NCG240014_NOV_20190925

ROY COOPER
Governor
MICHAEL S. REGAN
Secretory
S. DANIEL SMITH
Director
CERTIFIED MAIL: 7015 0640 0007 8168 5598
RETURN RECEIPT REQUESTED
NORTH CAROLINA
Environmental Quality
September 25, 2019
Cumberland County Solid Waste Management
Attn: Amanda Bader, Cumberland County Solid Waste Management Director -
698 Ann Street
Fayetteville, NC 28301
Subject: NOTICE OF VIOLATION (NOV-2019-PC-0634)
NPDES Stormwater General Permit NCG240000
Cumberland County Solid Waste Management
Wilkes Road Yard Waste Facility, Certificate of Coverage NGG240014
Cumberland County
Dear Ms. Bader:
On August 26, 2019, Melissa Joyner from the Fayetteville Regional Office of the Division of Energy, Mineral and Land
Resources (DEMLR), conducted a site inspection for the Wilkes Road Yard Waste facility located at 771 Wilkes Road,
Cumberland County, North Carolina. A copy of the Compliance Inspection Report is enclosed for your review. Chad
McLean, Solid Waste Management Landfill Operations Manager, Tim Middleton, Wilkes Road Facility Solid Waste
Equipment Supervisor and Jared Hamela, P.G., SCS Engineers, PC, Senior Project Geologist were also present during
the inspection and their time and assistance is greatly appreciated. A follow-up meeting occurred on September 20, 2019,
where Melissa Joyner, and Tim LaBounty, Fayetteville Regional Office Supervisor meet with the aforementioned
individuals as well as Neil Cunnington, Wilkes Road Solid Waste Heavy Equipment Supervisor. Technical information was
discussed and additional monitoring records were reviewed. The site visits and file reviews revealed that the subject
facility is covered by NPDES Stormwater General Permit NCG240000 under Certificate of Coverage NCG240014. Permit
coverage authorizes the discharge of stormwater from the facility to receiving waters designated as Pearces Mill Creek
(McPieces Creek), a Class C waterbody in the Cape Fear River Basin.
As a result of the site inspection, the following permit conditions violations are noted
1) Stormwater Pollution Prevention Plan (SPPP)
A Stormwater Pollution Prevention Plan (SPPP) has not been properly implemented.
2) Qualitative Monitoring
Qualitative monitoring has not been conducted and recorded in accordance with permit requirements.
3) Analytical Monitoring
Analytical monitoring has not been conducted and recorded in accordance with permit requirements.
Other Observations:
Please refer to the enclosed Compliance Inspection Report for additional comments and observations made during the
inspection.
Requested Response:
You are asked to respond to this office, in writing, within 30 calendar days from receipt of this notice. Your written
response should include a reasonable explanation as to why the aforementioned violations have occurred as well as a
Plan of Action;zi�7;n
tiolatjclgs from recurring.
Q�v North Carolina Department of Environmental Quality 1 Division of Energy. Mineral and Land Resources
Fayetteville Regional Office 1225 Green Street Suite 7141 Fayetteville, North Carolina 28301
z 910.433.3300

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
$26,000 per day for each violation. Should you have any questions regarding these matters, please contact inspector or
myself at [phone].
Sincerely,
Timothy L. LaBounty, PE
Regional Engineer
-DEMLR-
TLL/maj
Enclosure: Compliance Evaluation Inspection and Technical Assistance Reports
ec: 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)
Chad McLean, Landfill Operations Manager, Cumberland County Solid Waste Management (via email)
Tim Middleton, Solid Waste Equipment Supervisor, Wilkes Road Facility,Cumberland County Solid Waste
Management (via email)
Neil Cunnington, Wilkes Road Solid Waste Heavy Equipment Supervisor (via email)
Jared T. Hamela, P.G., Senior Project Geologist, SCS Engineers, PC (via email)
cc: FRO — DEMLR, Stormwater Files

