NCS000528_NOV_20230616

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
DOUGLAS R. ANSEL
interim Director
CERTIFIED MAIL: 7010 1870 0003 47751683
RETURN RECEIPT REQUESTED
Premiere Fibers
Attn: Dewey Fulton
P.O. Box 8930
Bristol, VA 24203
NORTH CAROLINA
Environmental Quality
June 27, 2023
Subject: NOTICE OF VIOLATION (NOV-2023-PC-0269)
Premiere Fibers
NPDES Stormwater Individual Permit NCS000528
Anson County
Dear Mr. Fulton:
On June 16, 2023, Melissa Joyner, Kelly Jonas and Denise Bruce from the Fayetteville Regional Office of the Division of
Energy, Mineral and Land Resources (DEMLR), conducted a site inspection for the Premiere Fibers facility located at 10056
US Hwy 52 N, Ansonville, Anson County, North Carolina. A copy of the Compliance inspection Report is enclosed for your
review. Chris Fowler, EHS Manager was also present during the inspection and his time and assistance is greatly.
appreciated. The site visit and file review revealed that the subject facility is covered by NPDES Stormwater Individual
Permit NCS000528. Permit coverage authorizes the discharge of stormwater from the facility to receiving waters designated
as an UT (un-named tributary) to Buffalo Creek, a Class C stream in the Yadkin -Pee Dee River Basin.
As a result of the site inspection, the following permit conditions violations are noted:
1) Stormwater Pollution Prevention Plan (SWPPP)
Per Part II, Section A ... A Stormwater Pollution Prevention Plan (SWPPP) has not been properly implemented.
2) Qualitative Monitoring
Per Part II, Section C... Qualitative monitoring has not been conducted and/or recorded in accordance with permit
requirements.
3) Analytical Monitoring
Per Part I, Section B...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.
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.
R' North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
.' e: D E �Fayetteville Regional Office 1225 Creep Street. Suite 7141 Fayetteville, North Carolina 28301
N:1R?F' C:A6?CiFANi. �F

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,
Ti othY �L.. LaBou PE
Regional Engineer
DEMLR
TLLlmaj
Enclosure: Compliance Inspection Report
ec: Chris Fowler, EHS Manager— Premiere Fibers (via email)
Toby Vinson, Jr., PE, CPESC, CPM, Chief of Program Operations — DEMLR (via email)
Brad Cale, PE, Chief of Regional Operations — DEMLR (via email)
Michael Lawyer, CPSWQ — Stormwater Program Supervisor — DEMLR (via email)
Kieu Tran, Environmental Specialist, Stormwater Program— DEMLR (via email)
DEMLR NPDES Stormwater Permit Laserfiche File
CC" FRO — DEMLR, Stormwater Files

Compliance Inspection Report
Permit: NCS000528 Effective: 06/01/15 Expiration: 05/31/20 Owner: Premiere Fibers
SOC: Effective: Expiration: Facility: Premiere Fibers
County: Anson 10056 US Hwy 52 N
Region: Fayetteville
Ansonville NC 28007
Contact Person: Dewey Fulton Title: Phone: [phone]
Directions to Facility:
System Classifications: SWNC,
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
On -site representative
Related Permits:
Certification:
Chris Fowler
Phone:
14*1to] 1011'1•0Eim, 11:
Inspection Date: 06/16/2023 EntryTime10:30AM Exit Time: 12:45PM / Primary Inspector: Melissa A Joyner 4-mw Phone:
Secondary Inspector(s):
Denise Bruce
Kelly Jonas
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ❑ Compliant 0 Not Compliant
Question Areas:
E Storm Water
(See attachment summary)
Page 1 of 3

Permit: NCS000528 Owner -Facility: Premiere Fibers
Inspection Date: 06/16/2023 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
The current permit expired on May 31, 2020. An application for the permit renewal has been submitted and is being
processed with the renewed permit currently under draft review. An inspection was conducted to determine compliance with
the conditions of the currentlexpired permit.
Melissa Joyner, Denise Bruce and Kelly Jonas met with Mr. Chris Fowler, EHS Manager. The facility's Stormwater Pollution
Prevention Plan (SWPPP), including the Analytical and Qualitative Monitoring records was reviewed. The SWPPP did not
have documentation of the annual review and update which should include all items listed under Part 11, Section A, Item 8 of
the current permit. The site map needed to be updated to include all items as listed under Part 11, Section A, Item 1 c of the
permit. The Spill Prevention and Response Procedures (SPRP) did not include the dated names and signatures of the
facility personnel responsible for implementing the SPRP. No records were available for review of the required semi-annual
facility and stormwater system inspections. There was no documentation of the required annual Employee Training available
for review during the inspection. A Best Manangement Practices Summary and Feasibility Study was not included in the
SPPP.
The Analytical and Qualitative Monitoring records were reviewed. In 2019, during Period 1, there were exceedances of the
benchmark values for Total Suspended Solids (TSS), at Outfall 1 and for Chemical Oxygen Demand (COD) at Outfalls 4 and
5. Tier One response actions were not initiated in response to these exceedances. No Analytical and Qualitative Monitoring
occurred during Period 1 in 2020. Qualitative Monitoring also did not occur during Period 2 in 2020 and Period 1 in 2021.
During Period 2, in 2020 there was another exceedance of the benchmark value for TSS at Outfall 1. During Period 1 in
2022, at Outfall 4, there was an exceedance of the benchmark value for COD. In Period 2 in 2022, no discharges occurred at
Outfalls 1-5. No monitoring occurred for Period 1 in 2023. At Outfall 4, during Period 2, in 2023, there was an exceedance of
the benchmark value for COD. Tier One and Tier Two response actions have not been initiated for these benchmark
exceedances. There have been two consecutive exceedances of COD at Outfall 4, not including the periods of non-discharg(
and non -sampling. Therefore, per the Tier Two response actions, immediately initiate at Outfall 4 monthly Analytical and
Qualitative Monitoring of all parameters until three consecutive sample results are below the benchmark value or within the
benchmark range.
Observations were made of site conditions including Outfalls 1-5. Erosion was observed near the outlet of Outfall 4 with
recommendations of repair and groundcover stabilization. An open, uncovered container with liquid contents was observed
on a pallet.
Page 2of3

Permit: NCS000628 Owner - Facility: Premiere Fibers
Inspection Date: 06/16/2023 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?
❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
0 ❑ ❑ ❑
# 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?
❑ W ❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
❑ 0 ❑ ❑
# Does the facility provide all necessary secondary containment?
N ❑ ❑ ❑
# Does the Plan include a i3MP 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?
E ❑ ❑ ❑
# Does the facility provide and document Employee Training?
E ❑ ❑ ❑
# 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?
❑ 0 ❑ ❑
Comment: The Stormwater Pollution Prevention Plan has not been implemented
per the conditions of the
permit.
Qualitative Monitorina Yes No NA NE
Has the facility conducted its Qualitative Monitoring? ❑ E ❑ ❑
Comment: Qualitative Monitoring has not been conducted per the conditions of the permit.
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? ❑ ❑ E ❑
Comment: Analytical Monitoring has not been conducted per the conditions of the permit.
Permit and Outfalis
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? 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? ❑ ■ ❑ ❑
Comment:
Page 3 of 3