NCGNE1091_COMPLETE FILE - HISTORICAL_20160517

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STORMWATER DIVISION CODING SHEET
,NCG PERMITS
PERMIT NO.
NCGNE
DOC TYPE
NHISTORICAL FILE
DOC DATE
YYYYMMDD

® PAT MCCRORY
Govemor
DONALD R. VAN DER VAART
Secretary
Energy, Mineral TRACY DAMS
and Land Resources
ENVIPONMENTAL OUA41TY
May 17, 2016 D,,c 1
Mr. Matt Bennett
WestRock Converting Company
376 Pine Street Ext
Forest City, NC 28043
Subject: Rescission of No Exposure Permit #NCGNE1091 AFA Warehouse, 135 Pine Street Ext,
Forest City, NC
❑ Rescission request denied. Reason:
request approved, effective immediatelv. Permit coverage rescinded on the followinp hacic-
❑
You reported that you have ceased all regulated activity and sold the facility.
❑
You reported that although you retain ownership or control of the facility, you have ceased all regulated
activit , and there are no materials remaining on site that may resent a risk of stormwater pollution.
You reported that continued permit coverage is not required because the site activities are not regulated
bv the NPDES stormwater permitting program.
❑
Note other basis:
IrDEMLR Regional Office (RO) inspection and concurrence
❑ No RO inspection. We are relying on your representation that a permit is no longer required.
Discharging regulated industrial stormwater, discharging wastewater, or operating a treatment facility
without a valid NPDES permit will subject the responsible party to a civil penalty of up to $25,000 per
day. The Division may pursue enforcement action on persons that have voluntarily relinquished permit
coverage when continuing permit coverage was necessary. If in the future you wish to again discharge to
the State's surface waters, you must first apply for and receive new coverage under an NPDES permit.
If you have questions about our determinations above, please contact the DEMLR Regional Office
(copied below), or Laura 41exande,- in the Raleigh Central Office at [phone].
Sincerely,
�J
for Tracy E. Davis, P.E., CPM, Director
Division of Energy, Mineral, and Land Resources
Stormwater Permitting Program files — with attachments Received
93AI Gentral f iTes
DEMLR 4t/e,1,Z1e Regional Office, Darlene Kucken
MAY 2 0 2016
State of North Carolina I Environmental Quality I Energy, Mineral and Land Resources Land /�Vallty Section
Mail Service Center 1 512 North Salisbury Street I Raleigh, North Carolina 27699-1612 LQuality
919 707 9220 T Asheville

Kucken, Darlene
From: Kucken, Darlene
Sent: Friday, January 29, 2016 10:15 AM
To: Alexander, Laura; Georgoulias, Bethany
Subject: Recission requests and more
Hi gals,
A while back I received some rescission requests for facilities in Rutherford county. I was able to get to these facilities on
1/26/2016 and here's what I found/recommend:
NCGNE1091— Westrock Converting Company —This is only a warehouse for storage of packaged materials. No process
or production.
NCGNE1089 — Westrock Converting Company —This is only a warehouse for storage of packaged materials. No process
or production.
NCGNE1090 — Westrock Converting Company —This is only a warehouse for storage of packaged materials. No process
or production.
I believe the above mentioned permits should be rescinded.
I also conducted an inspection of the main Westrock facility. There is a new Env. Mgr. and he's trying to get up to
speed. Here's what I found and have questions on:
1. Their current permit appears to still be in the name of Rock Tenn In -Store Solutions, Inc. (COC
NCG180003). Was there a request for a name change? If not, can you guide him on this process?
2. He does not find their permit on site (only the cover letter). Can you send this to him?
3. 1 have nothing in our paper or electronic files for a facility in this name or with this COC and I don't know why it
would even be a Textile COC. Can you help me with this?
4. There are currently 3 outfalls per their SWPPP (which is pretty complete). But I think only two are
representative of the facility. -
5. The facility is very clean with very little minor production, but without more information I don't know what else
to say about the facility.
6. The current contact is: Alan Hooper at 828-248-4921.
Please advise me on what to do next with this! He would like to know what he's supposed to be doing.
Thanks!
Darlene Kucken - [e-mail]
North Carolina Dept. of Environmental Quality
Asheville Regional Office
Division of Energy, Mineral, and Land Resources
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
may be disclosed to third parties.
I►,A Go Green! Print this email only when necessary, Thank you for helping NCDENR be environmentally responsible.

ROCK TENN-IN STORE SOLUTIONS
\ SPCC APPLICABILITY FOR AFA WAREHOUSE ON PINE STREET
MAY 20, 2015
RockTenn leases the AFA warehouse, which is serviced by three utility -owned transformers, each with
an oil holding capacity of approximately 700 gallons. RockTenn has not developed a Spill Prevention
Control and Countermeasure (SPCC) plan at the ASA warehouse due to the following:
a. These transformers are owned, operated, and controlled exclusively by Duke Power
b. Duke Power has exclusive access to the transformers. The transformers are locked, and only
Duke Power has the key.
c. Duke Power is responsible for addressing/cleaning up any transformer leaks and managing
other facility -related issues directly involving the transformers; Duke sent an email stating
this to Rock Tenn on April 13, 2015.
d. There are no other transformers on the property of the leased warehouse and RockTenn
does not own, operate, or control any transformers as part of its warehouse operation on
the leased property.
Based on these factors, RockTenn has determined that the transformers are a separate "facility" as
defined in 40 CFR 112.2, which is not owned, controlled, or operated by RockTenn.
Excluding the transformers since they are a separate facility, RockTenn's warehouse operation on the
leased property has far less than 1320 gallons of aboveground oil holding capacity (There are no oil
storage containers/drums 55 gallons or greater in the warehouse under Rock Tenn control) so it is not
required to develop and implement an SPCC plan for its warehouse operation.
In the event warehouse personnel discover a leak or other problem associated with the transformers,
they would immediately contact Duke Power at and report the problem. A copy of email letter from
Duke follows:

