NCG080834_COMPLETE FILE - HISTORICAL_20110719

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
/VGC�O�D��")
DOC TYPE
HISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE
o 10 1 I D"l I�
YYYYMMDD

YXIWI
NCDENR FILE
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor. Director Secretary
July 19, 2011
Mr. Gilbert Turner, Engineer
Norfolk Southern Corporation
312 West Liddell Street
Charlotte, NC 28206
Subject: Follow-up to the Compliance Evaluation Inspection of April 28, 2010 (NOV-2010-PC-0843)
Arrowwood Drill Yard, 13058 General Drive
NPDES Stormwater Permit NCG080000
Certificate of Coverage'— NCGO80834
Mecklenburg County
Dear Mr. Turner:
A follow-up evaluation was conducted by Andrew Martin of Charlotte -Mecklenburg Stormwater Services (CMSWS) in
response to the deficiencies noted in the Compliance Evaluation inspection conducted on June 29, 2011. A site visit was
not needed to complete the follow-up evaluation. The follow-up evaluation was conducted as part of a cooperative
working agreement between Mecklenburg County and the Division of Water Quality. In addition, the evaluation was
conducted on behalf of the City of Charlotte in compliance with the City's NPDES Permit, NCS000240, Part 11 Section H.
The follow-up compliance evaluation found that the Norfolk Southern Corporation has implemented corrective actions to
address the deficiencies noted in the original inspection including:
• Submittal of a complete facility site map
• Submittal of a complete facility -general location map
• Submittal of a narrative description of practices
• Submittal of paperwork documenting employee training
• Verification that Analytical Monitoring is not required
• Submittal of paperwork documenting an evaluation of the stormwater outfalls for non-stormwater discharges
• Submittal of paperwork documenting that Qualitative Monitoring was performed
Thank you for the assistance and cooperation following the original inspection. As noted above and in the enclosed
report, the facility has corrected the noted deficiencies and has satisfied the conditions of the Notice of Violation and
NCG080000. The facility has developed and implemented a Stormwater program and this Office commends the
permittee's efforts to ensure compliance with the NPDES permit.
If you have any questions, comments, or need assistance understanding any aspect of your permit, please do not hesitate
to contact Andrew Martin with CMSWS or Ms. Marcia Allocco of the Division of Water Quality at [phone].
Sincerely,
for Robert B. Krebs, Regional Supervisor
Surface Water Protection Section
Mooresville Regional Office
cc: Wetlands and Stormwater-CPU, S. Sullivan Rusty Rozzelle, MCWQP
Craig Miller, City of Charlotte Water Quality Central Files
Mr. Jody Younce, 5204 N. Graham St., Charlotte, NC 28269
Moeresvillo Regional Office r
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 One
Phone: [phone] Fax: [phone] Customer Service: 1-877-623-6748 NorthCaro.1111a
Internet: http:lportal.ncdenrorglweblwq Lril
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lr
Mr. Gil ,�ert4urne�i �V' rfolk Southern Corporation
FolloMLWA Page 2
July 19, 2011
ADDENDUM
The National Pollutant Discharge Elimination System (NPDES) program was established under the federal
Clean Water Act and then delegated to the Division of Water Quality for implementation in North Carolina. The
NPDES permitting program for stormwater discharges was established in 1990. Phase I focuses on site and
operations planning to reduce pollutant sources.
Through the NPDES permitting program industrial facilities that fall into one of the subject ten categories are
required to obtain permit coverage under a general permit or an individual permit, depending upon the
facilities SIC code and the industrial activity occurring at the facility. There are currently 19 active general
stormwater permits in North Carolina. One condition that is applicable to both the general permits and
individual stormwater permits is the requirement to develop and implement site -specific comprehensive
Stormwater Pollution Prevention plans (SPPP). These plans are required to include a comprehensive
evaluation of the site and operations to reduce pollutant sources and prevent pollutant discharge.
Copies of the general permits and accompanying documents can be accessed from the'following webpage:
http://h2o.enr.state.nc.us/su/Forms—Documents.htm, Permit text, technical bulletins, discharge monitoring
forms, and a Notice of Intent [which is the application for coverage under a NPDES General Stormwater
Permit] can be found on this website.
The following items are a subset of permit requirements and are listed to assist you and help bring your
attention to certain permitting issues, process and condition requirements of your permit. Please see the
above mentioned website to obtain a copy of the permit so you may fully comply with all the conditions therein.
Failure to properly comply with conditions of the permit, like those bulleted below, is a violation(s) of
the permit and subject to civil penalty assessment(s) of up to $25,000.00 per day.
• Industrial facilities that fall into one of the subject ten categories are required to obtain permit coverage
under a general NPDES stormwater permit or an individual-NPDES stormwater permit
• All persons desiring to have facilities covered by a General Permit must register with the Division of
Water Quality (DWQ) by filing of a Notice of Intent (NOI) and Applicable Fees.
• This Notice of Intent (NOI) must be submitted and a Certificate of Coverage issued prior to any
discharge of stormwater associated with the industrial activity, process wastewater, and/or mine
dewatering.
• Once the Notice of Intent is received, DWQ will review and determine whether a Certificate of Coverage
(COC) may be issued. If this Certificate of Coverage is issued the facility is covered by the General
Permit. That is, the permittee is authorized to discharge stormwater, process wastewater, and/or mine
dewatering pursuant to the type of General Permit until the permit expires or is modified or revoked.
• Any other point -source discharge to surface waters of the state is prohibited unless it is an allowable
non-stormwater discharge or is covered by another permit, authorization, or approval.
• There are currently 19 active general permits. Permit conditions vary accordingly; however, most of the
permits have the following condition requirements (you must read your entire permit to ensure full
compliance):
o Development and compliance with the Stormwater Pollution Prevention Plan
o Collection, reporting, and recording of Analytical Monitoring
o Collection, reporting, and recording of Qualitative Monitoring
Mooresville Regional Office
t-ocatim 610 East Center Ave., Suile 301 Mooresville, NO 28115
Phone: [phone] Fax: [phone] Customer Service: 1-877-623-6748
Internet: httpJ1por1al.ncdenr.or91web1wq
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0110
North Carol ina
Nahmally

