Loading...
HomeMy WebLinkAboutNCG080261_NOV_20190731ROY COOPER Governor MICHAEL S. REGAN Secretary S. DANIEL SMITH Director CERTIFIED MAIL: 7015 0640 0007 8168 5529 RETURN RECEIPT REQUESTED NORTH CAROLINA Enviranmental Quality July 31, 2019 Taylor Express, Inc. Attn: William Champine, President P.O. Box 1806 Hope Mills, NC 28348 Subject: NOTICE OF VIOLATION (NOV-2019-PC-0548) NPDES Stormwater General Permit NCGO80000 Taylor Express, Inc., Certificate of Coverage NCG080261 Cumberland County Dear Mr. Champine: On July 25, 2019, Melissa Joyner from the Fayetteville Regional Office of the Division of Energy, Mineral and Land Resources (DEMLR), conducted a site inspection for the Taylor Express, Inc. facility located at 5417 US 301 S.. Cumberland County, North Carolina. A copy of the Compliance Inspection Report is enclosed for your review. Ray Culler, General Manager and Lisa Kuykendall, Facility Manager 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 NODES Stormwater General Permit NCG080261 under Certificate of Coverage NCG080000. Permit coverage authorizes the discharge of stormwater from the facility to receiving waters designated as an Unnamed Tributary to Rockfish Creek, a Class C waterbody in the Cape Fear River Basin. As a result of the site inspection, the following permit conditions violations are noted 1) Stormwater Pollution Prevention Plan (SPPP) A Stormwater Pollution Prevention Plan (SPPP) has not been properly implemented. 2) Qualitative Monitoring Qualitative monitoring has not been conducted and recorded in accordance with permit requirements. 3) Analytical Monitoring Analytical monitoring has not been conducted and recorded in accordance with permit requirements. Other Observations: Please refer to the enclosed Compliance Inspection Report for additional comments and observations made during the inspection. Requested Response: You are asked to respond to this office, in writing, within 30 calendar days from receipt of this notice. Your written response should include a reasonable explanation as to why the aforementioned violations have occurred as well as a Plan of Action to prevent these violations from recurring. voa:r: r, onaimiaD � Q�� v.v.�n..M iuwamm�uu�u� North Carolina Department of Environmental Quality Division of Energy, Mineral and Land Resources Fayetteville Regional Office 1 225 Green Street. Suite T141 Fayetteville, North Carolina 28301 910.433.330 Thank you for your attention to this matter. This Office is considering sending a recommendation for enforcement to the Director of the Division of Energy, Mineral & Land Resources regarding these issues. Your above -mentioned response to this correspondence will be considered in this process. This office requires that the violations, as detailed above, be properly resolved. These violations and any future violations are subject to a civil penalty assessment of up to $25,000 per day for each violation. Should you have any questions regarding these matters, please contact Melissa Joyner or myself at (910) 433-3300. Sincerely, Timothy L. LaBc%aAy, PE Regional Engineer DEMLR TLL/maj Enclosure: Compliance Evaluation Inspection ec: Ray Culler, General Manager (via email) Lisa Kuykendall, Facility Manager (via email) William E. (Toby) Vinson, Jr., Section Chief— DEMLR (via email) Annette Lucas, PE, Program Manager— DEMLR, Stormwater Program (via email) Alaina Morman, Environmental Specialist — DEMLR, Stormwater Program (via email) cc: FRO — DEMLR, Stormwater Files Compliance Inspection Report Permit: NCG080261 Effective: 11/01/18 Expiration: 05/31/21 Owner: Celadon Trucking SOC: Effective: Expiration: Facility: Taylor Express Incorporated 5417 US 301 S County: Cumberland Region: Fayetteville Hope Mills NO 28348 Contact Person: Lisa Kuykendall Title: Phone: 910-423-2114 Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 07/25/2019 Primary Inspector: Melissa A Joyner Secondary Inspector(s): Certification: Phone: Entry Time: 09:50AM Exit Time: 11:20AM Phone: Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Transportation wNehicle Maintenance/Petroleum Bulk/Oil Water Separator Stormwater Discharge COO Facility Status: ❑ Compliant Not Compliant Question Areas: Storm Water (See attachment summary) Page 1 of 3 Permit: NCG080261 Owner- Facility: Celadon Trucking Inspection Date: 07/25/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine Inspection Summary: An inspection of the Taylor Express, Inc. facility was conducted with Lisa Kuykendall, Facility