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HomeMy WebLinkAboutNCG080817_COMPLETE FILE - HISTORICAL_20150610STORMWATER DIVISION CODING SHEET RESCISSIONS PERMIT NO. DOC TYPE ❑COMPLETE FILE -HISTORICAL DATE OF RESCISSION 0 �Q � � 0�0 lo YYYYMMDD NCDENR North Carolina Department of Environment and Natural Resources Pat McCrory Governor Mr. Anthony Spalvieri FedEx Ground Package System, Inc. 1000 FedEx Drive Allegheny, PA 15108 Dear Mr. Spalvieri: Donald R, van der Vaart Secretary June 10, 2015 Subject: Rescission of NPDES Stormwater Permit Certificate of Coverage Number NCG080817 New Hanover County On April 2, 2015, the Division of Energy, Mineral and Land Resources received your request to rescind your coverage under Certificate of Coverage Number NCG080817. in accordance with your request, Certificate of Coverage Number NCGO80817 is rescinded effective immediately. Operating a treatment facility, discharging wastewater or discharging specific types of stormwater to waters of the State without valid coverage under an NPDES permit is against federal and state laws and could result in fines. If something changes and your facility would again require stormwater or wastewater discharge permit coverage, you should notify this office immediately. We will be happy to assist you in assuring the proper permit coverage. If the facility is in the process of being sold, you will be performing a public service if you would inform the new or prospective owners of their potential need for NPDES permit coverage. If you have questions about this matter, please contact us at 919-707-9200, or the Stormwater staff in our Wilmington Regional Office (910) 796-7215. Sincerely, ORIGINAL SIGtIEQ BY BETHANY GEORGOULIAS for Tracy E. Davis, PE, CPM, Director Division of Energy, Mineral and Land Resources cc: Wilmington Regional Office Stormwater Permitting Program Central Files - wlattachments Division of Energy, Mineral, and Land Resources Energy Section • Geological Survey Section • Land Quality Section 1612 Mail Service Center, Raleigh, North Carolina 27699-1612.919-707-92001 FAX: 919-715-8801 512 North Salisbury Street, Raleigh, North Carolina 27604 • Internet: httpalportal.ncdenr.org/web/Ir/ An Equal Opportunity 1 Affirmative Action Employer — 50% Recycled 110% Post Consumer Paper Division of Energy, Mineral & Land Resources Land Quality Section/Stormwater Permitting Program NCDENRNational Pollutant Discharge Elimination System ����i �W ENVIFOMMCMT ,wa NN,JIUL RE]OUwtC9 RESCISSION REQUEST FORM FOR AGENCY USE ONLY Date Received Year Month I Qay Please fill out and return this form if you no longer need to maintain your NPDES stormwater permit. 1) Enter the permit number to which this request applies: Individual Permit (or) Certificate of Coverage N -c. S' N C G Q 8 O g / 7 .. - -.z) Owner/Facility information: * Final correspondence will be maYed.to the address noted beloty Owner/Facility Name F-edCX 6" Uhd TCI� e- Facility Contact 0A)K Street Address City County Telephone No. 3) Reason for rescission request (This is required information. Attach separate sheet if necessary): ❑ Facility closed or is closing on is All industrial activities have ceased such that no discharges of stormwater are contaminated by exposure to industrial activities or materials. ❑ Facility sold to s :_: • on'-_: - If the facility will continue operations under the new owner it may be more appropriate to request an ownership change to reissue to permit to the new owner. 4) Certification: I, as an authorized representative, hereby request rescission of coverage under the NPDES Stormwater Permit for the subject facility. I am familiar with the information contained in this request and to the best of my knowledge and belief such information is true. complete and accurate. Signature i. I I Print or type name of person signing above Date 51STI I T ; '7 1-ear Title Please return this completed rescission request form to: NPDES Permit Coverage Rescission Stormwater Permitting Program 1612 Mail Service Center Raleigh, North Carolina 27699-1612 20 1 1612 Mail Service Center, Raleigh, North Carolina 27699-1612 i Phone: 919-807-63001 FAX: 919-807-6492�'z`` r..'.