Mr. Gilbert Turner, Norfolk Southern Corporation
Follow-up to NOV-2010-PC-0843, Page 3
July 19, 2011
o Collection, reporting, and recording of Vehicle Maintenance Monitoring (if applicable)
o Records -- Visual monitoring shall be documented and records maintained at the facility along
with the Stormwater Pollution Prevention Plan. Copies of the analytical monitoring results shall
also be maintained on site. The Permittee shall retain records of all monitoring information,
including all calibration and maintenance records and all original strip -chart recordings for
continuous monitoring instrumentation, and copies of all reports required by this general permit
for a period of at least 5 years from the date of the sample measurement, report, or application.
o Expiration - The permittee is not authorized to discharge after the expiration date of the general
permit. In order to receive automatic authorization to discharge beyond the expiration date, the
permittee shall submit forms and fees as are required by the agency authorized to issue permits
no later than 180-days prior to the expiration date. Any permittee that has not requested
renewal at least 180 days prior to expiration, or any permittee that does not have a permit after
the expiration and has not ,requested renewal at least 180 days prior to expiration, will be
subject to enforcement. Failure to renew your permit is a violation.
o Transfer - The Certificate of Coverage (COC) issued pursuant to this general permit is not
transferable to any person expect after notice to and approval by -the Director. The Director may
require modification or revocation and reissuance of the Certificate of Coverage to change the
name and incorporate such other requirements as may be necessary under the Clean Water
Act. The Permit is NOT transferable.
o Name Change, Closure, or Facility Ownership change - Permittee is required to notify the
Division in writing in the event the permitted facility is sold or closed. The Division of Water
Quality views changes of name or ownership as a modification that requires the Director's
approval and reissuance of the permit. Name and ownership changes require you to complete a
Name/Ownership Change Form from the Division and mail it back to the Division of Water
Quality along with all appropriate information.
o Proper Operation and Maintenance is a requirement of the permit.
Mooresville Regional Office
Location: 610 EasI Center Ave., suite 301 Mooresville, NC 28115
Phone: [phone] k Fax: [phone] Customer service: 1-877-623-6746
Internet.- http:l/portal.ncdenr.orglweb/wq
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Noi hCarolina
Naturallil

WDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
July 12, 2010
CERTIFIED MAIL #7008 1140 0002 2716 1077
RETURN RECEIPT REQUESTED
Mr. Gilbert Turner, Engineer
Norfolk Southern Corporation
312 West Liddell Street
Charlotte, NC 28206
Subject: Notice of Violation - Compliance Evaluation Inspection
Tracking Number: NOV-2010-PC-0843 ..
Norfolk Southern Arrowwood Drill Yard at 13058 General Drive
NPDES Stormwater Permit NCGO80000
Certificate of Coverage -- NCGO80834
Mecklenburg County
Dear Mr. Turner:
On April 28, 2010, Andrew Martin from Charlotte -Mecklenburg Stormwater Services (CMSWS), conducted a
site inspection of the Arrowwood Drill Yard facility located at 13058 General Drive in Charlotte, North Carolina.
The site drains to Steele Creek, Class C waters located in the Catawba River Basin. The site visit and file
review revealed that the subject facility is covered by NPDES General Stormwater Permit — NCG080000.
This inspection was conducted as part of a cooperative working agreement between Mecklenburg County and
the Division of Water Quality. In addition, the inspection was conducted on behalf of the City of Charlotte in
compliance with the City's NPDES Permit, NCS000240, Part II Section H. The following observations and/or
permit condition violations were noted during the CMSWS inspection (please see the attached addendum for
information about your permit):
1 Stormwater Pollution Prevention Plan (SPPP)
A Stormwater Pollution Prevention Plan (SPPP) has been developed, recorded, and properly implemented.
Yes ❑ No
The SPPP general location map and site map are missing requirements as noted in the general permit.
Employee training has not been conducted annually. '
2) Qualitative Monitoring
Qualitative monitoring has been conducted and recorded in accordance with permit requirements.
Yes ❑ No
No qualitative monitoring records are on file. The permit requires the permittee to perform qualitative
monitoring semiannually.
Mooresville Regional Office
Location: 610 East Certer Ave., Suite 301 Mooresville, NC 28115 one
Phone: [phone] Fax: [phone] Customer service: 1-W-623-6748 North Carolina
Internet: http:llportal.ncdenr.orglweblwq �Nittlrrnlltt

