NCG050364_COMPLETE FILE - HISTORICAL_20110209

I h t, (,L d 19 W,I)
STORMWATER DIVISION CODING SHEET
RESCISSIONS
PERMIT NO.
DOC TYPE
Ci COMPLETE FILE - HISTORICAL
DATE OF
RESCISSION
❑ � 01 1 0 a 60 °
YYYYMMDD

Nomaco Inc. / Spongex LLC
3006 & 3002 Anaconda Rd. Tarboro, NC, 27886
Permit # NCG050364
Dear Mr. Smith,
This is in regard to the NOV Case No. NOV-2011-PC-0022 where Nomaco Inc. and Spongex LLC proved
to be in violation of the Storm Water Permit issued on December 8", 2008, by not having the required
Storm Water Pollution Prevention Plan established and in force at the time of inspection.
Per the requirements set for the in the NOV letter we received on January 10'h, 2011, we submit the
following timeline:
Item
Target Date
1) Re -produce a Stormwater Pollution Prevention Plan
Completed 2/8/11
2) Implement the monitoring requirements of your permit as soon as the
First representative storm
SDO have been identified. Provide documentation of the monitoring
event.
results to this office as soon as they are completed.
3) Provide a map identifying the SDO
Completed 2/8/11—see
site map in storm water
plan submitted to DWQ on
2/9/11
We hope this suffices in establishing our intent to fully comply with the requirements established by the
Stormwater permit.
Regards,
Peyton tamper
4 -
Plant Engineer, Nomaco Inc.
P: 252-563-1763 C: 919-302-3495
[e-mail]
�U►e EI ,
FEB -92011
.XE&F

NCDENR
North Carolina Department of Environment and Natura Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
January 7, 2011
CERTIFIED MAIL 7008 01300 0000 1109 4963
RETURN RECEIPT REQUESTED
Mr. Robert W. Palz
Nomalco/Spongex LLC
501 Nomalco Drive
Zebulon, NC 27597
Subject: NOTICE OF VIOLATION
Case No. NOV-2011-PC-0022
Compliance Evaluation Inspection
Stormwater Permit NCG050164
Nomalco, Inc.
Edgecombe County
Dear Mr. Palz:
On December 21, 2010, Dave Parnell of the Raleigh Regional Office carried out a stormwater
compliance evaluation inspection (CEI) for the above permit. Mr. Peyton Stamper was available to
assist Mr. Parnell. A file review indicates that this was the first time DWQ had inspected this facility.
See the enclosed inspection checklist. A number of issues emerged and are discussed below:
This permit was issued December 8, 2008 and it expires May 31, 2013. The permit was
produced during the CEI.
2. Mr. Stamper was unable to locate the Stormwater Pollution Prevention Plan (SP3) during the
inspection. After checking with former employees of the company in the days following the
CEI, Mr. Stamper called to inform Mr. Parnell that due to high tumover of employees at the
company, he was unable to locate the SP3. Mr. Parnell concluded that there had not been a
continuity of staff ensuring compliance with the permit. Also, Mr. Stamper was unsure of the
location of the Stormwater Discharge Outfalls (SDO) and could not produce any monitoring
results. As discussed during the CEI, the permit requires qualitative monitoring be conducted
at each (all) designated SDO, in a frequency directed by tables within your permit.
Please prepare a timeline addressing the following:
A) Re -produce a Stormwater Pollution Prevention Plan.
No YhCarolina
Naturally
North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone [phone] Customer Service
Internet: w .ncwaterquality.org 1628 Mail Service Center Raleigh, NC 27699-1628 FAX [phone]
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10 % Post Consumer Paper

Nomaco, Inc. Compliance Evaluation Inspecition
V1
Page 2 of 2
B) Implement the monitoring requirements of your permit as soon as the SDO have been
identified. Provide documentation of the monitoring results to this office as soon as they
are completed.
C) Provide a map identifying the SDO.
Please provide a written response to this letter, within 30 days of the receipt of this letter, detailing
Nomaco/Spongex LLC's compliance efforts with respect to the bold items found above in #2A, 92B,
and #2C. If there are any questions or comments about this inspection, please contact Dave Parnell at
919-791-4200 or david.parnellancdenr yov. Please note that a violation of Stormwater Permit
conditions, monitoring and record -keeping, are subject to civil penalties of up toy-5,000.00 per day
S' cer ly,
a12 fi
Danny Smitly�
Water Quali y Regional Supervisor
Raleigh Regional Office
cc: RRO/SWP Files
Central Office Files
Enclosure: Inspection checklist for Nomaco, Inc. dated December 21, 2010

4
Compliance Inspection Report
Permit: NCG050364 Effective: 12/08/08 Expiration: 05/31/13 Owner: Nomaco Inc
SOC: Effective: Expiration: Facility: Nomaco Inc / Spongex, LLC
County: Edgecombe 3006 Anaconda Dr
Region: Raleigh
Tarboro NC 27886
Contact Person: Robert W Paltz Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Certification: Phone:
Inspection Date: 12/21/2010 Entry Time: 11:30 AM Exit Time: 12:30 AM
Primary Inspector: David R Parnell Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Apparel/Printing/Paper/Leather/Rubber Stormwater
Discharge COC
Facility Status: ❑ Compliant ■ Not Compliant
Question Areas:
0 Storm Water
(See attachment summary)
Page: 1

