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HomeMy WebLinkAboutNCG150054_Compliance Evaluation Inspection_20240930 o STA q a. .;� 1\ ROY COOPER 0 -r,fry 2 Governor 1 , c MARY PENNY KELLEY ...:a„ri �7 Secretary ',zti a- rf' WILLIAM E.TOBY VINSON,JR NORTH CAROLINA Interim Director Environmental Quality 9/30/2024 Town of Elizabethtown Attn: Dane Rideout, Acting Town Manager P. O. Box 700 Elizabethtown, NC 28337 Subject: COMPLIANCE EVALUATION INSPECTION — Non-Compliance Status NPDES Stormwater General Permit NCG150000 Town of Elizabethtown Elizabethtown Airport, Certificate of Coverage NCG150054 Blades County Dear Mr. Rideout: On September 20, 2024, a site inspection was conducted for the Elizabethtown Airport facility located at 466 Airport Road, Elizabethtown, Bladen County, North Carolina. A copy of the Compliance Inspection Report is enclosed for your review. Ken Hadaway, Airport Director, Stephen Duffy, Public Services Director, and John Duffy, GIS/GPS Technician were 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 General Permit NCG150000 under Certificate of Coverage NCG150054. Permit coverage authorizes the discharge of stormwater from the facility to receiving waters designated as Browns Creek (Cross Pond) and Plum Branch, class C waters in the Cape Fear River Basin. As a result of the inspection, the facility was found to not be compliant with the conditions of the NCG150000 permit. 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 General 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 via e-mail at melissa.joyner@deq.nc.gov. Sincerely, 9h,lil v 0j vl, Melissa Joyner Environmental Senior Specialist DEMLR Enclosure: Compliance Inspection Report ec: Ken Hadaway, Airport Director —Town of Elizabethtown Stephen Duffy, Public Services Director—Town of Elizabethtown John Duffy, GIS/GPS Technician —Town of Elizabethtown DEMLR NPDES Stormwater Permit Laserfiche File cc: FRO — DEMLR, Stormwater Files D E -' - North Carolina Department of Environmental Quality I Division of Energy,Mineral and Land Resources ``7/J/� Fayetteville Regional Office 1225 Green Street,Suite 7f4 I Fayetteville,North Carolina 28301 noanIC.ROU A ceoe.t.�.H E„ws,.,n,l 0.1; 910.433.3300 Compliance Inspection Report Permit:NCG150054 Effective: 07/01/22 Expiration: 06/30/27 Owner: Town of Elizabethtown SOC: Effective: Expiration: Facility: Elizabethtown Airport County: Bladen 466 Airport Rd Region: Fayetteville Elizabethtown NC 28337 Contact Person:Mitch Taylor Title: Airport Director Phone:910-862-4522 Directions to Facility: System Classifications: SWNC, Primary ORC: Certification: Phone: Secondary ORC(s): On-Site Representative(s): On-site representative Ken Hadaway 910-862-4522 On-site representative John Duffy 910-862-2035 On-site representative Stephen Duffy 910-862-2035 Related Permits: Inspection Date: 09/20/2024 Entry Time}0011::1,6PM Exit Time: 03:20PM "'�Primary Inspector:Melissa A Joyner 1 " a''/" s 1" Phone: Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Air Transportation Stormwater Discharge COC Facility Status: 0 Compliant 1. Not Compliant Question Areas: El Storm Water (See attachment summary) Page 1 of 3 Permit: NCG150054 Owner-Facility:Town of Elizabethtown inspection Date: 09/20/2024 inspection Type:Compliance Evaluation Reason for Visit: Routine Inspection Summary: Melissa Joyner met with Ken Hadaway, Airport Director, Steve Duffy, Public Services Director and John Duffy, GIS/GPS Technician to conduct an industrial stormwater inspection at the Elizabethtown Airport. The Stormwater Pollution Prevention Plan (SWPPP)was reviewed. There has been a recent change of personnel.A Delegated Signature Authority(DOSA) and Permit Contact Update Request Form will need to be submitted reflective of these changes.After this occurs registration should occur for the submittal of Analytical Discharge Monitoring reports electronically(e-DMR). The following observations were made of the SWPPP.: There should be a documented, signed and dated annual review of the SWPPP.The updated Tenant list should also include updated narrative information about the Tenants. The Site Map should show the locations of the ditches and the direction of the movement of the stormwater