NCGNE0844_Email Correspondence_20230824

Eplin, Jerry W
From: Eplin, Jerry W
Sent: Thursday, August 24, 2023 9:22 AM
To: Tim Andrews
Subject: RE: [External] Marcal Paper - Newton - NC
Hello Mr. Andrews:
I reviewed our files for the property. I found that in 2012, the previous owner submitted a No Exposure Certification request for the site and that was granted on
May 4, 2012. However, obtaining that status does not eliminate required activities. For example, once a facility obtains a No Exposure exemption, they are
required to annually recertify the facility as continuing to meet the no exposure requirements. Those records do not get submitted to us, but they are to be
maintained on site, and made available to us upon request. So, those records should have been maintained, and ideally, would have been transferred to you
when the new ownership occurred.
What the new owner should have done when they purchased the facility was submit name change information and recertify the no exposure certification IF that
still applied at the time of the property transfer.
At this point, you have a couple of options: 1) You could submit your own no exposure certification request, and then we would inspect the facility and
determine if we agree. In that scenario, we would look very closely at the spill event that occurred, and it is unlikely that we could approve a no exposure
request when a spill has already happened. I do not yet know the details of the spill, but obviously there was an impact. "No Exposure" is a high standard to
meet. It is reserved for those instances when it is very unlikely that stormwater could be impacted. In this case, an impact already happened. 2) You could
look at the general permits that are available on our website, decide which one you should be covered under, and submit the NOI forms to get that process
started. Most likely, you would file for coverage under NCG050000, which includes converted paper and paperboard products, and similar operations.
Here is a link to the no exposure certification page:
https://www.deg.nc.gov/about/divisions/energy-mineral-and-land-resources/stormwater/stormwater-program/npdes-industrial-program/no-exposure-
rPrtifirntinn
Here is a link to the General Permits:
https://www.deg.nc.gov/about/divisions/energy-mineral-and-land-resources/stormwater/stormwater-program/npdes-industrial-program/general-industrial-
ep rmits
Let me know if you have questions.

Jerry W. Eplin, F
Assistant Regional Engineer
North Carolina Department of Environmental Quality
Division of Energy, Mineral, and Land Resources
Office: [phone] x2147
Email: [e-mail]
Physical and Mailing Address:
610 E. Center Ave. Suite 301
Mooresville, NC 28115
D.- EQ'-�
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
From: Tim Andrews <[e-mail]>
Sent: Wednesday, August 23, 2023 10:25 AM
To: Eplin, Jerry W <[e-mail]>
Subject: [External] Marcal Paper - Newton - NC
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message button located on your Outlook menu bar on
the Home tab.
Hi Jerry,
As we discussed this morning, my name is Tim Andrews with Marcal Paper, located in Newton, NC. I would like to discuss what appropriate
measures we need to take to follow Stormwater regulations. We do not store any materials outside our plant.
Facility information:

• Our plant is a paper converting facility which produces paper roll towels, napkins, facial tissue, and bath tissue.
• Size — approximately 260,000 sq. ft. Space includes manufacturing, maintenance, warehouse, shipping / receiving, and office areas.
• The facility is operated 7 days a week, 24 hours per day.
• Previously known, owned, and operated by vondrehle corporation at the address listed below. At the end of December 2022, the company
changed hands and is now owned and operated by Marcal Paper at the address below:
Marcal Paper
2245 W. Maiden Rd.
Newton, NC 28658
Please feel free to contact me at any time to answer any questions and to discuss this further. I can be reached at 828-514-1773 (cell) or 828-705-
2315 ext. 3325 (office). Thank you for your assistance.
Tim Andrews
Safety Specialist
Marcal Paper
Newton, NC
Disclaimer. This email and any files transmitted with it are intended solely for the use of the individual or entity to whom they are addressed and may contain confidential, proprietary and/or privileged information. If you have received
this email in error please refrain from forwarding or disclosing it in any way, delete it from your system, and notify tim.andrews(a�marcalpaper.com . Please note that any views or opinions presented in this email are solely those of the
author and do not necessarily represent those of the company. WARNING: The recipient should check this email and any attachments for the presence of viruses. Marcal Paper accepts no liability for any damage caused by any
virus transmitted by this email. Marcal Paper, 1 Market Street, Elmwood Park, NJ 07407