NCGNE0571_COMPLETE FILE - HISTORICAL_20120914

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STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO. NCGNE
DOC TYPE I ❑ HISTORICAL FILE
DOCOATE o aola n9iu
YYYYMMDD

WDEHR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P.E.
Governor Director
September 14, 2012
M. J. Soffe Co.
Attn: Adrian Quinn, Director of Maintenance and Environmental
One Soffe Drive
Fayetteville, NC 28312
Subject: COMPLIANCE EVALUATION INSPECTION
M. J. Soffe, LLC
Stormwater No Exposure Certification-NCGNE0571
Cumberland County
Dear Mr. Quinn:
Dee Freeman
Secretary
On September 4, 2012, a site inspection was conducted for the M. J. Soffe Co. facility located at One
Soffe Drive, Cumberland County, North Carolina. A copy of the Compliance Inspection Report is
enclosed for your review. The site visit and file review revealed that the subject facility is covered by
Stormwater No Exposure Certification-NCGNE0571.
As a result of the inspection, the facility was found to be in compliance with the No Exposure
Certification requirements. Please refer to the enclosed Compliance Inspection Report for additional
comments and observations made during the inspection.
If you or your staff has any questions or comments, please contact me at [phone].
Sincerely,
Hughie White
Environmental Specialist
Enclosure
cc: FRO -Surface Water Protection (HW)
Niki Maher-WBS Compliance & Permits Unit
DWQ Central Files
location: 225 Green Street: Suite 714, Fayetteville, North Carolina 28301 One
Phone: [phone] FAX: [phone]Customer Service: 1.877-623.6748 NorthCarol.i_n.a
Internet: http://portal.ncdenr.org/web/wq Nati *all_ _
An Equal Opportun4 t Allirmaiive Action Employer ]J/

Compliance Inspection Report
Permit: NCGNE0571 Effective: 01/26/09 Expiration: Owner: M J Soffee LLC
SOC: Effective: Expiration: Facility: M J Soffe Co.
County: Cumberland One Soffe Dr
Region: Fayetteville
Fayetteville NC 28312
Contact Person: Adrian Quinn Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 09/04/2012 Entry Time: 02:00 PM Exit Time: 02:15 PM
Primary Inspector: Hughie White /�' l`c/ Phone: [phone]
Secondary Inspector(s): Ex� g
Mike Lawyer Phone: [phone] Ex�
33i? 9
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, -No Exposure Certificate
Facility Status: ® Compliant 0 Not Compliant
Question Areas:
® Miscellaneous Questions E Misc
(See attachment summary)
Page: 1

Permit: NCGNE0571 Owner - Facility: M J Soffee LLC
Inspection Date: 09/04/2012 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
This facility has a No Exposure Certification for industrial stormwater. A visual inspection of the property surrounding the
facility was conducted and no raw materials or finished product appeared to be exposed. Exposure of such materials
would void the No Exposure Certification and would then require a General Stormwater Permit.
MISc
Is the facility compliant?
Comment.-
■ 0 0 0
Page: 2

.. l�
:+Xe 0
NCDENR
North Carolina Department of Environment and
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P.E.
Governor Director
September 14, 2012
M. J. Soffe Co.
Attn: Adrian Quinn, Director of Maintenance and Environmental
One Soffe Drive
Fayetteville, NC 28312
Natural Resources
Subject: COMPLIANCE EVALUATION INSPECTION
M. J. Soffe, LLC
Stormwater No Exposure Certification-NCGNE0571.
Cumberland County
Dear Mr. Quinn:
Dee Freeman
Secretary
On September 4, 2012, a site inspection was conducted for the M. J. Soffe Co. facility located at One
Soffe Drive, Cumberland County, North Carolina. A copy of the Compliance Inspection Report is
enclosed for your review. The site visit and file review revealed that the subject facility is covered by
Stormwater No Exposure Certification-NCGNE0571.
As a result of the inspection, the facility was found to be in compliance with the No Exposure
Certification requirements. Please refer to the enclosed Compliance Inspection Report for additional
comments and observations made during the inspection.
If you or your staff has any questions or comments, please contact me at [phone].
Sincerely,
Hughie White
Environmental Specialist
Enclosure
cc: FRO -Surface Water Protection (HW)
Niki Maher-WBS Compliance & Permits Unit
D WQ Central Files
Location: 225 Green Street, Suite 714, Fayetteville, North Carolina 28301 One Phone: [phone] L FAX: [phone] Customer Service: 1-8T-623-6748 No r-t.h C aro fi n a
Internet: hitpllporiat,ncdenr.orghveh?wg
AWrrrrlly
An Equal Opportunity 1 Affirmative Aciien Empfayer

Compliance Inspection Report
Permit: NCGNE0571 Effective: 01/26/09 Expiration: Owner: M J Soffee LLC
SOC: Effective: Expiration: Facility: M J Soffe Co.
County: Cumberland One Soffe Dr
Region: Fayetteville
Fayetteville NC 28312
Contact Person: Adrian Quinn Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Certification: Phone:
Inspection Date: 09/04/2012 Entry Time: 02:00 PM Exit Time: 02:15 PM
Primary Inspector: Hughie White /� Phone: [phone]
Secondary Inspector(s): ✓�(f' E g
Mike Lawyer Phone: [phone] Ex 7-W
33z9
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, No Exposure Certificate
Facility Status: ■ Compliant 1=l Not Compliant
Question Areas:
E Miscellaneous Questions Emisc
(See attachment summary)
Page: 1

rr
Permit: NCGNED571 Owner - Facility: M J 5offee LLC
Inspection Date: 09/04/2012 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
This facility has a No Exposure Certification for industrial stormwater. A visual inspection of the property surrounding the
facility was conducted and no raw materials or finished product appeared to be exposed. Exposure of such materials
would void the No Exposure Certification and would then require a General stormwater Permit.
Misc
Is the facility compliant?
Comment:
0
Yes No NA NE
■nnn
Page: 2