� An Equal Opportunity 1 Affirmative Action Employer Anthony Spalvieri Managing Director Regulatory Law Group and Environmental Services Legal Department Direct Dial 412-262-7638 aspalvieri®fedex.com Ground February 19, 2015 — Certified NC Department of Environment & Natural Resources Division of Water Quality 1617 Mail Service Center Raleigh, NC 27604 Re: FedEx Ground— WILMINGTON 2414 North 2P Street LFR 20 � Wilmington, NC 28401 j Storm water jPermit #. NCGOOi81Nance of Termination Vices To Whom It May Concern: FedEx Ground is no longer performing industrial activities at the above mentioned facility that require a storm water permit. We are now requesting a termination of the current Storm Water Discharge Permit (NCG080817). Sincerely 4nthonyv F. Spalvieri Managing Director Regulatory Law Group and Environmental Services FedEx Ground Package System, Inc. 1000 FedEx Drive Moon Township, PA 15108 Alexander, Laura From: Conway, Jean Sent: Wednesday, June 03, 2015 11:50 AM To: Alexander, Laura; Sams, Dan Subject: RE: Rescission Request for NCG080817 Attachments: NCG080817.pdf Fallow Up Flag: Follow up Flag Status: Flagged Laura, I inspected the FedEx site for rescission of permit NCG080817. The site is no longer conducting vehicle maintenance and has installed covered dock bays to limit exposure to stormwater. Mr. Kevin Olsen stated that no other vehicle maintenance is being conducted on site. recommend rescission of the permit. See attached inspection report. Feel free to contact me if you need further information. Jean Conway 910-796-7315 From: Alexander, Laura Sent: Thursday, May 21, 2015 11:56 AM To: Sams, Dan Cc: Conway, Jean Subject: RE: Rescission Request for NCG080817 Dan, The rescission request form may be somewhat confusing since we ask the permittee to list the address where they'd like their final correspondence mailed. In this case, it's FedEx in Allegheny, PA but the facility is located at 2414 N. 23" Street in Wilmington. Let me know if you have any other questions. Thank you, Laura From: Sams, Dan Sent: Thursday, May 21, 2015 11:46 AM To: Alexander, Laura Cc: Conway, Jean Subject: RE: Rescission Request for NCG080817 Laura No. Our last a -mails did not clarify why a rescission request was being made for a facility that was located in Allegheny County in Pennsylvania; therefore, we assumed it was a mistake and made no investigation. Where in New Hanover County is this facility? Thanks.... dan.sams From: Alexander, Laura Sent: Thursday, May 21, 2015 11:20 AM To: Sams, Dan Subject: FW: Rescission Request for NCG080817 Good Morning! This rescission request is for a facility in New Hanover County. Permittee is asking about the rescission and if inspection had been made. Has an inspection been done? Thank you, Laura From: Alexander, Laura Sent: Monday, April 06, 2015 9:19 AM To: Sams, Dan Subject: RE: Rescission Request for NCGO80817 I noticed that too but looked further and it is Allegheny County for Pennsylvania. From: Sams, Dan Sent: Monday, April 06, 2015 9:18 AM To: Alexander, Laura Subject: FW: Rescission Request for NCG080817 Laura This is an Allegheny County project. The Wilmington Regional Office does not include Alleghany County. Thanks.... clan From: Alexander, Laura Sent: Monday, April 06, 2015 9:09 AM To: Sams, Dan Subject: Rescission Request for NCG080817 Good Morning! Please see attached rescission request. Let me know if/when okay to rescind. Thank you! Laura Alexander F) CONSENT OF THE HOARD OF DIRECTORS OF FEDEX GROUND PACKAGE SYSTEM, INC. Pursuant to Section 1.41(f) of the Delaware General Corporation Law and Section 3.9 of Article III of the Amended and Restated Bylaws of FedEx Ground Package System, Inc. (the "Corporation"), the undersigned director hereby consents to the following action to be taken by the Board of Directors without a meeting: Officer Election RESOLVED, that the following individual is hereby elected to the office set forth opposite his name, to hold office until his successor is elected and qualified or until the earlier of his death, resignation or removal: Name Office Anthony F. Spalvieri Assistant Secretary IN WITNESS WHEREOF, the undersigned director of the Corporation has affixed his signature to this Consent which shall be filed with the minutes of the Corporation in counterpart with the consents of the other directors. David F. Rebhol Dated: December Z, 2011 909481 Alexander, Laura From: Sent: To: Subject: Attachments: Good Morning Mr. Spalvieri, Alexander, Llaura Wednesday, March 11, 2015 8:47 AM Iaspalvieri @fedex.com' Rescission Request for NCGO80817 NPDES-Rescission-Form-20140127-DEMLR-SW.doc We received your letter on February 25, requesting rescission of the above mentioned stormwater permit. Would you mind filling out the attached rescission form? Our regional office will go ahead and inspect the site and start the rescission process. We need the rescission form filled out for our files. Thanks for your help! Let me know if you have any questions. Laura Alexander Stormwater Permitting Program NC Division of Energy, Mineral and Land Resources 1612 Mail Service Center Raleigh, NC 27699-1612 (919) 807-6368 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. Alexander, !aura From: Alexander, Laura Sent: Thursday, May 21, 2015 11:56 AM To: Sams, Dan Cc: Conway, Jean Subject: RE: Rescission Request for NCG080817 Attachments: Rescission Request NCG080817.pdf Dan, The rescission request form may be somewhat confusing since we ask the permittee to list the address where they'd like their final correspondence