NCG050355_Revised NOV_20240611

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ROY COOPER
Governor
ELIZABETH S.BISER � ,,,
Secretary
WILLIAM E.TOBY VINSON,JR NORTH CAROLINA
Interim Director Environmental Quality
June 11, 2024
CERTIFIED MAIL: 7022 2410 0003 3233 5946
RETURN RECEIPT REQUESTED
Novipax LLC
Attn: Glenn Lovin
112 Sonoco Paper Mill Road
Rockingham, NC 28379
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. Lovin:
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 Paper Mill 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 and Mr. Mark Pearson, Maintenance Manager.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.
DE North Carolina Department of Environmental Quality I Division of Energy.Mineral and Land Resources
Fayetteville Regional Office 1225 Green Street,Suite 7t4I Fayetteville,North Carolina 28301
NOFtri!Cr�C4Nn
Ika)ArketeritalUntamed.)own 5,10,433,3300

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,
Ti othy L. LaBou , PE
Regional Engineer
DEMLR
TL/maj
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 Lavin Title: Phone:[phone]
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:S0PM
Primary Inspector:Kelly Jonas Phone: [phone]
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:/lwww.deq.nc.gov/about/d ivisions/e nergy-mi neral-and-land-resou rces/stormwater/stormwater-program/npdes-ind ustrial-
prog ram/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? • ❑ ❑ 0
#Does the Plan include a"Narrative Description of Practices"? • 0 0 0
#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? 0 ❑ • ❑
#Does the facility provide all necessary secondary containment? ❑ CHI ❑
#Does the Plan include a BMP summary? • ❑ ❑ ❑
#Does the Plan include a Spill Prevention and Response Plan(SPRP)? • ❑ ❑ ❑
#Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? • 0 0 0
#Does the facility provide and document Employee Training? 0 • 0 0
#Does the Plan include a list of Responsible Party(s)? 0 [] 0
# Is the Plan reviewed and updated annually? ❑ ❑
#Does the Plan include a Stormwater Facility Inspection Program? ❑ � ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented? ❑ • ❑ 0
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? ❑ • ❑ 0
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? ❑ ❑ I ❑
#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
#Were all outfalls observed during the inspection? • ❑ ❑ ❑
#If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ • ❑
#Has the facility evaluated all illicit(non stormwater)discharges? [] • 0 ❑
Comment:
Page 3 of 3
3

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF ENERGY, MINERAL,AND LAND RESOURCES
GENERAL PERMIT NO.NCG050000
CERTIFICATE OF COVERAGE No.NCG0S0355
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