. o�oF w a rF9pG 13eser[y Eaves Perdue, Governor
Dee freeman, Secretarn
� y North Carolina Department of Em�irgnment and Nalurti Kcsourccs
r
Q Coleen H. Sullins, Director
Division of Water Quality"
January 23, 2009
Mr. Scott Reynolds
M. J. Soffe LLC
One Soffe Drive
Fayetteville, NC 28312
Subject: No -Exposure Certification NCGNE0571
M. J. Soffe LLC
One Soffe Drive, Fayetteville, NC
Cumberland County
Dear Mr. Reynolds:
The Division has reviewed your submittal of the No -Exposure Certification for Exclusion from NPDES
Stormwater Permitting form. Based on your submittal and signed certification of no exposure at the above
referenced facility, the Division is granting your conditional exclusion from permitting as provided for under 40
CFR 126.22(g), which is incorporated by reference in North Carolina regulations.
Please note that by our acceptance of your no -exposure certification, you are obligated to maintain no -
exposure conditions at your facility. If conditions change such that your facility can no longer qualify for a no -
exposure exclusion, you are obligated to immediately obtain NPDES permit coverage for your stormwater
discharge. Otherwise, the discharge becomes subject to enforcement as an un-permitted discharge. Your
conditional no -exposure exclusion expires in five years (January 22. 1014). At that time you must re -certify
with the Division, or obtain NPDES permit coverage for any stormwater discharges from your facility.
Your conditional exclusion from permitting does not affect your facility's legal requirements to obtain
environmental permits that may be required under other federal, state, or local regulations or ordinances.
If you have any questions or need further information, please contact Robert Patterson at [phone], or
at [e-mail].
Sincerely,
for Coleen H. Sullins
cc: Fayetteville Regional Office -Mike Lawyer
Stormwater Permitting Unit No- Exposure Files
0CI) crR
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 [phone] Customer Service
1-877-623-6749

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NCDENR
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Division of Water Quality / Surface Water Protection
National Pollutant Discharge Elimination System
NO EXPOSURE CERTIFICATION for Exclusion
NCGNE0000
NO EXPOSURE CERTIFICATION
FOR AGENCY USE O 1.Y
Datc Rcecived
Ycar
Month I
Da
2
Certificate of Cnvert e
Please check here if this is a renewal: ❑ RENEWALI
National Pollutant Discharge Elimination System application for exclusion from a Stormwater Permit
based on NO EXPOSURE:
Submission of this No Exposure Certification constitutes notice that your facility does not require permit
authorization for its stormwater discharges associated with industrial activity in the State of North
Carolina because it qualifies for a no exposure exclusion. A condition of no exposure at an industrial
facility means all industrial materials and activities are protected by a storm resistant shelter (with some
exceptions) to prevent exposure to rain, snow, snowmelt, and/or runoff.
Industrial materials or activities include, but are not limited to: material handling equipment or activities,
industrial machinery, raw materials, intermediate products, by-products, final products, or waste
products. Material handling activities include the storage, loading and unloading, transportation, or
conveyance of any raw material, intermediate product, final product or waste product. A storm resk arr—
shelter is not required for the following industrial materials and activities: drums, barrels, tanks, agg
similar containers that are tightly sealed, provided those containers are not deteriorated and do ak..
CL
"Sealed" means banded or otherwise secured and with locked or non -operational taps or valves;
adequately maintained vehicles used in material handling; and final products, other than product t
would be mobilized in stormwater discharges (e.g., rock salt).
A No Exposure Certification must be provided for each facility qualifying for the no exposure excl
In addition, the exclusion from NPDES permitting is available on a facility -wide basis only --not fo,
individual outfalls. If any industrial activities or materials are, or will be, exposed to precipitation,.
facility is not eligible for the no exposure exclusion. By signing and submitting this No Exposure
Certification form, you certify that a condition of no exposure exists at this facility or site and are
obligated to comply with the terms and conditions of 40 CFR 122.26(g).
You must re-awly for the No Exposure Exclusion once every five (5
For questions, please contact the DWO Regional Office for your area. (See page 5)
(Please print or type)
1) Mailing address of owner/operator (address to which all certification correspondence will be mailed):
Name ,02 7✓ ._F il` to
Contact
Street Address
City
Telephone No.
2) Location of facility producing discharge:
Facility Name
Facility Contact
Street Address
City
County
Telephone No.
Page 1 of 5
SWU-NE-071406 Last revised 7/14/2008

NCGNE0000 No Exposure Certification
3) Physical location information:
Please provide a narrative description of how to get to the facility (use street names, state road numbers, and
distance and direction from a roadway intersection). g.cS �'g� ff�.i % o-j
S
(A copy of a map with the facility clearly located on it should be included with the certification application.)
4) Is the facility located on Native American Lands? ❑ Yes Plo
5) Is this a Federal facility? ❑ Yes y�' O
6) Latitude S, Longitude IS +t.c2 SOY i9gdeg., min., seconds)
7) This NPDES No Exposure Exclusion application applies to which of the following:
© New or Proposed Facility Date operation is to begin
V' Existing Date operation began Z99�
❑ Renewal of existing No Exposure Certification Certification No.: NCGNE
8) Was this facility or site ever covered under an NPDES Stormwater Permit? ❑ Yes mlgo
If yes, what is the NPDES Permit Number?
9) Standard Industrial Classification:
Provide the 4 digit Standard Industrial Classification Code (SIC Code) that describes the primary industrial
activity at this facility
SIC Code: _r2 p_ & 3
10) Provide ab/rief description of the types of industrlial activities and products produced mat- this facility:
%
11) Does this facility have any Non -Discharge permits (ex: recycle permits)?
iVNo
❑ Yes
If yes, list the permit numbers for all current Non -Discharge permits for this facility:
Exposure Checklists (12. - 14.)
12) Are any of the following materials or activities exposed to precipitation, now or in the foreseeable
future? (Please check either "Yes" or "No.") If you answer "Yes" to any of these items, you are not
eligible for the no exposure exclusion.
a. Using, storing, or cleaning industrial machinery or equipment, and areas where
residuals from using, storing or cleaning industrial machinery or equipment remain
and are exposed to stormwater
b. Materials or residuals on the ground or in stormwater inlets from spills/leaks
c. Materials or products from past industrial activity
d. Material handling equipment (except adequately maintained vehicles)
e. Materials or products during loading/unloading or transporting activities
f. Materials or products stored outdoors (except final products intended for outside
use [e.g., new cars] where exposure to stormwater does not result in the discharge
of pollutants)
❑ Yes 2-No
❑ Yes "0.
❑ Yes "o
❑ Yes ria 0
❑ Yes "o
❑ Yes pll o
Page 2 of 5
SWU-NE-071408
Last revised 7/14/2008

