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NCG030520_COMPLETE FILE - HISTORICAL_20190130
STORMWATER DIVISION CODING SHEET NCG PERMITS PERMIT NO. � GO 3 V 2,0 DOC TYPE dDHISTORICAL FILE ❑ MONITORING REPORTS DOC DATE ❑ YYYYMMDD u Illr�a � v ■�■ CORFLi1CiAT NL3 COT11P61VY Your Roof. For Life_" 701 5_ KING 5`r"EE-r PQ_ B4X 229 FAY ET-T'E VILLE. NC 283C 2-0224 PHONE (970) 483-0479 F^X (910) 483-8897 www_�nlo r"•metal roaFl nq_com January 28, 2019 NC Department of Environmental Quality Attn: Melissa Joyner 225 Greene Street, Suite 714 Fayetteville, NC 28301 C F \� FD RE MM JAN 3 p �p19 This letter is in response to the site inspection conducted on December 12, 2018 of Union Corrugating Company. The issues presented in the Notice of Violation have been addressed below with a Plan of Action to prevent these violations from recurring. Stormwater Pollution Prevention Plan (SPPP): Permit Condition Violation - A stormwater Pollution Prevention Plan (SPPP) has not been implemented. Response - An updated copy of General Permit No. NCG030000 has been procured and will be maintained at the permitted site. The current plan, along with all required notices, inspections, and reports, will be implemented. Qualitative Monitoring: Permit Condition Violation - Qualitative Monitoring has not been conducted and recorded in accordance with permit requirements. Response - Going forward, qualitative monitoring will be performed during a measurable storm event resulting in an actual discharge from the permitted site outfall. Performance of qualitative monitoring will be appropriately documented on the requisite Qualitative Monitoring Report form and maintained for future site inspections. Analytical Monitoring: Permit Condition Violation - Qualitative Monitoring has not been conducted and recorded in accordance with permit requirements. Response - analytical monitoring will be conducted and the results shall be maintained on -site or be available electronically to inspectors upon request. We do apologize for the issues that have arisen with our plan. We have been without a safety manager for several months but are currently in the process of filling the role. We do not anticipate this being an issue going forward. Sincerely yours, Shaneka Jones Director of Human Resources Fayetteville, NC Anderson, SC Tifton, GA Orange, VA Ocala, FL Vicksburg, MS Dayton, OH Oklahoma City, OK Scranton, PA Janesville, WI Morrison, TN le Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ■ Print your name and address on the reverse so that we can return the card to you. ■ Attach this card to the back of the maiipiece, or on the front if space permits. Article Addressed to: X ❑ Agent ❑ Addressee B. Rec ived by (Pd,a C. Date f D livex LG/JL c� 2 ya/� D. Is delivery address different from item 17 Yes If YES, enter delivery address below: ❑ No UNI(—!MRRUGATING COMPANY SHANEk,WJONES, HR/SAFETY DIRECT • PO BWt9 FAYETTEVILLE NC 28302 3 Se a Type press Mail ❑ Registered a Return Receipt foCMerchandise ❑ Insured Mall ❑ C.O.D. 4. Restricted Delivery? (Extra Fee) ❑ Yes 2. Article Number r _ — - -- - - ' (Pra�sfer, from seivice label} 7 01 2 3050,0001 9398 617 4 , PS Form?381-1 . February 2004 Domestic Return Receipt 102595-02-M-1540 ROY COOPER Governor MICHAEL S. REGAN Secretary WILLIAM E. (TOBY) VINSON, JR, Interim Director NORTH CAROLINA Environmental Quality December 17, 2018 CERTIFIED MAIL: 7012 3050 0001 9398 6174 RETURN RECEIPT REQUESTED Union Corrugating Company Attn: Shaneka Jones, HRISafety Director P.O. Box 229 Fayetteville, NC 28302 Subject: NOTICE OF VIOLATION (NOV-2018-PC-0477) NPDES Stormwater General Permit NCG030000 Union Corrugating Company, Certificate of Coverage NCG030520 Cumberland County Dear Ms. Jones: On December 12, 2018, Melissa Joyner from the Fayetteville Regional Office of the Division of Energy, Mineral and Land Resources (DEMLR), conducted a site inspection for the Union Corrugating Company facility located at 701 South King Street, Fayetteville, Cumberland County, North Carolina. A copy of the Compliance Inspection Report is enclosed for your review. Mr. Tom Eckert, General Manager, was also present during the inspection and his time and assistance is greatly appreciated. The site visit and file review revealed that the subject facility is covered by NPDES Stormwater General Permit NCG030000 under Certificate of Coverage NCG030520. Permit coverage authorizes the discharge of stormwater from the facility to receiving waters designated as Cape Fear River, a Class C waterbody in the Cape Fear River Basin. As a result of the site inspection, the following permit conditions violations are noted: 1) Stormwater Pollution_ Prevention Plan (SPPP) A Stormwater Pollution Prevention Plan (SPPP) has not been properly implemented. 2) Qualitative Monitoring Qualitative monitoring has not been conducted and recorded in accordance with permit requirements. 3) 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. Reauested 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. E i—Q,� North Carolina Department of Envtronmental Quality I Division of Energy, Mineral and Land Resources Fayetteville Regional Office 1 225 Green Street, Suite 714 1 Fayetteville, North Carolina 28301 910.433.3300 Compliance Inspection Report Permit: NCG030520 Effective: 11/01/18 Expiration: 05/31/21 Owner: Union Corrugating Company SOC: Effective: Expiration: Facility: Union Corrugating Company t County: Cumberland 701 S King St Region: Fayetteville Fayetteville NC 28301 Contact Person: Saneka Jones Title: Phone: 910-483-0479 Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 12/12/2018 Primary Inspector: Melissa A Joyner Secondary Inspector(s): Certification: Phone: Entry Time: 09:30AM Exit Time: 11:OOAM Phone: Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Metal Fabrication Stormwater Discharge COC Facility Status: ❑ Compliant Not Compliant Question Areas: Storm Water (See attachment summary) Page: 1 Permit: NCG030520 Owner - Facility: Union corrugating Company Inspection Date: 12/12/2018 Inspection Type : Compliance Eva}nation Reason for Visit: Routine Stormwater Pollution Prevention Plan Yes No NA WE 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 ❑ ❑ ❑ # 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? M 0 ❑ ❑ # Does the Plan include a BMP summary? 0 ❑ ❑ ❑ # Does the Plan include a Spill Prevention and Response Plan (SPRP)? ❑ [] ❑ # 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 Cl ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? ❑ ❑ ❑ Comment: The Stormwater Pollution Prevention Plan has not been fully implemented. Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ❑ M ❑ ❑ Comment: Qualitative Monitorinq has not been conducted semi-annually and has not been initiated on a monthly basis when the facility came under Tier Two in February 2017. Analytical Monitoring Has the facility conducted its Analytical monitoring? # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? Yes No NA NE Comment: Analytical Monitorinq has not been conducted on a monthly basis since the facilitv came under Tier Two in February 2017. Permit and Outfalls Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? O ❑ ❑ ❑ # Were all outfalls observed during the inspection? 