r
Permit: NCG050364 Owner- Facility: Nomaco Inc
Inspection Date: 12121/2010 Inspection Type: Compliance Evaluation - Reason for Visit: Routine
Inspection Summary:
Stormwater Pollution Prevention Plan
Yes • No
NA NE
Does the site have a Stormwater Pollution Prevention Plan?
❑ ■
❑ ❑
# Does the Plan include a General Location (USGS) map?
❑ ■
❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
❑ ■
❑ ❑
Al Does the Plan include a detailed site map including outfall locations and drainage areas?
❑ ■
❑ ❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
❑ ■
❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
❑ ■
❑ ❑
# Does the facility provide all necessary secondary containment?
❑ ■
❑ ❑
# Does the Plan include a BMP summary?
❑ ■
❑ ❑
Al Does the Plan include a Spill Prevention and Response Plan (SPRP)?
❑ ■
❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
❑ ■
❑ ❑
# Does the facility provide and document Employee Training?
Cl ■
❑ ❑
# Does the Plan include a list of Responsible Party(s)?
❑ ■
❑ ❑
# Is the Plan reviewed and updated annually?
❑ ■
❑ ❑
At Does the Plan include a Stormwater Facility Inspection Program?
❑ ■
❑ Cl
Has the Stormwater Pollution Prevention Plan been implemented?
❑ ■
❑ ❑
Comment: Peyton Stamper was unable to locate the plan and there was no indication
that a plan had been implemented.
Qualitative Monitoring
Yes No
NA NE
Has the facility conducted its Qualitative Monitoring semi-annually?
ONOO
Comment: No monitoring results available at time of inspection.
Permit and Outfalls
Yes No
NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site?
■ ❑
❑ ❑
# Were all outfalls observed during the inspection?
❑ ■
❑ ❑
# If the facility has representative outfall status, is it documented by the
❑ Cl ❑
properly Division?
■
# Has the facility evaluated all illicit (non stormwater) discharges?
❑ ❑ ❑ ■
Comment: Permit was found during inspection. Outfalls were not observed as Mr.
Stamper has not been the compliance official in the past and did not know the location
of the outfalls.
Page: 2

STORMWATER-POLLUTION PREVENTION PLAN
NOMACO, Inc.
3006 Anaconda Road
Tarboro, North Carolina 27886
Spongex, LLC
3002 Anaconda Road
Tarboro, North Carolina 27886
Prepared:
November 30, 2008
Revision:
Revision 4
ffa NOACO.
2[pnr
� ' k* J� � � ��
LLC

Revision Record
Revision Date
Corrections By
Changes Made
Reasons For Changes
11/30/08
Tracy Armstrong,
New Document
Stormwater Pollution Prevention
EHS Manager Noel
Plan created to comply with site
Group
stormwater permit (NCG050364)
requirements.
Tracy Armstrong,
Additional site
Stormwater Pollution Prevention
6/l/09
EHS Manager Noel
specific details added
Plan was not complete, still
Group
to draft SP3 Plan
partially in template format.
1/7/11
Hellman &
Change in document
Existing Stormwater Pollution
Associates, Inc.
organizational
Prevention Plan did not meet all
structure. Revision to
of the plan conditions identified
existing site -specific
in the site stormwater permit.
information and the
addition of required
information.
2/6/11
Peyton Stamper,
Revised document to
Stormwater Pollution Prevention
Plant Engineer
reflect current
Plan did not meet all of the plan
Nomaco Insulation
company structure
conditions indentified in the site
and provided missing
stormwater permit.
information.
FFR-92011
NOI)SC
f...:.:_IRegion^_1O C"a

Stormwater Pollution Prevention Plan
GENERAL COMPANY POLICY
The purpose of this program is to inform employees and other interested persons about policies,
controls, and procedures that have been implemented at Nomaco, Incorporated (Nomaco) and
Spongex, LLC (Spongex) to comply with EPA requirements for preparing and maintaining a
Stormwater Written Pollution Prevention Plan under the stormwater regulations (Title 40, Code
of Federal Regulations, Part 122). Since the stormwater permit covers both NOMACO and
Spongex, this stormwater pollution prevention plan covers operations at both facilities.
Our written pollution prevention plan consists of:
(1) An evaluation of the sources of pollution at our facilities, and
(2) A description of the practices and program elements to reduce pollutants in areas identified as
being potential pollutant sources for stormwater discharges associated with industrial activity.
We encourage any suggestions that our employees have for improving our Stormwater Written
Pollution Plan, as we are committed to developing and maintaining an effective plan. We strive
for clear understanding, safe behavior and involvement in the plan from every level of the
company.
ADMINISTRATIVE DUTIES
The Plant Managers are responsible for our written stormwater pollution prevention plan. Copies
of our written plan may be obtained from the shared drive on the intranet or the office of the site
Environmental contact. It is a company policy to make our plan available to our employees.
Employees can obtain access to the plan by requesting a copy of the plan from either the site
Environmental Contact. The plan is also available on the Company intranet to those who have
access.
The Plant Manager, Operations Manager, Plant Engineer, Maintenance Supervisors, and
Warehouse Supervisors make up our company's stormwater pollution prevention committee.
This committee is responsible for developing the stormwater pollution prevention plan and
assisting the Plant Manager in its implementation, maintenance and revision. In addition, the
pollution prevention team is also responsible for:
A. Implementing all general permit and pollution prevention plan requirements.
B. Defining and agreeing upon an appropriate set of goals for the facilities' stormwater
management program.
C. Maintaining a clear line of communication with plant management to ensure a cooperative
partnership.

