NCS000534_Inspection Report_20190513

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Interim Director
Clear Path Recycling, LLC
Attn: Kent Robinson, Plant Manager
3500 Cedar Creek Road
Fayetteville, NC 28312
NORTH CAROLINA
Environmental Quality
May 16, 2019
Subject: COMPLIANCE EVALUATION INSPECTION
NPDES Stormwater Permit NCS000534
Clear Path Recycling, LLC
Cumberland County
Dear Mr. Robinson:
On May 13, 2019, I, Michael Lawyer, Environmental Program Consultant with the Fayetteville Regional Office of the
Division of Energy, Mineral and Land Resources (DEMLR) along with Lauren Garcia, Environmental Specialist with
DEMLR's Stormwater Program 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. Ms. Elizabeth Wike, Senior Environmental Engineer, Mr. Rick Perez, SHE Supervisor, Ms. Sharon Frost and
Mr. Miguel Burgoa 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 [phone] or by e-mail at [e-mail].
Sincerely,
Michael Lawyer, CPSWQ
Environmental Program Consultant
DEMLR
Enclosure
ec: Elizabeth Wilke, Senior Environmental Engineer— DAK Americas, LLC
cc: FRO — DEMLR, Stormwater Files
D E�4A North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
Fayetteville Regional Office 1 225 Green Street, Suite 7141 Fayetteville, North Carolina 28301
NCP.TH CAROl11Jn _�
Deport torEnvironmental910.433.3300

Compliance Inspection Report
Permit: NCS000534 Effective: 05/01/10 Expiration: 04/30/15 Owner: Clear Path Recycling
SOC: Effective: Expiration: Facility: Clear Path Recycling
County: Cumberland 3500 Cedar Creek Rd
Region: Fayetteville
Fayetteville NC 28312
Contact Person: Elizabeth Wike Title: Senior Env. Engineer Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
On -site representative
Elizabeth Wike
910-512-4883
On -site representative
Sharon Smith Frost
910-433-8232
On -site representative
Miguel Burgoa
910-433-8210
On -site representative
Rick Perez
910-433-8227
Related Permits:
Inspection Date: 05/13/2019 Entry Time: f�1:00PM
Primary Inspector: Mike Lawyer/�YP,� ;�
Secondary Inspector(s): Y�
Lauren Garcia
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: Compliant Not Compliant
Question Areas:
Storm water
(See attachment summary)
Exit Time: 04:50PM
Phone: [phone] ExV_W
3 L
Inspection Type: Compliance Evaluation
Page 1 of 3

Permit: NCS000534 Owner - Facility: Clear Path Recycling
Inspection Date: 05/13/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Inspection conducted concurrently with the DAK Americas Cedar Creek Site facility, which is co -located on the property.
Both facilities are in the process of permit renewal. Made observations of stormwater discharge outfalls and overall site
conditions. At the time of inspection, excessive debris/fugitive material was observed on facility grounds as well as beyond
the fence line in several locations. The site -specific Stormwater Pollution Prevention Plan was provided for review and is
scheduled to be revised/updated as needed upon permit renewal. Recommendations were made by the inspector to
re-evaluate the effectiveness of the facility's good housekeeping program in order to better address and manage the amount
of fugitive material onsite. Monitoring has been conducted and recorded per requirements. Stormwater outfalls associated
with the Clear Path Recycling facility have been identified as A, B1, B2, B3, C, D, and E. Based on the 2018 Annual
Summary DMR, outfalls B1 and B2 are currently in Tier Two monthly monitoring. During the site observations it was evident
that outfall B3 has a very limited drainage area with no industrial activity and can therefore be removed from the monitoring
schedule. In regards to further monitoring of the remaining outfalls, the option and process for requesting Representative
Outfall Status (ROS) was discussed and a copy of the ROS Request Form was provided at the time of inspection.
Page 2 of 3

Permit: NCS000534 Owner - Facility: Clear Path Recycling
Inspection Date: 05/13/2019 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?
M ❑ ❑ ❑
# Does the Plan include a General Location (USGS) map?
0 ❑ ❑ ❑
# 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)?
0 ❑ ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
❑ ❑ ❑
# Does the facility provide and document Employee Training?
❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
0 ❑ ❑ ❑
# Is the Plan reviewed and updated annually?
M ❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
0❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
❑ ❑ ❑
Comment
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? 0 ❑ ❑ ❑
Comment:
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? ❑ ❑ ❑
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? ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ❑
# Has the facility evaluated all illicit (non stormwater) discharges? 0 ❑ ❑ ❑
Comment:
Page 3 of 3