NCG090031_NOV_20231020

M I?l
ROY COOPER
Governor r
ELIZABETH S.BBISER
Secretary
WILLIAM E.TOBY VINSON,JR NORTH CAROLINA
Interim Director EnvironmentaEQ=11ty
November 20, 2023
CERTIFIED MAIL: 7020 3160 0000 3835 2251
RETURN RECEIPT REQUESTED
Rockingham Group, LLC
Attn: Paul Sartorelli, Owner
106 Enterprise Drive- '
Rockingham, NC 28379
Subject: NOTICE OF VIOLATION (NOV-2023-PC-0568)
NPDES Stormwater General Permit NCGO90000
Rockingham Group,LLC
2135 Manufacturing, LLC, Certificate of Coverage NCG090031
Richmond County
Dear Mr. Sartorelli:
On October 17. 2023, Melissa Joyner and Kelly Jonas from the Fayetteville Regional Office of the Division
of Energy, Mineral and Land Resources(DEMLR), conducted a site inspection for the 2135 Manufacturing,
LLC facility located at 106 Enterprise Drive, Richmond County, North Carolina.A copy of the Compliance
Inspection Report is enclosed for your review. Mr. Andrew Sullivan, EHS Director and Ken Chaco, CEI,
ISW 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
NCGO90000 under Certificate of Coverage NCG090031. Permit coverage authorizes the discharge of
stormwater from the facility to receiving waters designated as Cartledge Creek, class C waters in the Yadkin
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 (SWPPP) has not been recorded, or properly
implemented.
2) Qualitative Monitoring
Per Part D, Section D-1...Qualitative monitoring has not been conducted and/or recorded in accordance
with permit requirements.
3)Analytical Monitoring
Per Part E, Section E-1 -E-4...Analytical monitoring has not been conducted and/or recorded in accordance
with permit requirements.
Other Observations
Please refer to the enclosed Compliance Inspection Reportfor additional comments and observations made
during the inspection.
/t�V North Carolina Department of Environmental Quality I Division of Energy,Mineral and Land Resources
'� Fayetteville Regional Office 1.225 Green Street,Suite 7141 Fayetteville,North Carolina 28301.
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wwineimwwaiiv. 910.433.3300

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.
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(910)433-3300.
Sincerely,
�j/y/.yam—r
Timothy L. LaBoun ,
Regional Engineer
DEMLR
TLL/maj
Enclosure: Compliance Inspection Report
ec: Andrew Sullivan, EHS Director—2135 Manufacturing, LLC (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)
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

Compliance Inspection Report
Permit:NCG090031 Effective: 07/01/21 Expiration: 06/30/26 Owner: Rockingham Group LLC
SOC: Effective: Expiration: Facility: 2135 Manufacturing, LLC
County: Richmond 106 Enterprise Dr
Region: Fayetteville -
Rockingham NC 28379
Contact Person:Andrew Sullivan Title: Phone:[phone]
Directions to Facility:
System Classifications: SWNC,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 10/17/2023 Entry Time 10:20AM Exit Time: 12:55PM
Primary Inspector:Melissa A Joyner 'yew a' Phone:
Secondary Inspector(s):
Kelly Jonas
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Paints,Varnishes, Lacquers Stormwater Discharge CDC
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 3

Permit: NCGO90031 Owner-Facility:Rockingham Group LLC
Inspection Date: 10/17/2023 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Melissa Joyner and Kelly Jonas met with Ken Chaco, CEI, ISW and Andrew Sullivan, EHS Director at the facility. The
Stormwater Pollution Prevention Plan (SWPPP)was reviewed.The annual review of the SWPPP was only documented for
2023. The font on the Site Map needs to be made more legible. The permanent stockpile locations should be labeled on the
Site Map.After the facility's construction project is completed, the Site Map will need to be updated with the location of the
possible additional outfall(s). Employee Training has not been documented. There was one record of annual documentation
of the facility not having/having spills for the past three years. There was no historical documentation of the
presence/absence of non-stormwater in the outfall. Under"Spill Prevention and Response Procedures (SPRP)"there was no
signed and dated acknowledgement of staff members accepting responsibilities for the SPRP. The Stormwater Facility
Inspection Program has not been conducted quarterly since this became a requirement of the renewed General Stormwater
Permit NCG090000 as of July 1, 2021.Analytical and Qualitative Monitoring was also required to be done quarterly and is
being done semi-annually.Total Suspended Solids, a required parameter, had not been monitored. The pH had also not
been measured within 15 minutes of the sample collection. The facility has not registered for a-DMR and has not been
submitting/uploading Discharge Monitoring Report Forms since this became a permit requirement. The facility's outfall, best
management practices and Aboveground Storage Tanks were reviewed. Previously there had been two outfalls but one of the
outfalls, a grassy swale, had been removed.This information will need to be provided to the Raleigh Central Office
Stormwater Program. Please contact Ms. Brittany Cook, at [e-mail] and provide her with the updated
information about the removed outfall and the future new outfall(s)associated with the new construction project.
Page 2 of 3

Permit: NCG090031 Owner-Facility:Rockingham Group LLC
Inspection Date: 10/17/2023 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? 0 ❑ ❑ ❑
#Does the Plan include a General Location (USGS)map? 0 ❑ ❑ ❑
#Does the Plan include a"Narrative Description of Practices"? 0 ❑ ❑ ❑
#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? ❑ 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? 0 ❑ ❑ ❑
#Does the Plan include a Spill Prevention and Response Plan(SPRP)? 0 ❑ ❑ ❑
#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? ❑ 0 ❑ ❑
Comment: The Stormwater Pollution Prevention Plan has not been implemented per the conditions of
General Permit NCG090000.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring? ❑ M ❑ ❑
Comment: Qualitative Monitoring has not been conducted per the conditions of General Permit
NCG090000.
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? ❑ E ❑ ❑
#Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ E ❑
Comment: Analytical Monitoring has not been conducted per the conditions of General Permit
NCG090000.
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? ❑ ❑ ❑
#If the facility has representative outfall status, is it properly documented by the Division? ❑ 1:10 ❑
#Has the facility evaluated all illicit(non stormwater)discharges? M ❑ ❑ ❑
Comment:
Page 3 of 3