0 ❑ ❑ ❑ # If the facility has representative outfall status, is it properly documented by the Division? ! ❑ Cl ❑ # Has the facility evaluated all illicit (non stormwater) discharges? ■ ❑ ❑ ❑ Comment: Page: 3 ROY COOPER covernor MICHAEL S. REGAN Secretary WILLIAM E. (TOBY) VINSON, JR. interim Director NORTH CAROLINA Environments[ Quality December 17, 2018 CERTIFIED MAIL: 7012 3050 0001 9398 6174 RETURN RECEIPT REQUESTED Union Corrugating Company Attn: Shaneka Jones, HRISafety Director P.O. Box 229 Fayetteville, NC 28302 Subject: NOTICE OF VIOLATION (NOV-2018-PC-0477) NPDES Stormwater General Permit NCG030000 Union Corrugating Company, Certificate of Coverage NCG030520 Cumberland County Dear Ms. Jones: On December 12, 2018, Melissa Joyner from the Fayetteville Regional Office of the Division of Energy, Mineral and Land Resources (DEMLR), conducted a site inspection for the Union Corrugating Company facility located at 701 South King Street, Fayetteville, Cumberland County, North Carolina. A copy of the Compliance Inspection Report is enclosed for your review. Mr. Tom Eckert, General Manager, was also present during the inspection and his time and assistance is greatly appreciated. The site visit and file review revealed that the subject facility is covered by NPDES Stormwater General Permit NCG030000 under Certificate of Coverage NCG030520. Permit coverage authorizes the discharge of stormwater from the facility to receiving waters designated as Cape Fear River, a Class C waterbody in the Cape Fear River Basin. As a result of the site inspection, the following permit conditions violations are noted 1) Stormwater Pollution Prevention Plan (SPPP) A Stormwater Pollution Prevention Plan (SPPP) has not been properly implemented. 2} Qualitative Monitoring Qualitative monitoring has not been conducted and recorded in accordance with permit requirements. 3) 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 aforementioned violations have occurred as well as a Plan of Action to prevent these violations from recurring. ®� North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources Fayetteville Regional Office 1225 Green Street, Suite 714 1 Fayetteville, North Carolina 28301 r�o� cnacauaa D.P `" °' E°" ° "i b1 �� 910.433.3300 Compliance Inspection Report Permit: NCG030520 Effective: 11/01/18 Expiration: 05/31/21 Owner: Union Corrugating Company SOC: Effective. Expiration: Facility: Union Corrugating Company County: Cumberland 701 S King St Region: Fayetteville Fayetteville NC 28341 Contact Person: Saneka Jones Title: Phone: 910-483-0479 Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 1211212018 Primary Inspector: Melissa A Joyner Secondary Inspector(s): Certification: Phone: Entry Time: 09:30AM Exit Time: 11:OOAM Phone: Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Metal Fabrication Stormwater Discharge COC Facility Status: ❑ Compliant Not Compliant Question Areas: Storm Water (See attachment summary) Page: 1 s Permit: NCG030520 Owner - Facility: Union Corrugating Company Inspection Date: 1211212018 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? ❑ ❑ ❑ # Does the Plan include a "Narrative Description of Practices"? ❑ ❑ [] # 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? N ❑ ❑ ❑ # Does the facility provide all necessary secondary containment? 0 ❑ ❑ ❑ # Does the Plan include a BMP summary? N ❑ ❑ ❑ # Does the Plan include a Spill Prevention and Response Plan (SPRP)? N ❑ ❑ ❑ # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? N ❑ ❑ ❑ # 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 ❑ ❑ # Does the Plan include a Stormwater Facility Inspection Program? ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? ❑ E ❑ ❑ Comment: The Stormwater Pollution Prevention Plan has not been fully implemented. Qualitative Monitoring Has the facility conducted its Qualitative Monitoring semi-annually? Comment: Qualitative Monitoring has not been conducted semi-annually and has not been initiated on a Yes No NA NE ❑ M ❑ ❑ monthly basis when the facility came under Tier Two in February 2017, Analytical Monitorinq Yes No NA NE Has the facility conducted its Analytical monitoring? ❑ ❑ ❑ # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ ❑ Comment: Analytical Monitorinq has not been conducted on a monthly basis since the facility calve under Tier Two in February 2017. 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? 0 ❑ ❑ ❑ # If the facility has representative outfall status, is it properly documented by the Division? E ❑ ❑ ❑ # Has the facility evaluated all illicit (non stormwater) discharges? 0 ❑ ❑ ❑ Comment: Page: 3 STORMWATER October 30, 2017 Lawrence Jones Union -Corrugating Co 701 S. King St Fayetteville, NC 28302 Mr. Jones: On.October 27, 2.017, a site inspection -was conducted,for compliance with your facilities for NPDI S Stormwater Discharge Permit, NCG030520 Certificate of Coverage and for Stormwater Fee Credit with the. City of Fayetteville. This. facility located at 701 S.Xing St, Fayetteville, North Carolina drains into the Cape,Fear River.. A copy of the Compliance Inspection Report -is attached for your review and records. The Following"is a' list of items noted during the.inspectiosi of your Facility. • SWPPP'needs to be reviewed and updated annually. • Stor►nwater facility inspectionprogram should be'done semi-annually at a mi'nimum.. • Qualitative •monitoririg should be conductcd.sefni=annually. • Exceeded the benchmark value for TSS in December 2016 and in February 2017 therefore putting you.into Tier 11. • General clean-up of windblown debris should be done on a regular basis. At.the time.of inspection, this facility was found.to be in compliance. I would like -to thank you and your staff -for the time and assistance in conducting this inspection. If there are any questions regarding this report, please contact one directly at (910) 433- . 09 L. nk you u Danny Strickland. Stormwater Inspector 433 Hay Street. Fayetteville, NC 28301-5537 (910) 433-1091 I www1ayeW6y_.il1e1ic.g9v I wW.W.fayN7xorn The City. of Payettevilte, North Carolina does not discriminate on the basis.of race, sex, sekual'orie.ntatioit, color, age, national origin, religion, 6r disability iii its employirnent opportunities, programs, services, or activities. Stormwater Facility Inspection ReportlChecktist Facility Name: Union Corrugating Inspection Type: Compliance NCG030520 Permit No.: NCSO Permit Effective 11-01-20.12 Date (if applicable): Not,Applicable Permit Status Active (If not currently permitted): Inspection 10-27-17 Discharges to: Cape Fear River Class WS-IV Dafe: Facility Personnel Inspector(s): Danny Strickland Assisting with Inspection Lawrence -Jones (Name/Phone Number): Entry Time: 1:00 PM Exit Time: 2:30 PM SIC Code: TFlity Hours of 8-11 ration: Facility Description: Metal Fabrication File Review/History: Page 1 of 6 Rev. 0 Stormwater Facility Inspection Repoit/Checklist L Site' lnspectlon Were'deficiencies observed with the following items? (lnspsctor should cornmenton violations/deficiencies ohserydd). Yes No NA Repeat Finding 1, Stormwater System: catch basins, open ditches, chanriels,plpes, ovtfalls, etc. ® ❑ ❑ ❑ Comments: Fabric inserts.need to be replaced in'some drop inlets. 2. Erosion Issues ❑ ® ❑ ❑ Comments: 3. Structural Stormwater BMPs ® ❑ ❑ ❑ Comments: Windblown -debris needs to be addressed. 4. Illicit Discharges i Connections ❑ ® ❑ ❑ Comments: 5. Aboveground Storage Tanks-(ASTs): List size, material type, and if.secondary is piovided ❑ ® ElElcontainment Comments: $. Underground Storage Tank (UST) Fill Port Area ❑ ❑ V ❑ Comments: 7. Outdoor'Matedal-Storage:Area(s) ❑ ®- ❑ ❑ Comments: recommend cove'Hn'g or'moving equipment outside. 