mailed. In this case, it's FedEx in Allegheny, PA but the facility is located at 2414 N. 23" Street in Wilmington. Let me know if you have any other questions. Thank you, Laura From: Sams, Dan Sent: Thursday, May 21, 2015 11:46 AM To: Alexander, Laura Cc: Conway, Jean Subject: RE: Rescission Request for NCG080817 Laura No. Our last e-mails did not clarify why a rescission request was being made for a facility that was located in Allegheny County in Pennsylvania; therefore, we assumed it was a mistake and made no investigation. Where in New Hanover County is this facility? Thanks.... dan.sams From: Alexander, Laura Sent: Thursday, May 21, 2015 11:20 AM To: Sams, Dan Subject: FW: Rescission Request for NCG080817 Good,Morning! This rescission request is for a facility in New Hanover County. Permittee is asking about the rescission and if inspection had been made. Has an inspection been done? Thank you, Laura From: Alexander, Laura Sent: Monday, April 06, 2015 9:19 AM To: Sams, Dan Subject: RE: Rescission Request for NCG080817 I noticed that too but looked further and it is Allegheny County for Pennsylvania. From: Sams, Dan Sent: Monday, April 06, 2015 9:18 AM To: Alexander, Laura Subject: FW: Rescission Request for NCGO80817 Laura: This is an Alleghany County project. The Wilmington Regional Office does not include Alleghany County. Thanks.... clan From: Alexander, Laura Sent: Monday, April 06, 2015 9:09 AM To: Sams, Dan Subject: Rescission Request for NCGO80817 Good Morning! Please see attached rescission request. Let me know if/when okay to rescind. Thankyou! Laura Alexander Stormwater Permitting Program NC Division of Energy, Mineral and Land Resources 1612 Mail Service Center Raleigh, NC 27699-1612 (919)807-6368 From: scanner.942A.arch0pncdenr.gov[mailto:scanner. 942A.arch@ncdenr.gov] Sent: Monday, April 06, 2015 9:53 AM To: laura.alexander@ncd_enr.com; Alexander, Laura Subject: Scanned page 2 Compliance Inspection Report Permit: NCG080817 SOC: County: New Hanover Region: Wilmington Effective: 11/01/12 Expiration: 10/31/17 Owner: Fedex Ground Package System Inc Effective: Expiration: Facility: Fedex Ground - N 23rd St 2414 N 23rd St Contact Person: Nancy Beaumont Title: Directions to Facility: From 117 North. Right on Gordon Road (.36 miles) Right on N. 23rd Street. System Classifications: Primary ORC: Certification: Secondary ORC(s): On -Site Representative(s): Related Permits: Wilmington NC 28401 Phone: 412-262-7306 Phone: Inspection Date: 05/27/2015 Entry Time: 03:OOPM Exit Time: 03:30PM Primary Inspector: Jean Conway Phone: 910-796-7215 Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Transportation w/Vehicle Maintenance/Petroleum BulkI00 Water Separator Stormwater Discharge COC Facility Status: Compliant Not Compliant Question Areas: Storm Water (See attachment summary) Page: 1 Permit: NGG080817 Owner - Facility: Fedex Ground Package System Inc Inspection Date: 0512712015 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: This inspection was triggered by a request for rescission by the permittee since the facility no longer conducts vehicle maintenance at the site. The site has covered truck bays where the trailers load and unload packages. The facility does not appear to provide any truck washing activity any more. Mr. Kevin Olsen staled that no other vehicle maintenance is being conducted at the site. This inspector recommends rescission of the permit. Page: 2 Permit: NCG080817 Owner • Facility: Fedex Ground Package System Inc Inspection Date: 0512712015 Inspection Type : Compliance Evaluation Reason for visit: Routine Page: 3 �0 WATF9Q cO 7 0 Y June 27, 2008 Mr. Joseph Stearns FedEx Ground Package System, Inc. 1000 FedEx Drive, Attn: Environmental Services Moon Township, PA 15108 Dear Mr. Stearns: Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Colcen 11. Sullins, Director Division of Water Quality Subject: General Permit No. NCG080000 FedEx Ground Package System, Inc. FedEx Ground Facility — Wilmington, NC COC NCG080817 New Hanover County In accordance with your application for a discharge permit received on April 2, 2008, 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 May 9, 1994 (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 Jennifer Jones at telephone number (919) 733-5083 ext. 591. Sin UMINAL SIGNED BY KEN PICKLE for Coleen H. Sullins CC' Wilmington Regional Office, Ed Beck Central Files Stormwater Permitting Unit Files No Carolina ,J�aturn!!