NCGNE0000 No Exposure Certification
g. Materials contained in open, deteriorated or leaking storage drums, barrels, tanks,
❑ Yes
No
and similar containers
h. Materials or products handled/stored on roads or railways owned or maintained by
❑ Yes
V No
the discharger
i. Waste material (except waste in covered, non -leaking containers (e.g., dumpsters])
❑ Yes
No
j. Application or disposal of process wastewater (unless otherwise permitted)
❑ Yes
V'No
k. Particulate matter or visible deposits of residuals from roof stacks and/or vents not
❑ Yes
No
otherwise regulated (i.e., under an air quality control permit) and evident in the
stormwater outflow
1. Empty containers that previously contained materials that are not properly stored
❑ Yes
/No
(i.e., not closed and stored upside down to prevent precipitation accumulation)
m. For any exterior ASTs, as well as drums, barrels, tanks, and similar containers
❑ Yes
V No
stored outside, has the facility had any releases in the past three (3) years?
13) Above Ground Storage Tanks (ASTs): If you answer "No" to any of the following items, you are not
eligible for the no exposure exclusion.
a. Are exterior ASTs. or piping free of rust, damaged or weathered coating, pits, or 0 Yes ❑ No
deterioration, or evidence of leaks?
b. Is secondary containment provided for all exterior ASTs? If so, is it free of any Yes ❑ No
cracks, holes, or evidence of leaks, and are drain valves maintained locked shut?
14) Secondary Containment: If you answer "No" to any of the following items, you are not eligible for the
no exposure exclusion.
a. Is secondary containment provided for single above ground storage containers
(including drums, barrels, etc.) with a capacity of more than 660-gallons?
b. is secondary containment provided for above ground storage containers stored
in close proximity to each other with a combined capacity of more than 1,320-
gallons?
c. Is secondary containment provided for any amount of Title III Section 313
Superfund Amendments and Reauthorization Act (SARA) water priority
chemicals?
d. Is secondary containment provided for an( amount of hazardous substances?
e. Are release valves on all secondary containment structures locked?.
15) Hazardous Waste:
❑ Yes ❑ No
0-Yes ❑ No
M/A ❑ Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
Page 3 of 5
SWU-NE-071408 Last revised 7/14/2008

NCGNE0000 No Exposure Certification
a. Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility? © Yes F No
b. Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous waste WYes ❑ No
generated per month) of hazardous waste?
c. Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste ❑ Yes Flo
generated per month) of hazardous waste?
If you answered yes to questions P. or c., please provide the following information:
Type(s) of waste:
How is material stored:
Where is material stored:
How many disposal shipments per year:
Name of transport / disposal vendor: A Ea ../
Vendor address: 5;,4 LOA... .(
16) Certification:
certify under penalty of law that I have read and understand the eligibility requirements for claiming a condition of "no
exposure" and obtaining an exclusion from NPDES stormwater permitting.
I certify under penalty of law that there are no discharges of stormwater contaminated by exposure to industrial activities
or materials from the industrial facility or site identified in this document (except as allowed under 40 CFR 122.26(g)(2)).
I understand that I am obligated to submit a no exposure certification form once every five (5) years to the North Carolina
Division of Water Quality and, if requested, to the operator of the local municipal separate storm sewer system (MS4) into
which the facility discharges (where applicable). I understand that I must allow the North Carolina Division of Water
Quality, or MS4 operator where the discharge is into the local MS4, to perform inspections to confirm the condition of no
exposure and to make such inspection reports publicly available upon request.
In the event that the site no longer qualifies for a No Exposure Exclusion, I understand that I must obtain coverage under
an NPDES permit prior to any point source discharge of stormwater from the facility. Additionally, I certify under penalty
of law that this document and all attachments were prepared under my direction or supervision in accordance with a
system designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based
on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is to the best of my knowledge and belief true, accurate and complete. I am aware
that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for
knowing violations.
certify that I am familiar with the information contained in this application and that to the best of my knowledge and
belief such information is true, complete, and accurate.
Printed Name of Person Signing: S(?w-r'r �AI0 C O s
Title: OAS rGf; a c.
Applicant)
(Date Signed)
Please note: This application for the No Exposure Exclusion is subject to approval by the
NCDENR Regional Office prior to issuance. The Regional Office may inspect your facility for
compliance with no exposure conditions prior to that approval. The Regional Office may also
inspect your facility at any time in the future for compliance with the No Exposure Exclusion.
Page 4 of 5
SWU-NE-071408 Last revised 7/14/2008