8..Outdcor Processing Area(s) ❑ ® ❑ ❑ Comments: 9. Loading/Unloading Area(s) ® ❑ ❑ ❑ Comments: Windblown,debris 10. Vehicle/Equipm6nFArea(s): fueling, washing, maintenance,:storage ❑ ❑ ® ❑ Comments: 11. OilMater Separator"1 Pretreatment ❑ ❑ ® ❑ Coaftnents• 12. Waste Storage [Disposal Area(s)`. scrap metal, dumpsters, grease bins, etc. ® ❑ ❑ ❑ Comments: Some "seconds" still on site and:wooden pallets are,in the process of being removed. 13. Food Service Areas) ❑ ❑ ® ❑ Comments: 14. Indoor Material Storage Area(s) ❑ ❑ ® ❑ Comments: 15. Indoor Processing Area(s) ❑ ❑ ® ❑ Comments:i Page 3 of 6 Rev. 0: Stormwater Facility lrispectibn ReportlCfhecklist M Stormwater Pollution Prevenilon Plan (continued) Yes No NA Repeat Finiin If connected to SW conveyance; controlled by manuatly.activated valves or other similar devices? (Closed?) • Collected water observed.for color,.faam, outfall staining„visible sheens, and dry weather flow prior to release • Document individual making observation, description of water, date, and.time of.release Retain record 5 years 8. Does the Plan include -a BMP summary? ® ❑ ❑ ❑ Narrative description of:BMPs to be considered including all and greaseseparation, debris control, vegetative -filter strips, infiltration and;stormwater detention or retention, where necessary. The need.for structural BMPs shall be based on the assessmenl,of potential sources to contribute significant quantities of ,pollutants to stormwater discharges and data ccilected,through monitoring of:siormwater. discharges. 9, Does the Plan include a Spill' Prevention and Response Plan (SPRP)? ® ❑ ❑ ❑ • Assessment of potential pollutant'saurces based on materials inventory of the.facility • Facility personnel responsible for implementing the=SPRP shall be,identifted • Responsible person.shall be on -site at all times during facitily operations that have the potential to contaminate stormwaterrunoff through spills or exposure'of riiaterials assoclated with the facility operations. id. Does the Plan include a Preventative'Maintenance and'Good Housekeeping ® ❑ ❑ Plan? • Document schedules of inspections and maintenance activities of stormwater control systems, plant equipment and systems Inspect material handling areas • Regular cleaning schedules. ofthese:areas 11, Does the: facility provide and document' Employee Training? ® ❑ ❑ ❑ • Provide at a mini(num, annual training'for all'personnel'including:.proper-spill response, cleahup'procedures, preventative"maintenance activities 'for.all personnel involved in any of -the facility's operations that'have.the potential to contaminate stormwater rundff • Develop training schedule aril identifyfacility personnel responsible:for implementing..the,training 12.- Does:the Plan inciude:.a list of Responsible Parties? ® ❑ ❑ ❑ Identify position re§ponsible for the'overall coordination, development, implementation, and revision of the SPPP 13. Is the Plan reviewedand updated,annually? ❑ ® ❑ ❑ Have there been:any changestoahe design, construction, operalion,;or maintenance of the ,facifity, vrhicti,would have a Leen ^Does effect on the. potential for -the -discharge of pollutants to surface waters. plan include changes? 14, Does the Plan include.a Stormwater Facility. Inspection Program? ❑ ® ❑ 0 • Inspect semi-annually at,a minimum - once in Fall and once in Spring • Inspection and subsequent maintenance activities performed shall tie documented a Record date`and time a Individual performing.inspection o Narrative description of the stormwater outfall and plant equipment and systems • Records should.be incorporated into the SPPP Stormwater Pollution Prevention Plan Comments: It was noted during the inspection, that, the SWPPP needs to reviewed and updated annually. The Stormwater facility inspection program had not been done since ApM 2015 and should be done on a semi-annual schedule: Page 5 of 6 Rev. 0 Energy, Mineral & Land Resources EN` A?0NMENTAL QUALITY October 17, 2017 Jim Biermann Union Corrugating Company 701 S King St Fayetteville, NC 28301 ROY COOPER. MICHAEL S. REGAN Se reiary Subject: NPDES General Permit Renewal and Electronic Reporting Requirements Union Corrugating Company NPDES Permit Certificate of Coverage (COC) Number: NCG030520 Dear NPDES Permittee: TRACY DAVIS r'.irr -tor The General Permit this facility is covered under expires on October 31, 2017. Our records indicate that your annual fees are up to date; therefore, your coverage will be automatically renewed unless you submit a rescission request for this permit. If you no longer need this permit, a rescission form can be found on our website (http://goo.gl/BcgD_P4). The Stormwater Program plans to reissue this General Permit for one year with no changes. This action has been posted for public comment on our website above (see the table of General Permits) and published in area newspapers statewide. The public comment period for the reissuance action concludes on November 1, 2017, and the new General Permit is scheduled to become effective on November 16, 2017. Upon issuance of the final General Permit, your coverage will be renewed for the one year period. Instead of being mailed new Certificates of Coverage (COCs), each permittee should print off the new General Permit Cover Page from our Stormwater Program website (with revised effective and expiration dates) after issuance in mid -November. Although the renewal process is automatic this year, two items require your action: (1) You must review your permit contact information and notify us of any changes no later than November 15, 2017, (2) You must submit outfall information on-line for this site in preparation for electronic data monitoring report (eDMR) requirements no later than November 30, 2017. Permit Contact Information Please review the permit contact information we have in our database. You can do this by clicking on the "review the permit contacts for your facility" link on the website above and entering your permit COC number. Ensure that Owner Affiliation and Permit Contact are accurate, and that e-mail addresses are provided. (Note that if you already did this recently, we may not have entered the changes yet.) -�" 'Nothing Compares.._ SState of North Carolina i Environmental Quality Energy. Mincrai and Land Resources 512 N. Salisbury Street 1 1612 Mail service Center € Raieigh. North Carolma 276,10-1612 919 707 4200 A. _ �, __. .1 „r 14 _�p'�'yy�'p✓ T-s �7s. M 4 `"1 � , �t :',ftk S+ ti *�� -. •r a a<�aXHY "_- - . ="-g'� `?46` f �: ^ F.r' A..+v. .,...