NCGNE1489_Ltr_20210811

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Chalam Pakala Engineering and Environmental Solutions
10017 Allyson Park Dr., Charlotte, NC 28277 Tel [phone], Fax: [phone]
July 23, 2021
RECEIVFD
Ms. Jennifer Jones, Environmental Engineer II AUG 11 M1
NC DENR — Stormwater Permitting Unit DENR-LAND QUALITY
1617 Mail Service Center STORMWATER PERMITTING
Raleigh, North Carolina 27699-1617
Re: Request for NPDES Stormwater No Exposure General Permit
Yanjan USA LLC
159 Walker Road
Statesville, North Carolina 28625
CPEES Project No.1185-001
Dear Ms. Jones:
On behalf of Yanjan USA, Inc., located at 159 Walker Road, Statesville, Iredell County, North
Carolina, CP Engineering and Environmental Solutions (CPEES) is pleased to resubmit the
attached NCGNE0000 request to the State for a NPDES Stormwater General Permit - No
Exposure for the subject facility operations. The facility conducts their operation under the SIC
code 2297 (NAICS = 31323) — "Nonwoven Fabric Mills". Therefore, the applicable NPDES
Stormwater General Permit for this SIC code is NCG170000. Yanjan had applied for NO
EXPOSURE certification in May 2018 and we made considerable changes to the facility
following the State inspection. Yanjan USA, Inc. is very diligent in controlling the exposure of
facility oil/chemical storage drums/totes and loadinglunloading operations to stormwater. Thus,
Yanjan USA, Inc., had requested CPEES to review the current facility operations and assess the
NPDES Stormwater General Permit Exemption criteria and NO EXPOSURE Certification.
NAME CHANGE 0C& 05 0 3` 2. — )H a.ahva.44
The facility had received an invoice (#2020PR007419) and is due by August 15, 2021. However,
the name on the invoice was Amesbury Textiles Group. Therefore, Yanjan did not pay the bill to
date. Yanjan appreciates your guidance on this issue and change the name on the invoice for
future invoices.
SITE REVIEW
On June 22, 2021, CPEES had conducted a site review for the facility operations exposed to
stormwater. During the facility review, the following areas were reviewed for the stormwater
exposure:
• Oil and Chemical storage areas/tanks out side the plant building;
• Materials storage outside the plant operations;
• Secondary containment structures;
• Loading and unloading docks;
• Roof discharges;
• Best Management Practices (BMPs) implemented at the site;
• General site erosion and sediment transport; and
• Potential spills/leaks from the building.

Chalam Pakala Engineering and Environmental Solutions
10017 Allyson Park Dr., Charlotte. NC 28277 Tel [phone], Fax: [phone]
FINDINGS
Based on the site review, CPEES believes Yanjan USA, Inc., had implemented several BMPs
controls to mitigate the exposure of oil/chemical storage areas, transfer practices and general
operations from stormwater. Some of our observations include:
• Minimal amounts of oils and chemicals in 55 gal drums are received at the site and they
are being handled either manually or with a hand trolleys for keeping them inside the
plant building. These drums are always inside the building on a secondary containment
pallet;
• The four empty silos exist at the site. Yanjan USA have NO intensions of storing any
materials in these silos;
• No aboveground storage tanks (AST) exist at the site;
• All empty drums are kept inside the building;
• No underground storage tanks were observed at the site;
• All wooden and plastic pallets are stored under a shed;
• One metal dumpster with a lid exists at the site with no exposure to rain;
• One dumpster for waste fabric bales exists and the dumpster is emptied at end of each
day. We believe no chemicals, pH or TSS will be leached into the stormwater from
these bales and in addition, these bales will be removed at the end of each day;
• A few local utility maintained transformers exist at the site. The maintenance of these
transformers is the responsibility of the utility company;
• No soil erosion was observed at the facility, and
• The overall facility yard appeared to be well maintained with no materials exposed to
stormwater.
NO EXPOSURE APPLICATION
CPEES has completed the State NCGNE0000 "No Exposure" application package to meet the
State requirements. The package includes the application, a Ste Location Map (Figure 1), an
Aerial View Map (Figure 2) and a Site Layout Map.
CONCLUSIONS AND RECOMMENDATIONS
Yanjan had applied for a NO EXPOSURE certification in May 2018 and the application was
rejected at that time due to wooden pallets exposed to stormwater and open dumpster with lots of
trash. Yanjan had corrected these issues and only one dumpster with non -spec non -woven fabric
bales exists at the site. Further, this open dumpster is emptied on a daily basis and therefore,
stormwater issues are mitigated. Please note this no -woven fabric is FDA approved and used in
feminine hygiene products. Therefore, any stormwater leaving this dumpster may not be an issue
even if that was a rare situation.
Based on our site review and findings, CPEES believes that the subject facility should be
exempted from the NPDES Stormwater General Permit at the present time. Further, the facility
had implemented a Stormwater Pollution Prevention Plan in order to maintain NO EXPOSURE
conditions and stormwater impact mitigation.
However, should the facility decide to change the operations in the future and thus, potentially
impact the stormwater, then the facility should apply for the NPDES Stormwater Permit at that
time to meet the NC DEQ Division of Energy, Mineral and land Resources -Land Quality Section
Requirements.