� North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone (919) 733-5093 Customer Service Internet: www.ncwaterauali3 ty,orLocation: 512 N. Salisbury St. Raleigh, NC 27604 Fax (919) 733-9612 1-977-623-6748 An Equal Opportu0y/Affirmative Action Employer— 50°% Recycled/10% Post Consumer Paper STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY GENERAL PERMIT NO. NCG080000 CERTIFICATE OF COVERAGE No. NCG080817 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, FedEx Ground Package System, Inc. is hereby authorized to discharge stormwater from a facility located at FedEx Ground 2414 North 23rd Street Wilmington New Hanover County to receiving waters designated as Smith Creek, a class C, Sw water in the Cape Fear River Basin, in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts 1, I1, III, IV, V, and VI of General Permit No. NCGO8000 as attached. This certificate of coverage shall become effective June 27, 2008. This Certificate of Coverage shall remain in effect for the duration of the General Permit. Signed this day June 27, 2008. ®RIGIKEN N PICKS BY for Coleen H. Sullins., Director Division of Water Quality By the Authority of the Environmental Management Commission LOCATION MAP: NCGO80817 FedEx Ground Package System, Inc. Wilmington, NC v Latitude: 340 15' 57" N Longitude: 770 55 10.764 W Receiving Stream: Smith Creek S Stream Class: C, Sw Map Scale 1:22,207 Sub -basin: 03-06-23 (Cape Fear River Basin) Facility Location Re: [F�vcl: Re: NCGO80818 FedF.x Winston-Salem May 26th, 20081 Subject: Re: [Fwd: Re: NCGO80818 FedEx Winston-Salem May 26th, 2008] From, Ed Beck <Ed.Beck a ncnzail.net> Date: Fri, 20 Jun 2008 07:58:25 -0400 To: Jennifer.Jones a ncniail.net CC: Linda Willis <Linda.Willis Di ncrnail.net>, John Hennessy <.1o11n.Hennessy c,NCMail.net> Jennifer Please cover them under the general permit. We will then deal with the truck: wash situation and any other compliance issues, thank you Ed Jennifer Jones wrote: Hi All, I am assuming that since you haven't replied you mean to issue the general permit? I will issue it tomorrow if I don't hear back. Thanks, Jen Jennifer Jones wrote: Ok. This one was due to send out the week of May 26th. Its overdue from our guidelines so if you could let me know by Wednesday that would be great. In all this snafu if you could please check on the other Fed Er, in Wilmington that would be great. I believe I forwarded you the information last week? It is NCGO80824. That one was originally due June 16th but if you let me know when you could visit if you have time then I will put that in EIMS. Thanks Linda! Jen Linda Willis wrote: Jen, I'll let Ed make that call on individual or general, makes no difference to me, either way they can't meet their permit requirements at this point. The NOV will give them the chance to figure out their next steps. Linda Jennifer Jones wrote: Hi Linda, Ok - so what I am hearing is is that you are going to issue the NOV... and I hear what you are -saying about the permits - it is frustrating. If you feel it meets the reasons/criteria below - we can ask them to apply under an individual permit. - although this is pretty rare that we do this. However - after they apply this may take a while - as our backlog for individual permits is pretty long. But if you think we need to write an individual permit we can do that. Samar went to a FedEx in Hickory today and left me a message: saying that their washing service had a contract with one to dispose of at a WWTP - could this be part of their compliance? Whatever happens - obviously FedEx Corporate needs to be responsible for the actions that are happening at each site. t of 7 6/20/2008 t 1:31 AM Re: [FNv& Re: NCGO80818 FedE\ Winston-Salem May 26th, 20081 Let me know what you want to do about the permit... Have a good weekend, jen *(i) The Director may require any person, otherwise eligible for" *coverage under a general permit, to apply for an individual NPDES permit by* * notifying that person that an application is required. * Notification shall consist of a written description of the reason(s) for the decision, appropriate permit application forms x and application instructions, * a statement establishing the required date for submission of the application, and a statement informing the person that coverage by the general permit shall automatically terminate upon issuance of the individual permit. Reasons for requiring application for an individual permit may be: =(1) the discharge is a significant contributor of pollutants;* (2) conditions at the permitted site change, altering the constituents or characteristics of the discharge such that the discharge no longer qualifies for coverage under a general permit; *(3) noncompliance with the general permit;" f9) noncompliance with Division Rules; or� (5) a change has occurred in the availability of demonstrated technology or practices for the control or abatement of poilutants applicable to the point source; (6) effluent limitations are promulgated for the point sources covered by the general permit; (7) a water quality management plan containing the requirements applicable to such point sources is approved after the issuance of the general permit; *(8) a determination that the water of the stream receiving