NCG050421_NOV Response_20191125

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BRANDS
November 14, 2019
2880 Kenny Biggs Road Michael Lawyer, CPSWQ RECEIVED
Lumberton, NC 28358 y '
225 Green Street, Suite 714 NOV 2 5 201
Fayetteville, Nc 28301 �! ' :/Ml"_l
+ 1.910.737.650main DEQ•FAYETTEVILLE NAL OFFICE
+ 1.910.737.6507 fax
RE: Notice of Violation (NOV-2019-PC0732)
newellbrands.com NPDES Stormwater General Permit NCG050000
Quickie Manufacturing Corporation
Dear Mr. Lawyer:
Based on the findings from the Stormwater Compliance Inspection conducted by the
North Carolina Department of Environmental Quality (NCDEQ) on November 05, 2019,
the facility's Qualitative Monitoring records were determined to be inadequate as we
were only able to show one record for the first half (January — July) of 2019, indicating
that there had been no qualifying storm events during that time. The NCDEQ issued a
Notice of Violation (NOV) for non-compliance with the Qualitative Monitoring
requirements of the NCG050000 permit, which states that Qualitative (visual)
Monitoring is to be conducted on a semi-annual schedule (January - June, July -
December) at all stormwater discharge outfalls.
We regret this oversite as we have been experiencing recent changes in personnel in
our Environmental, Health, and Safety (EHS) Department. Going forward our EHS
Department will be conducting and recording Qualitative Monitoring Inspections per
the conditions outlined in the NPDES Stormwater General Permit NCG050000. Our EHS
team will monitor the three (3) discharge outfalls semi-annually during the periods of
January - June and July - December.
Additionally, the NCDEQ reviewed our Stormwater Pollution Prevention Plan (SPPP)
(dated April 2018 with revisions in July 2019) and found it to contain all permit -required
components except for an updated list of significant spills or leaks during the previous
three (3) years or notation that none had occurred. The NCDEQ recommended that we
better document the annual review and update requirements per Part 11, Section A, Item
8 of the SPPP conditions contained in the permit. Going forward, we will be sure to
document the annual review and update in compliance with permit conditions.
W-0 ME I ME I I I OWN

If you have any questions or would like to discuss further, please do not hesitate to
contact me at 910-737-6500 or by email at [e-mail].
Sincerely,
Robin Kuhl
Quickie Manufacturing Corporation