Mr. Alan Hooper
RockTenn
Mooresville, N.C.
Subject: Customer Request for Spill Cleanup Information
Dear Mr. Hooper:
Duke Energy is committed to responsible environmental actions. We comply with all state, local and
federal requirements regarding oil spill reporting and cleanups. If any of our oil filled electrical
equipment leaks we are committed to the proper cleanup and disposal of any contaminated soil. We do
reserve the right to bill the responsible party that caused the equipment to leak if applicable. 1
Sincerely,
David Garner
EHS Professional
West Zone
864-380-6682

A
.t
NCDENR
E.mnOxw[xr uO NUULL F[%V1wC[]
Division of Energy, Mineral and Land Resources
Land Quality Section
National Pollutant Discharge Elimination System
NO EXPOSURE CERTIFICATION for Exclusion
NCGNE0000
FORAGENCY USEONLY
Date Received
Ycnr
Month
Day
1
1
Ccmfkatc
oMoverage
N
RECEIVED
National Pollutant Discharge Elimination System application for exclusion from a Wolrr)wtar&rmit based
on NO EXPOSURE:
DENR-LAND QUALITY
STORMWATER PERMITTING
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 must be self re -certified at least annually.
Please see information here:
For questions, please contact the DEMLR Regional Office for your area. (See page 6)
(Please print or type)
1) Mailing address of ownerfoperator (address to which all certification correspondence will be mailed):
Name WESTROCK CONVERTING COMPANY
Contact
Street Address
ALLEN HOOPER
376 PINE STREET EXT
City FOREST CITY
Telephone No. 828-248-4921 _
RECEIVED
OCT 27 2015
State NC ZIP Code 28043
Fax:
DENR-LAND QUALITY
STORMWATER PERMITTING
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NCGNE0O00 No Exposure Certification
2) Location of facility producing discharge:
Facility Name AFA WAREHOUSE
Facility Contact
Street Address
City
County
Telephone No.
ALLEN HOOPER
135 PINE STREET EXT
FOREST CITY
RUTHERFORD
828 248-4921
3) Physical location information:
State NC ZIP Code 28043
Fax:
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). US HIGHWAY 74 EXIT 182; GO SOUTH ON SOUTH
BROADWAY , TAKE LEFT ON PINE ST EXT TO 135 PINE STREET EXTENSION
(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? No
5) Is this a Federal facility? No
6) Latitude 35.31446 Longitude-81.8556 (deg., min., seconds)
7) This NPDES No Exposure Exclusion application applies to which of the following:
Existing
Date operation began
8) Was this facility or site ever covered under an NPDES Stormwater Permit? UNKNOWN
If yes, what is the NPDES Permit Number? UNKNOWN —SITE IS LEASED
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:4225
10) Provide a brief description of the types of industrial activities and products produced at this facility:
WAREHOUSE OPERATIONS ONLY -FINISHED PRODUCT BROUGHT IN FOR STORAGE, AND THEN
LOADED FOR SHIPMENT TO CUSTOMERS
11) Does this facility have any Non -Discharge permits (ex: recycle permits)?
No
If yes, list the permit numbers for all current Non -Discharge permits for this facility:
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NCGNE0000 No Exposure Certification
E
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 No
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 No
c. Materials or products from past industrial activity No
d. Material handling equipment (except adequately maintained vehicles) No
e. Materials or products during loading/unloading or transporting activities No
f. Materials or products stored outdoors (except final products intended for outside No
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, tanks, No
and similar containers
h. Materials or products handled/stored on roads or railways owned or maintained by No
the discharger
i. Waste material (except waste in covered, non -leaking containers [e.g., dumpsters]) No
j. Application or disposal of process wastewater (unless otherwise permitted) No
k. Particulate matter or visible deposits of residuals from roof stacks and/or vents not No
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 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 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 N/A
deterioration, or evidence of leaks?
b. Is secondary containment provided for all exterior ASTs? If so, is it free of any N/A
cracks, holes, or evidence of leaks, and are drain valves maintained locked shut?
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NCGNE0000 No Exposure Certification
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 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 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 N/A
Amendments and Reauthorization Act (SARA) water priority chemicals*?
d. Is secondary containment provided for hazardous substances'" designated in 40 N/A
CFR §116?
e. Are release valves on all secondary containment structures locked? N/A
15) Hazardous Waste:
a. Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility? N/A
b. Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous waste N/A
generated per month) of hazardous waste?
c. Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste 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:
How is material stored: _
Where is material stored:
How many disposal shipments per year:
Name of transport / disposal vendor:
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.
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NCGNE0000 No Exposure Certification
•
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.
a. Does your facility store used, recycled, or otherwise reclaimed pallets outside? No
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:
No
am
No
❑ Yes ❑ No ❑ N/A
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NCGNE0000 No ExposureeCCertification
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 submit a no exposure certification form once every five (5) year 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.
I 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: _Ken Warren f1C^I WA rrtrJ
Title: _Operations Manager
(Signature of 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.
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 fled 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.
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Jeff Lamm
P.O. Box 5395
Asheville, NC 28813
Ph: 828-253-6421
Fax: [phone]
IAIAT4c ann-9aa-rs 91