The pollution prevention team also must evaluate existing environmental management plans for
consistency and determine which, if any, provisions can be incorporated into the Stormwater
Pollution Prevention Plan. Other related plans may include the Preparedness, Prevention and
Contingency Plan (40 CFR Parts 264 and 265), the Spill Control and Countermeasures
requirements (40 CFR Part 112), the National Pollutant Discharge Elimination System Toxic
Organic Management Plan (40 CFR Parts 413, 433 and 469), and the Occupational Safety and
Health Administration (OSHA) Emergency Action Plan (29 CFR Part 1910).
STORMWATER PERMIT HISTORY
Prior to the start-up of Spongex (Spongex, LLC began operations in November of 2007),
NOMACO operations had applied for a Conditional No Exposure Certification (NEC) provided
for in 40 CFR 126.22. An extended period of time lapsed and the Spongcx project began prior to
a response from the Department of Water Quality. Given the potential for stonmwater exposure
and the contiguous property which encompasses both facilities, it was decided to submit a new
request for NEC which included both facilities. This time the DEQ responded with an inspection
and denied the request for NEC. It was at this time that a Notice of Intent was submitted and
subsequently coverage under the general permit was granted. Based on this sequence of events,
material exposure to precipitation and storm water runoff during the period of three years before
the permit was issued was limited to NOMACO operations only. Other than outside storage of
general trash, NOMACO operations were not exposed to precipitation or stormwater runoff.
Good housekeeping practices were employed to minimize material contact with stormwater.
SITE PLAN
Location Description and General Location Map
The Nomaco and Spongex facilities are located at 3006 and 3002 Anaconda Rd. respectively in
the township of Tarboro in Edgecombe county North Carolina.

NCGO5036 County: Edgecombe Receiving Stream: Unamed Tributary to Raccoon Branch
Noamco Inc. ! Spogex LLC Stream Class: WS-IV, NSW
Outfall #1 : Latitude: 35°54'45.66" N, Longitude
Outfall #2: Latitude: 35°54'50.37" N, Longitude
Outfall 93: Latitude: 35°54'55.3" N, Longitude:
Storage Practices
Sub -basin: TAR03(03-03-03) (Tar -Pamlico RB)
: 77°35'7.82" W
:77°35'12.25" W
77035'19.1" W
Some final product is stored uncovered at the Spongex facility during overflow storage conditions.
The final product is an article of closed cell foam in various shapes and sizes. There is no leaching
of raw material due to stonnwater exposure.
Loading and Unloading Activities
At the Spongex facility unloading of a flammable solvent is accomplished via tanker truck
delivery into one of two bulk storage tanks. Unloading of solvent raw material into bulk storage
tanks is located on the East side of the Spongex facility. Under normal conditions significant
amounts of the solvent are not exposed to storm water. In the case of a catastrophic failure during
unloading, there would potentially be exposure to storm water; however, the area does have
secondary containment.

At the Nomaco facility unloading of plastic resin pellets is accomplished via tanker truck
delivery into one or five bulk storage silos. This area is located on the Northeast side of the
facility. Under normal operating conditions no amount of plastic resin is exposed to stone water.
In the event of a catastrophic failure during unloading there would be potentially be exposure to
storm water.
Nomaco facility receives Isobutane to its storage tanks via tanker truck. This area is located on
the Northeast side of the facility. Under normal operating conditions no amount of isobutane is
exposed to storm water. In the event of a catastrophic failure during unloading there would be
potentially be exposure to storm water but due to the nature of this gas it will vaporize rather
than being carried away by stormwater.
Final product at both facilities is loaded from dock doors. All loading of final product occurs
under roof and is not exposed to precipitation. Unloading of raw materials is done via closed
conveyance systems and is not exposed to precipitation during normal operations.
Outdoor Process Areas
Nomaco: lsobutane storage and pumping systems located 75 feet from Northeast side of the
facility containing one 8,500 gal tank and one 5,500 gal tank. There is a fill manifold for both
tanks for the unloading of transport tankers.
Nomaco: Plastic resin storage systems located adjacent to the facility on the Northeast
Spongex: Two 10,000 gal solvent storage tanks and pumping systems within an enclosed dike
located 35 feet from the northeast side of the facility. There is a fill manifold for both tanks for
the unloading of transport tankers. Location for transport tanker is within a larger spill
containment area.
Dust or Particulate Generating or Control Processes
Nomaco: The operation for regrinding, densification and repelletizing of polyethylene plastic
generates dust which is captured by filtration systems within the process. The air for these
systems is discharged inside the facility.
Spongex: The operation for particle size reduction in the mixing area has five sources for
generating dust which is captured by filtration systems within the process. The air for these
systems is discharged to the exterior of the facility.
Waste Disposal Practices
Spongex also has scrap foam that is accumulated in covered roll -offs. The scrap foam itself will
not leach due to exposure to stormwater. Since disposal is not done during rainy conditions it is
assumed that any exposure to stormwater is minimal and would represent an exception or occur
due to unforeseen circumstances.
Roll -offs of general trash and some final product slated for land fill disposal is also accumulated
on site. The final product would be consistent with the final product storage described above.

Nomaco operations include roll -offs of general trash that is accumulated on -site.
Site Map
See Appendix A — Site map
Significant Spills or Leaks
No significant spills or leaks of toxic or hazardous materials have occurred at the facilities since
the stormwater permit was received.
No significant materials as identified in Section E. Part V1.27 of the General Stornwater Permit
(NCG050364) have been exposed to storm water between the time of three years prior to the date
of the issuance of the facilities permit and the present.
Stornwater Discharge Outfall Certification
See Appendix C
STORMWATER MANAGEMENT PLAN
The Nomaco facility handles raw materials for production of polyethylene foam. In addition the
plant handles a small inventory of machine oils and other miscellaneous maintenance chemicals
such as adhesives, cleaners, lubricants, etc. The Spongex facility handles raw materials used to
produce closed cell foam. There are both liquid and solid raw materials. Both facilities handle
scrap foam and miscellaneous maintenance chemicals.
Material management activities at both Spongex and Nomaco include: 1) Good housekeeping, 2)
Monitoring of unloading activities to minimize potential for uncontrolled spill, 3) Storage of
equipment and materials under roof to the extent possible, 4) Frequent pick-ups of trash hoppers;
5) Consumption of all product before disposal; 5) Frequent inspections, and 6) proper disposal of
all hazardous materials generated on site.
Neither Spongex nor Nomaco is subject to SARA Title III, Section 313 reporting requirements.
Precautions have been taken at both facilities to ensure that the materials of construction for
containers handling hazardous substances or toxic pollutants are compatible with the container's
contents and surrounding environment.
Feasibility Study
At our facilities, there are certain activities that have a high potential for contaminating
stormwater. These activities are: waste disposal, storage of final product and raw material

