NCG050421_NOV_20191112

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
CERTIFIED MAIL: 7012 3050 0001 9398 7423
RETURN RECEIPT REQUESTED
NORTH CAROLINA
Environmental Quality
November 12, 2019
Quickie Manufacturing Corporation
Attn: Shawn Squires, Plant Manager
2880 Kenny Biggs Road
Lumberton, NC 28358
Subject: NOTICE OF VIOLATION (NOV-2019-PC-0732)
NPDES Stormwater General Permit NCGO50000
Quickie Manufacturing Corporation
Quickie Manufacturing, Certificate of Coverage NCGO50421
Robeson County
Dear Mr. Squires:
On November 5, 2019, Mike Lawyer, Environmental Program Consultant, and Penny Markle, Environmental Specialist,
with the Fayetteville Regional Office of the Division of Energy, Mineral and Land Resources (DEMLR), conducted a site
inspection for the Quickie Manufacturing facility located at 2880 Kenny Biggs Road, Lumberton, Robeson County, North
Carolina. A copy of the Compliance Inspection Report is enclosed for your review. Mr. James Randy Hunt, Facility
Coordinator, Ms. Robin Kuhl, Safety Coordinator, and Ms. Clorissa Rose, .EHS Leader, 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 NCG050000 under Certificate of Coverage NCG050421. Permit
coverage authorizes the discharge of stormwater from the facility to receiving waters designated as Gum Branch Canal,
class C;Sw waters in the Lumber River Basin.
As a result of the site inspection, the following violation of permit conditions 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.
Action Items -
Conduct and record Qualitative Monitoring per the conditions of NPDES Stormwater General Permit NCG050000.
-..�North Carolina Department of Environmental Quality I Division of Energy. Mineral and Land Resources
:—D E Q� Fayetteville Regional Office 1 225 Green Street, Suite 7141 Fayetteville, North Carolina 28301
NORT) CAROHNA '�
twpaM—tmftwf. eMWIQ IN 910.433.3300

Thank you for your attention to this matter. This office requires that the violation, as noted above and detailed in the
enclosed Compliance Inspection Report, 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 or
concerns, please contact Mike Lawyer at [phone] or via e-mail at [e-mail].
Sincerely,
Ti eothyL. LaB ty, PE
Regional Engineer
DEMLR
TL/ml
Enclosure: Compliance Inspection Report
ec: James Randy Hunt, Facility Coordinator —Quickie Manufacturing
Robin Kuhl, Safety Coordinator — Quickie Manufacturing
Clorissa Rose, EHS Leader — Quickie Manufacturing
William E. (Toby) Vinson, Jr., PE, CPESC, CPM, Program Operations Chief — DEMLR
Annette Lucas, PE, Stormwater Program Supervisor— DEMLR, Stormwater Program
Alaina Morman, Environmental Specialist — DEMLR, Stormwater Program
cc: FRO — DEMLR, Stormwater Files

Permit: NCG050421
SOC:
County: Robeson
Region: Fayetteville
Contact Person: Robin Kuhl
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Compliance Inspection Report
Effective: 06/01/18 Expiration: 05/31/23 Owner: Quickie Manufacturing Corporation
Effective: Expiration: Facility: Quickie Manufacturing
2880 Kenny Biggs Rd
Title: Safety Coordinator
Certification:
Lumberton NC 28358
Phone: [phone] Ext.1000
Phone:
On -site representative James Randy Hunt 910-737-6500
On -site representative Clorissa Rose 620-221-8620
On -site representative Robin Kuhl 910-737-6500 ext 100(
Related Permits:
NCGNE0747 Quickie Manufacturing Corporation - Quickie Manufacturing
Inspection Date: 11/05/2019 Entry Time: 01: OPM Exit Time: 04:10PM
Primary Inspector: Mike Lawyei��' 7� Phone: [phone] Ext
339Y
Secondary Inspector(s):
Penny Markle'�p'�
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Apparel/Printing/Paper/Leather/Rubber Stormwater Discharge COC
Facility Status: ❑ Compliant N Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 3

Permit: NCG050421 Owner - Facility: Quickie Manufacturing. Corporation
Inspection Date: 11/05/2019 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Inspection conducted to determine compliance with the conditions of NPDES Stormwater General Permit NCG050000.
Facility initially obtained coverage under the NCG050000 permit on May 14, 2014 and coverage was subsequently renewed
in June 2018. This was the first compliance inspection for the facility. Met with Mr. James Randy Hunt, Facility Coordinator,
Ms. Robin Kuhl, Safety Coordinator, and Ms. Clorissa Rose, EHS Leader. Reviewed the facility's Stormwater Pollution
Prevention Plan (SPPP), which was dated April 2018 with revisions in July 2019. The SPPP appeared to contain all
permit -required components with the exception of an updated list of significant spills or leaks during the previous three years
or notation that none have occurred. Information regarding oil spills/leaks that had occurred in 2014 concerning a
compressor was listed in the SPPP. A recommendation was made to better document the annual review and update
requirements per Part II, Section A, item 8 of the SPPP conditions contained in the permit.
The NCG050000 permit requires Qualitative (visual) Monitoring to be conducted on a semi-annual schedule (January -June,
July -December) at all stormwater discharge outfalls. A discussion regarding the number and location of stormwater outfalls
associated with industrial activity was held. There appears to be three outfalls where a portion of the ditch that runs along
the western side of the property conveys stormwater to the southeast toward Kenny Biggs Road. The remaining portion of
the ditch conveys stormwater to the northwest toward the back of the facility and a retention pond on the eastern side of the
property conveys stormwater through an outlet pipe directly to Gum Branch Canal. When asked to review the facility's
Qualitative Monitoring records, only one record was presented, which was for the first half of 2019 indicating that there had
been no qualifying storm events from January to July 2019. Facility personnel were advised that a Notice of Violation would
be issued for non-compliance with the Qualitative Monitoring requirements of the NCG050000 permit. Regarding the
Analytical Monitoring requirements for onsite vehicle maintenance activities, facility personnel relayed that the facility does
not use more than 55 gallons of new motor oil or hydraulic oil per month.
After the records review, observations were made of stormwater outfall locations, loading docks, open -top dumpsters for
metal scrap and other waste as well as general site conditions. At the time of inspection, the facility appeared to be well
operated and maintained.
Page 2 of 3

Permit: NCG050421 Owner - Facility: Quickie Manufacturing Corporation
Inspection Date: 11/05/2019 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"?
0 ❑ ❑ ❑
# 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?
❑ ❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
0 ❑ ❑ ❑
# Does the facility provide all necessary secondary containment?
❑ ❑ 0 ❑
# Does the Plan include a BMP summary?
N ❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
N ❑ ❑ ❑
# 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)?
0 ❑ ❑ ❑
# Is the Plan reviewed and updated annually?
0 ❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
0 ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
0 ❑ ❑ ❑
Comment: Minor revisions needed to facility's SPPP to better document the annual review and update
requirements per Part II Section A, item 8 of the NCG050000 permit. Specifically, an updated list
of significant spills for the previous three years or notation that none have occurred.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ❑ E ❑ ❑
Comment: Facility personnel could only provide one record of Qualitative Monitoring for the first half of 2019,
which indicated that there had been no qualifying storm events during that period.
Analytical Monitorinq Yes No NA NE
Has the facility conducted its Analytical monitoring? ❑ ❑ 0 ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ 1:10 ❑
Comment:
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? 0 ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ E ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ❑ ❑ ❑
Comment:
Page 3 of 3