the} (discharge is not meeting applicable water quality standards., (j) Any interested person may petition the Director to take an action under Paragraph (i) of this Rule to require an individual 2oi7 6/20/2008 11:31 AM Re: [I-ivd: Re: NCGO80818 I7edEx Winston-Salem May 26th, 20081 NPDES permit. (k) General permits may be modified, terminated, or revoked and reissued in accordance with the authority and requirements of Rules .0112 and .0114 of this Section. Linda Willis wrote: John, Thanks for your thoughts. They are worthwhile. Just to give some background on this. . since we were likely to give them a NCG080 permit . . and we have a lot of other Fed Ex facilities using this same method of handling cosmetic washing. . an NOD seemed appropriate to get them to put in a system that will work: long term. We will be issuing a permit for activities at these sites that would contravene water quality standards when they discharge. Ultimately we need to get them to come up with a system that will not be based upon "we promise not to discharge to the nearby stormdrains". Another one we have is a ready mix facility that never put in any treatment basins for their mixing drum wastewater or stormwater runoff. We had to permit them because we had inadvertently had the permit for over a year or so and we felt obligated to go ahead and issue. So, in that case, going in and issuing an NOV for a permit we issued knowing the discharges couldn't meet the permit requirements seemed to me like it is indicating we permitted something we shouldn't have. At any rate. We're having fun, it's all good. We'll reissue NOV's as soon as I get dug out down here. I could use some input on MRS Inc. . if you or Shelton can call me about this one, I'd sure appreciate it. Given I haven't done many enforcements for WQ violations, this one is likely tricky and Ed informed me they have some high power lawyers involved. So, when you get a chance please? Next week I won't have time to work on anything since we are moving files on Monday and potentially Tues. and Wed -Friday I'm in Raleigh. Thanks. Linda John Hennessy wrote: For what is it worth, I think an NOV is warranted. How are they deficient? What are they deficient on? They don't have a permit. They do have a violation, however. Also, I know that management does not approve of NODS. They know that they are still used sometimes. But, I know they are uncomfortable with them. Obviously, it is your call. But, those are my thoughts for what it is worth. As to the permit issues. What we were discussing yesterday was whether we could, or should, withhold a permit based on non-compliance by a permittee. The short answer is we can. But, we shouldn't use it except in extreme circumstances, and would require discuss with upper management. What you are discussing in this situation is issuing, or denying, the permit based on its merits. That is a very different issue. The permit should always be judged on its own merits and decisions made accordingly. Well, that is my thoughts on the subject. Do with them what you will. I hope they helped. But, somehow, I suspect they didn't. I 3 of 7 6/20/2008 11 :3 l AM Re: [FNW: Re: NCGO80818 FedEx Winston-Salem May 26th, 20081 apologize if they didn't. Linda Willis wrote: Hi Jen, I won't issue an NOV. I sent a notice of deficiency, Ed beck (my supervisor} was in agreement that a notice of deficiency would be the best way to proceed. I did visit with him on this one before sending the notice. I think under the circumstances, we shouldn't issue a permit for a site that does not have a good plan for handlina this vehicle washing activity. Since it sounds like we have many of these fed ex sites that are not well equipped to handle their "cosmetic washing operations" we need to either impose the requirement to tap into a sanitary sewer or send their vehicles elsewhere for cosmetic washing. Or we are forced to trust that: they won'L be pumping these wash bays to stormdrains. Ed, would you like to weigh in? Linda Jennifer Jones wrote: Hey Linda, I spoke to Jahn Hennessy about this site and their discharge of truck: washing water directly to the storm drain. He told me this would be a violation and believes you should issue one to them - he said that he and Shelton Sullivan here can help you with that if you would like. In terms of issuing the permit -- it is rare that we would not issue a permit to someone that may have a stormwater violation - although apparently it has been done before. I think how to proceed would be to issue the NOV - perhaps after you tall: with the Compliance group in case I am missing something here? - and I will issue them their permit. I don't believe we send very many letters of deficiency now - especially to an organization that does not have a permit yet. *John - '-could you address this and let me know if Linda sends me the