�', t�M1Ra';7 '. � eMe 1l". Energy, Mineral and Land Resources ENVIRONMENTAL QUALITY January 22, 2016 Union Corrugating Company Attn: Buck Enquist, HR/Safety Director PO Box 229 Fayetteville, NC 28302 PAT MCCRORY Governor DONALD R. VAN DER VAART Subject: Request for Regulatory Relief from Monthly Monitoring Union Corrugating Company General Permit NCG030000, Certificate of Coverage NCG030520 Cumberland County Dear Mr. Enquist: Secretary TRACY DAVIS Director In response to your request for regulatory relief from monthly monitoring due to consecutive exceedances of the benchmark values for copper and zinc at outfall 001, a site inspection was conducted by Land Quality Section staff on July 22, 2015. The purpose of the inspection was to ensure compliance with the conditions of General Permit NCG030000 and to discuss any actions that had been taken to address the exceedances. Please keep in mind that benchmark exceedances are NOT limit violations or violations of permit conditions; however, you are obligated to follow the tiered response actions outlined in your permit. At the time of the inspection, the facility was found to be in compliance with the tiered response actions and other conditions of General Permit NCG030000. During the inspection, it was relayed that some additional sampling had been conducted at three different locations around the facility to check for zinc levels coming off the roof. In addition, scrap metal dumpsters had been relocated further away from drains, housekeeping had been increased, and better management of old equipment/waste material had been conducted. Subsequent to the inspection, an e-mail was sent to Ms. Irene Boden, HR/Safety Manager on July 24, 2015 concerning the continuation of monthly monitoring for just copper and zinc for at least three more sampling events along with a recommendation to cover or relocate/remove "seconds" that were being stored near the outfall. On January 19, 2016, staff with our office received an e-mail from Ms. Boden, which included monthly monitoring data for copper and zinc from July to December 2015. In reviewing the monitoring data, stormwater discharge samples that were taken after the facility had relocated or otherwise removed potential sources of copper and zinc related to their industrial activities, as noted above, did not show any significant difference from previous monitoring results. Since the monitoring results did not reveal significant variances following implementation of source control measures by the facility, we are granting regulatory relief in the form of a collapsed Tier 2 - Tier 3 response. Upon receipt of this letter, Union Corrugating Company may resume the permit specified semi-annual analytical monitoring for the remainder of the current permit term. Your current permit is set to expire on October 31, 2017. This decision applies only to the copper and zinc benchmarks. A benchmark exceedance of any other parameter listed in your permit will trigger the tiered response actions as described in the general permit. You must notify this office, in writing, within five business days if you become aware of any significant source of copper or zinc at your facility that has the potential to be exposed to stormwater. The relief granted in this letter is contingent upon the current industrial practices at Union Corrugating Company. If industrial practices change and copper or zinc does become a significant stormwater exposure risk then this office reserves the right to withdraw this decision and reinstate the permit specified tiered response or other actions that may be warranted by the new set of circumstances. State of North Carolina I Environmental Quality I Energy, Mineral and Land Resources Fayetteville Regional Office 1 22,5 Cheen Street, Suite 714 I Fayetteville, NC 28301 910-433-3300 Energy, Mineral and Land Resources . ENVIRONMENTAL QUALITY Union Corrugating Company Attn: Buck Ehquist, HR/Safety Director PO Box 229 Fayetteville, NC P-8302 PAT MCCRORY ' Governor DONALD R. VAN DER VAART S-re-Y TRACY DAVIS Director January 22, 2016 Subject: Request for Regulatory. Relief from Monthly Monitoring Union Corrugating Company General Permit NCG030000, Certificate of. Coverage NCG030520 Cumberland. County Dear Mr. Enquist: . In response to your request for regulatory relief from monthly monitoring due to consecutive exceedances of the benchmark values for copper and zinc at outfa11001, a site inspection was conducted by I and Quality Section staff on July 22,2015. The purpose of the inspection was to ensure compliance with the conditions of General Permit NCGO30000 and to discuss any actions that had been.taken to address the exceedances.. Please keep in mind that benchmark exceedances are NOT limit violations or violations of permit conditions; however, you are obligated to follow the tiered response actions outlined in your permit, At-the'time of the inspection, the facility was found to be in compliance with the tiered'response actions and other conditions of General Permit NCG03000O.'During the inspection, it was relayed that some.additional sampling had been conducted at- three different locations around the facility to check for zinc levels coming off the roof. In addition, scrap_metal dumpsters had been relocated further away from drains, housekeeping had been increased, and better. management of old equipment/waste material had. been conducted. Subsequent to'the inspection, an e-mail was sent to Ms. Irene Boden, HR/Safety.Manager on July. 24, 2015 concerning the continuation of monthly monitoring for just copper and zinc for at least three more sampling events along with a recommendation to cover or relocate/remove "seconds" that were being stored near the outtalk. On January 19, 2016, staff with our office received an e-mail from Ms. Boden, which included monthly monitoring data for copper and zinc from July to December 2015. In reviewing the monitoring .data, stormwater discharge samples that were taken after the facility had relocated or otherwise removed potential sources of•copper and zinc related to their industrial activities, as noted above,_ did not show any significant difference from previous monitoring results. Since the monitoring results did not reveal significant variances following implementation of source control measures by the facility, we are granting regulatory relief in the form of a collapsed Tier 2 - Tier.3 response: . Upon - receipt. of this letter, Union Corrugating Companymay:resume the permit specified semi-annual analytical monitoring for the remainder of the current permit term. Your current permit is set to expire on October 31; 2017. This decision applies only to the copper and zinc benchmarks. A benchmark exceedance of any other parameter listed in your permit will trigger the tiered'response actions as described In the general permit. You must notify this office, in writing, within five business'days if you becorrie.aware of any significant source of copper or lino at your facility that has.the potential to be exposed to stormwater.'The relief granted in this letter is contingent upon the current industrial practices at Union Corrugating Company. If industrial practices change and copper or zinc does become a signif!cantstormwater exposure risk then this office reserves the right to withdraw this decision and reinstate the permit specified tiered.response or other actions that maybe warranted by the new set of circumstances:' State of North Carolina I Favi'=eEw Quality I Sy. Mineral ►nd Land Reso� Fayeaevelle RegioW office 1 =5 Green Suee; Suite 714 1 Fayetteville, NC 28301 910433-33M Lawyer, Mike From: Irene Boden <iboden@unioncorrugating.com> Sent: Monday, January 18, 2016 7:18 AM To: Lawyer, Mike, Ior.Britt@ncdenr.gov Cc: Buck Enquist Subject: Union Corrugating NCG030520 Stormwater Results 2015 Attachments: Fayetteville Stormwater MONTHLY results.xls Importance: High Good Morning, You will find attached our results for the year 2015. Since our last visit on July 22nd, we tested only Copper and Zinc per your direction. The zinc results are still not consistent