NCG020279_NOD_20180829

Energy, Mineral
and Land Resources
ENVIRONMENTAL QUALITY
August 29, 2018
CERTIFIED MAIL: 7012 3050 0001 9398 7270
RETURN RECEIPT REQUESTED
Southern Products and Silica Co., Inc.
Attn: Robert Bradsher
PO Box 189
Hoffman, NC 28347
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
WILLIAM E. (TOBY) VINSON, JR.
Interim Director
Subject: NOTICE OF DEFICIENCY (NOD -2018 -PC -0280)
NPDES General Permit NCG020000
Southern Products and Silica Co., Inc.
Drowning Creek Deposit Mine, Certificate of Coverage NCG020279
Richmond County
Dear Mr. Bradsher:
On August 22, 2018, Mike Lawyer, Environmental Program Consultant from the Fayetteville Regional Office
of the Division of Energy, Mineral and Land Resources (DEMLR), conducted a site inspection for the
Drowning Creek Deposit Mine located at 4303 US Highway 1 in Richmond County, North Carolina. A copy of
the Compliance Inspection Report is enclosed for your review. Mr. Steve Mills, Mr. Eric Hartman and Mr.
Scott Bradsher 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 General Permit
NCG020000 under Certificate of Coverage NCG020279. Permit coverage authorizes the discharge of
stormwater, mine dewatering wastewater and/or process wastewater from the facility to receiving waters
designated as Drowning Creek, a Class WS-II;Sw,HQW waterbody in the Lumber River Basin.
As a result of the site inspection, the following deficiency is noted:
1) Analytical Monitoring
Analytical monitoring has not been conducted and 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 deficiency has occurred as well as a
Plan of Action to prevent this deficiency from recurring.
Thank you for your attention to this matter. This office requires that the deficiency, as noted above and
detailed in the enclosed inspection report, be properly resolved. Failure to address the deficiency
could result in the issuance of a Notice of Violation, which is subject to a civil penalty assessment of
up to $25,000 per day for each violation. Should you have any questions or concerns, please contact Mike
Lawyer or myself at [phone].
State of North Carolina I Environmental Quality I Energy, Mineral and Land Resources
Fayetteville Regional Office 1 225 Green Street, Suite 714 1 Fayetteville, NC 28301
910-433-3300

Sincerely,
imothy L. La unty, PE
Regional Engineer
DEMLR
TL/ml
Enclosure
ec: Eric Hartman — Southern Products and Silica Co., Inc.
Scott Bradsher — Southern Products and Silica Co., Inc.
Annette Lucas, PE, Program Manager - DEMLR, Stormwater Permitting Program
Laura Alexander, Administrative Assistant — DEMLR, Stormwater Permitting Program
cc: FRO — DEMLR, Stormwater Files

Compliance Inspection Report
Permit: NCG020279 Effective: 10/01/15 Expiration: 09/30/20 Owner: Southern Products and Silica Co Inc
SOC: Effective: Expiration: Facility: Drowning Creek Deposit Mine
County: Richmond 4303 Hwy US #1 N
Region: Fayetteville
Hoffman NC 28347
Contact Person: Robert L Bradsher Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
On-site representative Steve Mills 910-281-3189
On-site representative Eric Hartman 910-281-3189
On-site representative Scott Bradsher 910-281-3189
Related Permits:
Inspection Date: 08/22/2018 E try Time: 09: AM Exit Time: 11:55AM
Primary Inspector: Mike La wy Phone: [phone] Exl,72J'
11
Secondary Inspector(s): 339'
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Mining Activities Stormwater Discharge COC
Facility Status: ❑ Compliant Not Compliant
Question Areas:
0 Storm Water
(See attachment summary)
Page: 1

Permit: NCG020279 Owner - Facility: Southern Products and Silica Co Inc
Inspection Date: 08/22/2018 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Facility's Stormwater Pollution Prevention Plan contains all permit -required components and there is documentation of an
annual review and update. -Monitoring records for 2016 and 2017 were not available at the time of inspection, but were
provided by e-mail on August 29, 2018. Based on the monitoring records for 2016 and 2017, monitoring was not conducted
in the third quarter of 2016. Records for fourth quarter 2015 and first and second quarter 2016 were reviewed during the
previous inspection on July 26, 2016. Third quarter 2016 would have been the fourth quarterly sampling event for the first year
of coverage under the current permit. For 2017, monitoring was conducted in the first, third and fourth quarters. Monitoring
has thus far not been conducted in 2018 due to a misunderstanding of the permit conditions related to upstream and
downstream monitoring where the upstream and downstream sampling locations were reportedly inaccessible. Specific
monitoring requirements of the NCG020000 permit were reviewed and discussed during the inspection. Facility personnel
were informed that a Notice of Deficiency would be issued for failing to adhere to the monitoring requirements of the permit.
All available monitoring results are below the applicable effluent limitations contained in the permit. Therefore, the facility
may reduce their monitoring frequency from quarterly to semi-annually per Footnote 1 under Table 7 in the NCG020000
permit beginning with the second half of 2018.
Page: 2

Permit: NCG020279 Owner - Facility: Southern Products and Silica Co Inc
Inspection Date: 08/22/2018 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 1:11:1 ❑
# Does the Plan include a "Narrative Description of Practices"?
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?
❑ ❑ ❑
# 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?
❑ ❑ ❑
# 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?
❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
0 ❑ ❑ ❑
Comment:
Qualitative Monitoring
Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ❑ ❑ 0 ❑
Comment: Facility has no stormwater-only outfalls.
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? ❑ ❑ M ❑
Comment: No monitoring results for third quarter 2016, which would have been the fourth quarterly sampling
event for the first year of coverage under the current permit's wastewater monitoring schedule.
No monitoring results for the first half of 2018.
Permit and Outfalls 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? 1-11:1 ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ M ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ❑ ❑ M ❑
Comment:
Page: 3