Chalam Pakala Engineering and Environmental Solutions
10017 Allyson Park Dr.. Charlotte. NC 28277 Tel [phone], Fax: [phone]
CLOSING
It is my pleasure to complete this important project for Yanjan USA, Inc., and please call me at
704-756-7451 should you have any questions on this permit exemption request.
Respectfully submitted,
CP Engineering and Environmental Solutions
(A Cost Effective Sohition Provider for Manufacturing)
Chalam V. Pakala, P.E.
Managing Principal
1%%1klII11//!/
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f�"tigl4M V • PA �� 7/22/2021

NPDES - NO EXPOSURE EXEMPTION PERMIT APPLICATION
NCGNE0000

Division of Energy, Mineral and Land Resources
Land Quality Section
National Pollutant Discharge Elimination System
NO EXPOSURE CERTIFICATION for Exclusion
Enviroranental Quality NCGNE0000
FOR AGENCY USE ONLY
Date Received
Year
I Month
Day
1
10 29
1 1
Certificate of Coverage
NICIGINIE11 111019
M,wZ'D
National Pollutant Discharge Elimination System application for exclusion from a Stormwater Permit based
on NO EXPOSURE:
Submission of this No Exposure Certification constitutes notification that your facility does not require a
permit for 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.
For permitted facilities in North Carolina, DEMLR must approve your application for No
Exposure Certification before this exclusion is effective. Until you are issued a No
Exposure Certification and your NPDES permit is rescinded, your facility must continue
to abide by the terms and conditions of the current permit.
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).
If approved, your conditional No Exposure Exclusion has no expiration date
BUT MUST BE self re -certified at least annually.
Please look for information about re -certification under the No Exposure section on this page:
hftps://deg. nc.gov/about/divisions/energy-mineral-land-resources/energy-mineral-land-permits/stormwater-
For questions, please contact the DEMLR Regional Office for your area. (See page 6)
(Please print or type)
1) Mailing address of owner/operator (address to which all certification correspondence will be mailed):
Name YANJAN USA LLC
Contact
Street Address
City
Telephone No.
MR. JIM JEAN
159 WALKER ROAD
STATESVILLE
704 929-3596
State NC ZIP Code 28625
Fax: [phone]
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NCGNE0000 No Exposure Certification
2) Location of facility producing discharge:
Facility Name
YANJAN USA LLC
Facility Contact
MR. JIM JEAN
Street Address
159 WALKER ROAD
City
STATESVILLE
County
IREDELL
Telephone No.
704 929-3596
3) Physical location information:
State NC ZIP Code 28625
Fax: [phone]
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). TAKE 1-77N AND TAKE 140 WEST TO ASHEVILLE. TAKE EXIT 148 ON 1-40
TURN RIGHT AT THE EXIST-TAYLORSVILLE RD.AND TURN RIGHT ON NC90 W AND RIGHT ON COMMSCOPE WAY AND LEFT ON WALKER ROAD (SEE ATTACHED USGS TOPO MAP)
(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 /© No
5) Is this a Federal facility? ® Yes //® No
6) Latitude 35 48' 14.55" Longitude 80 56' 7.23" (deg., min., seconds)
7) This NPDES No Exposure Exclusion application applies to which of the following:
in New or Proposed Facility
® -' Existing
Date operation is to begin MAY 2018
Date operation began
® Renewal of existing No Exposure Certification Certification No.: NCGNE
8) Was this facility or site ever covered under an NPDES Stormwater Permit? 0 Yes i 13 No
If yes, what is the NPDES Permit Number? N/A
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: 2 2 9 7
10) Provide a brief description of the types of industrial activities and products produced at this facility:
NON -WOVEN FABRIC MILL
11) Does this facility have any Non -Discharge permits (ex: recycle permits)?
/® No
® Yes
If yes, list the permit numbers for all current Non -Discharge permits for this facility:
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NCGNE0000 No Exposure Certification
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 0 Yes ,,I No 0 N/A
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
0 Yes 'b No
© N/A
c. Materials or products from past industrial activity
0 Yes/p No
0 N/A
d. Material handling equipment (except adequately maintained vehicles)
0 Yes-,'® No
0 N/A
e. Materials or products during loading/unloading or transporting activities
0 Yes, M No
© N/A
f. Materials or products stored outdoors (except final products intended for outside
D Yes /0 No
0 N/A
use [e.g., new cars] where exposure to stormwater does not result in the
discharge of pollutants)
g. Materials contained in open, deteriorated or leaking storage drums, barrels,
0 Yes /p No
0 N/A
tanks, and similar containers
h. Materials or products handled/stored on roads or railways owned or maintained
0 Yes /0 No
0 N/A
by the discharger
i. Waste material (except waste in covered, non -leaking containers [e.g., 0 Yes 15 No 0 N/A
dumpsters])
j. Application or disposal of process wastewater (unless otherwise permitted) © Yes /® No © N/A
k. Particulate matter or visible deposits of residuals from roof stacks and/or vents 0 Yes -1 No 0 N/A
not otherwise regulated (i.e., under an air quality control permit) and evident in the
stormwater outflow
I. Empty containers that previously contained materials that are not properly stored 0 Yes /p No 0 N/A
(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 0 Yes �0 No 0 N/A
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 /® Yes 0 No ® N/A
deterioration, or evidence of leaks?
/
b. Is secondary containment provided for all exterior ASTs? If so, is it free of any ❑ Yes ❑ No e N/A
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.
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NCGNE0000 No Exposure Certification
a. Is secondary containment provided for single above ground storage containers 0 Yes M No 101 N/A
(including drums, barrels, etc.) with a capacity of more than 660-gallons?
b. Is secondary containment provided for above ground storage containers stored 0 Yes 0 No �El N/A
in close proximity to each other with a combined capacity of more than 1,320-
gallons?
c. Is secondary containment provided for Title III Section 313 Superfund 0 Yes E3 No i9 N/A
Amendments and Reauthorization Act (SARA) water priority chemicals"?
d. Is secondary containment provided for hazardous substances"' designated in p Yes p No -I® N/A
40 CFR §116?
e. Are release valves on all secondary containment structures locked? 0 Yes M No -"M N/A
15) Hazardous Waste:
a. Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility? E3 Yes -,13 No p N/A
b. Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous M Yes 40 No E3 N/A
waste generated per month) of hazardous waste?
c. Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste a Yes -I No ® N/A
generated per month) of hazardous waste?
If you answered yes to questions b. or c., please provide the following information:
Type(s) of
waste: N/A
How is material stored:
Where is material stored:
How many disposal shipments per year:
Name of transport / disposal
vendor: N/A
Vendor address:
Footnotes to Questions 14) c. & d.
"Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require
secondary containment. However, some exceptions may be made for de minimis amounts of certain substances,
and/or other qualifiers, as described in the exemptions from reporting requirements of Title III SARA 313 in 40 CFR
§372.38.
"Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require
secondary containment. However, some exceptions may be made for amounts less than the Reportable
Quantities of the hazardous substances listed in 40 CFR §117.3.
16) Other information: If you answer "Yes" to any of the following items, you might not be eligible for the
no exposure exclusion. A more in-depth evaluation of the site circumstances may be required.
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NCGNE0000 No Exposure Certification
a. Does your facility store used, recycled, or otherwise reclaimed pallets outside?
b. Does your facility have coal piles on site?
c. Does your facility store other fuel sources outside in piles, such as wood chips,
sawdust, etc.?
d. Does your facility have air emissions associated with its industrial activity (e.g.,
degreasing operations, plating, painting and metal finishing)? If so, describe the
industrial activity:
e. If you answered yes to d., are those emissions permitted by an Air Quality
Permit? Please specify:
f. Please list any other environmental program permits (federal, state, etc.) not
specified earlier in this application (such as Hazardous Waste Permits, etc.):
Permit: , Program:
Permit: , Program:
Permit: Program:
Permit: Program:
Permit:
Program:
Permit: Program:
Permit: Program:
p Yes in No © N/A
p Yes A No © N/A
p Yes io No in N/A
© Yes -'® No © N/A
® Yes 0 No X® N/A
Page 5 of 7
SWU-NCGNE Last revised 9/28/2016

