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HomeMy WebLinkAboutNCG100164_Revised NOD_20190722ROY COOPER Governor MICHAEL S. REGAN Secretary S. DANIEL SMITH Director NORTH CAROLINA Environmental Quality July 22, 2019 CERTIFIED MAIL: 7015 0640 0007 8168 5512 RETURN RECEIPT REQUESTED Ed's Auto Service and Salvage Attn: Edward C. Schantz, President 6006 Raeford Road Fayetteville, NC 28304 Subject: NOTICE OF DEFICIENCY (NOD-2019-PC-0162) NPDES Stormwater General Permit NCG100000 Ed's Auto Service and Salvage, Certificate of Coverage NCG100164 Cumberland County Dear Mr. Schantz: On July 10, 2019, Melissa Joyner, from the Fayetteville Regional Office of the Division of Energy, Mineral and Land Resources (DEMLR), conducted a site inspection for the Ed's Auto Service and Salvage facility located at 1238 Slocomb Road, Cumberland County, North Carolina. A copy of the Compliance Inspection Report is enclosed for your review. Jennifer Pettit, Administrative Assistant and Jim Schantz, Manager 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 NCG100000 under Certificate of Coverage NCG100164. Permit coverage authorizes the discharge of stormwater from the facility to receiving waters designated as a UT to the Cape Fear River, a Class C waterbody, in the Cape Fear River Basin. As a result of the site inspection, the following deficiencies are noted: 1. Qualitative Monitoring Qualitative monitoring has not been conducted and recorded in accordance with permit requirements. 2. 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, 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 to prevent these violations from recurring. North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources Fayetteville Regional Office 1 225 Green Street, Suite 7141 Fayetteville, North Carolina 28301 mn.,um aunty .�waeapa� /"� 910.433.3300 Thank you for your attention to this matter. This office requires that the deficiencies, as noted above and detailed in the enclosed inspection report, be properly resolved. Failure to address the deficiencies could result in the issuance of a Notice of Violation, which is subject to a civil penalty assessment of up to $26,000 per day for each violation. Should you have any questions or concerns, please contact Melissa Joyner or myself at (910) 433-3300. Sincerely, TeothLa0ty.PE Regional Engineer DEMLR TLL/maj Enclosure: Compliance Evaluation Inspection Report ec: Annette Lucas, PE, Program Manager — DEMLR, Stormwater Permitting Program Alaina Morman, Environmental Specialist — DEMLR, Stormwater Permitting Program cc: FRO — DEMLR, Stormwater Files Compliance Inspection Report. Permit: NCG100164 Effective: 11/01/18 Expiration: 05/31/21 Owner: Ed's Auto Service And Salvage SOC: Effective: Expiration: Facility: Ed's Auto Service And Salvage County: Cumberland 1238 Slocomb Rd Region: Fayetteville Linden NC 28356 Contact Person: Edward C Schantz Title: President Phone: 910-864-3500 Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s(: Related Permits: Inspection Date: 07/10/2019 Primary Inspector: Melissa A Joyner Secondary Inspector(s): Certification: Phone: Entry Time: 01:05PM Exit Time: 02:40PM Phone: Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Used Motor Vehicle Parts Stormwater Discharge CDC Facility Status: ❑ Compliant N Not Compliant Question Areas: E Storm Water (See attachment summary) Pagel of 3 Permit: NCG100164 Owner - Facility: Ed's Auto Service And Salvage Inspection Date: 07/10/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine Inspection Summary: Melissa Joyner met with Mr. Ed Schantz, President and Jennifer Pettit, Administrative Assistant. The facility had received a Notice of Violations previously on November 27, 2017, for not conducting semi-annual Analytical and Qualitative monitoring in accordance with General Permit NCG100000 conditions. This issue was mostly addressed as discussed later in this Compliance Evaluation Report. The Stormwater Pollution Prevention Plan (SPPP) was reviewed and appeared neat and orderly. Since the previous inspection, a Solvent Management Plan has been developed so that Total Toxic Organics no longer needs to be monitored. Per General Permit NCG100000 conditions, the Solvent Management Plan requires an annually updated and quantified inventory of total toxic organics. An inventory was noted in the SPPP but it was not dated. The Analytical and Monitoring records were reviewed. Analytical and Qualitative Monitoring has been occurring semi-annually at Outfalls 1-3, since the previous inspection, except for Period 1, in 2019. Also, sampling occurred for Period 2, in 2018, on December 10, 2018, but the laboratory information did not include the results for this sampling date. Discharge Monitoring Report Forms should be submitted to the address on the form within 30 days from when the facility receives the sampling results from the laboratory. If there is no discharge from the outfall during a particular Period, than "No Discharge" should be stated on the form. The facility grounds and Outfalls 1-3 were inspected and appeared well -maintained with no issues noted. Page 2 of 3 Permit: NCG100164 Owner -Facility: Ed's Auto Service And Salvage Inspection Date: 07/10/2019 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? 0 ❑ ❑ ❑ # Does the Plan include a General Location (USGS) map? 0 ❑ ❑ ❑ # Does the Plan include a "Narrative Description of Practices'? E ❑ ❑ ❑ # Does the Plan include a detailed site map including outfall locations and drainage areas? 0 ❑ ❑ ❑ # 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? 0 ❑ ❑ ❑ # 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)? E ❑ ❑ ❑ # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? 0 ❑ ❑ ❑ # Does the facility provide and document Employee Training? M ❑ ❑ ❑ # Does the Plan include a list of Responsible Party(s)? 0 ❑ ❑ ❑ # Is the Plan reviewed and updated annually? 0 ❑ ❑ ❑ # Does the Plan include a Stormwater Facility Inspection Program? ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? ❑ ❑ ❑ Comment. Qualitative Monitoring 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 Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? ❑ 0 ❑ ❑ # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑E ❑ 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? E ❑ ❑ ❑ # If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ N ❑ # Has the facility evaluated all illicit (non stormwater) discharges? ❑ ❑ ❑ Comment. Page 3 of 3