NCGNE0000 No Exposure Certification
North Carolina General Statute 143-215.6 B(i) provides that:
Any person who knowingly makes any false statement, representation, or certification in any application, record, report, plan, or other
document filed or required to be maintained under this Article or a rule implementing this Articie; or who knowingly makes a false
statement of a material fact in a rulemaking proceeding or contested case under this Article; or who falsifies, tampers with, or knowingly
renders inaccurate any recording or monitoring device or method required to be operated or maintained under this Article or rules of the
[Environmental Management] Commission implementing this Article shall be guilty of a Class 2 misdemeanor which may include a fine
not to exceed ten thousand dollars ($10,000).
There is currently no fee for a No Exposure Exclusion.
Final Checklist
This application should include the following items:
❑ This completed application and all supporting documentation.
❑ A map with the location of the facility clearly marked.
❑ If this is a renewal, indicated current NCGNE number in Question 7.
Mail the entire package to:
Stormwater Permitting Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Note
The submission of this document does not guarantee the issuance of a No Exposure Exclusion.
For questions, please contact the DWO Regional Office for your area.
DW0 Regional Office Contact Information:
Asheville Office ......
[phone]
Fayetteville Office ...
[phone]
Mooresville Office ...
[phone]
Raleigh Office ........
[phone]
Washington Office ...(252)
946-6481
Wilmington Office ...
[phone]
Winston-Salem ......
[phone]
Central Office .........(919)
807-6300
Page 5 of 5
SWU-NE-071408 Last revised 7/14/2008

o�
P.O. Box 2507 . One Soffe Drive . Fayetteville, North Carolina 28302-2507
[phone] *Corporate [phone] - Fax [phone]
To: Storm Water Permitting Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, N.C. 27699-1617
From: M. J. Soffe Co.
One Soffe Dr.
Fayetteville, N. C. 28312
Ref: Storm Water Permit
No Exposure Application
CA
M. J. Soffe Co. investigated the need to obtain a Storm Water Permit. We met
with Mike Lawyer in November of 2007 to discuss requirements for this permit. At the
time of this meeting we were evaluating the installation of a Salt Water Brine Tank
(20,000 Gals_) outside of our dye operation. That proposal has been dropped since that
meeting. There are presently four (4) tanks outside of our dye plant. One of those tanks
(1) is a 20,000 gal hot water tank, one (1) is a 30,000 gal. tempered water tank, there is
also a 20,000 gal. waste water tank, and one (1) 65,000 gal waste water tank. The two
waste water tanks contain hot waste water from our dye operation. We store this water
until we can reclaim the heat using a Luddell hot water recovery system, at that time it is
sent straight to the (PWC) Public Works Commission treatment facility at Rockfish
Creek. We do not have to treat this water as it contains no hazardous chemicals. This
water has a PH slightly higher than neutral which PWC needs to assist in their treatment
process. M. J. Soffe has had no violations with our Discharge Permit since being in
operation in 1992. M. J. Soffe did win PWC's Compass award in 2003 for Excellence in
Direction and Commitment to Environmental Compliance.
In the application for a No Exposure Certification, Mike Lawyer said to leave the
questions to item #14 blank and send this cover along with his cover letter, as you can see
in Mike's email letter he believes Soffe does qualify for a No Exposure Certification.
Thanks for your assistance in this issue and if you have any questions please call myself
or Scott Reynolds.

Wc�)80FPE@(DCI
P.O. Box 2507 . One Soffe Drive . Fayetteville, North Carolina 28302-2507
[phone] . Corporate [phone] . Fax [phone]
Adrian O'Quinn
Dir. Of Maintenance and
4
i
M. J. Soffe Co.
910-435-3132
Cell 910-988-0667
[e-mail]
Scott Reynolds
V. P. of Operations
M. J. Soffe Co.
910-483-2500 ext6447
sre nolds m'soffe.com

Adrian O'Quinn
From: Mike Lawyer [[e-mail]]
Sent: Wednesday, October 29, 2008 2:45 PM
To: Adrian O'Quinn
Subject:_ Emailing: No_Exposure_Application_rev07l4O8.pdf
Attachments: No_Exposure_Application_rev07l4O8.pdf
u
Nc Exposure_Appli
cation_rev071...
Adrian, ,
I found no permits or other documents that we have issued to the Soffe facility.
The No Exposure Certification is issued to industrial facilities that have no materials,
products, equipment, etc. stored outside that could contribute pollutants to stormwater
runoff. One of the requirements, however, is that above -ground storage tanks that contain
petroleum products, chemicals, or other hazardous materials have secondary containment
structures in place, either with a poured concrete wall or a double -walled tank. The
Division of Water Quality typically does not require such secondary containment around
storage tanks that contain only water. Based on the site visit that I conducted last year
and the information you have provided, I feel that the Soffe facility does qualify for the
No Exposure Certification. Please complete the attached form and submit it to our
Stormwater Permitting Unit in Raleigh (address is on the form) within 30 calendar days.
You should probably include a cover letter signed by the owner or facility manager and
please send me a copy as well.
If you need any assistance or have any questions, please contact me.
Thanks,
Mi ke
The message is ready to be sent with the following file or link
attachments:
No^Exposure_Application_rev07l4O8.pdf
Note: To protect against computer viruses, e-mail programs may prevent sending or
receiving certain types of file attachments. Check your e-mail security settings to
determine how attachments are handled.
Michael Lawyer
Environmental Specialist
NCDENR-Division of water Quality
Surface Water Protection Section
Fayetteville Regional Office
Direct: [phone]
Main: [phone]
Fax: [phone]

