NCG070163_NOD_20210902

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
BRIAN WRENN
Director
CERTIFIED MAIL: 7019 0700 0000 3643 3636
RETURN RECEIPT REQUESTED
Oldcastle APG-Adams
Attn: Phil Murphy, EH & S Manager
333 N. Greene Street
Greensboro, NC 27401
NORTH CAROLINA
Envtronmental Quality
September 2, 2021
Subject: NOTICE OF DEFICIENCY (NOD-2021-PC-0460)
NPDES Stormwater General Permit NCG070000
Oldcastle APG-Adams
Adams Products (formerly Bonsai American, Inc.), Certificate of Coverage NCG070163
Anson County
Dear Mr. Murphy:
On August 24, 2021, Melissa Joyner from the Fayetteville Regional Office of the Division of Energy, Mineral and Land
Resources (DEMLR), conducted a site inspection for the Adams Products (formerly Bonsai American, Inc.) facility located
at 351 Hailey's Ferry Road, Lilesville, Anson County, North Carolina. A copy of the Compliance Inspection Report is
enclosed for your review. Mr. Mike Poteat, Site Manager and Mr. Corey Jeacock, Safety Manager were present during the
inspection and their time and assistance is greatly appreciated. The site visit and file review revealed that the subject facility
is covered by N PDES Stormwater General Permit NCG070000 under Certificate of Coverage NCG070163. Permit coverage
authorizes the discharge of stormwater from the facility to receiving waters designated as a UT to Island Creek, a class C
waters in the Yadkin Pee -Dee River Basin.
As a result of the site inspection, the following deficiencies are noted:
1. The Stormwater Pollution Prevention Plan (SPPP) has not been fully developed, recorded or properly
implemented.
2. Qualitative 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
A written response is not requested at this time.
Action Items
Immediately review and amend the facility's SPPP as needed and begin incorporating documentation pertaining to the
annual update requirements of the permit. Conduct and record Qualitative Monitoring per the conditions of the permit.
,� North Carolina. Department of Environmental Quality I Division of Energy, Mineral and Land Resources
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Fayetteville Regional Office 1 225 Green Street. Suite 7141 Fayetteville, North. Carolina 28301
wwTme�taam�n.m:,au.mr� /^'r 910,433,3300

Thank you for your attention to this matter. This office requires that the deficiencies, as noted above and detailed in
the enclosed inspection report, be properly resolved. Failure to address the deficiencies could result in the
issuance of a Notice of Violation, which is subject to a civil penalty assessment of up to $25,000 per day for each
violation. Should you have any questions or concerns, please contact Melisa Joyner or myself at [phone].
Sincerely,
�. LaB un PE
Regional Engineer
DEMLR
TLL/maj
Enclosure: Compliance Inspection Report
ec: Mike Poteat, Site Manager, Adams Products (formerly Bonsal American, Inc.) (via email)
Corey Jeacock, Safety Manager, Adams Products (formerly Bonsai American, Inc.) (via email)
Doug Fouts, Environmental H & S Director, Oldcastle APG-Adams (via email)
Toby Vinson, Jr., PE, CPESC, CPM, Section Chief— DEMLR, Land Quality Section, Program Operations
(via email)
Brad Cole, PE, Section Chief— DEMLR, Land Quality Section, Regional Operations (via email)
Annette Lucas, PE, Supervisor— DEMLR, Land Quality Section, Stormwater Program (via email)
Alaina Morman, Environmental Specialist— DEMLR, Land Quality Section, Stormwater Program (via
email)
DEMLR NPDES Stormwater Permit Laserfiche File
cc: FRO — DEMLR, Stormwater Files