Gilbert Turner, Arrowwood Drill Yard
NOV-2010-PC-0843, Page 2
July 12, 2010
3) Analytical Monitoring
Analytical monitoring has been conducted and recorded in accordance with permit requirements.
Yes ❑ No ® NA ❑
No Analytical monitoring records are on file. The permit requires the permittee to perform analytical monitoring
semiannually.
4) Permit and Outfalls
A copy of the Permit and Certificate of Coverage were not available at the site and the stormwater outfalls
have not been evaluated annually for non-stormwater discharges.
5) City of Charlotte Stormwater Ordinance Review:
During the inspection rail ties were observed in a pile outdoors and exposed to stormwater. The rail car ties
should be stored indoors or under cover until they are ready to be used on the tracks.
Thank you for the assistance and cooperation during the inspection. As noted above and in the enclosed
report, permit and/or City of Charlotte Stormwater Ordinance violations were noted during the inspection. It is
requested that a written response be submitted to this Office by August 13, 2010, addressing these violations.
In responding to the violations, please address your comments to the attention of Ms. Allocco at the letterhead
address.
Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) may
be assessed against any person who violates or fails to act in accordance with the terms, conditions, or
requirements of any permit issued pursuant to G.S. 143-215.1.
The permittee will have 90 days from the letterhead date to come into compliance with the noted issues. A
follow-up evaluation will be conducted by CMSWS after October 11, 2010, to ensure compliance with the
facility's Stormwater Permit and/or compliance with the City of Charlotte Stormwater Ordinance.
If you have any questions, comments, or need assistance understanding any aspect of your permit, please do
not hesitate to contact Andrew Martin with CMSWS or Ms. Marcia Allocco of the Division of Water Quality at
[phone],
Sincerely,
for Robert B. Krebs
Regional Supervisor
Surface Water Protection Section
Mooresville Regional Office
cc; NPS-ACO Unit
Rusty Rozzelle, MCWQP
Craig Miller, City of Charlotte
Water Quality Central Files
Mooresville Regional Office
Localion: 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] Fax: [phone] Customer Service: 1-877-623-6748
Internet: hltp:Npoctal,ncdenrorglweblwq
NorthCarolina
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Gilbert Tumer, Arrowwood Drill Yard
NOV-201 a-PC-0843, Page 3
July 12, 2010
ADDENDUM
The National Pollutant Discharge Elimination System (NPDES) program was established under the federal
Clean Water Act and then delegated to the Division of Water Quality for implementation in North Carolina. The
NPDES permitting program for stormwater discharges was established in 1990. Phase I focuses on site and
operations planning to reduce pollutant sources.
Through the NPDES permitting program industrial facilities that fall into one of the subject ten categories are
required to obtain permit coverage under a general permit or an individual permit, depending upon the
facilities SIC code and the industrial activity occurring at the facility. There are currently 19 active general
stormwater permits in North Carolina. One condition that is applicabje to both the general permits and
individual stormwater permits is the requirement to develop and implement site -specific comprehensive
Stormwater Pollution Prevention plans (SPPP). These plans are required to include a comprehensive
evaluation of the site and operations to reduce pollutant sources and prevent pollutant discharge.
Copies of the general permits and accompanying documents can be accessed from the following webpage:
httpalportal ncdenr.org/web/wg/ws/su/npdessw#General Permits _NPDErS. Permit text, technical bulletins,
discharge monitoring forms, and a Notice of Intent [which is the application for coverage under a NPDES
General Stormwater Permit] can be found on this website,
The following items are a subset of permit requirements and are listed to assist you and help bring your
attention to certain permitting issues, process and condition requirements of your permit. Please see the
above mentioned website to obtain a copy of the permit so you may fully comply with all the conditions therein.
Failure to properly comply with conditions of the permit, like those bulleted below, is a violation(s) of
the permit and subject to civil penalty assessment(s) of up to $25,000.00 per day.
• Industrial facilities that fall into one of the subject ten categories are required to obtain permit coverage
under a general NPDES stormwater permit or an individual NPDES stormwater permit
• All persons desiring to have facilities covered by a General Permit must register with the Division of
Water Quality (DWQ) by filing of a Notice of Intent (NO[) and Applicable Fees.
• This Notice of Intent (NOI) must be submitted and a Certificate of Coverage issued prior to any
discharge of stormwater associated with the industrial activity, process wastewater, and/or mine
dewatering,
• Once the Notice of Intent is received, DWQ will review and determine whether a Certificate of Coverage
(COC) may be issued. If this Certificate of Coverage is issued the facility is covered by the General
Permit. That is, the permittee is authorized to discharge stormwater, process wastewater, and/or mine
dewatering pursuant to the type of General Permit until the permit expires or is modified or revoked.
• Any other point -source discharge to surface waters of the state is prohibited unless it is an allowable
non-stormwater discharge or is covered by another permit, authorization, or approval.
• There are currently 19 active general permits. Permit conditions vary accordingly; however, most of the
permits have the following condition requirements (you must read your entire permit to ensure full
compliance):
o Development and compliance with the Stormwater Pollution Prevention Plan
o Collection, reporting, and recording of Analytical Monitoring
o Collection, reporting, and recording of Qualitative Monitoring
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 0110
Phone: [phone] Fax: (704) 663,60401 Customer Service, 1-877-523-6748 NorthCarol ina
Internet: http:llportal.ncdenr.arghvehlwq ;Vahlrally
An Equal Opportunity l Affirmative Action Employer— 30% Recycled?30% Post Consumer paper