nor meeting the required passing number of 0.067mg/L. We will continue with the monthly test of only the Zinc and Copper, and continue with the annual testing of all other elements, until directed differently. If you have any questions or require any other documentation, please do not hesitate to contact me. Thank you, Irene Boden Union Corrugating Human Resource & Safety Manager 701 South King Street Fayetteville. NC 28302-0229 Office: 910-813-2431 Fax:910-485-7991 Email: IBoden @ unioncorrugating.com This e-mail message is intended only for the use of the individual or entity to which it is addressed and may contain information that is privileged, confidential or exempt from disclosure under applicable law. If you are not the intended recipient, any dissemination. distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify us immediately by reply e-mail or telephone and delete or destroy all copies of the original message. Favetteville RESULTS Month Year Copper Lead Zinc pH Oil/Grease Total Suspended Solids HEM REQUIREMENT _ �T .007/mg/L 0.03mg/L 0.067mg/L 6.0 - 9.0 15mg/L 100mg/L or-50 mg/1-4 October 2014 0.023 0.0071 0.23 nla 1.55 November 2014 MNO. =F..LQWM No1F.low December 2014 0.01 0.006 0.234 7 1.2 13.8 January 2015 =NO= MFVQW Na'Flow� February 2015 0.033 0.445 0.033 6.6 <5.00 84 March 2015 No Flow,' April 2015 0.008 <0.0015 0.227 5.8 <5.00 33.4 May 2015 0.006 <0.00150 0.104 7.2 11.6 9.5 June 2015 0.019 <0.00300 0.174 6.8 <5.00 35.4 June Front Bldg 2015 0.249 June North Bldg 2015 0.06 June Back Bldg 2015 0.25 July 2015 ®NOS =FLUWM NoiFlaw August 2015 WNO� ==..LOW= N-IFlow September 2015 0.014 0.01 0.201 6.7 <5.00 16 October 2015 <0.005 0.125 November 2015 0.013 0.301 December 2015 <0.005 0.107 Lawyer, Mike From: Lawyer, Mike Sent: Friday, July 24, 2015 3:30 PM To: 'iboden@unioncorrugating.com' Cc: Britt, Lori; Danny Strickland (Danny.Strickland@ci.fay.nc.us) Subject: stormwater permit inspection/monthly monitoring Attachments: Compliance Inspection_Union Corrugating Company_NCG030520_7-22-15.pdf Irene, Attached is a copy of the compliance inspection report for your files. Original will be mailed out today to Buck. Regarding the request for relief from monthly monitoring, we would like for you to continue with monthly monitoring for just copper and zinc for at least three more sampling events. We have concerns about the "seconds" that are stored near the outfall and whether or not they are contributing to the exceedances. We propose that you relocate the "seconds" indoors or adequately cover them with a tarp, shelter, etc. during the monthly sampling. Once you have the monitoring results from the three sampling events, you may contact us for a follow-up site visit where we can re- evaluate the data and make a formal decision about relieving you from monthly monitoring. Based on the data for all other parameters being consistently below their respective Benchmark Values, you may return to the semi-annual monitoring schedule as listed in the permit for those parameters. Please keep in mind that a benchmark value exceedance of any of the other parameters will trigger the tiered response actions as described in the permit. Please place a printed copy of this e-mail in your SPPP as documentation of our decisions above. If there are any questions or concerns, please contact me or Lori. Thanks, Mike Michael Lawyer, CPSWQ Environmental Program Consultant NCDENR — Division of Energy, Mineral and Land Resources Land Quality Section Fayetteville Regional Office P: (910) 433-3394 F: (910) 486-0707 e-mail: mike.lawyer@ncdenr.gov E-mail correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties unless the content is exempt by statute or other regulation. city of g Engineering & Infrastructure Stormwater Division October 13, 2014 Irene Boden Union Corrugating Co 610 S. King St Fayetteville, NC 28302 Mrs. Boden: 433 flay Street Fayetteville, NC 28301-5537 (910) 433-1613 www.cikyoff,iyetteville.org On October 9, 2014 a site inspection was conducted for compliance with your facilities for NPDES Stormwater Discharge Permit, NCG030520 Certificate of Coverage and for Stormwater Fee Credit with the City of Fayetteville. This facility located at 610 S. King St, in Fayetteville NC drains into the Cape Fear River, A copy of the Compliance Inspection Report is attached for your review and records. The Following is a list of items noted during the walk-thru of your Facility. • The sediment baskets that have been placed in the catch basins need to be emptied and cleaned on a regular basis or as needed. • General clean-up of the grounds should be done on a regular basis. • All trash containers should be covered or protected from contact with falling precipitation. • All equipment that uses oil in them or on them should be properly stored under a shelter. • Metal machinery located outside of the maintenance shed needs to be covered. The employee training program was being implemented during the time of the inspection. • No sampling for Year 2-Period 1. At the time of inspection, this facility was found to be in compliance with your permitted Certificate of Coverage and will be recommended for continual fee credit with the City of Fayetteville. I would like to thank you and your staff for the time and assistance in conducting this inspection. If there are any questions regarding this report, please contact me directly at (910) 433-1091. r--vn U 2 you i f& The City of Fayetteville, Norlh Carolina does not discriminate on the basis of race, sex, color, age, national origin, religion, or disability in its employment opportunities, programs, servlceS, or activities. Ind ort Permit 9:Nt( O30 10 - Effective; _�i^1-2�oi2 Expiration: 10-31-2of�n� Owner; �nlo_rt/�5{i'�a 1_•n���. sic: 3 Facility: hio CO('r V 5 C,4 t Contact Person; r'�"�C. _�oC'r_ Title: MdnPhone; 9/0' Faeiiity Address:. Inspection Date: C I I A 1' r1. •/--) ►_Q / i rrimary inspector: --/Kn4 Reason for Inspection; 4 L Permit Inspection Type: ca mono; _ flu - r j - ! w Inspection Type: H/if�V q l Jr C V 1� ' I FadlityStatus: Question Areas: Kl�compliant ❑ Not Compliant I Storm Water NoteslComnfents: e c. Ca v ct 04 bcsrJ f s�, crl nc ;'eCav i eta c g�1S i 339 ALEXANDER STREET FAYETTEVILLE, NC 29301-5797 (910) 433-166011661 • FAX (910) 433-1647 www.cityoffayctlevitic _org An Eaua) Qonortuniiv Emnlnver CWoWI t • Engineering & Infrastructure Stormwater Division March 19, 2014 ShanekaJones Union Corrugating Co 610 S. King St Fayetteville, NC 28302 Ms. Jones: 433 Hay Street Fayetteville, NC 28301-5537 (910)433-1613 www.cityoffayettevil le.org On March 14, 2014 a site inspection was conducted for compliance with your facilities for NPDES Stormwater Discharge Permit, NCG030520 Certificate of Coverage and for Stormwater Fee Credit with the City of Fayetteville. This facility located at 610 S. King St, in Fayetteville NC drains into the Cape Fear River. A copy of the Compliance Inspection Report is attached for your review and records. At the time of inspection, this facility was found to be in compliance with your permitted Certificate of Coverage and will be recommended for continual fee credit with the City of Fayetteville. I would like to thank you and your staff for the time and assistance in conducting this inspection. If there are any questions regarding this report, please contact me directly at (910) 433-1091. Thank you, The following