letter if I should proceed with sending it or. to FedEv corporate if we are going to /also /issue an NOV? *A11 *- Let me know if you agree with how to handle this... Thanks for your help and doing such a good job Linda! Jen Linda Wi.liis wrote: I'll put them on the list for a site inspection soon. Hopefully this week, but work is stacl:ing up quite a bit since we've lost one of our staff and are in the process of training someone new. Linda Jennifer Jones wrote: 4 of 7 6/20/2008 l 1:31 AM Re: [Find: Re: NCG080818 Fed Ex Winston-Salem May 26th, 20081 y Ok - sounds good. It does sound like she's saying they are covering the SW drain and capturing runoff at the moment - but are you concerned about the long term? I agree with your comments if they are hauling it - and even if they had access to municipal systems they MS might not want it and/or might ask them do to some kind of pretreatment... sounds like pump and haul would be their best bet. 1'll talk to Rose and let you know what she says. If Ed says anything about it can you let me know? You always do such a thorough job - thanks Linda!! Jen Linda Willis wrote: Seems risky to believe they are covering the storm drain, we've made facilities put in discharge to municipal systems. This particular facility as well as Rose's (likely) won't have access to municipal systems. I'd think they would be required to put in some kind of recycle system that over time gets pumped out and hauled off for proper disposal. I'll have to talk to Ed Beck about how we should proceed. Thanks for the heads up. linda Jennifer Jones wrote: IHey Linda, Ok I think I might have killed both your and my email with that last one. I am resending this to you and forwarding Rose's email for their Winston facility (below). Sorry For the previous huge email! Jen Sorry to get back to you late - Here is the map and NOI. Their address is: 2414 North 23rd Street Wilmington, NC 28401. I'll also forward Rose Pruitt's comments - she went to the FedEx place in Winston and looked at their vehicle washing - you might find a similar thing in Wilmington...? Let me know if you have any questions... Thanks 5 of 7 6/20/2008 1 1:3l AM Re: [Fwd: Re: NCC,080818 FedE\ WInSt0]1 Saleni May 26th, 2008] Linda!! r Jen --------- original Message --------- Subject: Re: NCG080818 FedEx Winston-Salem May 26th, 2008 Date: Thu, 01 May 2008 12:51:32 -0400 From: Rose Pruitt <Rose.Pruitt_@ncmail.net> Reply -To: Rose.Pruitt@N�mail.net Organization: NC DENR - Winston-Salem Regional Office To: Jenni�er.Jones@nc_nail.net References: <48i253C7.3000?07@ncmail.net> Jennifer, OK to issue this permit. I went out to the site and asked about the vehicle washing. fed ex is washing approx 25 vehicles a week at their site. They have a contract mobile unit that covers the SW drain and captures the runoff. They were in the process of paving a side lot with no SW drains and will move the mobile washing there when complete. Rose Pruitt NCDENR-DWQ Winston-Salem Regional Office Division of Water Quality, Surface Water Protection 585 Waughtown Street Winston-Salem, NC 27107 Voice: (336) 771-5000 FAX: (336) 771-4630 On 4/25/2008 5:57 PM, Jennifer Jones wrote: Dear Rose, We've received an NOI from Fedex Ground. in Winston. -Salem (Forsyth County) for coverage of their small package distribution center under NCGO8 (Transportation SW permit). The site discharges stormwater into a UT to Salem Creek (C). The NOT is attached. They did state on their NOI that they were doing some "cosmetic vehicle washing". If you have a chance to go out there could you try to see that and/or ask them about that - it is not included under our SW permit but would like to know if it is very minor or if they are doing it all the time and where it is going etc. Does the Winston-Salem Regional Office have any concerns about issuing this facility a COC 6 of'7 6/20/2008 1 1:31 AM Re: [FNVd: Re: NCG080818 FedEx Winston-Salem May 26th, 20081 1. for this general permit? If we don't receive any objections, we'll issue the COC in 30 days. Thanks, Jen Jones Jennifer Jones Environmental Engineer NCDENR I DWQ I Stormwater Permitting Unit 1617 Mail Service Center, Raleigh, NC 27699-1617 512 N. Salisbury St, Raleigh, NC 27604 Phone: (919) 733-5083 ext. 591 Fax: (919) 733-9612 Email: jennifer.jones@ncmail.net Websi:e: http://h2o.enr.state.nc.us/su/stormwater.html 7 of 7 6/20/2008 1 1:31 AM Re: [FNvd: Re: NCGO80818 Fed Ex Winston-Salem May 26th, 20081 Subject: Re: [Fwd: Re: NCGO80818 FedEx Winston-Salem May 26th, 20081 From: Linda Willis <Linda.Willis a ncmail.net> Date: Fri, 13 Jun 2008 10:16:43 -0400 To: John Hennessy <John.Hennessy aNCMail.net> CC: Jenniler.Jones a ncmail.net, Ed Beck DWQ-WRO <ed.beck a ncmail.net> John, Thanks for your thoughts. They are worthwhile. Just to give some background on this. . since we were likely to give them a NCGO80 permit . . and