Gilbert Turner, Arrowwood Drill Yard
NOV-2010-PG-0843, Page 4
July 12, 2010
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c Collection, reporting, and recording of Vehicle Maintenance Monitoring (if applicable)
o Records — Visual monitoring shall be documented and records maintained at the facility along
with the Stormwater Pollution Prevention Plan. Copies of the analytical monitoring results shall
also be maintained on site. The Permitted shall retain records of all monitoring information,
including all calibration and maintenance records and all original strip -chart recordings for
continuous monitoring instrumentation, and copies of all reports required by this general permit
for a period of at least 5 years from the date of the sample measurement, report, or application.
o Expiration — The permittee is not authorized to discharge after the expiration date of the general
permit. In order to receive automatic authorization to discharge beyond the expiration date, the
permittee shall submit forms and fees as are required by the agency authorized to issue permits
no later than 180-days prior to the expiration date. Any permittee that has not requested
renewal at least 180 days prior to expiration, or any permittee that does not have a permit after
the expiration and has not requested renewal at least 180 days prior to expiration, will be
subject to enforcement. Failure to renew your permit is a violation.
o Transfer — The Certificate of Coverage (COC) issued pursuant to this general permit is not
transferable to any person expect after notice to and approval by the Director. The Director may
require modification or revocation and reissuance of the Certificate of Coverage to change the
name and incorporate such other requirements as may be necessary under the Clean Water
Act, The Permit is NOT transferable.
o Name Change, Closure, or facility Ownership change — Permittee is required to notify the
Division in writing in the event the permitted facility is sold or closed. The Division of Water
Quality views changes of name or ownership as a modification that requires the Director's
approval and reissuance of the permit. Name and ownership changes require you to complete a
Name/Ownership Change Form from the Division and mail it back to the Division of Water
Quality along with all appropriate information.
o Proper Operation and Maintenance is a requirement of the permit.
U.S. Postal Service,r.,
CERTIFIED MAIL,,., RECEIPT
(Domestic Nfnil Only; No insurance Coverage Provided)
MRGILl3ERTTURNER, ENGINEER
TW NORFOLK SOUTHERN CORPORATION
srr, 312 WEST LIDDELL STREET
°r) CHARL01-TE NC 28206 ...........
ou swphna 7/12/10
r
One
NorthCarolina
Naturally
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Permit: NCG080834
SOC:
County: Mecklenburg
Region: Mooresville
Compliance Inspection Report
Effective: 03/20/09 Expiration: 10/31/12 Owner: Norfolk Southern Railway Company
Effective: Expiration: Facility: Arrowwcod DTL Fuel Site
13058 General Dr
Contact Person: David F Julian
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Charlotte NC 28273
Title: Phone,, 540-981-5373
Certification: Phone:
inspection Date: 04/28/2010 Entry Time: 09:30 AM Exit Time: 11.00 AM
Primary Inspector: Water Quality Program Meckenburg County Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Transportation wNehicte Maintenance/Petroleum Bulk/Oil
Water Separator Slormwater Discharge COC
Facility Status: rl Compliant ■ Not Compliant
Question Areas:
Storm Water
■ Complete'Items 1, 2, and 3. Also complete
Um 4 if Restricted Delivery Is desired.
■ Print your name and address on the reverse
so that we can return the card to you.
■ Attach this card to the back of the mallplece,
or on the front If space permits.
t. Article Addressed to:
MR GILBERT TURNER, ENGINEER
NORFOLK SOUTHERN CORPORATION
312 WEST LIDDELL STREET
CHARLOTTE NC 28206
swp/ma 7/12/10
A. Signature
X 0 Agent
13 Addressee
liReceived byel
n�Nam�} C. Date of Delivery
D. Is delivery address different fiom Item 17 O Yes
it YES, enter delivery address below: ❑ No
3. Service Type
14 Certified Mail ❑ Express Mail
Registered M Return Receipt for Merchandlse
❑ Insured Mail El C.O.P.
4. Restricted Delivery? (afm Fee) ❑ Yes
2.A 7008 1140 0002 2716 1077 I.
{; _.. _.. , , . _ - Page: 1
PS Form 3811, February 2004 Domestic Return Receipt 1102595-024M.1940