items were noted during the inspection: You exceeded the limit for Zinc in 2013 and will fall under Tier 1 since no sample was taken due to no flow in the second sampling period of 2013. k You Cnn 71 Strickland Stormwater Inspector City of Fayetteville ERM Q i You 'I lie City of Fayetteville, forth Carolina does not discriminate on the basis of race, sex, iolor, age, national origin, religion, or disability in its employment opporhinities, programs, services, or activities, 1 Industrial Compliance Inspection Report Permit if: j,1CC W b S �o Effective: _t (- �' 241 L Expiration: 10-31 - 2% 7 Owner. Coy f SIC: 3 444 Facility: %.4 )A,-ft[_� Contact Person: / �evi,kg ^n <-S racility Address: mot 6. k, ') S+ Title: H tz 4�< } Phone: ^�la� T G �— - - - -ri Inspection Date: 3-j Entry Time: �I : S _ _ Exit Time: aQ Primary Inspector: �phone:, ( 10 ^ `r3 3 n Reason for Inspeetlon: Inspection Type: n V- Permit Inspection Type: Facility Status: Question Areas: Storm Water LIPIJ Notes/Comments: rl ❑ Compliant ❑ Not Compliant 0 FKL. A, L Zsnc I k in �L-nt--�_o\ �. At all st%I C ,tr n < - - - L 339 ALEXANDER STREET FAYETTEVILLE, NC 29301-5797 (910) 433,166011661 - FAX (910) 433-1647 www.61yoffayettevilic.org An Equal Opportunity Employer AJZA. NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Governor Jim Biermann Union Corrugating Company 701 S King St Fayetteville, NC 28301 Dear Permittee: Charles Wakild, P. E. Director December 4, 2012 Dee Freeman Secretary Subject: NPDES Stormwater Permit Coverage Renewal Union Corrugating Company COC Number NCG030520 Cumberland County In response to your renewal application for continued coverage under stormwater General Permit NCG030000 the Division of Water Quality (DWQ) is forwarding herewith the reissued General Permit. This permit is reissued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between the state of North Carolina and the U.S. Environmental Protection Agency, dated October 15, 2007 (or as subsequently amended). The following information is included with your permit package: • A new Certificate of Coverage (COC) • A copy of General Permit NCG030000 • A copy of the Technical Bulletin for the General Permit • Two copies of the Discharge Monitoring Report (DMR) Form • Two copies of the Qualitative Monitoring Report Form The General Permit authorizes discharges of Stormwater, and it specifies your obligations for discharge controls, management, monitoring, and record keeping. Please review the new permit to familiarize yourself with all the changes in the reissued permit. Your facility has six (6) months from the time of receipt of the permit to update your current SPPP to reflect all new permit requirements. The first sample period of your permit begins January 1, 2013. Your facility must sample a "measureable storm event" beginning during the periods beginning January 1 and July 1 of every year (or, if applicable, report "No Flow," as outlined in Part III, Section E). Also, please note that Tier 3 Actions in Part II of your permit are triggered by benchmark exceedances on four occasions beginning on the effective date of this permit and do not count prior exceedances. The more significant changes in the General Permit since your last COC was issued are noted either in the Draft Permit Fact Sheet that accompanied the public notice (http://portal,ncdenr.org/web/wq/ws/su/current- notices), or in the Response to Comments / Summary of Changes and Technical Bulletin documents that are posted on the Stormwater Permitting Unit's website with the new General Permit. Please visit http://Portal.ncdenr.org/web/wq/ws/su/npdessw (click on 'General Permits' tab) to review that information for your specific General Permit carefully. 1617 Mall Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N Salisbury St. Raleigh, North Carolina 27604 Phone: 9IM07-63001 FAX: 919-807-6492 Internet: www.nmaleroualitxorg An Equal Opportunity 1 Afrrmahe Action Emplayer One NorthCarolina Naturally " L 1 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY GENERAL PERMIT NO. NCG030000 CERTIFICATE OF COVERAGE No. NCG030520 STORM WATER 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, Union Corrugating Company is hereby authorized to discharge stormwater from a facility located at: Union Corrugating Company 701 S King St Fayetteville Cumberland County to receiving waters designated as CAPE FEAR RIVER, a class WS-IV;CA waterbody in the Cape Fear River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III, and IV of General Permit No. NCG030000 as attached. This certificate of coverage shall become effective December 4, 2012, This Certificate of Coverage shall remain in effect for the duration of the General Permit. Signed this 41h day of December, 2012. for Charles Wakild, P.E., Director Division of Water Quality By Authority of the Environmental Management Commission NCDENR North Carolina Department of Environment and Natural Resources Beverly Eaves Perdue Governor Jim Biermann Union Corrugating Company 701 S King St Fayetteville, NC 28301 Dear Permittee: Division of Water Quality Charles Wakild, R E. Director December 4, 2012 Dee Freeman Secretary Subject: NPDES Stormwater Permit Coverage Renewal Union Corrugating Company COC Number NCGO30520 Cumberland County In response to your renewal application for continued coverage under stormwater General Permit NCG030000 the Division of Water Quality (DWQ) is forwarding herewith the reissued General Permit. This permit is reissued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between the state of North Carolina and the U.S. Environmental Protection Agency, dated October 15, 2007 (or as subsequently amended). The following information is included with your permit package: • A new Certificate of Coverage (COC) • A copy of General Permit NCG030000 • A copy of the Technical Bulletin for the General Permit • Two copies of.the Discharge Monitoring Report (DMR) Form • Two copies of the Qualitative Monitoring Report Form The General Permit authorizes discharges of stormwater, and it specifies your obligations for discharge controls, management, monitoring, and record keeping. Please review the new permit to familiarize yourself with all the changes in the reissued permit. Your facility has six (6) months from the time of receipt of the permit to update your current SPPP to reflect all new permit requirements. The first sample period of your permit begins January 1, 2013. Your facility must sample a "measureable storm event" beginning during the periods beginning January 1 and July 1 of every year (or, if applicable, report "No Flow," as outlined in Part III, Section E). Also, please note that Tier 3 Actions in Part 11 of your permit are triggered by benchmark exceedances on four occasions beginning on the effective date of this permit and do not count prior exceedances. The more significant changes in the General Permit since your last COC was issued are noted either in the Draft Permit Fact Sheet that accompanied the public notice (htt ortal.ncdenr.org/web/wgLws/su current - notices), or in the Response to Comments / Summary of Changes and Technical Bulletin documents that are posted on the stormwater Permitting Unit's website with the new General Permit. Please visit http://Portal.ncdenr.ocp/web/w /ws/su/npdessw (click on `General Permits' tab) to review that information for your specific General Permit carefully. 