unloading activities are exposed to stormwater at both the Nomaco and Spongex facility.
However, secondary containment, good housekeeping practices, and spill control procedures
minimize greatly reduce the potential for any contamination of stormwater. In addition, there are
pollutants of concern that may be associated with these activities. These pollutants are:
particulate, plastic pellets, and a flammable solvent. Both bulk storage and unloading activities
have secondary containment.
Certain types of pollutants have the potential to be exposed to stonnwater. These pollutants are
Scrap material collected in roll -offs located at the Northeast corner of the Spongex facility
represents the area of the facilities with reasonable potential for containing significant amounts
of pollutants. No chemical constituents are released due to exposure to stormwater. Given this,
the greatest risk is for solid scrap remnants or Total solids to be exposed to stonnwater in this
area of the facility. The scrap containers are covered except when material is being added.
Material is not added during storm events. In addition, spills are cleaned up in a timely fashion.
Although the potential for significant amounts of pollutants to be exposed to stormwater is not
great, this represents the greatest potential at this facility.
The potential for runoff from both the Spongex and Nomaco facility is low. The Spongex facility
has a concrete wall that prevents any contaminated runoff from the site. The Nomaco site has a
recessed loading dock and a holding pond on the West side of the facility that prevents any
contaminated runoff from this side of the facility.
See Appendix A & B — Site map and area topography map respectively.
Secondary Containment Schedule
The storage tanks at the Spongex facility have secondary containment. Two 10,000 gallon bulk
storage tanks are located inside a containment area with enough capacity for one tank plus
sufficient freeboard to allow for the 25-year, 24-hour storm event. In addition to the secondary
containment the loading area is sloped so that a catastrophic failure would be contained by a
containment wall which prevents any spill from entering into a nearby creek. The unloading area
is paved with asphalt.
The Nomaco facility has a loading dock on the West side of the facility which serves as
secondary containment. It is drained by a sump pump which discharges through a 4" PVC pipe
to stormwater holding pond which also serves as secondary containment.
BMP Summary
At Spongex the structural controls include secondary controls for outside storage of bulk storage
tanks. The secondary containment is a block wall that is large enough to contain the largest tank
plus enough freeboard for a 100 year stormwater event. There is a discharge pipe that is
controlled via a normally closed ball valve which is kept under lock and key. Tertiary control is
provided by a block containment wall which ensures that any spillage during unloading will be
contained. Non-structural controls include procedures, stormwater pollution prevention training
and inspections conducted by associates knowledgeable in the both regulatory requirements and

the requirements of this plan. Procedures include housekeeping, spill control and response and
inspection of accumulated stormwater prior to release from containment areas. Non-structural
controls also include frequent disposal of trash containers to prevent overflow.
Given the absence of outside material storage and processes and exposed raw material unloading
at Nomaco, there is no need for structural controls. However, there is a recessed loading dock
located at the South West corner of the facility and a stonnwater holding pond adjacent to the
west side of the facility. The loading dock containment area is drained via a discharge pipe that is
controlled via a normally closed ball valve which is kept under lock and key. Grassy areas have
been planted to reduce erosion at both sites. Non-structural controls are in place at both facilities.
Stormwater is untreated at both Nomaco and Spongex.
SPILL PREVENTION AND RESPONSE PLAN
Spill Response Equipment is located in areas where spill potential exists. With regard to storm
water pollution the most significant spill likely to be encountered would be associated with the
solvent storage tanks on the East side of the Spongex facility. Other spills that might be
encountered at both facilities of less likely hood or significance would be:
• Vehicle fuel
• Vehicle oil
• Equipment oil
• Plastic pellets
Our Maintenance associates are trained in HAZWOPER procedures and respond to major spills.
See Table 1 — Spill Kit Inventory
See Table 2 — Material Handling & Spill Prevention / Clean-up Procedures
PREVENTATIVE MAINTENANCE AND GOOD HOUSEKEEPING PLAN
Preventative Maintenance
We maintain an ongoing preventive maintenance program. The current preventative maintenance
program includes frequent inspections for valves and equipment, maintenance of equipment
according to manufacturer's recommendations. Any oil handling equipment is included in the
preventative maintenance program.
See Table 3 — Preventative Maintenance / Routine House Keeping Inspections
See Form l — Preventative Maintenance / Housekeeping Inspection Form

Good Housekeeping
It is our policy to maintain clean and orderly facilities to minimize potential for industrial runoff
as well as to ensure the safety of our employees. Our good housekeeping program emphasizes
reducing the possibility of mishandling chemicals or equipment and training of employees in
housekeeping techniques.
Good housekeeping practices have been implemented to ensure that spills are cleaned up in a
timely manner preventing foam or any other solid material runoff into stone drains and surface
runoff. In addition, good housekeeping and spill response procedures have been implemented to
minimize risk of exposure due to spills that could potentially occur during connection or
disconnection of loading/unloading equipment.
See Table 3 — Preventative Maintenance / Routine House Keeping Inspections
See Form I — Preventative Maintenance / Housekeeping Inspection Form
EMPLOYEE TRAINING
All associates receive hazard communication training initially and on a periodic basis.
Associates are trained when new chemicals are introduced at the site. Employees at both
facilities are trained in the following elements:
Training Topic
Covered Personnel
Frequency
Preventative Maintenance Procedures
Maintenance
Annually
Good House Keeping Practices
Maintenance / Receiving
Annually
Qualitative Monitoring Procedures
Maintenance
Annually
Spill Response & Reporting
Maintenance
Annually
Good Material Handling Practices
Maintenance / Receiving
Annually
In addition, employees are trained not to dispose of any chemical without the approval of the
site Plant Engineer or supervisor. We maintain annual employee training in stormwater pollution
prevention to inform personnel at all levels of responsibility of the components and goals of the
stormwater pollution prevention plan.
The Site Plant Engineer is responsible for conducting employee training.
See Form 2 — Employee Training form
RESPONSIBLE PARTY
The Nomaco and Spongex facilities have collectively formed a Stormwater Pollution Prevention
Committee. Each individual on the stormwater pollution prevention committee has a set of
responsibilities.
m