Compliance Inspection Report
Permit:NCG070163 Effective: 06/01/18 Expiration: 05/31/23 Owner: Bonsal American Inc
SOC: Effective: Expiration: Facility: Bonsai American - Lilesville
County: Anson 351 Hailey's Ferry Rd
Region: Fayetteville
Lilesville NC 28091
Contact Person: Phil Murphy Title: EH&S Manager Phone: [phone]
Directions to Facility:
System Classifications: SWNC,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 08/24/2021 Entry Time 10:05AM Exit Time: 12:45PM
Primary Inspector: Melissa A Joyner Phone:
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Stone, Clay, Glass, and Concrete Products Stormwater Discharge COC
Facility Status: ❑ Compliant E Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 3

Permit: NCG070163_ Owner- Facility: Bonsal American Inc
Inspection Date: 08/24/2021 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Melissa Joyner met with Mr. Mike Poteat, Site Manager, and Mr. Corey Jeacock, Safety Manager, at the Bonsai American,
Inc. facility. She reviewed the Stormwater Pollution Prevention Plan (SPPP). The SPPP appeared orderly and contained
most of the required information per General Permit NCG070000. The name of the facility is now Adams Products and the
legally responsible person for the Certificate of Coverage NCG070163 is now Phil Murpy. The Name/Ownership Change fora
will need to be completed with the updated information and can be accessed via this link:
https://deq. nc.gov/about/divisions/energy-mineral-land-resources/npdes-industrial-stormwater
The SPPP also needed to be updated with removing the name of Shane Scoggins, the previous Regional Operations
Manager. On the site map, the ditch associated with Outfall 3, a drainage ditch next to the haul road, and the location of the
stream, near the northern side of the property should be labeled. If no significant spills have occurred, this should be
documented annually in the SPPP. The feasability study should be reviewed and updated annually.The required semi-annual
facility inspections had only been done annually and were not documented. A list of all the Best Management Practices
(BMPS) was not included in the SPPP.
The facility was only required to do Qualitative, not Analytical monitoring per the conditions in General Permit NCG070000.
The facility had three outfalls. Outfall 1 had been monitored but not during 2019 and not during the first period of 2020.
Outfalls 2 and 3 had not been monitored. If no discharge occurs during a monitoring period, it should be noted "No
Discharge" on the monitoring form.
- The facility-glrounds were' reviewed in regards to Outfalls 1; •2 and 3 and the BMPs. There was erosion below Outfall 1. It was
recommended that the erosion be repaired and a riprap apron be installed. There was also erosion on the slopes near the
invert of Outfall Two. It was recommended that the slopes be repaired and stabilized with groundcover. There were no issues
with Outfall 3. Near a drop inlet, next to the main building, sand was noted which should be removed. Silt fence was
observed around a second drop inlet which was not trenched in. Please refer to the Erosion and Sediment Control Planning
and Design Manual for information about acceptable drop inlet protection which may be accessed via the following link:
https://deq. nc.gov/about/divisions/energy-mineral-land-resources/energy-mineral-land-permit-guidance/erosion-sediment-con
rol-planning-design-manual On the southern side of the property, it was recommended that silt fence and silt fence outlets
be installed at the base of perimeter slopes where erosion was observed to prevent possible of -site sedimentation.
Page 2 of 3

Permit: NCG070163 Owner -Facility: Bonsai American Inc
Inspection Date: 08/24/2021 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan?
0
❑ ❑ ❑
# Does the Plan include a General Location (LISGS) map?
0
❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
0
❑ ❑ ❑
# 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?
N
❑ ❑ ❑
# 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)?
0
❑ ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
0
❑ ❑ ❑
# Does the facility provide and document Employee Training?
0
❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
E
❑ ❑ ❑
# Is the Plan reviewed and updated annually? "" -
❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
❑
E ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
❑
0 ❑ ❑
Comment: The Stormwater Pollution Prevention Plan (SPPP) has not been fully developed, recorded or
properly implemented.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ❑ 0 ❑ ❑
Comment: Qualitative monitoring has not been conducted and recorded in accordance with permit
requirements.
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? ❑ ❑ E ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ ❑
Comment:
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? 0 ❑ ❑ ❑
Comment:
Page 3 of 3