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 Phone: 919-t'07-63001 FAX: 919-807-64 ,2 Internet: wvnri ncwaterggality oro An Equal Opp.--;niy 1 Aff xiative Actian Empl- . w NorthCarol; na aharall y STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY GENERAL PERMIT NO. NCG030000 CERTIFICATE OF COVERAGE No. NCG030520 ` STORMWATER 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, Union Corrugating Company is hereby authorized to discharge stormwater from a facility located at: Union Corrugating Company 701 S King St Fayetteville Cumberland County to receiving waters designated as CAPE FEAR RIVER, a class WS-IV;CA waterbody in the Cape Fear River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, 111, and IV of General Permit No. NCG030000 as attached. This certificate of coverage shall become effective December 4, 2012. This Certificate of Coverage shall remain in effect for the duration of the General Permit. Signed this 4th day of December, 2012. for Charles Wakild, P.E., Director Division of Water Quality By Authority of the Environmental Management Commission M UIMIC31M CORRUGATING COMPANY Your Roof. For Life.'" 07/19/2010 NCDENR Division of Water Quality 225 Green St, Ste 714 Fayetteville, NC 28301 Re: Response to Violations To Whom It May Concern: Shaneka Jones Human Resource/Safety P.O. Box 229, Fayetteville, NC 28302 Fax: (910) 485-7991 Phone: (910) 483-0479, ext. 118 ®ENR-FRO JUL 2 2 2010 DWO The following is in response to violations noted during a visit on June 24, 2010. The areas noted as in violation included; Qualitative/analytical monitoring and failing to perform tier 2 monthly monitoring. I have enclosed a plan of action to address compliance deficiencies. it is my hope that the enclosed plan serves as a good faith measure that we are indeed committed to making sure we are in compliance with our permit NCG030000. Please allow me to point out some steps that we have taken to help ensure that we are acting in accordance with our permit as well as making sure we are getting the most accurate results. We have recently purchased a new pH meter that will help us obtain a better reading. We are also going to begin testing the pH of the rainfall before it enters the drain in an attempt determine if there is a natural reason as to why we are having issues regarding our pH readings. One other measure we have taken is to install filter fabric in our drains to help catch a significant amount of the debris that may otherwise enter our drains. It is our hope that the presence of the filter will help address not only our pH issue, but the elevated TSS levels as well. As previously stated, we are committed acting within the parameters of our permit and sincerely apologize for the areas of oversight. Should any Questions arise please feel free to contact me at 910-483-0479 Ext. 118. Respectfully, Shaneka Jones Enclosure O Complete Items 1, 2, and 3. "Als6 complete Item 4 if Restricted Dellvery is desired. ■ Print your name and address on the reverse so that we can return the card to you. ■ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: UNION CORRU(',A'I'ii%G CO\•IPANY N111 BUCK EN'QUISI- POSC OFFICE BON ?21) . FAYi T"1TVILL N( 28302-0229 Al X Re6"d 6y'( Prated Name) wry address different from item 17 ❑ Yes enter delivery address below: ❑ No a. FS*cre Tyne tified Mail ❑ Express Mail egistered ❑ Retum Receipt for Merchandise ❑ Insured Mail ❑ C.O.D. 4. Restricted Delivery? (Extra Fee) 13 Yes 2. Article Number (1rarslt-rfrom service Iabelj 7D©.9" ©820 :000d ;2473 7896 PS Form 3811. February 2004 Domestic Return Receipt 102595-02-M-lW KkV9 NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director Julv 2, 2010 CERTIFIED MAIL: 7009 0820 0000 2473 7896 RETURN RECEIPT REQUESTED Union Corrugating Company Attn: Buck Enquist PO Box 229 Fayetteville, NC 28302-0229 Subject: NOTICE OF VIOLATION (NOV-2010-PC-0824) Union Corrugating Company NPDES Stormwater General Permit-NCG030520 Cumberland County Dear Mr. Enquist: Dee Freeman Secretary On June 24, 2010, Michael La\vyer from the Fayetteville Regional Office of the Division of Water Qualitv, conducted a site inspection for the Union Corrugating Company facility located at 701 South King Street in Fayetteville, Cumberland County. North Carolina. A copy of the Compliance Inspection Report is enclosed for your review. Ms. Shaneka Jones Nvas also present during the inspection and her time and assistance is greatly appreciated. Stormwater from the facility drains to a section of the Cape Fear River classified as a Class C water located in the Cape Fear River Basin. The site visit and file review revealed that the subject facility is covered by NPDES Stormwater General Permit- NCG030520. Accordingly, the following observations and/or permit conditions violations were noted during the Division of Water Quality inspection: l) Stormwater Pollution Prevention Plan (SWPPP) A Stormwater Pollution Prevention Plan (SWPPP) has been developed, recorded, and properly implemented. es ■ No ❑ 2) ualitative Monitoring Qualitative monitoring has been conducted and recorded in accordance with permit requirements. es ❑ No ■ Location: 225 Green Street, Suite 714, 'Fayetteville, North Carolina 28301 Phone: 910-433-33001 FAX: 91OA86-07071 Customer Service: 1-877-623-6748 Intemet: www.ncvaterouakty.org An Equal Opportunity 1 Affirmative Action Employer None irth Carolina Aawally Compliance Inspection Report Permit: NCG030520 Effective: 11/01/07 Expiration: 10/31/12 Owner: Union Corrugating Company SOC: Effective: Expiration: Facility: Union Corrugating Company County: Cumberland 701 S King St Region: Fayetteville Fayetteville NC 28301 Contact Person: Buck Enquist Title: Phone: 910-483-0479 Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): On -site representative Shaneka Jones Related Permits: Certification: Phone: Phone: 910-483-0479 Inspection Date: 0612412010 Entry Time: 09:15 AM Exit Time: 11:00 AM Primary Inspector: Mike Lawyer�,� � Phone: 910-433-3300 Extr733z--"� Belinda S Henson Phone: 910-433-3300 Exj,72T Reason for Inspection: Routine Inspection Type: Compiiance Evaluation 3� Permit Inspection Type: Metal Fabrication Stormwater Discharge COC Facility Status: ❑ Compliant ■ Not Compliant Question Areas: 0 Storm Water (See attachment summary) Page: 1 Permit: NCGO30520 Owner - Facility: Union Corrugating Company Inspection Date: 0612W2010 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 n n # Does the Plan include a General Location (USGS) map? ■ n ❑ 0 # Does the Plan include a "Narrative Description of Practices"? ■ D n n # Does the Plan include a detailed site map including outfall locations and drainage areas? ■ n n n # Does the Plan include a list of significant spills occurring during the past 3 years? ■ n n n # Has the facility evaluated feasible alternatives to current practices? ■ n ❑ n # Does the facility provide all necessary secondary containment? ■ n n n # Does the Plan include a BMP summary? ■ n n n # Does the Plan include a Spill Prevention and Response Plan (SPRP)? ■ n n n # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ■ Q # Does the facility provide and document Employee Training? ■ n n n # Does the Plan include a list of Responsible Party(s)? ■ Q ❑ n # Is the Plan reviewed and updated annually? ■ Cl n n # Does the Plan include a Stormwater Facility Inspection Program? ■ n Q Q Has