The plant managers at each facility are responsible for the overall quality of this plan as well as
overall compliance with regulatory and plan requirements. The Spongex Plant Manager and the
Nomaco Plant Engineer shall be responsible for coordinating the design, implementation, and
maintenance of the plan as it relates to each facility. The Nomaco Plant Engineer shall have
overall responsibility for maintenance of the plan and any regulatory reporting requirements. A
site -wide stormwater pollution prevention team shall be assembled. Representative members
from each of the following areas at each plant shall make up the team: Environmental,
Engineering, Maintenance, Warehouse. This team shall be responsible for conducting semi-
annual inspections and annual review of this plan against regulatory requirements. The Plant
Manager/Plant Engineer or their designee shall ensure that containment areas are inspected and
approved prior to any release of stormwater from containment areas. The Plant Manager/Plant
Engineer shall also ensure the qualitative monitoring is completed in accordance with the permit
requirements listed in Table 1 of Section B.
The Plant Manager is responsible for spill prevention at each facility. These responsibilities
include ensuring associates are assigned responsibility for training and spill response including
inventory control and management, maintenance of supplies and good housekeeping.
The Site Plan Engineer is responsible for 1) conducting periodic site investigations, 2) keeping
records of all inspections and reports, and updating the plan as needed.
PLAN AMMENDMENT
This Stormwater Pollution Prevention Plan shall be amended whenever there is a change in
design, construction, operation, or maintenance which has a significant effect on the potential for
the discharge of pollutants to surface waters. In addition, the Plan shall be reviewed and updated
on an annual basis.
See Form 3 — Annual SWPPP Review Form
FACILITY INSPECTION PROGRAM
Inspections of the facility and all stormwater systems shall occur on a semi-annual schedule -
during the first half of the year (January to June) and during the second half (July to December),
with at least 60-days separating inspection dates. The inspection and any subsequent
maintenance activities performed shall be documented, recording date and time of inspection,
individual(s) making the inspection and a narrative description of the facility's stormwater
control systems, plant equipment and systems.
See Form 4 — Comprehensive Site Inspection Form
QUALITITATIVE MONITORING PROGRAM
Qualitative monitoring in the form of visual inspections of each stormwater outfall is performed
as specified below in Fig 1. For this type of monitoring, no analytical tests are required.

However, qualitative monitoring of stormwater outfalls must be performed during a
representative stone event.
A representative storm event is defined as a storm event that measures greater than 0.1 inches
of rainfall and that is preceded by at least 72 hours in which no storm event measuring greater
than 0.1 inches has occurred. A single storm event may contain up to 10 consecutive hours of no
precipitation. For example, if it rains for 2 hours without producing any collectable discharge,
and then stops, a sample may be collected if a rain producing a discharge begins again within the
next 10 hours.
Fig 1. Qualitative Monitoring Requirements
Discharge Characteristics
Frequency Monitoring
Location'
Color
Semi -Annual
SDO
Odor
Semi -Annual
SDO
Clarity
Semi -Annual
SDO
Floating Solids
Semi -Annual
SDO
Suspended Solids
Semi -Annual
SDO
Foam
Semi -Annual
SDO
Oil Sheen
Semi -Annual
SDO
Other obvious indicators
of stormwater pollution
Semi -Annual
SDO
Footnotes:
3 Monitoring Locations: Qualitative monitoring shall be performed at each stormwater discharge outfall (SDO)
regardless of representative outfall status.
A guidance document for conducting qualitative stormwater monitoring is found online at
httl::Hportal.ncdenr.org/c/document library/get file?uuid=2b010736-9c8b-4f2O-bc80-
8efc3dfed6f4&groupld=3 8364
Onsite vehicle maintenance is not performed at the Nomaco/ Spongex facilities thus the
monitoring requirements identified in Section C of the general permit do not apply to these
facilities.
12

APPENDIX A - si'm MAP
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Tol.l aar. 3m.J ,8,9B3
ro
ro ro
Imp, f:wz« mao75%
• ® DRAINAGE MELD
O ExpmrM eollmmis: V.hickolls,B..w,d<Aris,•
pminors imcnu
Toul ama: sw., . , p a
4
Impervious ewx<vea: 39,rA
p m I LD3
E,psPolluuVNik oils, (Ionung
dcLria.•
P
p
l
AP-C-W..m nl dike noondsangc unAa
i
.mNu
Tolalmca:l,.a r1
�, O Impcn,ous 31N %
rvfaracc m<a.
�
00
O
roc
SDO2
' BMP- Saaodan mnminmrnl •mll xiW bcW Mmag<.al.c.