Permit: NCG080834 Owner • Facility: Norfolk Southern Railway Company
Inspection Date: C412812010 Inspection Typo: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Facility Description:
Railroad cars are dropped off at the facility and split uo for delivery to local industries. The facility has one small main
building and a temporary housing trailer for train engineers to stay overnight. A diesel locomotive is kept on site to deliver
rail cars to businesses. Direct to locomotive fueling occurs cn site from a fuei truck that is provided by an outside
contractor when needed. The facility has no permanent employees and operates 24 hours a day, seven days a week. No
maintenance or vehicle washing is conducted on site.
Compliance History:
The permittee/facility does not have any prior compliance issues with the NC Division of Water Quality or with
Charlotte -Mecklenburg Storm Water Services (CMSWS).
Industrial Operations/City of Charlotte Stormwater Ordinance Review:
This inspection was conducted during dry weather conditions. During the inspection rail ties were observed in a pile
outdoors and exposed to stormwater. The odor of cresol was noticed on the rail car ties.
Cresol is a chemical that can possibly impact surface waters. The rail car ties should be stored indoors or under cover
until they are ready to be used on the tracks.
Page: 2

Permit: NCGO80834 Owner - Facility: Norfolk Southern Railway Company
Inspection Date: 04/28/2010 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?
■
n
❑
0
# Does the Plan include a General Location (USGS) map?
n
■
n
n
# Does the Plan include a "Narrative Description of Practices"?
■
Cl
n
Cl
# Does the Plan include a detailed site map including outfall locations and drainage areas?
n
■
0
n
# Does the Plan include a list of significant spills occurring during the past 3 years?
■
❑
n
Cl
# Has the facility evaluated feasible alternatives to current practices?
■
n
Cl
n
# Does the facility provide all necessary secondary containment?
n
❑
■
0
# Does the Plan include a BMP summary?
®
n
n
n
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■
n
n
CJ
# Does the Plan include a Preventative Maintenance and Good }housekeeping Plan?
■
❑
# Does the facility provide and document Employee Training?
n
o
n
n
# Does the Plan include a list of Responsible Party(s)?
O
n
0
n
# is the Plan reviewed and updated annually?
■
n
n
n
# Does the Plan include a Stormwater Facility Inspection Program?
®
n
❑
0
Has the Stormwater Pollution Prevention Plan been implemented?
n
m
n
n
Comment: The SPPP general location map does not name the receiving stream and
is missing the longitude and latitude of discharge points. The site map is missing
drainage areas for each outfall, impervious area percentage, and a narrative description
of potential pollutants expected to be present at each outfall. Training has not been
conducted. The SPPP has not been fully implemented
Qualitative Monitoring
,es
NO
NA ne
Has the facility conducted its Qualitative Monitoring semi-annually?
lien
n
Comment: No qualitative monitoring records on file. The permit requires the permittee
to perform qualitative monitoring semi-annually.
Analytical Monitoring
Yes
No
NA NE
Has the facility conducted its Analytical monitoring?
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
n
Comment: No Analytical monitoring records on file. The permit requires the permittee
to perform 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?
n
®n
n
# Were all outfalls observed during the inspection?
■
n
n n
Page: 3

1
Permit: NCGC80834 owner - Facility: Norfolk Southern Railway Company
Inspection Date: 04/2812010 Inspection Type: Compliance Evaluation Reason for Visit: Routine
# If the facility has representative outfall status, is it properly documented by the Division? Q ❑ ■ Q
# Has the facility evaluated all illicit (non starmwater) discharges? U ■ ❑ 0
Comment: A copy of the Permit and Certificate of Coverage were not available at the
site. The stormwater outfalls have not been evaluated for non-stormwater discharges
annually as required by the permit.
Page: 4

Allocco, Marcia
From:
Allocco, Marcia
Sent:
Friday, September 03, 2010 10:03 AM
To:
'Mark Neal'
Cc:
'Hall, Erin R.'
Subject:
RE: Norfolk Southern Arrowood Yard - Notice of Violation
Hi Mark,
i have no problem in providing a second extension with a due date of 9117/10, 1 would rather get the final
decision even if that takes longer.
Regards,
Marcia
From: Mark Neal [maiito:mark. neal@mma1,com]
Sent: Thursday, September 02, 2010 11:19 AM
To: Allocco, Marcia
Subject: RE: Norfolk Southern Arrowood Yard - Notice of Violation
Marcia,
We appreciate your consideration on this matter. Norfolk Southern management personnel are still determining the
feasibility of terminating operations at the Arrowwood Yard. We had hoped to have a decision made sooner so that an
accurate response to the NOV could be filed. Would it be possible for you Office to grant an additional two week (9/17/10)
extension of time to facilitate an accurate response by Norfolk Southern? Thank you.
Mark
From: Allocco, Marcia[mailto:[e-mail]]
Sent: Thursday, August 12, 2010 11:52 AM
To: Mark Neal
Cc: Gilbert Turner; Adam Czaplinski
Subject: RE: Norfolk Southern Arrowood Yard - Notice of Violation
Hi Mark,
As we discussed yesterday, this Office will approve your NOV response extension with a revised date of
September 3, 2010, to facilitate an accurate response by Norfolk Southern on the future of the Arrowood Yard.
Regards,
Marcia
From: Mark Neal [mailto:mark.nea@mural .comJ
Sent: Wednesday, August 11, 2010 2:48 PM
To: Allocco, Marcia
Cc: Gilbert Turner; Adam Czaplinski
Subject: Norfolk Southern Arrowwood Yard - Notice of Violation
Marcia,

