The URL can be used to link to this page

Home My WebLink AboutNCG050355_Novipax LLC NOV_20240523 =tea,,,. - ,,..STATE r>. MYKarh ROY COOPER . . l'^ = Governor : yr �Q;i; ELIZABETH S.BISER Secretory ^M "ter* WILLIAM E.TOBY VINSON,JR NORTH CAROLINA Interim Director Environmental Quality May 23, 2024 CERTIFIED MAIL: 9589 0710 5270 0597 7463 26 RETURN RECEIPT REQUESTED Novipax LLC Attn: Jeff Williams 2215 York Road, Suite 504 Oak Brook, IL 60523 Subject: NOTICE OF VIOLATION (Case#NOV-2024-PC-0329 and NPDES Stormwater General Permit NCG050000 Novipax LLC Novipax LLC, Certificate of Coverage NCG050355 Richmond County Dear Mr. Williams: On January 31, 2024, Ms. Kelly Jonas and Ms. Melissa Joyner from the Fayetteville Regional Office of the Division of Energy, Mineral and Land Resources (DEMLR), conducted a site inspection for the Novipax LLC facility located at 112 Sonoco Road, Rockingham, Richmond County, North Carolina. A copy of the Compliance Inspection Report is enclosed for your review. They met with Mr. Allan Martin, Plant Manager, Mr. Mark Pearson, Maintenance Manager and Mr. Glenn Lovin, Materials Manager Scheduler. They also met with personnel of CDG, Ms. Mandy Tzannis, Team Leader and Ms. Meredith Brock, Environmental Scientist. Their time and assistance are greatly appreciated. The site visit and file review revealed that the subject facility is covered by NPDES Stormwater General Permit NCG050000 under Certificate of Coverage NCG050355. Permit coverage authorizes the discharge of stormwater from the facility to receiving waters designated as Hitchcock Creek(Midway Pond, Steeles Mill Pond),class C waters in the Yadkin River Basin. As a result of the site inspection, the following permit conditions violation(s) are noted: 1) Stormwater Pollution Prevention Plan (SWPPP) The SWPPP has not been fully implemented per the conditions of the NPDES General Permit NCG050000. 2) Qualitative Monitoring Qualitative Monitoring has not been conducted per the conditions of the NPDES General Permit NCG050000. 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. ..-y North Carolina Department of Environmental Quality Division of Energy.Mineral and Land Resources !!!`LL��JJ1//l Fayetteville Regional Office 1225 Green Street.Suite 714? Fayetteville.North Carolina 28301 Department of Emhonmennlal QuelltY 910.433,3300 Action Items The following corrective actions are required: 1. Implement the new SWPPP when provided by CDG. 2. Update the detailed Site Map to include topographic contours, percent impervious in the drainage area, and latitude/longitude locations of the outfalls. 3. Document any significant spills within the last three years or a statement indicating no spills had occurred. 4. Provide annual certification of no solvent storage located outside. 5. Update the SPRP to include a list of responsible parties with dated signatures and a list of response controls with their locations. 6. Evaluate the facility's outfalls annually for illicit(non-stormwater) discharges. 7. Conduct annual employee training per the conditions of the General Permit NCG050000. 8. Conduct Quarterly Qualitative Monitoring per the conditions of the General Permit NCG050000. 9. Conduct Quarterly Analytical Monitoring per the conditions of the General Permit NCG050000. 10. Obtain a rain gauge and calibrated pH meter. 11. Register on the online portal for submitting Analytical Monitoring reports (eDMR). 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 Kelly Jonas or myself at(910)433-3300. Sincerely, 'cop/ Timothy L. LaBounty, PE Regional Engineer DEMLR TL/kbj Enclosure: Compliance Inspection Report ec: Allan Martin, Plant Manager— Novipax LLC Toby Vinson, Jr., PE, CPESC, CPM, Chief of Program Operations— DEMLR Brad Cole, PE, Chief of Regional Operations— DEMLR Michael Lawyer, CPSWQ—Stormwater Program Supervisor— DEMLR Kieu Tran, Environmental Specialist, Stormwater Program— DEMLR DEMLR NPDES Stormwater Permit Laserfiche File cc: FRO— DEMLR Compliance Inspection Report Permit:NCG050355 Effective: 06/01/23 Expiration: 05/31/28 Owner: Novipax LLC SOC: Effective: Expiration: Facility: Novipax, LLC County: Richmond 112 Sonoco Rd Region: Fayetteville Rockingham NC 28379 Contact Person:Glenn Lovin Title: Phone:910-206-0760 Directions to Facility: Intersection of Highway 220 and Highway 74.Take HWY 74 W 1/4 mile,take a left onto Yates Hill Road. System Classifications: SWNC, Primary ORC: Certification: Phone: Secondary ORC(s): On-Site Representative(s): Related Permits: Inspection Date: 01/31/2024 Entry Time 02:35PM Exit Time: 03:50PM Primary Inspector:Kelly Jonas Phone: 910-433-3300 Secondary Inspector(s): Melissa A Joyner Phone : Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Apparel/Printing/Paper/Leather/Rubber Stormwater Discharge COC Facility Status: ❑ Compliant Not Compliant Question Areas: Storm Water (See attachment summary) Page 1 of 3 Permit: NCG050355 Owner-Facility:Novipax LLC Inspection Date: 01/31/2024 Inspection Type:Compliance Evaluation Reason for Visit: Routine Inspection Summary: Kelly Jonas and Melissa Joyner met with Novipax personnel Mr.Allan Martin, Plant Manager, Mr. Mark Pearson, Maintenance Manager and Mr. Glenn Lovin, Materials Manager Scheduler.They also met with personnel of CDG, Ms. Mandy Tzannis,Team Leader and Ms. Meredith Brock, Environmental Scientist to conduct an industrial stormwater inspection at the Novipax facility in Rockingham, Richmond County, NC. The Stormwater Pollution Prevention Plan (SWPPP)was reviewed per the conditions of the National Pollutant Discharge Elimination System (NPDES)General Permit NCG050000.The current SWPPP was dated April 27, 2018 and appeared to be complete and well organized, though outdated. CDG is in the process of developing an updated SWPPP.An annual review of the SWPPP had not been documented since 2018. The detailed Site Map