Appendix B
Nomaco / Spongex LLC Topo Map
NCG05036 Nomaco Inc.: Spongex LLC
APPENDIX 13 -TOPO MAP

Nomaco / Spongex LLC Storm Water Pollution Prevention Plan
Appendix C
Representative Storm Water Outfall Certification
for
Nomaco / Spongex LLC
3006 & 3002 Anaconda Rd. Tarboro, NC, 27886
Permit # NCGO50364
This is to certify that the stormwater outfalls located at:
SDO# 1: Latitude: 35°54'57.34" N, Longitude: 77°35'18.84" W
SDO# 2: Latitude: 35°54'53.74" N, Longitude: 77°35'6.65" W
are associated with similar industrial activities such that the characteristics of storm water runoff are
essentially the same. Therefore, Nomaco / Spongex LLC requests that it be allowed to sample the
outfalls located at:
SDO # 001: Latitude: 35°54'45.66" N, Longitude: 77°35'7.82" W
SDO # 002: Latitude: 35°54'50.37" N, Longitude: 77°35'12.25" W
SDO # 003: Latitude: 35°54'55.3" N, Longitude: 77°35'19.1" W
as the representative outfalls.
The above outfalls have been evaluated for the presence of non-stormwater discharges and that there
are no other significant discharges.
Certification: I certify that I have chosen points that are most likely to contain pollutants from the area. 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 gather
and evaluate 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 fines and imprisonment.
Doug Stolpe, Operatio s Mana er, Nomaco Insulation:
Signature: / Date:
James Welch, Plant Manager, Spongex LLC
Signature: -0-, Date: Zl411/

Table 1- Spill Kit Inventory
Location
Absorbents
Tools
PPE
Other Supplies
(Spongex) Maintenance Shop
Pads, absorbent clay, pigs
Shovels, brooms, squeegees,
Rubber gloves, face shield, dust
Warning tape, traffic cones,
tarp
masks
labels, markers, MSDS
(Spongex) Mixing Room
Pads, absorbent clay, pigs
Shovels, brooms, squeegees,
Rubber gloves, face shield, dust
Warning tape, traffic cones,
tarp
masks
labels, markers, MSDS
(Nomaco) Maintenance Shop
Pads, absorbent clay, pigs
Shovels, brooms, squeegees,
Rubber gloves, face shield, dust
Warning tape, traffic cones,
tarp
masks
labels, markers, MSDS
Responsible Parties:
Nomaco: Peyton Stamper, Bryan Rooker
Spongex: Jack Smith
Spill Response Contractor:
Eastern Environmental Management
24 hr. Phone #: [phone]
NCDWQ Spill Reporting Emergency Hotline:
1-800-858-0368

Table 2 — Material Handling & Spill Prevention / Clean-up Procedures
Potential Spill Area
Material Handling & Storage Procedures
Spill Response Procedures & Equipment
Spongex - Two 10,000 gal. Solvent storage tanks
• Solvents are transferred to the 10,000 gal.
• Minor spills that occur due to the coupling and
storage tanks from tankers via hose and quick
uncoupling of fill lines is treated by
connect couplings by the tanker driver.
maintenance personnel using absorbent clay
• Receiving personnel unsecure the tank fill lines
from spill kit located in the mixing room
by means of locking devices on the ball fill line
adjacent to the solvent storage area. The clay is
ball valves prior to unloading.
then disposed of according to the companies
• Receiving personnel must confirm that the
waste disposal program.
primary and secondary drain valves are closed
• In the event of a large spill the maintenance
and secured.
response personnel will secure the area and
• Receiving personnel must supervise the
contact the Spill Response Contractor.
unloading process.
• Receiving personnel secure the tank fill lines by
means of locking devices on the ball fill line ball
valves after unloading.
Nomaco / Spongex property —General spills
• If possible, liquid or hazardous materials should
• Clean up minor spills immediately.
be handled, used, stored, re -package and
• Block any down gradient storm drains with
transferred indoors or under cover
berms, covers, absorbent socks or "pigs".
• Deliveries of bulk liquids should be supervised.
• Never hose down spills or leaks.
Down gradient storm drain inlets should be
• Always use "Dry Cleanup Methods" for cleanup
covered during deliveries.
of fuel spills (gas, diesel, motor oil or kerosene).
• Cover and contain containers, materials and waste.
1. Spread absorbents ("kitty litter" or loose
• Keep all containers closed unless adding or removing
absorbents, sheets, pillows, pigs, or socks)
mater
on the spill.
2. Sweep up or pick up the absorbed
materials.
3. Dispose of wastes properly.
• If fluids are leaking or have spilled on an
impermeable surface, such as a roadway, locate
nearest down gradient storm drain and dike or
berm the drain to prevent fluids from entering
it.
• Put down absorbent on the spill area.
• After clean up, be sure to sweep up the contaminated
absorbent and remove the berm or dike at storm
drain.
• If Fluids are leaking or have spilled on a permeable
surface, such as gravel, soil or grass, mark the area
and report the spill to the spill response contactor.

Table 2 — Material Handling & Spill Prevention / Clean-up Procedures Continued
Responsible Parties:
Nomaco: Peyton Stamper, Bryan Rooker, James Mann
Spongex: Jack Smith, Ronnie House
Spill Response Contractor:
Eastern Environmental Management
24 hr. Phone #: [phone]
NCDWQ Spill Reporting Emergency Hotline:
1-800-858-0368