Per our telephone conversation, Norfolk Southern Railway Company (NSRC) is formally requesting an
extension of time to provide written comments to the Notice of Violation (NOV-2010-PC-0843) issued for the
above referenced facility, As we discussed, NSRC is considering the cessation of industrial activities at the
facility and submitting a notice of termination for the NPDES permit. Approval from NSRC management is
needed before facility operations can be terminated. It is anticipated that a final decision on terminating the
facility operations will be made within three (3) weeks. Therefore, NSRC is requesting a three (3) week
extension of time until September 3, 2010 to provide written comments on the NOV. NSRC appreciates your
consideration on this matter. Please let me know if you have any questions or need any additional information.
Mark
Mark Neal
Senior Scientist /Environmental Compliance Manager
Marshall Miller and Associates, Inc.
534 industrial Park Road
Bluefield, VA 24605
Tel: [phone]
Fax: [phone]
This communication contains information which is confidential and may also be privileged. It is for the
exclusive use of the intended recipient(s). If you are not the intended recipient(s), please note that any
distribution, copying or use of this communication or the information in it is strictly prohibited. If you have
received this communication in error, please notify the sender immediately and then destroy any copies of it.
This communication contains information which is confidential and may also be privileged. It is for the
exclusive use of the intended recipient(s). If you are not the intended recipient(s), please note that any
distribution, copying or use of this communication or the information in it is strictly prohibited. If you have
received this communication in error, please notify the sender immediately and then destroy any copies of it,
This communication contains information which is confidential and may also be privileged. It is for the exclusive use of the intended recipient(s). 4f you are not the
intended recipient(s), please note that any distribution, copying or use of this communication or the information in it is strictly prohibited. if you have received this
communication in error, please notify the sender immediately and then destroy any copies of it.

RECEIVE
DIVISION OF WATER QUALITY
JUN 2 4 2011
SWp SEGTlON RE61W p
MOORESVlLLE REG! NAL OFFICE
lUN z 3
September 2, 2010 20If
Mr. Robert Krebs, Regional Supervisor
North Carolina Department of Environment and Natural Resources
Division of Water Quality, Surface Water Protection Section
610 East Center Avenue, Suite 301
Mooresville, NC 28115
Re: Response to Notice of Violation
Norfolk Southern Railway Company Arrowwood Drill Yazd
13058 General Drive.
Charlotte, NC 28273
National Pollutant Discharge Elimination System Permit NCG080834
Dear Mr, Krebs:
Norfolk Southern Railway Company (NSRC) has reviewed the Notice of Violation
(NOV) dated July 12, 2010 for the facility referenced above, related to an inspection
conducted at the facility on April 28, 2010. We appreciate you granting a minor
extension of time to respond in writing while NSRC management personnel determined
the feasibility of terminating the facility operations. NSRC has determined that facility
operations will continue. The NOV alleges compliance issues involving monitoring,
record keeping, and housekeeping. The following responses correspond to comments
presented in the NOV.
Comment:
1) Stormwater Pollution Prevention Plan (SPPPI. The SPPP general location map and
site map are missing requirements as noted in the general permit. Employee training has
not been conducted annually.
Response:
NSRC has reviewed the SPPP general location map and site map and modified the
maps to include the required information. Copies of the modified general location
map and site map are enclosed, Employee training was conducted on August 10,
2010. A copy of the employee training log is enclosed.

Mr. Robert Krebs, NCDENR
NOV Responae for NPDES Permit NCO080834
September 2, 2010
Page 2 of 3
Comment:
2) Qualitative Monitoring No qualitative monitoring records are on file. The permit
requires the permittee to perform qualitative monitoring semiannually.
Response:
In the future, NSRC will ensure that qualitative monitoring is conducted on a semi-
annual basis. The inspector will visually inspect stormwater discharges for indicators
of storm water quality as specified in Table 5 of the facility's NPDES permit. Each
qualitative monitoring event will be documented on a Storm Water Discharge Outfall
Qualitative Monitoring Report that will be kept onsite with the SPPP.
Comment:
3) Analytical _Monitoring. No analytical monitoring records are on file. The permit
requires the permittee to perform analytical monitoring semiannually.
Response:
Analytical monitoring is not required for the facility. Part 11L Sections B and C of the
facility's NPDES permit describe the analytical monitoring requirements. In
accordance with Section B, analytical monitoring is not required because the facility
does not use more than 55 gallons of new motor oil per month. In accordance with
Section C, analytical monitoring is not required because the facility does not utilize
an oil/water separator or operate as a petroleum bulk station or terminal.
Comment:
4) Permit and Qutfalls. A copy of the Permit and Certificate of Coverage were not
available at the site and the stormwater outfalls have not been evaluated annually for non-
stormwater discharges.
Response:
A copy of the SPPP along with the facility's NPDES permit and certificate of
coverage will be maintained onsite. The existing stormwater outfall will be evaluated
in 2010 and documentation of annual evaluations will be maintained onsite with the
SPPP,
Comment:
5) City of Charlotte Stormwater Ordinance Review During the inspection rail ties were
observed in a pile outdoors and exposed to stormwater. The rail car ties should be stored
indoors or under cover until they are ready to be used on the tracks.
Response:
The rail car ties will be removed from the facility by October 31, 2010.

