NCG030699_NOV_20220819

ROY COOPER
Governor
ELIZABETH S. BISER
Secmtoary
BRIAN WRENN
Director
CERTIFIED MAIL: 7020 0090 0001 7206 4042
.RETURN RECEIPT REQUESTED
CCL Metal Science
Attn: Ed Derr, Plant Manager
520 E. Railroad Street
Clinton, NC 28328
NORTH CAROLINA
Environmental Quality
August 19, 2022
Subject: NOTICE OF VIOLATION (NOV-2022-PC-0441)
NPDES Stormwater General Permit NCG030000
Rheinfeilden Americas, Certificate of Coverage NCG030699
Sampson County
Dear Mr. Derr:
On July 29, 2022, Melissa Joyner from the Fayetteville Regional Office of the Division of Energy, Mineral and Land
Resources (DEMLR), conducted a site inspection for the Rheinfelden Americas (now known as CCL Metal Science)
facility located at 520 E. Railroad Street, Sampson County, North Carolina. A copy of the Compliance Inspection Report
is enclosed for your review. Christine Torres, Environmental Health and Safety Manager, Scott Holder, Maintenance
Manager and Ali Farhadi, Operations Manager were also 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 NPDES Stormwater
General Permit NCGO30000 under Certificate of Coverage NCG030699. Permit coverage authorizes the discharge of
stormwater from the facility to receiving waters designated as Rowans Branch, a class C:SW waters in the Cape Fear
River Basin.
As a result of the site inspection, the following permit conditions violations are noted:
1) Stormwater Pollution Prevention Plan (SPPP)
Per Part B... A Stormwater Pollution Prevention Plan (SPPP) has not been properly implemented.
2) Analytical Monitoring
Per Part E, Section E-1 -E-4... Qualitative monitoring has not been conducted and/or recorded in accordance with permit
requirements.
3) Qualitative Monitoring
Per Part D, Section C... Analytical monitoring has not been conducted and/or 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
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 violations have occurred as well as a
Plan of Action to prevent these violations from recurring.
North Carolina Department of Environmental Quality I Divisron of Energy, Mineral and Land Resources
Q - Z Fayetteville Regional office i 225 Green Street. Suite 714 j Fayetteville, North Carolina 28301
&p't t.Fnuvur 910,4W,3300

Action Items
Immediately review and amend the facility's SWPPP as needed and begin incorporating documentation pertaining to the
annual update requirements of the permit. Conduct and record 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 Melissa Joyner or myself
at [phone].
Sincerely,
r
Timothy L. La ty, PE
Regional Engineer
DEMLR
TLLlmaj
Enclosure: Compliance Inspection Report
ec: Christine Torres, Environmental Health and Safety Manager (via email)
Ali Farhadi, Operations Manager (via email)
Scott Holder, Maintenance Manager (via email)
Toby Vinson, Jr., PE, CPESC, CPM, Chief of Program Operations — DEMLR (via email)
Brad Cole, PE, Chief of Regional Operations — DEMLR (via email)
Danny Smith, Supervisor— DEMLR, Stormwater Program (via email)
DEMLR NPDES Stormwater Permit Laserfiche File
cc: FRO — DEMLR, Stormwater Files

Compliance Inspection Report
Permit: NCGO30699 Effective: 07101 /21 Expiration: 06/30/26 Owner: Rheinfelden Americas LLC
SOC: Effective: Expiration: Facility: Rheinfelden Americas
County: Sampson 520 E Railroad St
Region: Fayetteville
Clinton NC 28328
Contact Person: Edwin Castrillon Title: Plant Manager Phone: [phone]
Directions to Facility:
From NC-24 in Clinton, take Southeast Blvd south to turn left at E Railroad Street. Continue for 800 feet until arriving at the facility on
the right.
System Classifications: SWNC,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 07/29/2022 Entry Time 09:15AM Exit Time: 11:40AM
Primary Inspector: Melissa A Joyner Phone:
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Metal Fabrication Stormwater Discharge COC
Facility Status: ❑ Compliant E Not Compliant
Question Areas:
0 Storm Water
(See attachment summary)
Page 1 of 3

Permit: NGG030699 Owner - Facility: Rheinfelden Americas LLC
Inspection Date: 07/29/2022 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Melissa Joyner met with Mr. Ed Derr, Plant Manager and Ms. Christine Torres, Environmental Health and Safety Manager,
Mr. Scott Holder, Maintenance Manager and Mr. Ali Farhadi, Operations Manager at the Rheinfelden Americas facility. The
facility was bought out by CCL Metal Science in late 2020. The Name/Ownership Change Form will need to be completed
and submitted with the new owner's information. The facility grounds were inspected, including the Best Management
Practices and Outfalls 1 and 2. A third outfall was also observed. This outfall will need to be shown on the Site Map and
added to the outfalls' monitoring schedule. On the facility grounds, there was a waste product pile of aluminum dust, old
pallets, old metal equipment and an open scrap hopper noted. On the side of the swale which was discharging to Outfall 1
there was another outfall observed coming from the direction of Railroad Street. It was determined after the inspection that
no stormwater is entering the outfall swale from this location because the invert of the outfall was blocked and filled in with
sod.
The Stormwater Pollution Prevention Plan (SWPPP) was reviewed. The Site Map should include all information under "Part
B: Stormwater Pollution Prevention Plan, B-3 Site Map" in General Permit NCG030000. The facility does not use solvents.
This must be certified in the SWPPP. The outfalls have not been evaluated to determine the presence of possible
non-stormwater discharges. The Spill Prevention and Response Procedures should contain all pertinent information per the
conditions of General Permit NCG030000. The Preventative Maintenance and Good Housekeeping program has not been
implemented, nor has the annual Employee Training occurred. Since this inspection, documentation was sent of Annual
Employee Training which occurred after the inspectioin. No Analytical or Qualitative monitoring of stormwater has occurred
at the outfalls since the facility was permitted in 2019.
Page 2 of 3

Permit: NCG030699 Owner - Facility: Rheinfelden Americas LLC
Inspection Date: 07/29/2022 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?
❑ ❑ ❑
# Does the Plan include a General Location (USGS) map?
0 ❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
M ❑ ❑ ❑
# 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?
M ❑ ❑ ❑
# 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?
❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
0 ❑ ❑ ❑
# 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)?
■ ❑ ❑ ❑
# 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? ❑ 0 ❑ ❑
Comment: The Stormwater Pollution Prevention Plan has not been implemented Der the the conditions of
General Permit NCG030000.
.Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring? ❑ 0 ❑ ❑
Comment: Qualitative Monitoring has not been conducted per the conditions of General Permit
NCG030000.
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? ❑ ■ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ ❑
Comment: Anal ical Monitoring has not been conducted Der the conditions of General Permit
NCG030000.
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? ❑ M ❑ ❑
# Were all outfalls observed during the inspection? ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ 0 ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ❑ M ❑ ❑
Comment:
Page 3 of 3