NCG030677_NOV_20220216

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ROY COOPER
Governor
ELIZABETH S.BISER
MN r„^
Secretary WA>
BRJAN WRENN NORTH CARO'LINA
Director Environmental Quality
February 16, 2022
CERTIFIED MAIL: 7018 0040 0000 4771 9572
RETURN RECEIPT REQUESTED
Southeastern Tool and Die
Attn: Jimmy Thompson, President
105 Taylor Street
Aberdeen, NC 28315
Subject: NOTICE OF VIOLATION (NOV-2022-PC-0056)
NPDES Stormwater General Permit NCG030000
Southeastern Tool and.Die
Certificate of Coverage NCG030677
Moore County
Dear Mr. Thompson:
On February 10,2022, Mike Lawyer, Environmental Program Consultant with the Fayetteville Regional Office of the Division
of Energy, Mineral and Land Resources (DEMLR), conducted a site inspection for the Southeastern Tool and Die facility
located at 105 Taylor Street, Aberdeen, Moore County, North Carolina. A copy of the Compliance Inspection Report is
enclosed for your review. Ms. Ashley Poe, HR/EHS Manager, was also present during the inspection and her time and
assistance is greatly appreciated. The site visit and file review revealed that the subject facility is covered by NPDES
Stormwater General Permit NCG030000 under Certificate of Coverage NCG030677. Permit coverage authorizes the
discharge of stormwater from the facility to receiving waters designated as Aberdeen Creek, class C waters in the Lumber
River Basin.
As a result of the site inspection, the following permit conditions violation(s) are noted:
1)Stormwater Pollution Prevention Plan (SWPPP)
Per Part B...The Stormwater Pollution Prevention Plan (SWPPP) has not been properly implemented.
Per Part B-6...An annual evaluation of the stormwater outfall for the presence of any non-stormwater discharges has not
been documented for 2021.
Per Part B-9...An updated listing of significant spills or notation that none have occurred.has not been documented for 2021.
Per Part B-12...Annual employee training has not been documented for 2021.
Per Part B-14...An annual review and update of all aspects of the SWPPP has not been conducted.
2) Qualitative Monitoring
Per Part D...Qualitative monitoring has not been conducted and/or recorded in accordance with permit requirements.
3)Analytical Monitoring
Per Part E...Analytical monitoring has not been conducted and/or recorded in accordance with permit requirements.
...... North Carolina Department of Environmental Quality I Division of Energy,Mineral and Land Resources
+^ Fayetteville Regional Office 1225 Green Street.Suite 7141 Fayetteville,North Carolina 28301
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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 violation(s)have occurred as well as a Plan of Action
to prevent these violation(s) from recurring.
Action Items
Immediately review and amend the.facility's SWPPP in accordance with the current NCG030000 permit and begin
incorporating documentation pertaining to the annual update requirements of the permit. Conduct and record qualitative
and analytical monitoring per the conditions of the permit.
Thank you for your attention to this matter. 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 Mike Lawyer or myself at
[phone].
Sincerely,
4TTiothy L: LaBo PE
Regional Engineer
DEMLR
TL/ml
Enclosure: Compliance Inspection Report
ec: Ashley Poe, HR/EHS Manager Southeastern Tool and Die
Toby Vinson,Jr., PE, CPESC, CPM, Section Chief, Program Operations— DEMLR, Land Quality Section
Brad Cole,-PE,-Section Chief, Regional Operations— DEMLR, Land Quality Section
Alaina Morman, Environmental Specialist— DEMLR, Land Quality Section, Stormwater Program
DEMLR NPDES Stormwater Permit Laserfiche File
cc: FRO—DEMLR, Stormwater Files

Compliance Inspection Report
Permit:NCG030677 Effective: 07/01/21 Expiration: 06/30/26 Owner: Southeastern Tool and Die
SOC: Effective: Expiration: Facility: Southeastern Tool and Die
County: Moore 105 Taylor St
Region: Fayetteville
Aberdeen NC 28315
Contact Person:Ashley Poe Title: HR/EHS Manager Phone:[phone]
Directions to Facility;
System Classifications: SWNC,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
On-site representative Ashley Poe 910-944-7677
Related Permits:
Inspection Date: 02/10/2022 E ry Time 02:30PM Exit Time: 04:30PM
Primary Inspector:Mike Lawy`%% -' Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Metal Fabrication Stormwater Discharge COC
Facility Status: ❑ Compliant 0 Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 3

Permit: NCG030677 Owner-Facility:Southeastern Tool and Die
Inspection Date: 02/10/2022 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Inspection conducted to evaluate facility's compliance with the conditions of NPDES NCG030000 Stormwater General
Permit,which was renewed effective July 1, 2021 with expiration date of June 30,2026.The renewed NCG030000 permit
increased the monitoring frequency from semi-annual to quarterly with the first monitoring period being July 1,2021 to
September 30, 2021 (third calendar quarter 2021).The renewed permit also removed the Total Toxic Organics(TTO)
parameter,which was replaced with Chemical Oxygen Demand (COD), and required the development and implementation of
a Solvent Management Plan or certification in the SWPPP that solvents are not stored or used onsite. Met with Ashley Poe,
HR/EHS Manager,who provided the facility's Stormwater Pollution Prevention Plan (SWPPP)for review.The SWPPP was
developed in September 2020 by a consultant and contains all components as required under the previous permit term.
However,the SWPPP had not been updated to incorporate the new monitoring conditions under the renewed/current permit.
Documentation related to significant spills or notation that none have occurred, employee training, and non-stormwater
evaluation was not recorded for 2021. Monioring records indicate an analytical monitoring event occurred in June 202.1 under
the previous permit term. There were no qualitative or analytical monitoring records for the third or fourth quarter of 2021.
After the records review, observations were made at the facility's stormwater discharge outfall and the appropriate
stormwater discharge sampling location was discussed.
Page 2 of 3

Permit: NCG030677 Owner:Facility:Southeastern Tool and Die
Inspection Date: 02/10/2022 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(USGS)map? 0 ❑ ❑ ❑
#Does the Plan include a"Narrative Description of Practices"? E ❑ ❑ ❑
#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? ❑ 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? N ❑ ❑ ❑
#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? ❑ 0 ❑ ❑
#Does the Plan include a list of Responsible Party(s)? N ❑ ❑ ❑
#Is the Plan reviewed and updated annually? ❑ 0 ❑ ❑
#Does the Plan include a Stormwater Facility Inspection Program? 0 ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented? ❑ E ❑ ❑
Comment: See Inspection Summary for details regarding the facility's SWPPP.
Qualitative Monitorinq Yes No NA NE
Has the facility conducted its Qualitative Monitoring? ❑ 0 ❑ ❑
Comment: At the time of inspection there were no qualitative monitoring records for third or fourth quarter
2021.
Analytical Monitorinq Yes No NA NE
Has the facility conducted its Analytical monitoring? ❑ 0 ❑ ❑
#Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ E ❑
Comment: At the time of inspection there were no analytical monitoring records for third or fourth quarter
2021.
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? ❑ ❑ 0 ❑
#Has the facility evaluated all illicit(non stormwater)discharges? ❑ N ❑ ❑
Comment:
Page 3 of 3