Manager. The Stormwater Pollution Prevention Plan (SPPP) was reviewed. Robert Taylor, the facility's former President, has been replaced by William Champine. This information will need to be updated in the SPPP and an Owner Designation/Affiliation form submitted electronically, using this link: https://deq.nc.gov/aboutidivisions/energy-mineral-land-resources/npdes-industrial-stormwater. The following items in the SPPP have not been implemented: Documentation of the annual review and update of the SPPP, an updated list of significant spills or leaks or the notation that no spills have occurred, recertification that the stormwater Outfall 1 has been evaluated for non-stormwater discharges, conducting/documenting facility inspections semi-annually, documented re-evaluation of the effectiveness of the Best Management Practices, implementing/conducting employee training and providing an updated table or summary of all Aboveground Storage Tanks (AST's) and their associated secondary containment structures. The Analytical and Qualitative Monitoring records were reviewed. Monitoring was documented once in November, 2017 and once in January, 2019. Earlier records were not available. The amount of new motor oil usage or hydraulic oil usage (gal./month) was not being estimated. In January, 2019, the Non -Polar Oil & Grease benchmark value was exceeded. This was a violation of General Permit NCGO80000 conditions. Tier One responses, according to the conditions in General Permit NCGO80000 were not enacted. If there is another exceedance during the next monitoring period, the facility will be in Tier Two and will need to initiate monthly monitoring for all parameters until there are three consecutive sample results below the benchmark value or within benchmark range. Sampling results must be submitted to the Regional Office within 30 days from the date that facility receives the sampling results. The annual Summary Data Monitoring Report form has not been completed and submitted. The facility grounds were inspected. Secondary containment was not previously but is now installed around the oil tanks and the air compressor. There was fresh oil on the ground from a pump next to the containment structure. Also, there was staining under another pump near the exterior of the roof, not within this structure. Pollution prevention measures need to be provided for this area or it should be relocated within the existing structure. This area was located upslope of the concrete swale leading to Outfall 1. The concrete swale had sediment in it and needed maintenance. Containers containing used anti -freeze which were to be removed from the facility grounds did not have lids on them and one of the containers was leaking antifreeze onto the concrete pad beneath it. Page 2 of 3 Permit: NCGO80261 Owner- Facility: Celadon Trucking Inspection Date: 07/25/2019 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? E ❑ ❑ ❑ # Does the Plan include a General Location (USGS) map? 0 ❑ ❑ ❑ # Does the Plan include a "Narrative Description of Practices"? 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 ❑ ❑ # Has the facility evaluated feasible alternatives to current practices? ❑ ❑ ❑ # Does the facility provide all necessary secondary containment? E ❑ ❑ ❑ # Does the Plan include a BMP summary? E ❑ ❑ ❑ # Does the Plan include a Spill Prevention and Response Plan (SPRP)? 0 ❑ ❑ ❑ # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? E ❑ ❑ ❑ # Does the facility provide and document Employee Training? ❑ 0 ❑ ❑ # Does the Plan include a list of Responsible Party(s)? ❑ N ❑ ❑ # Is the Plan reviewed and updated annually? ❑ 0 ❑ ❑ # Does the Plan include a Stormwater Facility Inspection Program? M ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? ❑ 0 ❑ ❑ Comment: The Stormwater Pollution Prevention Plan has not been implemented. Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ❑ ❑ ❑ Comment. The facility has not conducted its Qualitative Monitoring semi-annually. Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? ❑ M ❑ ❑ # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑E ❑ ❑ Comment: The facility has not conducted its Analytical Monitoring semi-annually. Permit and Outfalls Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? 0 ❑ ❑ ❑ # Were all outfalls observed during the inspection? E ❑ ❑ ❑ # If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ■ ❑ # Has the facility evaluated all illicit (non stormwater) discharges? ❑ ! ❑ ❑ Comment. Page 3 of 3