we have a lot of other Fed Ex facilities using this same method of handling cosmetic washing. . an NOD seemed appropriate to get them to put in a system that will work long term. We will be issuing a permit for activities at these sites that would contravene water quality standards when they discharge. Ultimately we need to get them to come up with a system that will not be based upon "we promise not to discharge to the nearby stormdrains". Another one we have is a ready mix facility that never put in any treatment basins for their mixing drum washwater or stormwater runoff. We had to permit them because we had inadvertently had the permit for over a year or so and we felt obligated to go ahead and issue. So, in that case, going in and issuing an NOV for a permit we issued knowing the discharges couldn't meet the permit requirements seemed to me like it is indicating we permitted something we shouldn't have. At any rate. We're having fun, it's all good. We'll reissue NOV's as soon as I get dug out down here. I could use some input on MRS Inc. . if you or Shelton can call me about this one, I'd sure appreciate it. Given I haven't done many enforcements for WQ violations, this one is likely tricky and Ed informed me they have some high power lawyers involved. So, when you get a chance please? Next week 1 won't have time to work on anything since we are moving files on Monday and potentially Tues. and Wed -Friday I'm in Raleigh. Thanks. Linda John Hennessy wrote: For what is it worth, I think an NOV is warranted. How are they deficient? What are they deficient on? They don't have a permit. They do have a violation, however. Also, I know that management does not approve of NODS. They know that they are still used sometimes. But, I know they are uncomfortable with them. Obviously, it is your call. But, those are my thoughts for what it is worth. As to the permit issues. What we were discussing yesterday was whether we could, or should, withhold a permit based on non-compliance by a permittee. The short answer is we can. But, we shouldn't use it except in extreme circumstances, and would require discuss with upper management. What you are discussing in this situation is issuing, or denying, the permit based on its merits. That is a very different .issue. The permit should always be judged on its own merits and decisions made accordingly. Well, that is my thoughts on the subject. Do with them what you will. I hope they helped. But, somehow, I suspect they didn't. I apologize if they didn't. Linda Willis wrote: I Hi Jen, I won't issue an NOV. I sent a notice of deficiency, Ed beck (my supervisor) was in agreement that a notice of deficiency would be the best way to proceed. I did visit with him on this one before sending the notice. I think under the circumstances, we shouldn't issue a permit for a site that does not have a good plan for handling this vehicle washing activity. Since it sounds like we have many of these fed ex sites that are not well equipped to handle their "cosmetic washing operations" we need to either impose the requirement to tap into a sanitary sewer or send their vehicles elsewhere for cosmetic washing. Or we are forced to trust that they won't be pumping these wash bays to stormdrains. Ed, would you like to weigh in? I of 4 6/ 13/2008 1:45 PM Re: [Fwd: Re: NCGO80818 FedEx Winston-Salem Mav 26th, 2008] Linda Jennifer Jones wrote: Hey Linda, I spoke to John Hennessy about this site and their discharge of truck washing water directly to the storm drain. He told me this would be a violation and believes you should issue one to therzt - he said teat he and Shelton Sullivan here can help you with that if you would like. in terms of issuing the permit - it is rare that we would not issue a permit to someone that may have a stormwater violation - although apparently it has been done before. I think how to proceed would be to issue the NOV - perhaps after you talk with the Compliance group in case I am missing something here? - and I will issue them their permit. I don't believe we send very many letters of deficiency now - especially to an organization that does not have a permit yet. 