Permit: NCG240014
SOC:
County: Cumberland
Region: Fayetteville
Compliance Inspection Report
Effective: 10/02/17 Expiration: 09/30/22 Owner: Cumberland County Solid Waste
Management
Effective: Expiration: Facility: Wilkes Road Yard Waste Facility
771 Wilkes Rd
Contact Person: Amanda Bader Title:
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: O812612019 Entry Time: 09:OOAM
Primary Inspector: Melissa A Joyner
Secondary Inspector(s):
Fayetteville NC 28301
Phone: [phone]
Certification: Phone:
Exit Time: 10:30AM
Phone:
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Compost Operations Stormwater/Wastewater Discharge COG
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 3

Permit: NCG240014 Owner • Facility: Cumberland County Solid Waste Management
Inspection Dale: 08/26/2019 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Melissa Joyner, Inspector, met with Amanda Bader, Cumberland County Solid Waste Management Director, Chad McLean,
Solid Waste Management Landfill Operations Manager, Tim Middleton, Wilkes Road Facility Solid Waste Equipment
Supervisor and Jared Hamela,P.G., Senior Project Geologist, SCS Engineers,PC at the Wilkes Road Yard Waste Facility.
Jeff Brown is still shown in the database as the Owner and Contact for this facility. A Permit Owner Affiliaticin Designation
Form will need to be submitted to the DEMLR - Stormwater Program in Raleigh, NC with the updated contact information.
The Stormwater Pollution Prevention Plan (SPPP) was reviewed. The Site Map will need to be updated showing the location
of the double -sided Above Ground Storage Tank on the site and the updated usage of part of the closed LCID Landfill area.
Information should be included in the SPPP about the AST, the materials it contains and the associated secondary
containment area. Employee Annual -Training was -documented in May 2019_ In the SPPP there -was no updated list of ----- --- -
significant spills or leaks of pollutants for the previous three years, or a statement that significant spills or leaks had not
occurred. There was also no written certification that the stormwater outfall had been evaluated for the presence of
non-stormwater discharges and no annual documented re-evaluation of the effectiveness of the on -site Best Management
Practices, The records for the semi-annual facility inspections which are required under the Preventative Maintenance and
Good Housekeeping Program were not available for review. There were also no Analytical or Monitoring Records available for
review. Ms. Bader was going to check for additional records and send Ms. Joyner this information.
The facility grounds and Ouffalls # 1 and #2 were inspected. No Analytical or Qualitative Monitoring had occurred at these
Outfalls since 2018 because of the lack of positive drainage. It was discussed during the inspection about the possible
relocation of these Ouffalis where monitoring would be able to occur. There will be a follow-up site meeting where this will be
investigated more fully. Quarterly Analytical and Qualitative Monitoring will need to be initiated immediately after the
locations of the Outfalls have been modified. The Outfalls will need to be monitored for processed wastewater. An Annual
Discharge Monitoring Form should be completed and sent to the Division of Water Resources (see address on form) by
March 1 at of each year. If a discharge does not occur during a monitoring quarter the notation of "No Discharge" should be
written on the form. Failure to monitor and report per the permit terms may result in the Division requiring monthly monitoring
and reporting for all paramenters for a specified time period. Also, if there is an exceedance of an effluent limitation, that is
considered a violation of the Permit.
Additional information was sent via email to the Inspector after the inspection which included an updated Site Map. Data
from Analytical Monitoring for stormwater, not wastewater, which occurred during 2014-2016 was also emailed to the
Inspector. The monitoring was not done according to the stormwater monitoring schedule per General Permit NCG240000.
Exceedances of the benchmark values were noted for Chemnical Oxygen Demand (COD) on 9/30/2014 and for Fecal
coliform on 6/30/2015.
Page 2 of 3