4
Mr. Robert Krebs, NCDENR
NOV Response for NPDBS Permit NCG080834
September 2, 2010
Page of
NSRC appreciates the opportunity to present this information to you and is committed to
meeting environmental regulatory requirements. Should you have any questions or wish
to discuss any of the material contained in this correspondence, please do not hesitate to
call me at 704-378-3841.
Sincerely,
'lbert Turner
Engineer Environmental Operations
cc: IN Gennette, NSRC
L.G, Western, NSRC
MA Neal, MM&A

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LONGRUDS: 8VB64T W

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OIL HANDLINGIRESPONSE PERSONNEL TRAINING LOG
&eYlw.,r- C Training Location
This session satisfies the training requirements for the following pollution prevention plans.
Check all that apply. Afro AMM p�p� p Ss flRS�
Ya!dsor F cillty NOrnts Re resented:
Split Prevention Control and Countanneasure (SPCC) Plan 61
flf� e- r��•t
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Storm Water Pollution Prevention Plan (SWPPP)
Federal Register Vol. 65. No. 210
�} Scrap Lead Acid Battery Pollution Praventlon Training
Federal Register Vol. 65, No. 210 - S.N.4.2.6
j Facility Response Plan (FRP)
j-" 40 CFR 112.21
Slug Discharge Prevention and Response Training/
Sludge Storage, Handling, and Disposal Training
0 Other:��
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NCDETR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins an
Governor DirectorR E
Uecrary
March 20, 2009 MAR 2 5 2009
Mr. Gilbert Turner
Norfolk Southern Railway Company
110 Franklin Road, S.E., Box 13 DINQ-Suftce Wader R 'iC "on
Roanoke, VA 24042
Subject: General Permit No. NCGO80000
Norfolk Southern Railway Company
Arrowwood DTL Fuel Site
COC NCGO80834
Mecklenburg County
Dear Mr. Turner:
In accordance with your application for a discharge permit received on February 5, 2009,
we are forwarding herewith the subject certificate of coverage to discharge under the subject state
— NPDES general permit. This permit is issued pursuant to the requirements of North Carolina
General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the .
US Environmental Protection Agency dated October 15, 2007 (or as subsequently amended).
Please take notice that this certificate of coverage is not transferable except after notice to
the Division of Water Quality. The Division of Water Quality may require modification or
revocation and reissuance of the certificate of coverage.
This permit does not affect the legal requirements to obtain other permits which may be
required by the Division of Water Quality or permits required by the Division of Land Resources,
Coastal Area Management Act or any other federal or local governmental permit that may be
required.
If you have any questions concerning this permit, please contact Brian Lowther at
telephone number [phone]
SincerelgRIGINAL SIGNED BY
BETHANY GEORGOULIAS
for Coleen H. Sullins
M. Mooresville Regional Office
Central Files
Stormwater Permitting Unit Files
Wetlands and Stormwater Branch
1617 Mail Service Center, Raleigh, North Carolina 27699.1617
Location, 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service', 1-877-623-6748
Internet: www.ncwaterquality.org
One
NorthCarolina
Naturally

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG080000
CERTIFICATE OF COVERAGE No. NCGO80834
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-2I 5.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Norfolk Southern Railway Company
is hereby authorized to discharge stormwater from a facility located at
Arrowwood DTL Fuel Site
13058 General Drive
Charlotte
Mecklenburg County
to receiving waters designated as unnamed tributary to Steele Creek, a class C water in the
Catawba River Basin, in accordance with the effluent limitations, monitoring requirements, and
other conditions set forth in Parts I, II, III, IV, V, and VI of General Permit No. NCGO80000 as
attached.
This certificate of coverage shall become effective March 20, 2009.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this 2W11 day of March, 2009, ORIGINAL. SIGNED BY
BETHANY GEORGOULIAS
for Coleen H. Sullins., Director
Division of Water Quality
By the Authority of the Environmental Management Commission