NCGNE0000 No Exposure Certification
17) 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)).
I understand that I am obligated to maintain no exposure conditions and complete a Self -Recertification form at least once
each year, and if requested, provide this certification 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
Energy, Mineral, and Land Resources, 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. I understand I
must keep a copy of annual re -certifications on file at the facility.
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
Title:
(Signature of
Signing: MR. JIM JEAN
J, g , d
(Date Signed)
Please note: This application for the No Exposure Exclusion is subject to approval by the NCDEQ
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.
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 fee for a No Exposure Exclusion.
Page 6 of 7
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NCGNE0000 No Exposure Certification
Final Checklist
This application should include the following items:
❑i This completed application and all supporting documentation.
❑/ A map with the location of the facility clearly marked.
C4' If the site currently has an NPDES Stormwater Permit, be sure to indicate the permit number in Question 8.
Mail the entire package to:
DEMLR - Stormwater Program
Dept. of Environmental Quality
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
Note
The submission of this document does not guarantee the issuance of a No Exposure Exclusion.
For questions, please contact the DEMLR Regional Office for your area.
DEMLR Regional Office Contact Information:
Asheville Office ......
[phone]
Fayetteville Office
... [phone]
Mooresville Office
... [phone]
Raleigh Office ........
[phone]
Washington Office ...[phone]
Wilmington Office
... [phone]
Winston-Salem ......
[phone]
Central Office .........(919)
707-9220
Page 7 of 7
SWU-NCGNE Last revised 9/28/2016

FIGURES
FIGURE 1: SITE LOCATION MAP
FIGURE 2: SITE AERIAL MAP
FIGURE 3: SITE LAYOUT MAP

Map Name: STATESVILLE WEST Scale: 1 inch = 2,000 ft.
Print Date: 03/24/18 Map Center: 035' 48' 15.04" N, 0800 56' 06.47" W
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