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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