Table 3 — Preventative Maintenance / Routine Housekeeping Inspections
Description of Area or Equipment
Tasks
Frequency
Spongex— Solvent storage tanks
1. Inspect containment dike structure for cracks or damage.
Monthly
2. Inspect integrity of interior coating.
3. Inspect drain valve for leaks and proper operation. R&R as needed.
4. Inspect structural integrity of tanks.
5. Check tanks for leaks.
6. Check pumps for leaks. R&R as needed.
7. Check piping for leaks. R&R as needed.
Spongex— Secondary containment wall
1. Inspect containment wall structure for cracks or damage.
Monthly
2. Inspect drain valve for leaks and proper operation. R&R as needed.
Spongex — Outfall #1
1. Inspect outfall and remove collected debris is needed.
Weekly
Nomaco / Spongex—Facility exterior
1. Check for vehicular oil spills. Clean up accordingly.
Weekly
2. Check for unsecured trash. Clean up accordingly.
3. Check for signs of structural corrosion to building and exterior
equipment (Iron oxide, flaking paint, etc) that might potentially be
carried away by storm water. Clean up accordingly.
4. Check for improperly stored materials.
5. Check storm water drains for debris and remove as needed.
6. Check trash storage bins for leaks or physical damage.
7. Inspect pallet storage area for cleanliness.
8. Inspect all exterior equipment for oil leaks.
Nomaco —Outfall #2
1. Inspect outfall and remove collected debris is needed.
Weekly
Nomaco —Outfall #3
1. Inspect outfall and remove collected debris is needed.
Weekly
Nomaco— Secondary containment— West dock
1. Verify proper operation of sump pump.
Monthly
2. Inspect drain valve for leaks and proper operation. R&R as needed.
3. Inspect piping for leaks. R&R as needed.
Nomaco— Secondary containment— Holding pond
1. Inspect pond for debris.
Monthly
2. Inspect integrity of pond for erosion of banks and discharge area.

Form 1— Preventative Maintenance / Housekeeping Inspection Form
Date: Time:
Inspector
Print: Signature:
Areas inspected Observation Corrective Actions Taken

Form 2 — Employee Training form
Date:
Trainer
Print: Signature:
Topics Covered:

Form 3 — Annual SWPPP Review Form
Date of Review:
Reviewer
Print: Signature:
Annual SWPPP Review Checklist
1. Facility general information and SWPPP team information is current and accurate
YES
NO
2. Site map is current and accurate
YES
NO
3. Significant material inventory is current and accurate
YES
NO
4. New exposures, processes and related controls have been documented
YES
NO
N/A
5. Spills have been recorded and reported as appropriate
YES
NO
N/A
6. Records of routine preventative maintenance, housekeeping and employee training
are available in the SWPPP file
YES
NO
7. Comprehensive site inspections have been completed, certified and filed in the SWPPP
file
YES
NO
8. Corrective actions noted in the inspection reports have been completed
YES
NO
9. Annual fees have been paid
YES
NO
10. Permit renewal request has been processed
YES
NO
N/A
11. SWPPP has been reviewed by the designated representatives
YES
NO
Additional Comments:

Form 4 — Comprehensive Site Inspection Form
Date: Time:
Inspector:
Print: Signature:
is the taciiity in commiance witn the tienerai rerma ana the �wrvr
Areas inspected I Observation I Corrective Actions Taken

Stormwater Discharge Outfall (SDO)
Qualitative Monitoring Report
Permit No.: N/C/_/_/_/_/_/_/_/ or Certificate of Coverage No.: N/C/G/_/_/_/_/_/_/
Facility Name:
County: Phone No.
Inspector:
Date of Inspection:
By this signature, I certify that this report is accurate and complete to the best of my knowledge:
(Signature of Pennittee or Designee)
1. Outfall Description
Outfall No. Structure (pipe, ditch, etc.)
Receiving Stream:
Describe the industrial activities that occur within the outf ll drainage area:
2. Color
Describe the color of the discharge using basic colors (red, brown, blue, etc.) and fin (light, medium,
dark), as descriptors:
3. Odor
Describe any distinct odors that the discharge may have (i.e., smells strongly of oil, weak chlorine odor,
etc.)
4. Clarity
Choose the number which best describes the clarity of the discharge where I is clear and 10 is very
cloudy:
1 2 3 4 5 6 7 8 9 10
Page 1
S W U-242-020705

5. Floating Solids
Choose the number which best describes the amount of floating solids in the stonmvater discharge where
I is no solids and 10 is the surface covered with floating solids:
l 2 3 4 5 6 7 8 9 10
6. Suspended Solids
Choose the number which best describes the amount of suspended solids in the stormwater discharge
where I is no solids and 10 is extremely muddy:
1 2 3 4 5 6 7 8 9 10
7. Foam
Is there any foam in the stormwatcr discharge? Yes No
8. Oil Sheen
Is there an oil sheen in the stormwatcr discharge? Yes No
9. Deposition at Outfall
Is there deposition of material (sediment, etc.) at or immediately below the outfall? Yes No
10. Erosion at Outfall
Is there erosion at or immediately below the outfall? Yes No
11. Other Obvious Indicators of Stormwater Pollution
List and describe
Note: Low clarity, high solids, and/or the presence of foam, oil sheen, deposition or erosion may be
indicative of conditions that warrant further investigation and corrective action.
Page 2
S W U-242-020705

Stormwater Discharge Outfall (SDO)
Qualitative Monitoring Report Supplement SWU-242A:
Guidance for Rating Stormwater Discharge
This supplement is intended only as a guide for rating visually observed parameters on a scale of
1-5. The inspector should use best professional judgment when characterizing the quality of
stormwater discharge. Also, the pictures included here do not necessarily show stormwater
discharges but serve to illustrate the characteristics described.
Clarity
(1 is clear, and 5 is very opaque or cloudy)
1 3
Floating Solids
(1 is no solids, and 5 is the surface covered
with floating solids or significant trash/debris)
1 3
5
5
SWU-242A- I808

Suspended Solids
(1 is no solids, and 5 is extremely muddy or clouded with other
k1
Tannic Water
5
Water naturally high in tannins in the eastern part of North Carolina may still have low amounts
of suspended solids and high clarity but not appear "clear" because of coloration. The examples
below will help rate discharges that must be observed in tannic waters.
Clear tannic water may look like tea or coffee, but waters that look more "milky" or like
"chocolate milk" have less clarity and higher suspended solids.
Suspended Solids / Clarity in waterbodies naturally high in tannins
1/1 3/3
Page 2 of 10
5/5
SWU-242A-061808

