HomeMy WebLinkAboutNCG180253_NOV_20190716ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
July 16, 2019
CERTIFIED MAIL: 7012 3050 0001 9398 7409
RETURN RECEIPT REQUESTED
American Woodmark Corporation
Attn: Robert Young, Director of Operations Hamlet NC
200 Development Drive
Hamlet, NC 28345
Subject: NOTICE OF VIOLATION (NOV-2019-PC-0513)
NPDES Stormwater General Permit NCG180000
American Woodmark Corporation
Certificate of Coverage NCG180253
Richmond County
Dear Mr. Young:
On July 11, 2019, Mike Lawyer, Environmental Program Consultant with the Fayetteville Regional Office of the Division of
Energy, Mineral and Land Resources (DEMLR), conducted a site inspection for the American Woodmark Corporation
facility located at 200 Development Drive, Hamlet, Richmond County, North Carolina. A copy of the Compliance
Inspection Report is enclosed for your review. Ms. Stephanie Kane, EHS Supervisor Hamlet, and Mr. Bobby Goode, EHS
Supervisor Lincolnton, were also present during the inspection and their time and assistance is greatly appreciated. The
site visit and file review revealed that the subject facility is covered by NPDES Stormwater General Permit NCG180000
under Certificate of Coverage NCG180253. Permit coverage authorizes the discharge of stormwater from the facility to
receiving waters designated as Marks Creek, a Class C waterbody in the Yadkin -Pee Dee River Basin.
As a result of the site inspection, the following permit condition violation is noted:
1) Qualitative Monitoring
Qualitative 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 violation has occurred as well as a Plan
of Action to prevent this violation from recurring.
m'4 North Carolina Department of Environmental Quality 1 Division of Energy. Mineral and Land Resources
EQ
! Fayetteville Regional Office 1 225 Green Street, Suite 7141 Fayetteville, North Carolina 28301
NORTI: G1R041Nd
OepeMnent of Etwlrommmt�ulmlit, 910.433.3300
Thank you for your attention to this matter. This office requires that the violation, as detailed above, be properly
resolved. This violation and any future violations are subject to a civil penalty assessment of up to $25,000 per
day for each violation. Should you have any questions regarding this matter, please contact Mr. Lawyer or myself at
(910) 433-3300.
Sincerely,
Timothy L. La nty, PE
Regional Engineer
DEMLR
TL/ml
Enclosure (Compliance Inspection Report)
ec: Stephanie Kane, EHS Supervisor Hamlet — American Woodmark Corporation
Bobby Goode, EHS Supervisor Lincolnton — American Woodmark Corporation
Annette Lucas, PE, Stormwater Program Supervisor— DEMLR, Stormwater Program
Alaina Morman, Environmental Specialist — DEMLR, Stormwater Program
cc: FRO — DEMLR, Stormwater Files
Compliance Inspection Report
Permit: NCG180253 Effective: 11/16/16 Expiration: 08/31/19 Owner: American Wood mark Corporation
SOC: Effective: Expiration: Facility: American Woodmark Corporation
County: Richmond 200 Development Dr
Region: Fayetteville
Hamlet NC 28345
Contact Person: Robert Young Title: Director of Operations Hamlet NC Phone: 910-716-6531
Directions to Facility:
take exit 319 from 1-74 and turn north onto NC 38N, from NC 38N, turn left onto Freeman Mill Rd, the site will be on the left 0.7 miles.
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
On -site representative Bobby Goode
On -site representative Stephanie Kane
Related Permits:
Inspection Date: 07/11/2019 I;ptry Time: 01 � OPM
Primary Inspector: Mike Lawye_%�
Secondary Inspector(s):
Exit Time: 03:35PM
Reason for Inspection: Routine Inspection Type
Permit Inspection Type: Furniture and Fixtures Stormwater Discharge COC
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Storm Water
(See attachment summary)
828-428-5130
910-716-6532
Phone: 910-433-3300 Ext,7_2
33?'/
Compliance Evaluation
Page 1 of 3
Permit: NCG180253 Owner -Facility: American Woodmark Corporation
Inspection Date: 07/11/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Inspection conducted to determine compliance with the conditions of NPDES Stormwater General Permit NCG180000.
Facility obtained coverage under the NCG180000 permit on November 16, 2016 with Certificate of Coverage NCG180253.
Met with Stephanie Kane, EHS Supervisor Hamlet, and Bobby Goode, EHS Supervisor Lincolnton. Mr. Goode expressed
that there had been significant staff turnover at the Hamlet facility in recent months. Facility's current Stormwater Pollution
Prevention Plan (SWPPP) is dated January 1, 2019 and was developed using an online template. Revisions and updates to
the SWPPP are on -going. Records of semi-annual qualitative monitoring of stormwater discharges as required by the
NCG180000 permit could not be provided for review. At the time of inspection, facility appeared to be well operated and
maintained. However, there are significant erosion issues adjacent to the stormwater ditch on the west side of the plant.
According to Mr. Goode, these areas have been evaluated and will be addressed.
Page 2 of 3
Permit: NCG180253 Owner -Facility: American Woodmark Corporation
Inspection Date: 07/1112019 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan
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?
# Does the Plan include a list of significant spills occurring during the past 3 years?
# Has the facility evaluated feasible alternatives to current practices?
# Does the facility provide all necessary secondary containment?
# Does the Plan include a BMP summary?
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
# Does the facility provide and document Employee Training?
# Does the Plan include a list of Responsible Party(s)?
# Is the Plan reviewed and updated annually?
# Does the Plan include a Stormwater Facility Inspection Program?
Has the Stormwater Pollution Prevention Plan been implemented?
Yes No NA NE
■❑❑❑
❑ ❑ ❑
■❑❑❑
N ❑ ❑ ❑
■❑❑❑
■❑❑❑
❑❑■❑
❑ ❑ ❑
■❑❑❑
■❑❑❑
E ❑ ❑ ❑
❑ ❑ ❑
■❑❑❑
■❑❑❑
❑ ❑ ❑
Comment: Regarding secondary containment there were no tanks or containers of liquid materials located
outside at the time of inspection.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ❑ E ❑ ❑
Comment: Qualitative monitoring has not been conducted and recorded in accordance with permit
conditions.
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? ❑ ❑ E ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ N ❑
Comment: Facility does not use more than 55 -gallons of new motor oil per month for onsite vehicle
maintenance. Therefore analytical monitoring is not required under the conditions of the
NCG180000 permit.
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? ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ❑
# Has the facility evaluated all illicit (non stormwater) discharges? E ❑ ❑ ❑
Comment: Facility has two stormwater discharge outfalls which are ditches leading to basins with overflow
pipes located on each side of the plant.
Page 3 of 3