41
I
jo

Re: NCGNE0571 - MJ Soffe Co., Cumberland CouniN
Subject: Re: NCGNE0571 - MJ Soffe Co., Cumberland County
From: Mike Lawyer <[e-mail]>
Date: Fri, 16 Jan 2009 15:33:05 -0500
To: Robert Patterson <Robert. Pattersoncr nemail.net>
Robert,
I advised them to leave item 14 blank because the ASTs they do have contain only
water, which we usually don't require to have secondary containment. Not sure why
they marked item 13b as yes, probably an oversight. I did speak with Mr. Scott
Reynolds at the facility today. He said the hot water tank holds water at around 140
degrees and'the tempered water tank at around 90 degrees, but they are several
hundred yards away from any stream and any spill or leak would either soak into the
ground or cool off before reaching the stream. The two waste water tanks as they call
them actually hold process water, which may contain traces of dye, but at very
diluted levels. I explained to Mr. Reynolds that without permit coverage they would
not be "protected" should a spill occur that reached surface waters and that we would
likely issue an NOV. I don't really have too much concern with issuing them the NEC.
They are one of our better facilities with open communication and good track record.
If you feel otherwise, that.they need to provide containment, please let me know.
Thanks,
Mike
Robert Patterson wrote:
Mike,
We received the attached NE certification from MJ Soffe Co back on November 24,
2008. It sounds like you have already been out to the site in 2007, and feel they
qualify. Does the FRO have any concerns with granting no exposure for this
facility? I'm not sure I follow why they left number 14 blank?
Thanks.
Robert
Michael Lawyer
Environmental Specialist
NCDENR-Division of Water Quality
Surface Water Protection Section
Fayetteville Regional Office
Direct: [phone]
Main: [phone]
Fax: '[phone]
of 1 1/21/2009 9:36 AM

F%%,: permit
Subject: Fw: permit
From: "Mike.Lawyer cr ncmai].net" <[e-mail]>
Date: Wed, 21 Jan 2009 08.49:00 -0500 (EST)
To: [e-mail]
Robert,
Could you update B1MS with the following name change for the M J Soffe
No Exposure application?
Thanks, P
Mike
----Original Message ----
From: [e-mail]
Date: Jan 19, 2009 10:19
To: <[e-mail]>
Cc: <[e-mail]>, <[e-mail]>
Subj: permit
Mike: Since our last conversation and since we sent in the application
for the storm water permit M. J. Soffe has had a name change. The
original permit application had M. J. Soffe Co. The new name is M. J.
Soffe LLC. Could you please make Lhe required name change on the
application?
Thanks Adrian
I
1 of 1 1/21/2009 9:35 AM

Beverly Eaves Perdue, Governor
A
Mr. Scott Reynolds
M. J. Soffe LLC
One Soffe Drive
Fayetteville, NC 28312
Dear Mr. Reynolds:
Dee Freeman, Secretary
North Carolina Department of Environment and Nalural Resources
January 23, 2009
Subject: No -Exposure Certification NCGNE0571
M. J. Soffe LLC
One Soffe Drive, Fayetteville, NC
Cumberland County
CDleell 11. Sullins, Director
Division of Water Quality
DENR-FRO
JAN 2 7 2009
The Division has reviewed your submittal of the No -Exposure Certification for Exclusion from NPDES
Stormwater Permitting form. Based on your submittal and signed certification of no exposure at the above
referenced facility, the Division is granting your conditional exclusion from permitting as provided for under 40
CFR 12622(g), which is incorporated by reference in North Carolina regulations.
Please note that by our acceptance of your no -exposure certification, you are obligated to maintain no -
exposure conditions at your facility. If conditions change such that your facility can no longer qualify for a no -
exposure exclusion, you are obligated to immediately obtain NPDES permit coverage for your stormwater
discharge. Otherwise, the discharge becomes subject to enforcement as an un-permitted discharge. Your
conditional no -exposure exclusion expires in five years (January 22, 1014). At that time you must re -certify
with the Division, or obtain NPDES permit coverage for any stormwater discharges from your facility.
Your conditional exclusion from permitting does not affect your facility's legal requirements to obtain
environmental permits that may be required under other federal, state, or local regulations or ordinances.
If you have any questions or need further information, please contact Robert Patterson at [phone], or
at [e-mail].
Sincerely,
ORIGINAL SIGNED By
KEN PICKLE
for Coleen H. Sullins
cc: Fayetteville Regional Office -Mike Lawyer
Stormwater Permitting Unit No- Exposure Files
"CDEtNIR
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 [phone] Customer Service
1.877-623-6749

Re: NCGNE0571 - MJ Soffe Co., Cumberland County
Subject: Re: NCGNL0571 - MJ Soffe Co., Cumberland County
From: Mike Lawyer <Mike.Lawyer@ncnlaihiet>
Date: Fri, 16 Jan 2009 15:33:05 -0500
To: Robert Patterson <[e-mail]>
Robert,
I advised them to leave item 14 blank because the ASTs they do have contain only
water, which we usually don't require to have secondary containment. Not sure why
they marked item 13b as yes, probably an oversight. I did speak with Mr. Scott
Reynolds at the facility today. He said the hot water tank holds water at around 140
degrees and the tempered water tank at around 90 degrees, but they are several
hundred yards away from any stream and any spill or leak would either soak into the
ground or cool off before reaching the stream. The two waste water tanks as they
call them actually hold process water, which may contain traces of dye, but at very
diluted levels. I explained to Mr. Reynolds that without permit coverage they would
not be "protected" should a spill occur that reached surface waters and that we
would likely issue an NOV. I don't really have too much concern with issuing them
the NEC. They are one of our better facilities with open communication and good
track record. If you feel otherwise, that they need to provide containment, please
let me know.
Thanks,
Mike
Robert Patterson wrote:
Mike,
We received the attached NE certification from MJ Soffe Cc back on November 24,
2008. It sounds like you have already been out to the site in 2007, and feel
they qualify. Does the FRO have any concerns with granting no exposure for this
facility? I'm not sure I follow why they left number 14 blank?
Thanks.
Robert
Michael Lawyer
Environmental Specialist
NCDENR-Division of Water Quality
Surface Water Protection Section
Fayetteville Regional Office
Direct: [phone]
Main: [phone]
Fax: [phone]
1 of 1 1 /27/2009 1:44 P,N,1