in these ditches. During the required quarterly facility inspections observations of the ditches and outfalls should occur. As part of the Spill Prevention and Response Procedures(SPRP)there should be names with dated signatures of all those involved with these responsibilities,including the Tenants. Please include all required information for the SPRP as stipulated in General Stormwater Permit NCG150000 (Page 5 of 33).As part of the SPRP it is required to annually document whether there have been significant spills or that none have occurred over the past three years. There should also be annual documentation that the 5 Outfalls have been inspected for the presence of non-stormwater. The required annual training of employees (including the Tenants) has not occurred. The facility(including the current Tenants)does not have a Solvent Management Plan.A Certification statement about this must be developed and included in the SWPPP-annually signed/dated. This information must be updated if one of the future Tenants does have solvents. No Qualitative and Analytical Monitoring records were available for review. Information was relayed about Qualitative and Analytical Monitoring. Water sampling should occur within the first 30 minutes of the first measurable storm event which occurs when there is enough rain to cause the outfalls to discharge. Conductivity and pH need to be tested within 15 minutes of collection with calibrated testing meters. The parameter Non-Polar Oil&Grease needs to be tested regardless of whether the facility(including the Tenants) is using more than 55 gallons of new motor and/or hydraulic oil per month when averaged over the calendar year. The facility grounds were inspected, including the stormwater control measures,outfalls and Aboveground Storage Tanks. Washing of vehicles is conducted outside and occurs on a concrete pad with water sheet flowing to a nearby grassy area. Vehicle maintenance occurs indoors. The facility grounds appeared orderly. The facility is not in compliance due to not implementing the SWPPP and doing the Qualitative and Analytical Monitoring per the conditions of General Stormwater Permit NCG150000. The facility will be inspected within 6 months of receiving this Compliance Report. Page 2 of 3 Permit: NCG150054 Owner-Facility:Town of Elizabethtown Inspection Date: 09/20/2024 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? • ❑ El ❑ #Does the Plan include a General Location(USGS)map? • 0 ❑ El #Does the Plan include a"Narrative Description of Practices"? • 0 0 ❑ #Does the Plan include a detailed site map including outfall locations and drainage areas? • ❑ ❑ 0 #Does the Plan include a list of significant spills occurring during the past 3 years? ❑ • 0 0 #Has the facility evaluated feasible alternatives to current practices? • 0 0 0 #Does the facility provide all necessary secondary containment? • ❑ ❑ 0 #Does the Plan include a BMP summary? ■ 0 ❑ 0 #Does the Plan include a Spill Prevention and Response Plan(SPRP)? • El ❑ ❑ #Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? • ❑ ❑ El #Does the facility provide and document Employee Training? ❑ • ❑ El #Does the Plan include a list of Responsible Party(s)? 0 • El ❑ #Is the Plan reviewed and updated annually? 0 • ❑ 0 #Does the Plan include a Stormwater Facility Inspection Program? • ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? ❑ IIII ❑ ❑ Comment: The Stormwater Pollution Prevention Plan has not been implemented per General Stormwater Permit NCG150000 conditions. Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring? ❑ • 0 ❑ Comment: Qualitative Monitoring has not been conducted per General Stormwater NCG150000 conditions. 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 MI ❑ Comment: Analytical Monitoring has not been conducted per General Stormwater NCG150000 conditions. Permit and Outfalls Yes No NA NE #Is a copy of the Permit and the Certificate of Coverage available at the site? • ❑ 0 0 #Were all outfalls observed during the inspection? • ❑ ❑ ❑ #If the facility has representative outfall status, is it properly documented by the Division? ❑ 0 i El #Has the facility evaluated all illicit(non stormwater)discharges? 01100 Comment: Page 3 of 3