LOCATION MAP:
NCGO80834
MW Scale 1:24,000
Norfolk Southern Railway Comapny
Arrowwood DTL Fuel Site
Ladtude; 350 07' 07" N
f_ongiUxle: 800 56' 46" W
County: Mecklenburg
Receiving Stream; UT to Steele Creek
Stream Class: C
Sub -basin : 03-08-34 (CatzwbaRiverBasin)
„�i+,=� ■i1�N �f� F
Facility Location

A *A,
j.
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
March 20, 2009
Mr. Gilbert Turner
Norfolk Southern Railway Company
110 Franklin Road, S.E., Box 13
Roanoke, VA 24042
Subject: General Permit No. NCGO80000
Norfolk Southern Railway Company
Arrowwood DTL Fuel Site
COC NCGO80834
Mecklenburg County
Dear Mr. Turner:
Dee Freeman
Secretary
In accordance with your application for a discharge permit received on February 5, 2009,
we are forwarding herewith the subject certificate of coverage to discharge under the subject state
— NPDES general permit. This permit is issued pursuant to the requirements of North Carolina
General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the
US Environmental Protection Agency dated October 15, 2007 (or as subsequently amended).
Please take notice that this certificate of coverage is not transferable except after notice to
the Division of Water Quality, The Division of Water Quality may require modification or
revocation and reissuance of the certificate of coverage.
. This permit does not affect the legal requirements to obtain other permits which may be
required by the Division of Water Quality or pen -nits required by the Division of Land Resources,
Coastal Area Management Act or any other federal or local governmental permit that may be
required.
If you have any questions concerning this permit, please Wntact Brian Lowther at
telephone number [phone]
SincerAGINAL SIGNED BY
BETHANY GEORGOULIAS
for Coleen H. Sullins
cc: Mooresville Regional Office
Central Files '
Stormwater Permitting Unit Files
Wetlands and Stormwater Branch
1617 Mail Service Center, Raleigh, North Carolina 27699.1617
Location: 612 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Serviw 1-877-623-6748
Internet: www.ncwaterquality.org
._ r...-, n_..�..,<... .u,�. a........ ram.,...._
NonhCarohna
Naturallrf

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG080000
CERTIFICATE OF COVERAGE No. NCGO80834
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Norfolk Southern Railway Company
is hereby authorized to discharge stormwater from a facility located at
Arrowwood DTL Fuel Site
13058 General Drive
Charlotte
Mecklenburg County
to receiving waters designated as unnamed tributary to Steele Creek, a class C water in the
Catawba River Basin, in accordance with the effluent limitations, monitoring requirements, and
other conditions set forth in Parts I, II, III, IV, V, and VI of General Permit No. NCGO80000 as
attached.
This certificate of coverage shall become effective March 20, 2009.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this 20`i' day of March, 2009. ORIGINAL SIGNED BY
BETHANY GEORGOULIAS
for Coleen H. Sullins., Director
Division of Water Quality
By the Authority of the Environmental Management Commission

LOCATION MAP:
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NCGO80834
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M49 Scale 124,aV
Norfolk Southern Railway Comapny
Arrowwood DTL Fuel Site
Lab tude: 350 07' 07" N
Longitude: 800 56' 46" W
County: ivL-cklenburg
Receiving Stream: UT to Steele Creek
Stream Class; C
Sub -basin: 03-08-34 (Catawba River Basin)
Facility Location

Re: Three General Permits ncg08
Subject: Re: Three General Permits ncg08
From: Michael Parker <[e-mail]>
Date: Mon, 16 Mar 2009 15:45:34 -0400
To: Brian Lowther <[e-mail]>
Brian,
Samar has gone home for the day, but I checked my email and could not find any reply
where he might have gotten back to you on any of these three facilities. Typically,
it would be a rare occurrence for us to recommend not issuing a COC unless the site
was already covered under a regular NPDES.permit and we felt that was the best permit
for them to operate under. This, however, is not the case with these facilities, so
it would be prudent to move forward with issuance of the COC at this time. Obviously,
having them under a permit gives us better legal footing should we find surface water
violations, so go ahead and issue the COCs.
Mike
Brian Lowther wrote:
Mike,
We've received three NOIs from Norfolk Southern Railway Company for their
facilities in Gastonia (Gaston County), Kannapolis (Cabarrus County), and Charlotte
(Mecklenburg County) for coverage of their fueling stations under NCG08 (Railroad
Transportation (SIC 401 SW permit). The site discharges stormwater into UT to
Catawba Creek (C), UT to Cold Water Creek (WS-IV) and UT to Steele Creek (C)
respectively. The NOIs are attached.
Does the Mooresville Regional Office have any concerns about issuing this facility
a COCs for these general permits? If we don't receive any objections, we'll issue
the COC in 30 days.
Thanks,
Brian Lowther
Michael Parker - [e-mail]
Environmental Engineer II
North Carolina Dept. of Environment
Division of Water Quality
610 East Center Avenue
Suite 301
Mooresville, NC 28115
Ph: [phone] Fax: (704)
& Natural Resources
663--6040
E-mail correspondence to and from this address may be subject to the North Carolina
Public Records Law and may be disclosed to third parties.
1 of 1 3/16/2009 3:48 PM