NOV 14 2008
0)0 DWO
P.O. Box 2507 . One Soffe Drive . Fayetteville, North Carolina 28302-2507
[phone] . Corporate [phone] . Fax [phone]
To: Storm Water Permitting Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, N.C. 27699-1617
From: M. J. Soffe Co.
One Soffe Dr.
Fayetteville, N. C. 28312
Ref: Storm Water Permit
No Exposure Application
M. J. Soffe Co. investigated the need to obtain a Storm Water Permit. We met
with Mike Lawyer in November of 2007 to discuss requirements for this permit. At the
time of this meeting we were evaluating the installation of a Salt Water Brine Tank
(20,000 Gals.) outside of our dye operation. That proposal has been dropped since that
meeting. There are presently four (4) tanks outside of our dye plant. One of those tanks
(1) is a 20,000 gal hot water tank, one (1) is a 30,000 gal. tempered water tank, there is
also a 20,000 gal. waste water tank, and one (1) 65,000 gal waste water tank. The two
waste water tanks contain hot waste water from our dye operation. We store this water
until we can reclaim the heat using a Luddell hot water recovery system, at that time it is
sent straight to the (PWC) Public Works Commission treatment facility at Rockfish
Creek. We do not have to treat this water as it contains no hazardous chemicals. This
water has a PH slightly higher than neutral which PWC needs to assist in'their treatment
process. M. J. Soffe has had no violations with our Discharge Permit since being in
operation in 1992. M. J. Soffe did win PWC's Compass award in 2003 for Excellence in
Direction and Commitment to Environmental Compliance.
In the application for a No Exposure Certification, Mike Lawyer said to leave the
questions to item #14 blank and send this cover along with his cover letter, as you can see
in Mike's email letter he believes Soffe does qualify for a No Exposure Certification.
Thanks for your assistance in this issue and if you have any questions please call myself
or Scott Reynolds.

90cPSOFFECG;@)o
P.O. Box 2507 . One Soffe Drive . Fayetteville, North Carolina 28302-2507
[phone] . Corporate [phone] . Fax [phone]
Adrian O'Quinn
Dir. Of Maintenance and -�Vironfiliental
a
M. J. Soffe Co.
910-435-3132
Cell 910-988-0667
aoquinn a,njsoffe.coin
Scott Reynolds
V. P. of Operations
M. J. Soffe Co.
910-483-2500 ext 6447
sreynolds ajsolliecom

Adrian O'Quinn
From: Mike Lawyer [[e-mail]]
Sent: Wednesday, October 29, 2008 2:45 PM
To: Adrian O'Quinn
Subject: Emailing: No_Exposure_Application_rev07l4O8.pdf
Attachments: No_Exposure_Application_rev07l4O8. pdf
L�J
No_Exposure_Appli
cation rev071...
Adrian,
I found no permits or other documents that we have issued to the Soffe facility.
The No Exposure Certification is issued to industrial facilities that have no materials,
products, equipment, etc. stored outside that could contribute pollutants to stormwater
runoff. One of the requirements, however, is that above -ground storage tanks that contain
petroleum products, chemicals, or other hazardous materials have secondary containment
structures in place, either with a poured concrete wall or.a double -walled tank. The
Division of Water Quality typically does not require such secondary containment around
storage tanks that contain only water. Based on the site visit th-3t I conducted last year
and the information you have provided, I feel that the Soffe tacility does qualify for the
No Exposure Certification. Please complete the attached form and submit it to our
Stormwater Permitting Unit in Raleigh (address is on the form) within 30 calendar days.
You should probably include a cover letter signed by the owner or facility manager and
please send me a copy as well.
If you need any assistance or have any questions, please contact me.
Thanks,
Mike
The message is ready to be sent with the following file or link
attachments:
No_Exposure_Application_rev071408.pdf
Note: To protect against computer viruses, e-mail programs may prevent sending or
receiving certain types of file attachments. Check your e-mail security settings to
determine how attachments are handled.
Michael Lawyer
Environmental Specialist
NCDENR-Division of Water Quality
Surface Water Protection Section
Fayetteville Regional Office
Direct: [phone]
Main: [phone]
Fax: [phone]
1

IFJ
��' • Division of Water Quality / Surface Water Protection
NCD., NR National Pollutant Discharge Elimination System
NO EXPOSURE CERT[FICAT[ON for Exclusion
fMvmv„r.rr ua, ra c�nN. Mrye.rr
NCGNE0000
FOR AGENCY USE ONLY
Date Received
Year
I Month
Day
certificate of coverage
NICIGINI
NO EXPOSURE CERTIFICATION Please check here if this is a renewal: n RENEWAL
National Pollutant Discharge Elimination System application for exclusion from a Stormwater Permit
based on NO EXPOSURE:
Submission of this No Exposure Certification constitutes notice that your facility does not require permit
authorization for its stormwater discharges associated with'industrial activity in the State of North
Carolina because it qualifies for a no exposure exclusion. A condition of no exposure at an industrial
facility means all industrial materials and activities are protected by a storm resistant shelter (with some
exceptions) to prevent exposure to rain, snow, snowmelt, and/or runoff.
Industrial materials or activities include, but are not limited to: material handling equipment or activities,
industrial machinery, raw materials, intermediate products, by-products, final products, or waste
products. Material handling activities include the storage, loading and unloading, transportation, or
conveyance of any raw material, intermediate product, final product or waste product. A storm resistant
shelter is not required for the following industrial materials and activities: drums, barrels, tanks, and
similar containers that are tightly sealed, provided those containers are not deteriorated and do not leak.
"Sealed" means banded or otherwise secured and with locked or non -operational taps or valves;
adequately maintained vehicles used in material handling; and final products, other than products that
would be mobilized in stormwater discharges (e.g., rock salt).
A No Exposure Certification must be provided for each facility qualifying for the no exposure exclusion.
In addition, the exclusion from NPDES permitting is available on a facility -wide basis only —not for
individual outfalls. if any industrial activities or materials are, or will be, exposed to precipitation, the
facility is not eligible for the no exposure exclusion. By signing and submitting this No Exposure
Certification form, you certify that a condition of no exposure exists at this facility or site and are
obligated to comply with the terms and conditions of 40 CFR 122.26(g).
You must re -apply for the No Exposure Exclusion once every five (5)
For questions, please contact the DWO Regional Office for your area. (See page 5)
(Please print or type)
1) Mailing address of owner/operator (address to which all certification correspondence will be mailed):
Name 10.J, }
Contact
Street Address
City
Telephone No.
I —
IN
2) Location of facility producing discharge:
Facility Name fn .:F. 5 a
Facility Contact
Street Address
City -
County
Telephone No.
6
State ;0 ,C,­ ZIP Code �1
Fax: _V0 y�'3 30�3
State rJ L-" ZIP Code o1 edl
_6.m pw'u /f - cG
h/d YS 3'' 73 2- Fax: � � 3-o33S
Page 1 of 5
SWU-NE-071408 Last revised 7/14/2008

