NCG080760_Compliance Inspection_20190425

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
InterimDirector
ABF Freight System Incorporated
Attn: Chris Brown
PO Box 10048
Fort Smith, AR 72917
Subject: Compliance Inspection
Permit No. NCG 080760
NORTH CAROLINA
Environmental Quality
April 25, 2019
ABF Freight Systems, Inc. — Kernersville
Forsyth County
Dear Permit Holder:
On April 25, 2019, Brandon Wise and Tyler Pearson inspectors with the North Carolina
Department of Environmental Quality (NCDEQ) — Division of Energy, Minerals, and Land
Resources met with site contacts at the facility located at 1165 NC Highway 66 South in Forsyth
County, to conduct a compliance inspection per the authority of NCDEQ. The inspection
consisted of review of the Stormwater Pollution Prevention Plan (SWPPP) and each of its
components, review of the facility outfalls, as well as the review of the overall site conditions.
The compliance inspection was conducted to ensure all site practices and facilities are in working
order. The inspection was also conducted as part of NCDEQ's mission to inspect all permitted
facilities during each permit period.
Permit:
This facility has General Stormwater Permit NCGO80760 to discharge stormwater from
the industrial activity of Vehicle Maintenance Areas associated with activities classified as
Motor Freight Transportation and Warehousing [SIC 421 under the National Pollutant
Discharge Elimination System (NPDES). The permit was originally issued on May 201h, 2005
and the current version of the permit was issued on November 1st, 2018 and expires on May 315t
2021.
Records/Reports:
This facility is required to develop and maintain a SWPPP in accordance with Part II,
Section A of the permit. All qualitative and analytical monitoring records are required to be
maintained with the SWPPP for a minimum of five (5) years. Under this permit, analytical
monitoring is required under current operating procedures. The facility records included records
dating back 5 years meeting conditions of the permit. The facility is required to review and
update the SWPPP on an annual basis in accordance with Part II, Section A, Item 8 of the permit.
The original SWPPP was written in 2014 and there were records that it had been updated in
2017, however no records were shown after 2017 of any review or updates. Overall the SWPPP
was well put together and record keeping was very organized and ready for NCDEQ to review.
North Carolina Department of Environmental Quality I Division of Energy. Mineral and Land Resources
Winston-Salem Regional Office 1 450 Hanes Mill Road. Suite 3001 Winston-Salem, North Carolina 27103
336.776,9800

Facility Site Review:
This facility operates as a fleet maintenance and distribution center, owned and operated
by ABF Freight Systems, Inc. The main maintenance facility is located north of the distribution
area. Surrounding these two buildings are large parking lots for employee vehicles, trailers ready
for transport, and semis preparing for travel. The main area where maintenance is done is
located in the center of the maintenance building and is very well maintained with minimal
visible spills on the ground inside of the building and very little potential pollutants outside of
the building. Drums and used oil containers are all stored with secondary containment in case of
spills. A diesel exhaust fluid (DEF) filling area was located at the edge of the covered
maintenance area. A spill kit was located nearby however NCDEQ recommends placing of a
berm or other measure in between the DEF storage and storm drain. This measure will increase
the amount of response time prior to pollutants reaching the stormwater system. The distribution
center is primarily covered, with only the trailers and one covered dumpster exposed to
stormwater. A single roll -off was located east of the maintenance building, this was uncovered
and in use during the inspection, however a tarp to cover the roll -off was located nearby. A
single totaled semi was located at the facility near the northern edge of the facility. NCDEQ was
informed this is a rare occurrence and that it would be removed in the future, this should be done
quickly as this presents the opportunity for fluids to leak and reach the stormwater system. A
fueling area was located on the south edge of the facility. All tanks in this area had secondary
containment which was observed and inspected by NCDEQ personnel during the inspection.
Storage containers were located directly next to the fueling area with spill kits for quick response
to any spills. Some dirt and road debris was observed around the fueling area. Overall site
conditions around the buildings at the facility were good, trash and debris was minimal. Overall
site conditions around the parking lots were very poor. Trash could be seen building up around
the fence line and could be seen in the parking area for the semis. Dirt and road debris was
present all around the parking lot but a large build up was observed in the northeast and
southeast corners of the facility. The southeastern corner of the facility appeared to be poorly
maintained as a large amount of dirt and road debris had built up around the sampled outfall in
this area. These housekeeping issues should be addressed and can be grounds for non-
compliance during fixture inspections.
There are two sampled outfalls located at the facility. One outfall is located at the
southeastern corner of the facility and catches the stormwater from the fueling area along with a
large parking lot. The current second outfall is located at the northeastern corner of the facility,
however this outfall catches only stormwater from a parking lot and does not contain any
industrial activity. This outfall should remain on the qualitative (visual) monitoring schedule to
ensure no potential pollutants are being discharged from this outfall. A new sampled outfall will
be added and the sample will be collected from the outfall pipe located in the woods east of the
main facility. This outfall collects all stormwater from the drains that run adjacent to the
maintenance facility. In order for this outfall to be sampled, a small walking path to the outfall
should be created and maintained. NCDEQ also recommends that all outfalls are labeled by
either spray paint or signage on site.
�DEQJ�% North Carolina Department of Environmental Quality I Division of Energy. Mineral and Land Resources
Winston-Salem Regional Office 1 450 Hanes Mill Road, Suite 3001 Winston-Salem, North Carolina 27103
336.776.9800

Effluent Receiving Waters:
Effluent from this facility drains into West Fork Deep River, class "WS-IV" waters of the
Cape Fear River Basin. These waters are also designated as a Critical Supply Watershed as
specified in 15A NCAC 2B .0248.
Self -Monitoring Program:
This facility is required to provide Qualitative and Analytical Monitoring twice annually.
The outfall located in the northeastern corner of the facility should continue to be monitored
twice annually but will not require analytical monitoring. The outfall in the woods being added
and the outfall in the southeastern corner of the facility should be monitored twice annually both
qualitatively and analytically. Regular site inspections and monitoring were being performed
and should continue. During the record review a response to the Tier 1 sampling of TSS was
observed and should any results continue into the Tier system, responses should continue to be
documented and filed with all records.
The facility is considered to be in compliance, however as stated in this report there are a
few housekeeping details that should be addressed in order to remain in compliance. If you have
any questions or need additional information, please contact Brandon Wise at [phone] or
[e-mail].
Sincerely,
B ndon Wise
Stormwater Specialist
Land Quality Section
Winston-Salem Regional Office
Enclosures: Inspection Report
cc: NCDEQ — DEMLR (WSRO) w/o enclosure
Corey Athens — Branch Manager — 1165 Highway 66 South, Kemersville, NC 27284
North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
Winston-Salem Regional Office 1450 Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27103
330.776.9800