NCS000534_Compliance Evaluation Inspectioin_20240531

ROY COOPER "
Governor
ELIZABETH S.BISER Y 1Nna
Secretary %
nm .r
WILLIAM E.TOBY VINSON,JR NORTH CAROLINA
Interim Director Environmental Quality
May 31, 2024
Clear Path Recycling, LLC
Attn: Matthew Hendrickson, Site Director
3500 Cedar Creek Road
Fayetteville, NC 28312
Subject: COMPLIANCE EVALUATION INSPECTION
NPDES Stormwater Permit NCS000534
Clear Path Recycling, LLC
Cumberland County
Dear Mr. Hendrickson:
On May 3, 2024, Melissa Joyner with the Fayetteville Regional Office of the Division of Energy, Mineral
and Land Resources (DEMLR)conducted a site inspection for the Clear Path Recycling, LLC facility
located at 3500 Cedar Creek Road in Cumberland County, North Carolina. A copy of the Compliance
Inspection Report is enclosed for your review. Mr. Robert O'Hern, Environmental Safety Officer, Ms.
Elizabeth Wike, Senior Environmental Engineer and Tony Freeman, Services Supervisor were also
present during the inspection and their time and assistance is greatly appreciated. The site visit and file
review revealed that the subject facility is covered by NPDES Stormwater Permit NCS000534. Permit
coverage authorizes the discharge of stormwater from the facility to receiving waters designated as the
Cape Fear River, a Class C waterbody in the Cape Fear River Basin.
As a result of the inspection, the facility was found to be in compliance with the conditions of NPDES
Stormwater Permit NCS000534. Please refer to the enclosed Compliance Inspection Report for additional
comments and observations made during the inspection.
Please be advised that violations of the NPDES Stormwater Permit are subject to a civil penalty
assessment of up to$25,000 per day for each violation. If you or your staff have any questions,
comments, or needs assistance with understanding any aspect of your permit, please contact me at(910)
433-3384 or by e-mail at [e-mail]
Sincerely,
Melissa Joyner
Environmental Senior Specialist
DEMLR
Enclosure: Compliance Evaluation Inspection Report
ec: Robert O'Hern, Environmental Safety Officer, Clear Path Recycling, LLC
Elizabeth Wike, Senior Environmental Engineer-Clear Path Recycling, LLC
Tony Freeman, Services Supervisor-Clear Path Recycling, LLC
cc: FRO-DEMLR, Stormwater Files
North Carolina Department of Environmental Quality I Division of Energy,Mineral and Land Resources
DEFayetteville Regional Office 1225 Green Street,Suite 7144 I Fayetteville.North Carolina 28301
ile0.6rtentormwrw, rw.my� /" 910.433,3300

S
,�

Compliance Inspection Report
Permit:NCS000534 Effective: 08/01/19 Expiration: 07/31/24 Owner: Clear Path Recycling
SOC: Effective: Expiration: Facility: Clear Path Recycling
County: Cumberland 3500 Cedar Creek Rd
Region: Fayetteville
Fayetteville NC 28312
Contact Person:Miguel Burgoa Title: Phone:[phone]
Directions to Facility:
System Classifications: SWNC,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 05/03/2024 Entry Time 09:00AM Exit Time: 11:37AM
Primary Inspector:Melissa A Joyner lya, ;; ‘t< 4v Phone:
Secondary Inspector(s):
Reason for Inspection: Other Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: Compliant ❑ Not Compliant
Question Areas:
El Storm Water
(See attachment summary)
Page 1 of 3

Permit: NCS000534 Owner-Facility:Clear Path Recycling
Inspection Date: 05/03/2024 Inspection Type:Compliance Evaluation Reason for Visit: Other
Inspection Summary:
Melissa Joyner met with Mr. Bobby O'Hern, Environmental Safety Officer, Ms. Elisabeth Wikes, Senior Environmental
Engineer and Mr.Tony Freeman, Services Supervisor to conduct an inspection of the Clear Path Recycling,
LLC/NCS000534 facility which is in the process of having its Individual Permit renewed. The Stormwater Pollution Prevention
Plan (SWPPP)was reviewed. The site map needed to be updated with the contours, showing the locations of additional
buildings and showing the locations of the applicable outfalls more clearly.Additional facility inspections and employee
training records also needed to be included in the SWPPP. This information was received via email after this inspection was
conducted. Records had not been retained of the annual review/update of the SWPPP except for the current year. Retention
should occur for five years of this documentation.A spill had been documented in 2022. If there have been no spills during
the previous three years this information should also be documented in the SWPPP.The Analytical and Qualitative
Monitoring records were reviewed. There were four documented exceedances of the benchmark parameters,one for TSS at
Outfall A and three for COD at Outfalls B and 61 documented in 2020, 2021 and 2022.Tier One responses occurred and the
following monitoring results were below the benchmark values. The facility grounds, Best Management Practices and
Outfalls A, B1, B2, C, D and E were inspected.The Inspector was informed that roof drains are only discharging to Outfall E.
If there is no particulates being emitted from air vents or mechanical equipment located on the roof and only non-stormwater
is being discharged to Outfall E it will no longer need to be monitored. Please contact Ms.Brianna Young at
[e-mail] about the removal of Outfall E from the monitoring cycle. It is recommended that there be
additional management of the plastic debris which was noted near the railroad tracks, near Outfalls C and D.
Page 2 of 3

Permit: NCS000534 Owner-Facility:Clear Path Recycling
Inspection Date: 05/03/2024 Inspection Type:Compliance Evaluation Reason for Visit: Other
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)? • ❑ CI CI
#Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? [A ❑
#Does the facility provide and document Employee Training? • ❑ CI ❑
#Does the Plan include a list of Responsible Party(s)? • ❑ CI ❑
# Is the Plan reviewed and updated annually?
#Does the Plan include a Stormwater Facility Inspection Program?
Has the Stormwater Pollution Prevention Plan been implemented?
Comment:
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring?
Comment:
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? ❑
#Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
Comment:
Permit and Outfalls Yes No NA NE
#is a copy of the Permit and the Certificate of Coverage available at the site? • ❑ � ❑
#Were all outfalls observed during the inspection? • l ❑ CI
#If the facility has representative outfall status, is it properly documented by the Division? CI CI � []
#Has the facility evaluated all illicit(non stormwater)discharges? • ❑ El CI
Comment:
Page 3 of 3