NCGNE0000 No Exposure Certification
3) Physical location information:
Please provide a narrative description of how to get to the facility (use street nam
distance and direction from a roadway intersection). &a.S_ 7 _gj xl .)
(A copy of a map with the facility clearly located on it should be included with the certification application.)
4) is the facility located on Native American Lands? ❑ Yes P"No
5) Is this a Federal facility? ❑ Yes OJO
6) Latitude �7; 3.W/�� Longitude -)d' 1c; SSG, kL71deg., min., seconds)
7) This NPDES No Exposure Exclusion application applies to which of the following:
❑ New or Proposed Facility Date operation is to begin
V Existing Date operation began 1,9f7
❑ Renewal of existing No Exposure Certification Certification No.: NCGNE
8) Was this facility or site ever covered under an NPDES Stormwater Permit? ❑ Yes M-NO
If yes, what is the NPDES Permit Number?
9) Standard Industrial Classification:
.Provide the 4 digit Standard Industrial Classification Code (SIC Code) that describes the primary industrial
activity at this facility
SIC Cade: ,g
10) Provide a brief description of the types of industrial activities and products produced at this facility:
11) Does this facility have any Non -Discharge permits (ex: recycle permits)?
[fio
❑ Yes
If yes, list the permit numbers for all current Non -Discharge permits for this facility:
Exposure Checklists (12. - 14.)
12) Are any of the following materials or activities exposed to precipitation, now or in the foreseeable
future? (Please check either "Yes" or "No.") If you answer "Yes" to any of these Items, you are not
eligible for the no exposure exclusion.
a. Using, storing, or cleaning industrial machinery or equipment, and areas where
residuals from using, storing or cleaning industrial machinery or equipment remain
and are exposed to stormwater
b. Materials or residuals on the ground or in stormwater inlets from spills/leaks
c. Materials or products from past industrial activity
d. Material handling equipment (except adequately maintained vehicles)
e. Materials or products during loading/unloading or transporting activities
f. Materials or products stored outdoors (except final products intended for outside
use [e.g., new cars] where exposure to stormwater does not result in the discharge
of pollutants)
❑ Yes Rfgo
❑ Yes
"o
❑ Yes
"o
❑ Yes
P-No
❑ Yes
ErNo
❑ Yes
Rlo
Page 2 of 5
SWU-NE-071408 Last revised 7/14/2006

NCGNE0000 No Exposure Certification
Yes
V No
g. Materials contained in open, deteriorated or leaking storage drums, barrels, tanks,
❑
and similar containers
/
h. Materials or products handled/stored on roads or railways owned or maintained by
Li Yes
9 No
the discharger
i. Waste material (except waste in covered, non -leaking containers [e_g., dumpsters])
❑ Yes
/ No
j. Application or disposal of process wastewater (unless otherwise permitted)
❑ Yes
VNo
k. Particulate matter or visible deposits of residuals from roof stacks and/or vents not
❑ Yes
No
otherwise regulated (i.e., under an air quality control permit) and evident in the
stormwater outflow
1. Empty containers that previously contained materials that are not properly stored
❑ Yes
V No
(i.e., not closed and stored upside down to prevent precipitation accumulation)
m. For any exterior ASTs, as well as drums, barrels, tanks, and similar containers
❑ Yes
o
stored outside, has the facility had any releases in the past three (3) years?
13). Above Ground Storage Tanks (ASTs): If you answer "No" to any of the following items, you are not
eligible for the no exposure exclusion.
a. Are exterior ASTs or piping free of rust, damaged or weathered coating, pits, or if1 Yes ❑ No
deterioration, or evidence of leaks?
b. Is secondary containment provided for all exterior ASTs? If so, is it free of any 10 Yes ❑ No
cracks, holes, or evidence of leaks, and are drain valves maintained locked shut?
14) Secondary Containment: If you answer "No" to any of the following items, you are not eligible for the
no exposure exclusion.
a. Is secondary containment provided for single above ground storage containers
❑ Yes ❑ No
(including drums, barrels, etc.) with a capacity of more than 660-gallons?
b. Is secondary containment provided for above ground storage containers stored
❑ Yes ❑ No
in close proximity to each other with a combined capacity of more than 1,320-
gallons? ,.
c. Is secondary containment provided for any amount of Title III Section 313
ifih ❑ Yes ❑ No
Superfund Amendments and Reauthorization Act (SARA) water priority
chemicals?
d. Is secondary containment provided for any amount of hazardous substances?
p Yes ❑ No
e. Are release valves on all secondary containment structures locked?
❑ Yes ❑ No
15) Hazardous Waste:
Page 3 of 5
SWU-NE-071408 Last revised 7/14/2008