needed to include topographic contours, percent impervious in the drainage area, and latitude/longitude locations of the outfalls. No spills were noted in 2018 and none have occurred within the last three years. The SWPPP needed to include certification of no solvent storage located on site. The Spill Prevention and Response Plan (SPRP)needed to include a list of responsible parties with dated signatures, as well as a list of response controls and their locations. Illicit(non-stormwater)discharges have not been annually evaluated since 2018. Employee training records were not available. The facility does not conduct any vehicle maintenance or cleaning at the facility. The facility does not have any aboveground storage tanks(ASTs) located outside. No solvent storage is was assumed outside. Qualitative and Analytical Monitoring has not been conducted per the conditions of the General Permit NCG050000. The facility is within the 6-month grace period for Analytical Monitoring. However,Analytical Monitoring should be conducted on a quarterly basis per the conditions of the NPDES General Permit NCG050000.The facility was not registered on electronic Discharge Monitoring Report(eDMR)to submit Analytical Monitoring results electronically. The facility will need to implement measures to record rainfall and pH (i.e. onsite rain gauge or regional gauge within one mile of facility). The facility grounds were inspected, including the outfalls.The facility appeared to be well-maintained. The following corrective actions are required: * Implement the new SWPPP when provided by CDG. * Update the detailed Site Map to include topographic contours, percent impervious in the drainage area, and latitude/longitude locations of the outfalls. * Document any significant spills within the last three years or a statement indicating no spills had occurred. * Provide annual certification of no solvent storage at facility. *Update the SPRP to include a list of responsible parties with dated signatures and a list of response controls with their locations. * Evaluate the facility's outfalls annually for illicit(non-stormwater)discharges. *Conduct annual employee training per the conditions of the General Permit NCG050000. *Conduct Quarterly Qualitative Monitoring per the conditions of the General Permit NCG050000. *Conduct Quarterly Analytical Monitoring per the conditions of the General Permit NCG050000. *Obtain a rain gauge or regional rain fall data,and calibrated pH meter. * Register on eDMR. eDMR Registration is available at the following website: https://www.deq.nc.gov/about/divisions/energy-mineral-and-land-resources/stormwater/stormwater-program/npdes-industrial- program/stormwater-electronic-discharge-monitoring-reports-edmr The following action is recommended: 1. Update the Stormwater Permit Data with current information. The Stormwater Permit Summary Report Form can be obtained at the following website: https://www.deq.nc.gov/about/divisions/energy-mineral-and-land-resources/stormwater/stormwater-program/npdes-industrial- program Page 2 of 3 Permit: NCG050355 Owner-Facility:Novipax LLC Inspection Date: 01/31/2024 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"? 110E10 #Does the Plan include a detailed site map including outfall locations and drainage areas? • ❑ ❑ ❑ #Does the Plan include a list of significant spills occurring during the past 3 years? • ❑ ❑ ❑ #Has the facility evaluated feasible alternatives to current practices? DOME' #Does the facility provide all necessary secondary containment? ❑ ❑ • ❑ #Does the Plan include a BMP summary? • 0 0 0 #Does the Plan include a Spill Prevention and Response Plan(SPRP)? I 0 0 0 #Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? • ❑ ❑ ❑ #Does the facility provide and document Employee Training? ❑ • ❑ ❑ #Does the Plan include a list of Responsible Party(s)? • ❑ ❑ ❑ #Is the Plan reviewed and updated annually? 0 • ❑ 0 #Does the Plan include a Stormwater Facility Inspection Program? ❑ IN ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? ❑ ❑ ❑ Comment: The Stormwater Pollution Prevention Plan has not been fully implemented per the conditions of the NPDES General Permit NCG050000. Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring? ❑ ❑ ❑ Comment: Qualitative Monitoring has not been conducted per the conditions of the NPDES General Permit NCG050000. 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: Analytical Monitoring begins in Quarter 1 of 2024. Permit and Outfalls Yes No NA NE #Is a copy of the Permit and the Certificate of Coverage available at the site? • 0 0 0 #Were all outfalls observed during the inspection? MOOD #If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ❑ #Has the facility evaluated all illicit(non stormwater)discharges? ❑ II 0 ❑ Comment: Page 3 of 3 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF ENERGY, MINERAL,AND LAND RESOURCES GENERAL PERMIT NO. NCG050000 CERTIFICATE OF COVERAGE No. NCG050355 STORMWATER DISCHARGES NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Novipax LLC is hereby authorized to discharge stormwater from a facility located at: Novipax, LLC 112 Sonoco Rd Rockingham Richmond County to receiving waters designated as Hitchcock Creek (Midway Pond, Steeles Mill Pond), class C waters in the Yadkin River Basin(s), in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in General Permit No. NCG050000 which can be downloaded by entering"deq.nc.gov/SW-industrial" in the browser window and navigating to the "NPDES Stormwater General Permits" web page. This certificate of coverage shall become effective June 1, 2023. This Certificate of Coverage shall remain in effect for the duration of the General Permit or until rescinded. Michael Lawyer, Stormwater Program Supervisor Division of Energy, Mineral and Land Resources By the Authority of the Environmental Management Commission • r: