NCG210459_NOV_20191003

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
CERTIFIED MAIL: 7015 0640 0007 8168 5604
RETURN RECEIPT REQUESTED
Pack IQ
Attn: Mark Beck, CEO
1 American Way
Anderson, SC 29621
NORTH CAROLINA
Environmental Quality
October 3; 2019
Subject: NOTICE OF VIOLATION (NOV-2019-PC-0675)
NPDES Stormwater General Permit NCG210000
Pack IQ
Pack IQ Fayetteville, Certificate of Coverage NCG210469
Cumberland County
Dear Mr. Beck:
On September 30, 2019, Melissa Joyner from the Fayetteville Regional Office of the Division of Energy, Mineral and Land
Resources (DEMLR), conducted a site inspection for the Pack IQ Fayetteville facility located at 880 Technology Drive,
Cumberland County, North Carolina. A copy of the Compliance Inspection Report is enclosed for your review. Mr.
Gerardo Berrizbeitia, Plant Manager, was also present during the inspection and his time and assistance is greatly
appreciated. The site visit and file review revealed that the subject facility is covered by NPDES Stormwater General
Permit NCG210000 under Certificate of Coverage NCG210459. Permit coverage authorizes the discharge of stormwater
from the facility to receiving waters designated as Rockfish Creek, a Class C waterbody in the Cape Fear River Basin.
As a result of the site inspection, the following permit conditions violations are noted
1) Stormwater Pollution Prevention Plan (SPPP)
A Stormwater Pollution Prevention Plan (SPPP) has not been properly implemented.
2) Qualitative Monitoring
Qualitative monitoring has not been conducted and recorded in accordance with permit requirements.
3) 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 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 violations have occurred as well as a
Plan of Action to prevent these violations from recurring.
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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
91OA33.330

Thank you for your attention to this matter. This Office is considering sending a recommendation for enforcement to the
Director of the Division of Energy, Mineral & Land Resources regarding these issues. Your above -mentioned response to
this correspondence will be considered in this process. This office requires that the violations, as detailed above, be
properly resolved. These violations 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 these matters, please contact Melissa
Joyner or myself at [phone].
Sincerely,
Timothy
nty, PE
Regional Engineer
DEMLR
TLUmaj
Enclosure: Compliance Evaluation Inspection
ec: Gerardo Berrizbeitia, Plant Manager — Pack IQ Fayetteville (via email)
Wiliam E. (Toby) Vinson, Jr., Section Chief — DEMLR (via email)
Annette Lucas, PE, Program Manager— DEMLR, Stormwater Program (via email)
cc: FRO — DEMLR, Stormwater Files

Compliance Inspection Report
Permit: NCG210469 Effective: 08/01/18 Expiration: 07/31/23 Owner: Pack lq
SOC: Effective: Expiration: Facility: PacklQ Fayetteville
County: Cumberland 880 Technology Dr Ste 110
Region: Fayetteville Fayetteville NC 28306
Contact Person: Sulley M Quinones Title: Phone: [phone]
Directions to Facility:
from 195 bus, left onto snow hill rd, right onto claude lee rd, right onto research dr, left onto tom starling rd, right onto production dr,
right onto technology dr, destination on left.
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
On -site representative
Related Permits:
Inspection Date: 09/30/2019
Primary Inspector: Melissa A Joyner
Secondary Inspector(s):
Gerardo 8errizbeitia
EntryTime: 01:13PM Exit Time: 02:25PM
910-3644041
Phone:
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Timber Products Stonnwater Discharge COG
Facility Status: ❑ Compliant 0 Not Compliant
Question Areas:
0 Storm Water
(See attachment summary)
Page 1 of 3

Permit: NCG210469 Owner -Facility: Pack lq
Inspection Date: 09130/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Melissa Joyner met with Mr.Gerardo Berrizbeitia, Plant Manager at the Pack IQ facility. The Stormwater Pollution Prevention
Plan (SPPP) was reviewed. The site map should be modified to indicate the percentage of each drainage area which is
impervious. The annual Employee Training records should be dated. A list of significant spills or leaks or the notation that
none have occurred should be documented in the SPPP. The Best Management Practices Summary should be reviewed
and updated annually. Also, the facility and all stormwater systems should be inspected semi-annually as part of the
Preventative Maintenance and Good Housekeeping Program. The Analytical Monitoring records were reviewed. No
monitoring occurred in the first period of 2019. Qualitative Monitoring has not been conducted. The two Outfalls were
inspected with no issues noted.
Page 2 of 3

Permit: NCG210459 Owner -Facility: pack lq
Inspection Date: 09/30/2019 Inspection Type : Compliance Evaluation Reason forVlsit: Routine
Stormwater Pollution Prevention Plan
Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan?
E ❑ ❑ ❑
# Does the Plan include a General Location (USGS) map?
E ❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
■ ❑ ❑ ❑
# 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?
0 ❑ ❑ ❑
# Does the Plan include a BMP summary?
0 ❑ ❑ ❑
# 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?
E ❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
N ❑ ❑ ❑
# Is the Plan reviewed and updated annually?
❑ N ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
0 ❑ ❑ ❑
Has the Stonnwater Pollution Prevention Plan been implemented?
❑ N ❑ ❑
Comment: The Stormwater Pollution Prevention Plan is not being fully implemented.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ❑ N ❑ ❑
Comment: The Qualitative Monitoring is not being conducted semi-annually,
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? ❑ N ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ E ❑
Comment: Analytical Monitoring has not been conducted for the first period of 2019.
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? ❑ ❑ ❑
# Has the facility evaluated all illicit (non stormwater) discharges? E ❑ ❑ ❑
Comment:
Page 3 of 3