NCG210415_NOV_20230206

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
DOUGLAS R. ANSEL
Interim Director
NORTH CAROLINA
Environmental Quaftty
February 6, 2023
CERTIFIED MAIL: 70101810 0002 1109 0623
RETURN RECEIPT REQUESTED
Cotton Creek Chip Company
Attn: Robert B. Jordan, IV, President
4483 Spies Road
Mount Gilead, NC 27306
Subject: NOTICE OF VIOLATION (NOV-2023-PC-0057)
NPDES Stormwater General Permit NCG210000
Cotton Creek Chip Company, Certificate of Coverage NCG210415
Moore County
Dear Mr. Jordan:
On January 11, 2023, Melissa Joyner from the Fayetteville Regional Office of the Division of Energy, Mineral and Land
Resources (DEMLR), conducted a site inspection for the Cotton Creek Chip.Company facility located at 4483 Spies Road, in
Mount Gilead, Moore County, North Carolina. A copy of the Compliance Inspection Report is enclosed foryour review. The site
visit and file review revealed that the subject facility is covered by NPDES Stormwater General Permit NCG210000 under
Certificate of Coverage NCG210415, Permit coverage authorizes the discharge of stormwater from the facility to receiving
waters designated as Cabin Creek, a class C waters in the Yadkin River Basin.
As a result of the site inspection, the following permit condition violation is noted:
1) Stormwater Pollution Prevention Plan (SPPP)
Per Part B... A Stormwater Pollution Prevention Plan (SPPP) has not been properly implemented.
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.
Action Items
Immediately fully develop and implement the facility's Stormwater Pollution Prevention Plan.
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 $26,000 per
day for each violation.
North Carolina Department of Environrnental Quality I Division of Energy, Mineral and Land Resources
Fayetteville Regional Office i 225 Green.Street, Suite 7141 Fayetteville, North Carolina 28301
hCW,T'4 CARD 1A
e.p�tasnesa nwW,1 910.433.3300

Should you have any questions regarding these matters, please contact Melissa Joyner or myself at [phone].
Sincerely,
Timothy L. LaBounty, PE
Regional Engineer
DEMLR
TLLlmaj
Enclosure: Compliance Inspection Report
ec: Douglas E. Richardson, Chip Operations Manager— Cotton Creek Chip Company (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)
DEMLR NPDES Stormwater Permit Laserfiche File
cc: FRO — DEMLR, Stormwater Files

Compliance Inspection Report
Permit: NCG210415 Effective: 08/01/18 Expiration: 07/31/23 owner: Cotton Creek Chip Company
SOC: Effective: Expiration: Facility: Cotton Creek Chip Company
County: Moore 4483 Spies Rd
Region: Fayetteville
Mount Gilead NC 27306
Contact Person: Douglas E Richardson Title: Phone: [phone]
Directions to Facility:
System Classifications: SWNC,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 01/11/2023 Entry Time 09:30AM Exit Time: 11:50AM
Primary Inspector: Melissa A Joyner iy c Phone.
Secondary Inspector(s): , r
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Timber Products Stormwater Discharge COC
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 3

Permit: NCG210415 Owner - Facility: Cotton Creek Chip Company
Inspection Date: 01/11/2023 Inspection Type; Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Melissa Joyner met with Mr. Doug Richardson, Chip Operations Manager at the Cotton Creek Chip Company facility. The
Stormwater Pollution Prevention Plan (SWPPP) was reviewed which appeared orderly. The site map did not include the
information as stipulated per the conditions of General Permit NCG210000. The SWPPP had not been annually reviewed
and updated as required. A list of significant spills/leaks of pollutants had not been documented during the previous three
years or the notation made that significant spills/leaks did not occur. Certification had not occurred that the stormwater
outfalls had been evaluated for the presence of non-stormwater discharges. A feasibility study had not been developed. In
regards to the Spill Prevention and Response Procedures, a list of employees involved with these procedures had not been
provided. Facility inspections had occurred but there was no documentation of these inspections.
The facility grounds were inspected. Outfalls #1 and #2 as representative of Outfall #3 appeared in good condition.
Page 2 of 3

Permit: NCG210415 owner - Facility: Cotton Creek Chip Company
Inspection Date: 01/11 /2023 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"?
E
❑ ❑ ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
E
❑ ❑ ❑
# 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?
❑
E ❑ ❑
# 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)?
E
❑ ❑ ❑
# 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)?
0
❑ ❑ ❑
# 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: The Stormwater Pollution Prevention Plan has not been implemented.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring? 0 ❑ ❑ ❑
Comment:
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? 0 ❑ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ 0 ❑
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? ■ ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? 0 ❑ ❑ ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ❑ 0 ❑ ❑
Comment:
Page 3 of 3