhamer St
Region: Winston-Salem
Kernersville NC 27284
Contact Person: Jeff Sexten Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 09129/2009 Entry Time: 09:00 AM Exit Time: 1C:30 AM
Primary Inspector: Jennifer F Graznak Phone: [phone]
Secondary inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Transportation w/Vehicte Maintenance/Petroleum Bulk/Oil
Water Separator Stormwater Discharge COC
Facility Status: ❑ Compliant ■ Not Compliant
Question Areas:
®Storm Water
(See attachment summary)
Page: 1

Permit: NCGC60637 Owner-Facility: Con-Way Freight
Inspection Date: 09/29/2009 inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
1. Permit
The permit became effective November 1, 2007 and expires October 31, 2012.
2. Records/Reports
During the inspection, it was determined that your facility has developed a Stormwater Pollution Prevention Plan (SPPP),
which was updated in February 2009, as required by the permit. The SPPP appeared to be thorough and complete,
including a location map of the outfalls and a site plan listing potential stormwater pollutants and best management
practices used at the site. Employee Training of the SPPP occurs on an annual basis with the most recent event taking
place on March 16, 2009.
3. Facility Site Review
The maintenance shop was closed in December 2008 at this location. All truck maintenance occurs at the Charlotte
location. A vendor visits the facility regularly to do light maintenance such as tire changes and light bulb replacements.
No new or used motor oils are stored on site. The facility does have three underground storage tanks for diesel fuel.
Therefore, it was determined during the visual inspection of the property that a condition of No Exposure exists at this
facility. All chemicals and materials at the facility are covered by a storm resistant shelter to prevent exposure to rain,
snow, snowmen, and runoff. Therefore, it is recommended that you apply for a No Exposure Certification for Exclusion
from NPDES Stormwater Permitting. A No Exposure application is attached to this letter should you choose to proceed in
that direction. If you wish to proceed in this route, please complete and send the application to:
The Stormater Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
4. Effluent/Receiving Waters
The SPPP lists three outfalls at the site. However, Ms. Graznak determined during the inspection that these were not
outfalls but were actually storm water inlets Although the storm water outfall for the inlets was never discovered, it is
most likely located in the stream across Bodenhamer Street. You should make an effort to locate the storm water
discharge outfall for your site. According to the permit, stormwater from the property discharges to an unnamed tributary
to the Abbots Creek in the Cape Fear River Basin,
5. Self-Monitoring Program
It was determined during the inspection that you have not performed the analytical self-monitoring requirements of the
General Permit since 2007. The stormwater permit requires semi-annual qualitative and analytical monitoring of
stormwater discharge outfalls and effluent. Qualitative monitoring was performed as required by the permit, with the last
monitoring event occurring on June 4, 2009. The last analytical monitoring event took place on June 11, 2007, All results
were within permit limits: phi 5.2, Total Suspended Solids 54 mgll, and Oil and Grease <5 mg1l. You explained that your
consultant (Biymyer Engineering) assured you that Con-Way did not need to do analytical monitoring, which was incorrect
guidance. However, should you apply for and receive No Exposure Certification; your facility would be exempt from these
monitoring requirements.
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Permit: NCGO80637 Owner-Facility: Con lvVay Freight
Inspection Date: 09/29/2009 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? rl fl
#Does the Plan include a General Location(USGS) map? ® n n n
#Does the Plan include a"Narrative Description of Practices"? 0 n n f l
#Does the Plan include a detailed site map including outfall locations and drainage areas? ® n n n
#Does the Plan include a list of significant spills occurring during the past 3 years? ® n n n
#Has the facility evaluated feasible alternatives to current practices? 6 n n fl
#Does the facility provide all necessary secondary containment? ® n ❑ f l
#Does the Plans include a BMP summary? ® n rl n
#Does the Plan include a Spill Prevention and Response Plan (SPRP)? ® ❑ ❑ n
#Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ® n ❑ 0
#Does the facility provide and document Employee Training? ® n n n
#Does the Plan include a list of Responsible Party(s)? ® n n n
#Is the Plan reviewed and updated annually? ® n n n
#Does the Plan include a Stormwater Facility Inspection Program? ® 0 Cl 0
Has the Stormwater Pollution Prevention Plan been impiemented? ® n n n
Comment:
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ® n n
Comment:
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? ❑ E 0 n
#Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ D ® n
Comment: The last analytical monitoring event took place on June 11, 2007. You
stated that 8lymyer Engineering told you that Con-Way did not need to do analytical
monitoring, which was incorrect guidance.
Permit and Qutfalls Yes No 'NA NE
#Is a copy of the Permit and the Certificate of Coverage available at the site? ® ❑ n n
#Were all outfalls observed during the inspection? ❑ ® n n
# If the facility has representative outfall status, is it properly documented by the Division? n n ® n
#Has the facility evaluated all illicit(non stormwater)discharges? n IN n n
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Permit: NCG080637 Owner-Facility: Can-V1ay Freight
Inspection Date: 09/29/2009 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Comment: The SPPP lists three outfalls at the site. However, Ms. Graznak
determined during the inspection that these were not outfalls but were actually storm
water inlets. Although the storm water outfall for the inlets was never discovered, it is
most likely located in the stream across Sodenhamer Street. You should make an effort
to locate the storm water discharge outfall for your site.
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