NCGNE0000 No Exposure Certification
a. Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility? ❑ Yes VNo
b. Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous waste WYes ❑ No
generated per month) of hazardous waste?
c. Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste ❑ Yes "o
generated per month) of hazardous waste?
If you answered yes to questions P. or c., please provide the following information:
Type(s) of waste: =�
How is material stored:
Where is material stored:
How many disposal shipments per year:
Name of transport / disposal vendor: SA Er d
Vendor address: 5,4 A ) L
16) Certification:
I certify under penalty of law that I have read and understand the eligibility requirements for claiming a condition of "no
exposure" and obtaining an exclusion from NPDES stormwater permitting.
I certify under penalty of law that there are no discharges of stormwater contaminated by exposure to industrial activities
or materials from the industrial facility or site identified in this document (except as allowed under 40 CFR 122.26(g)(2)).
understand that I am obligated to submit a no exposure certification form once every five i5) years to the North Carolina
Division of Water Quality and, if requested, to the operator of the local municipal separate storm sewer system (MS4) into
which the facility discharges (where applicable). I understand that 1 must allow the North Carolina Division of Water
Quality, or MS4 operator where the discharge is into the local MS4, to perform inspections W confirm the condition of no
exposure and to make such inspection reports publicly available upon request.
In the event that the site no longer qualifies for a No Exposure Exclusion, I understand that I must obtain coverage under
an NPDES permit prior to any point source discharge of stormwater from the facility. Additionally, I certify under penalty
of law that this document and all attachments were prepared under my direction or supervision in accordance with a
system designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based
on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is to the best of my knowledge and belief true, accurate and complete. I am aware
that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for
knowing violations.
1 certify that I am familiar with the information contained in this application and that to the best of my knowledge and
belief such information is true, complete, and accurate.
Printed Name of Person Signing: T-17 dc.gS
Title: 1i t� 4'. --c7 o As
Applicant)
/t' /- -2
(Date Signed)
Please note: This application for the No Exposure Exclusion is subject to approval by the
NCDENR Regional Office prior to issuance. The Regional Office may inspect your facility for
compliance with no exposure conditions prior to that approval. The Regional Office may also
inspect your facility at any time in the future for compliance with the No Exposure Exclusion.
Page 4 of 5
SWU-NE-071408 Last revised 7/1412008

NCGNEOOOO No Exposure Certification
North Carolina General Statute 143-215-6 B(i) provides that:
Any person who knowingly makes any false statement, representation, or certification in any application, record, report, plan, or other
document filed or required to be maintained under this Article or a rule implementing this Article; or who knowingly makes a false
statement of a material fact in a rulemaking proceeding or contested case under this Article; or who falsifies, tampers with, or knowingly
renders inaccurate any recording or monitoring device or method required to be operated or maintained under this Article or rules of the
[Environmental Management] Commission implementing this Article shall be guilty of a Class 2 misdemeanor which may include a fine
not to exceed ten thousand dollars ($10,000).
There is currently no tee for a No Exposure Exclusion.
Final Checklist
This application should include the following items:
❑ This completed application and all supporting documentation.
❑ A map with the location of the facility clearly marked.
❑ It this is a renewal, indicated current NCGNE number in Question 7.
Mail the entire package to:
Stormwater Permitting Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Note
The submission of this document does not guarantee the issuance of a No Exposure Exclusion.
For questions, please contact the DWO Regional Office for your area.
DWO Regional Office Contact Information:
Asheville Office ...... [phone]
Fayetteville Office
... [phone]
Mooresville Office
... [phone]
Raleigh Office ........
[phone]
Washington Office
...(252) 946-648).
Wllmington Office
... [phone]
Winston-Salem ......
[phone]
Central Office .........(919)
807-6300
Page 5 of 5
SWU-NE-071408 East revised 7/14/2008

1��

no exposure certification
Subject: no exposure certification
From: Mike Lawyer <[e-mail]>
Date: Mon, 24 Sep 2007 13:13:36 -0400
To: [e-mail]
CC: Belinda Henson <[e-mail]>
Mr. O'Quinn,
I discussed your facility's situation with my supervisor, Belinda Henson, and we
agreed that holding off on submitting the No Exposure Certification (NEC)
application until work is completed concerning secondary containment is the
appropriate action at this time. Obtaining coverage under the general stormwater
permit for your industrial activity during the interim period is not advised.
Considering your facility's desire for compliance, the lack of exposed materials or
products on facility grounds and the relatively short time period it should take to
provide secondary containment around all above ground storage tanks (6-12 months),
our office will not take civil penalty action pertaining to lack of permit coverage.
Please be advised, however, that should a leak or spill occur from the subject tanks
and cause an impact to any surface waters or wetlands, our office may issue a Notice
of Violation and require proper cleanup and/or restoration. Please provide our
office with a reasonable time frame that you expect the work involving secondary
containment to be completed. we also request that you please notify us when the work
begins as well as when it is close.to completion. Once completed, you will submit
the NEC application to our Stormwater Permitting Unit located at our central office
in Raleigh. I have attached a copy of our new NEC application (please discard the
older one that I left with you during my site visit as it is no longer valid). The
submittal address is on the attached application. If you have any questions, please
contact me.
Thanks,
Mike
Michael Lawyer
Environmental Specialist
NCDENR-Division of water Quality
Surface Water Protection Section
Fayetteville Regional Office
Direct: [phone]
Main: [phone]
Fax: [phone]
NCGNE_Application_OOO.pdf Content -Type: application/pdf
Content -Encoding: base64
l of 1 l 1/l/2007 8:43 AM