'John - *could you address this and let me know if Linda sends me the letter if I should proceed with sending it on -o EedEx corporate if we are going to /also /issue an NOV? *All '- Let me know if you agree with how to handle this... Thanks for your help and doing such a good job Linda! Jen Linda Willis wrote: I'll put them on the list for week, but work is stacking up staff and are in the process Linda a site inspection soon. Hopefully this quite a bit since we've lost one of our of training someone new. Jennifer Jones wrote: Ok - sounds good. It does sound like she's saying they are covering the SW drain and capturing runoff at the moment - but are you concerned about the long term? I agree with your comments if they are hauling it - and even if they had access to municipal systems they MS might not want it and/or might ask them do to some kind of pretreatment... sounds like pump and haul would be their best bet. I'll talk to Rose and let you 'Know what she says. If Ed says anythina about it can you let me know? You always do such a thorough job - thanks Linda!! Jen Linda Willis wrote: Seems risky to believe they are covering the storm drain, we've made facilities put in discharge to municipal systems. This particular facility as well as Rose's (likely) won't have access to municipal systems. I'd think they would be required to put in some kind of recycle system that over time gets pumped out and hauled off for proper disposal. I'll have to talk to Ed Beck about how we should proceed. Thanks for the heads up. linda 2 of4 6/13/2008 1:45 PM Re: [F%v& Re: NCGO80818 FedEx Winston-Salem May 26th, 20081 Jennifer Jones wrote: Hey Linda, Ok I think I might have killed both your and my email with that last one. I am reseeding this to you and forwarding Rose's email for their Winston facility (below). Sorry for the previous huge email! Jen Sorry to get back to you late - Here is the map and NOI. 'their address is: 2414 North 23rd Street Wilmington, NC 26401. I'll also forward Rose Pruitt's comments - she went to the FedEx place in Winston and looked at their vehicle washing - you might find a similar thing in Wilmington...? Let me know if you have any questions... Thanks Linda!! Jen -------- Original Message -------- Subject: Re: NCGO80818 FedEx Winston-Salem May 26th, 2008 Date: Thu, 01 May 2008 12:51:32 -0400 From: Rose Pruitt <Rose.Pruitt@ncmail.net> Reply -To: Rose.Pruitt@NCmail.net Organization: NC DENR - Winston-Salem Regional Office To: Jeniiifer.Jones@ncmail.net References: <481253C7.3000307@ncmail.net> Jennifer, OK to issue this permit. I went out to the site and asked about the vehicle washing. fed ex is washing approx 25 vehicles a week at their site. They have a contract mobile unit that covers the SW drain and captures the runoff. They were in the process of paving a side lot with no SW drains and will move the mobile washing there when complete. Rose Pruitt NCDENR-DWQ Winston-Salem Regional Office Division of Water Quality, Surface Water Protection 585 Waughtown Street Winston-Salem, NC 27107 Voice: (336) 771-5000 FAX: (336) 771-4630 On 4/25/2008 5:57 PM, Jennifer Jones wrote: IDear Rose, 3 of 6/13/2008 1:45 PM Re: [FNv& Re: NCGO80818 FedEx Winston-Salem May 26th, 2008] We've received an NOI from Fedex Ground. in Winston --Salem (Forsyth County) for coverage of their small package distribution center under NCG08 (Transportation SW permit). The site discharges stormwater into a U_ to Salem Creek (C). The NOI is attached. They dial state on their NOT that they were doing some "cosmetic vehicle washing". If you have a chance to go out there could you try to see that and/or ask them about that - it is not included under our SW permit but would like to know if it is very minor or if they are doinc it all the time and where it is going etc. Does the Winston-Salem Regional Office have any concerns about issuing this facility a COC for this general permit? If we don't receive any objections, we'll issue the CCC in 30 days. Thanks, Jen Jones Jennifer Jones Environmental Engineer NCDENR I DWQ I Stormwater Permitting Unit 1617 Mail Service Center, Raleigh, NC 27699-1617 512 N. Salisbury St, Raleigh, NC 27604 Phone: (919) 733-5083 ext. 591 Fax: (919) 733-9612 Email: jennifer.jones@ncmail.net Website: httT)://hlo.enr.state.nc.tis/su/stormwater.html Linda Willis <linda.wil[is u nemail.net> Environmental Engineer Surface Water Protection Section Division Of Water Quality 4 of4 6/13/2008 1:4i PM FedEx Ground Environmental Services P.O. Box 108 Pittsburgh, PA 15230 PHONE (412) 262-7347 FAX (412) 859-2232 LETTER OF TRANSMITTAL PR p SENT: FedEx CERTIFIED MAIL X TO: NC Division of Water Quality DATE: March 28, 2008 Stormwater Permitting Unit RE: FedEx Ground Facilities: 1617 Mail Service Center 2414 North 23`d Street Raleigh, NC 27699-1617 Wilmington, NC 28401 3946 Westpoint Blvd Winston-Salem, NC 27103 WE ARE SENDING YOU: X Enclosed File Partially Executed Drawings Copies Fully Executed COPIES DATE DESCRIPTION 1 03/28/08 Notice of Intent — Wilmin on, NC 1 02/28/08 Too Ma — USGS Castle Ha e C Quadrangle 1 03/28/08 Notice of Intent — Winston-Salem, NC 1 02/28/08 Top Ma — USGS Winston-Salem West (NC) uadran le 1 03/24/08 Check No. 1729379 in the amount of $200,00 THESE ARE TRANSMITTED as checked below: For Execution Approved as Submitted Return Co s for File For Your Use A roved as Noted Resubmit for Approval As Requested Returned for Correction Return Corrected X As R uired Other eturned For Your Signature REMARKS: cc: File FROM: Nancy Beaumont MS4 Environmental Administrator 412-262-7347