NCG080478_NOV_20190819

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ROY COOPER
Governor ; ✓
MICHAEL S.REGAN ,Fm •
Secretary a
S.DANIEL SMITH NORTH CAROLINA
Director Environmental Quality
August 19, 2019
CERTIFIED MAIL: 7015 0640 0007 8168 5543
RETURN RECEIPT REQUESTED
AAA Cooper Transport
Attn: Joya Wallace, Environmental Compliance Manager
1751 Kinsey Road
Dothan, AL 36302
Subject: NOTICE OF VIOLATION (NOV-2019-PC-0577)
NPDES Stormwater General Permit NCGO80000
AAA Cooper Transport
AAA Cooper Transportation - Cumberland, Certificate of Coverage NCGO80478
Cumberland County
Dear Ms. Wallace:
On August 8, 2019, Melissa Joyner from the Fayetteville Regional Office of the Division of Energy, Mineral and Land
Resources (DEMLR), conducted a site inspection for the AAA Cooper Transportation—Cumberland facility located at 923
Chicken Foot Road, Cumberland County, North Carolina. A copy of the Compliance Inspection Report is enclosed for
your review. Mike Champion, Service Center Manager was also present during the inspection and his time and assistance
is greatly appreciated. The site visit and file review revealed that the subject facility is covered by NPDES Stormwater
General Permit NCG080000 under Certificate of Coverage NCG080478. Permit coverage authorizes the discharge of
Stormwater from the facility to receiving waters designated as Grays Creek, a Class B waterbody in the Cape Fear River
Basin.
As a result of the site inspection, the following permit condition 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.
Q North Carolina Department of Environmental Quality 1 Division of Energy,Mineral and Land Resources
D E Fayetteville Regional Office 1 225 Green Street,Suite 7141 Fayetteville,North Carolina 28301
VOR'I'fAAOI N/. �/
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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,
Time LaBo ty, PE
Regional Engineer
DEMLR
TLL/maj
Enclosure: Compliance Evaluation Inspection
ec: Mike Champion, Service Center 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: NCG080478 Effective: 11/01/18 Expiration: 05/31/21 Owner: AAA Cooper Transport
SOC: Effective: Expiration: Facility: AAA Cooper Transportation-Cumberland
923 Chickenfoot Rd
County: Cumberland
Region: Fayetteville
Hope Mills NC 28348 '..
Contact Person: Mike Champion Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 08/08/2019 Entry Time: 09:30AM Exit Time: 10:35AM
Primary Inspector: Melissa A Joyner Phone:
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Transportation wNehicle Maintenance/Petroleum Bulk/Oil Water Separator Stormwater Discharge CDC
Facility Status: ❑ Compliant Not Compliant
Question Areas:
E Storm Water
(See attachment summary)
Page 1 of 3

Permit: NCGO80478 Owner-Facility:AAA Cooper Transport
Inspection Date: 08/08/2019 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
An inspection of the AAA Cooper Transportation-Cumberland facility was conducted with Mike Champion,Service Center
Manager.The Stormwater Pollution Prevention Plan(SPPP)was reviewed.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,an updated list of the facility personnel associated with implementing the Spill
Prevention and Response Procedures,recertification that the stormwater from 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 and implementing/conducting annual employee training.The Qualitative
Monitoring records were reviewed.There was documentation that Qualitative Monitoring had occurred once in 2015.
Qualitative Monitoring should occur semi-annually with the monitoring forms being retained in the SPPP.
The facility grounds were inspected.There was some sand in the parking lot upslope of Outiall 1 which may impact the
water being discharged from this outfall. It is recommended that the sand be removed from the parking lot.
Page 2 of 3

Permit: NCGO80478 Owner-Facility:AAA Cooper Transport
Inspection Date: 08/08/2019 Inspection Type:Compliance Evaluation Reason forVlslt: Routine
Stormwater Pollution Prevention Plan Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan? 0 ❑ ❑ ❑
#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? M ❑ ❑ ❑
#Does the Plan include a list of significant spills occurring during the past 3 years? ❑ M ❑ ❑
#Has the facility evaluated feasible alternatives to current practices? ❑ 0 ❑ ❑
#Does the facility provide all necessary secondary containment? ❑ ❑ M ❑
#Does the Plan include a BMP summary? 0 ❑ ❑ ❑
#Does the Plan include a Spill Prevention and Response Plan(SPRP)? 0 ❑ ❑ ❑
#Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? M ❑ ❑ ❑
#Does the facility provide and document Employee Training? ❑ 0 ❑ ❑
#Does the Plan include a list of Responsible Party(s)? ❑ 0 ❑ ❑
#Is the Plan reviewed and updated annually? ❑ 0 ❑ ❑
#Does the Plan include a Stormwater Facility Inspection Program? ❑ 0 ❑ ❑
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? ❑ M ❑ ❑
Comment: The facility has not conducted its Qualitative Monitoring semi-annually.
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? ❑ ❑ M ❑
Comment:
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? M ❑ ❑ ❑
#If the facility has representative outfall status,is it properly documented by the Division? ❑ ❑ 0 ❑
#Has the facility evaluated all illicit(non stonnwater)discharges? ❑ 0 ❑ ❑
Comment:
Page 3 of 3