permit: NGG240014 Owner. Facility: Cumberland County Solid Waste Management
Inspection Date: 08126/2019 Inspection Type: Compliance Evaluation Reason for Visa: Routine
Stormwater Pollution Prevention Plan
Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan?
❑ ❑ ❑
# Does the Plan include a General Location (USGS) map?
❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices'?
❑ ❑ ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
N ❑ ❑ ❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
❑ 0 ❑ ❑
- -- #- Has -the facility evaluated -feasible -alternatives -to current practices? - -- - - - -- - -
- - ❑ -E ❑-❑- - - - -
# Does the facility provide all necessary secondary containment?
E ❑ ❑ ❑
# Does the Plan include a BMP summary?
0 ❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
E ❑ ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
0 ❑ ❑ ❑
# Does the facility provide and document Employee Training?
0 ❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
E ❑ ❑ ❑
# Is the Plan reviewed and updated annually?
❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
❑ E ❑ ❑
Comment: The Stormwater Pollution Prevention Plan has not been annually implemented.
Qualitative Monitorina Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ❑ 0 ❑ ❑
Comment: The facility has not conducted its Qualitative Monitoring semi-annually.
Analytical Monitorina Yes No NA NE
Has the facility conducted its Analytical monitoring? ❑ M ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ ❑
Comment: The facility has not conducted its Analytical Monitoring semi-annually.
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? 0 ❑ ❑ ❑
# Were all outfalls observed during the inspection? - N ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ N ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ❑ 0 ❑ ❑
Comment:
Page 3 of 3

Compliance Inspection Report
Permit: NCG240014 Effective: 10/02/17 Expiration: 09/30/22 Owner: Cumberland County Solid Waste
Management
SOC: Effective: Expiration: Facility: Wilkes Road Yard Waste Facility
771 Wilkes Rd
County: Cumberland
Region: Fayetteville
Fayetteville NC 28301
Contact Person: Amanda Bader Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 0912012019 Entry Time: 09:30AM
Primary Inspector: Melissa A Joyner
Secondary Inspector(s):
Certification:
Phone:
Exit Time: 11:30AM
Phone:
Tim L LaBounty
Reason for Inspection: Routine Inspection Type: Technical Assistance
Permit Inspection Type: Compost Operations Stormwater/Wastewater Discharge CDC
Facility Status: Compliant ❑ Not Compliant
Question Areas:
M Storm Water
(See attachment summary)
Page 1 of 3

permit: NCG240014 Owner- Facility: Cumberland County Solid Waste Management
Inspection Date: 09/20/2019 Inspection Type : Technical Assistance Reason for Visit: Routine
Inspection Summary:
On Friday, 9/20/2019, Melissa Joyner and Tim LaBounty, Fayetteville Regional Office Supervisor, met on -site with Amanda
Bader, Chad McLean, Tim Middleton, Jared Hamela and Neil Cunnington, Wilkes Road Facility Heavy Equipment
Supervisor. There was a discussion about the location of the two Outfalls on the site and about possible site modifications. It
was recommended that a Representative Outfall Status Request Form be immediately sent to the Fayetteville Regional
Office. There was also discussion about the Total Flow volume which would be recorded by a continuous flow measurement
instrument per the conditions in the General Permit. Possible site modifications will need to occur by March 31, 2020. In the
interim, the outfalls will need to be monitored in accordance with the conditions in General Permit NCG240000.
-- - During this meeting; additional records were reviewed for Analytical -Monitoring -during -2017.. Exceedances-of benchmark- - - -- - -
values were not noted. Qualitative Monitoring records were also reviewed for 2014, 2015 and 2019. The Analytical and
Qualitative monitoring were not conducted according to the stormwater monitoring schedule. Semi-annual facility inspections
were reviewed for 2019, but were not recorded for other years. The Site Map will need to be updated with the new locations
of the Outfalls.
Page 2 of 3

permit:
NCG240014
Owner- Facility: Cumberland County Solid Waste Management
Inspection Date:
09/20/2019
Inspection Type : Technical Assistance
Reason for Visit:
Routine
Page 3 of 3