NCG090019_NOV_20190402

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Interim Director
NORTH CAROLINA
Environmental Quality
April 2, 2019
CERTIFIED MAIL: 7017 2620 0000 9759 0553
RPM Wood Finishes Group, Inc
Attn: Aaron Berwick, Environmental, health and Safety Manager
Post Office Box 22000
Hickory, North Carolina 28603-0200
Subject: NOTICE OF VIOLATION (NOV-2019-PC-0227)
NPDES Stormwater General Permit NCG090000
RPM Wood Finishes Group, Inc., Certificate of Coverage NCG090019
Caldwell County, North Carolina
Dear Sirs:
On March 21, 2019, Isaiah Reed from the Asheville Regional Office of the Division of
Energy, Mineral and Land Resources (DEMLR), conducted a site inspection for the RPM
Wood Finishes Group facility located at 3194 Hickory Blvd, Hudson, Caldwell County, North
Carolina. A copy of the Compliance Inspection Report is enclosed for your review. David E.
Phillips and Abbey Duggan 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 NCG090000 under Certificate of
Coverage NCG090019. Permit coverage authorizes the discharge of stormwater from the
facility to receiving waters designated as Gunpowder Creek, a Class WS-IV waterbody in
the Catawba River Basin.
D E Q North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
NIXiTiC
Asheville Regional Office 12090 U.S. Highway 70 1 Swannanoa, North Carolina 28778
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Notice of Violations
RPM Wood Finishes Group, Inc
Page 2 of 2
As a result of the site inspection, the following permit conditions violation(s) is/are noted:
1) Secondary Containment
Secondary containment is not provided at the facility in all areas where bulk liquid
materials are being stored. The facility contact was informed that the current storage
practices were not in compliance with the General Permit in the previous inspection report
dated March 12, 2018.
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 violation has occurred as well as a Plan of Action to prevent this violation
from recurring.
Thank you for your attention to this matter. This Office is considering sending a
recommendation for enforcement to the Director of the Division of Energy, Mineral & Land
Resources regarding these issues. Your above -mentioned response to this correspondence
will be considered in this process. 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 Isaiah Reed or myself at (828) 296-
4500.
Sincerely,
Stanley E. Aik14
en
Regional Engineer
Land Quality Section
Enclosure:
Inspection Report
ec: Alaina Morman, Environmental Specialist Alaina.mormangncdenr.gov
Stanley E. Aiken- Regional Engineer stan.aikenna,ncdenr.gov

,I
Permit: NGG090019
SOC:
it
County: Caldwell
Region: Asheville
Contact Person: Alicia Boppe
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Compliance Inspection Report
Effective: 11/01/18 Expiration: 05/31/21 Owner: Rpm Wood Finishes Group Inc
Effective: Expiration: Facility: RPM Woad finishes Group, Inc.
3194 Hickory Blvd
Title: EHS Manager
Certification:
Hudson NC 28638
Phone: [phone] Ext.1819
Phone:
Inspection Date: 03/21/2019 Entry Time: 01:30PM Exit Time: 03:OOPM
Primary Inspector: Isaiah L Reed Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Paints, Varnishes, Lacquers Stormwater Discharge COC
Facility Status: Compliant Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 3

permit: NCGO90019 Owner - Facility: Rpm Wood Finishes Group Inc
Inspection Date: 03/21/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary
On March 21, 2019 this facility was inspected for compliance. Tyler Pearson and myself met with David Phillips, Aaron
Berwick and Abbey Duggan on site. During the inspection, the following compliance issue was noted:
1) Secondary containment is not provided at the facility in all areas where bulk liquid materials are being stored. The facility
contact was informed that the current storage practices were not in compliance with the General Permit in the previous
inspection report dated March 12, 2018. The permittee is directed to provide secondary containment as required by the
Stormwater General Permit NCG09000. The permittee is also directed to provide a written response including a reasonable
explanation as to why the aforementioned violation has occurred as well as a Plan of Action to prevent this violation from
recurring.
If you have any questions concerning the above compliance issue, please contact this office at [phone].
Page 2 of 3

Permit: NCG090019 Owner - Facility: Rpm Wood Finishes Group Inc
Inspection Date: 03/21/2019 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?
N ❑ ❑ ❑
# Does the Plan include a General Location (USGS) map?
0 ❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
E ❑ ❑ ❑
# 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?
❑ ❑ ❑
# 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)?
❑ ❑ ❑
# Is the Plan reviewed and updated annually?
❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
❑ ❑ ❑
Comment: Secondary containment has not been Provided for bulk storage of liquid materials.
Qualitative Monitoring
Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? 0 1111 ❑
Comment:
Analytical Monitoring
Yes No NA NE
Has the facility conducted its Analytical monitoring? 0 ❑ 1111
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ 0 ❑
Comment:
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? ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? 11110 ❑
# Has the facility evaluated all illicit (non stormwater) discharges? 0 ❑ 110
Comment:
Page 3 of 3