Example 1
1. Outfall Description:
Outfall No. Structure (pipe, ditch, etc.)
Receiving Stream:
Describe the industrial activities that occur within the outfall drainage area:
2. Color: Describe the color of the discharge using basic colors (red, brown, blue, etc.) and tint
(light, medium, dark) as descriptors:
3. Odor: Describe any distinct odors that the discharge may have (i.e., smells strongly of oil, weak
chlorine odor, etc.):
4. Clarity: Choose the number which best describes the clarity of the discharge, where 1 is clear
and 5 is very cloudy:
1 O 3 4 5
5. Floating Solids: Choose the number which best describes the amount of floating solids in the
stormwater discharge, where I is no solids and 5 is the surface covered with floating solids:
2 3 O 5
6. Suspended Solids: Choose the number which best describes the amount of suspended solids in
the stormwater discharge, where 1 is no solids and 5 is extremely muddy:
I 2 O 4 5
Page 3 of 10
SWU-242A4161808

Example 3
1. Outfall Description:
Outfall No. Structure (pipe, ditch, etc.)
Receiving Stream: _
Describe the industrial activities that occur within the outfall drainage area:
2. Color: Describe the color of the discharge using basic colors (red, brown, blue, etc.) and tint
(light, medium, dark) as descriptors: _
3. Odor: Describe any distinct odors that the discharge may have (i.e., smells strongly of oil, weak
chlorine odor, etc.):
4. Clarity: Choose the number which best describes the clarity of the discharge, where 1 is clear
and 5 is very cloudy:
1 2 3 O 5
5. Floating Solids: Choose the number which best describes the amount of floating solids in the
stormwater discharge, where 1 is no solids and 5 is the surface covered with floating solids:
1 2 3 O 5
6. Suspended Solids: Choose the number which best describes the amount of suspended solids in
the stormwater discharge, where 1 is no solids and 5 is extremely muddy:
1 2 O 4 5
Page 7 of 10
SWU-242A-061808

7. Is there any foam in the stormwater discharge? Yes No
8. Is there an oil sheen in the stormwater discharge? Yes No
9. Is there evidence of erosion or deposition at the outfall? Yes No
10. Other Obvious Indicators of Stormwater Pollution:
List and describe
Page 8 of 10
SWU-242A-061808

E_.volnplc 4
1. Outfall Description:
Outfall No. Structure (pipe, ditch, etc.)
Receiving Stream:
Describe the industrial activities that occur within the outfall drainage area:
2. Color: Describe the color of the discharge using basic colors (red, brown, blue, etc.) and tint
(light, medium, dark) as descriptors:
3. Odor: Describe any distinct odors that the discharge may have (i.e., smells strongly of oil, weak
chlorine odor, etc.): _
4. Clarity: Choose the number which best describes the clarity of the discharge, where 1 is clear
and 5 is very cloudy:
O 2 3 4 5
5. Floating Solids: Choose the number which best describes the amount of floating solids in the
stormwater discharge, where I is no solids and 5 is the surface covered with floating solids:
O 2 3 4 5
6. Suspended Solids: Choose the number which best describes the amount of suspended solids in
the stormwater discharge, where 1 is no solids and 5 is extremely muddy:
O 2 3 4 5
Page 9 of 10
SWU.242A-061808

1.It, ? of d. cunt.
7. Is there any foam in the stormwater discharge? Yes No
S. Is there an oil sheen in the stormwater discharge? Yes No
9. Is there evidence of erosion or deposition at the outfall? Yes No
10. Other Obvious Indicators of Stormwafer Pollution:
List and describe \l a
Pace 10 of 10
S W U-242A-061808

^I: i of J, runt.
7. Is there any foam in the stormwater discharge? Yes No
8. Is there an oil sheen in the stormwater discharge? Yes No
9. Is there evidence of erosion or deposition at the outfall? Yes No
10. Other Obvious Indicators of Stormwater Pollution:
List and describe V \
Page 4 of 10
SNVU-242A-O61808

Example 2
1. Outfall Description:
Outfall No. Structure (pipe, ditch, etc.)
Receiving Stream:
Describe the industrial activities that occur within the outfall drainage area:
2. Color: Describe the color of the discharge using basic colors (red, brown, blue, etc.) and tint
(light, medium, dark) as descriptors: _
3. Odor: Describe any distinct odors that the discharge may have (i.e., smells strongly of oil, weak
chlorine odor, etc.):
4. Clarity: Choose the number which best describes the clarity of the discharge, where I is clear
and 5 is very cloudy:
1 O 3 4 5
5. Floating Solids: Choose the number which best describes the amount of floating solids in the
stormwater discharge, where I is no solids and 5 is the surface covered with Floating solids:
1 O 3 4 5
6. Suspended Solids: Choose the number which best describes the amount of suspended solids in
the stormwater discharge, where 1 is no solids and 5 is extremely muddy:
1 O2 3 4 5
Page 5 of 10
6y"AM.M.WW 7t:?118

of 4. cunt.
7. Is there any foam in the stormwater discharge? Yes No
8. Is there an oil sheen in the stormwater discharge? Yes No
9. Is there evidence of erosion or deposition at the outfall? Yes No
I11. Other Obvious Indicators of Stormwater Pollution:
List and describe Sonic di,plaecment of 2ratel and .edroc,it ubset\ed..n the owlall. kko,
14.& 't tie \\atcr hccnme, more turbidicloudN hcpmd the uutfall 1i.e.. clm it
„1 ; \Le„1\e .olid, heim, carried into recei� m2'\:uCr.
This example illustrates how additional information in number 10. can be
important to characterizing stormwater discharge impacts.
Page 6 of 10
swU-242A-061808