the Stormwater Pollution Prevention Plan been implemented? ■ n 0 Comment: Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? n ■ n n Comment: Monitoring event missed for second half of 2009. Ms. Jones communicated this to the regional office at the time and submitted documentation to Central Files with proposal to conduct "make-up" event in 2010. Analytical Monitorin Yes No NA NE Has the facility conducted its Analytical monitoring? ❑ ■ ❑ n # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? n ❑ ■ n Comment: As stated above, monitoring event missed in second half of 2009. In reviewing monitoring data from first half of 2009 and first half of 2010, results for TSS and pH showed exceedance of Benchmark Values for both events. Since two consecutive monitoring events had exceedances, the Tier Two guidelines in the permit require the facility to immediately institute monthly monitoring, which has not been conducted. Permit and Outfalls Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? ■ 0 n n Page: 3 A NCDENR North Carolina Department of Environment and Natural Resources Beverly Eaves Perdue Governor Union Corrugating Company Attn: Buck Enquist PO Box 229 Fayetteville. NC 28302-0229 Division of Water Quality Coleen H. Sullins Director March 25, 2009 Subject: COMPLIANCE EVALUATION INSPECTION Union Corrugating Company NPDES Stormwater General Perm it-NCG030520 Cumberland County Dear Mr. Enquist: Dee Freeman Secretary On March 18, 2009, 1, Michael Lawyer from the Fayetteville Regional Office of the Division of Water Quality, conducted a site inspection at the Union Corrugating Company facility located at 701 South King Street in Fayetteville, Cumberland County, North Carolina. A copy of the Compliance Inspection Report is enclosed for your review. The inspection was conducted jointly with Mr. Dennis Miller with City of Fayetteville Stormwater. Ms. Jane Caddell, HR & Safety Manager, Mr. Andy Pope, General Manager, and Mr. Rick Mulvey, Production Manager, were also present during the inspection and their time and assistance is greatly appreciated. Stormwater from the facility drains to a section of the Cape Fear River, a Class C water located in the Cape Fear River Basin. The site visit and file review revealed that the subject facility is covered by NPDES Stormwater General Permit-NCG030520. Accordingly, the following observations were noted during the Division of Water Quality inspection: 1) Stormwater Pollution Prevention Plan (SPPP) A Stormwater Pollution Prevention Plan (SPPP) has been developed, recorded, and properly implemented. es ■ No ❑ 2) Qualitative Monitoring Qualitative monitoring has been conducted and recorded in accordance with permit requirements. Yes ■ No ❑ Location: 225 Green Street, Suite 714, Fayetteville, North Carolina 28301 Phone: 910-433-33001 FAX: 91OA86-07071 Customer Service: 1-877-623-6748 Internet: www.ncwate uali .or An Equal Opportunity 1 Affirmative Action Employer NorthCarolina naturally Compliance Inspection Report Permit: NCG030520 Effective: 11/01/07 Expiration: 10/31/12 Owner: Union Corrugating Company SOC: Effective: Expiration: Facility: Union Corrugating Company County: Cumberland 701 S King St Region: Fayetteville Fayetteville NC 28301 Contact Person: Buck Enquist Title: Phone: 910-483-0479 Directions to Facility: System Classifications: Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): On -site representative Andy Pope Phone: 910-483-0479 ext 115 On -site representative Jane Caddell Phone: 910-483-0479 ext 118 On -site representative Rick Mulvey Phone: 910-483-0479 Related Permits: Inspection Date: 0311812009 Entry Time: 10:000� O Exit Time: 11:50 AM Primary Inspector: Mike Lawyer,,, Phone: 910-433-3300 Geeo 1111 Exy, - 3304 4.0.6"X„ /; Belinda S Henson Phone: 910-433-3300 Ext„72&— Reason for Inspection: Routine inspection Type: Compliance Evaluation 334G Permit Inspection Type: Metal Fabrication Stormwater Discharge COC Facility Status: ■ Compliant ❑ Not Compliant Question Areas: 0 Storm water (See attachment summary) Page: 1 Permit: NCGO30520 Owner - Facility: Union Corrugating Company Inspection Date: 03/18/2009 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? ■ D ❑ D # Does the Plan include a General Location (USGS) map? ■ ❑ D D # Does the Plan include a "Narrative Description of Practices"? ■ Cl D ❑ # Does the Plan include a detailed site map including outfall locations and drainage areas? ■ D D D # Does the Plan include a list of significant spills occurring during the past 3 years? ■ D D D # Has the facility evaluated feasible alternatives to current practices? ■ D D D # Does the facility provide all necessary secondary containment? ■ n D D # Does the Plan include a BMP summary? ■ D D Q # Does the Plan include a Spill Prevention and Response Plan (SPRP)? ■ D D D # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ■ ❑ D D # Does the facility provide and document Employee Training? ■ ❑ Q D # Does the Plan include a list of Responsible Party(s)? ■ ❑ Cl D # Is the Plan reviewed and updated annually? ■ D D D # Does the Plan include a Stormwater Facility Inspection Program? ■ D ❑ 11 Has the Stormwater Pollution Prevention Plan been implemented? ■ ❑ Cl Q Comment: Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ■ D D D Comment: Based on documentation, facility personnel have been conducting visual monitoring of outfalls on a monthly basis exceeding the minimum requirement of semi-annually. Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? ■ D D D # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? D D C D Comment: Due to previous sampling event showing an exceedance of TSS, personnel have placed filter fabric in selected drains as a proactive approach to preventing solids from entering storm drain system. There have been some pH levels below the range of 6-9. Some recommendations were made at the time of inspection to evaluate the cause or source of this. Also, pH has previously been measured using color strips instead of a calibrated meter and this practice should change to provide more accurate readings and follow the appropriate method for pH testing. Permit and Outfalls Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? ■ Q D D Page: 3 Michael F. Easley, Governor J5v s Y CL William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Alan W, Klimek, P.E. Director Division of Water Quality SURFACE WATER PROTECTION SECTION PETU IIT NAMEIOWNERSHM CHANGE FORM 1. Please enter the permit number for which the change is requested. NPDES Permit (or) Certificate of Coverage N I C N I C I G 10 13 1 Q 11. Permit status prior to status change. a. Permit issued to (company name): /0 Coauc)/(_17G C 8 b. Person legally responsible for permit: _C m First / MI / Last rn Title rP o ( SO cl TH r' G Permit Holder Mailing Address d 830/ a City State Zip _ ( �o� Y - O1/77 o>WE d Phone /� Fax c. Facility name (discharge): (J/�//QN l ozeoC'/1 /71�� �'Ql�/J'iyN d. Facility address: ?o/ S00-8 k0V(5 STK— C T Address FA Y£TTEYt 4-k-C , AIC aMl City ,� l State Lip e. Facility contact person: ak _TIJ% Nf (N) 1`7 ` NIT First 1 MI / Last Phanc 111. Please provide the following for the requested change (revised permit). a. Request for change is a result of: 0 Change in ownership of the facility O Name change of the facility or owner Ifetherplease explain: NTIJCT AIANC LHAN -)k. ON b. Permit issued to (company name): UiW04 ('0KKUG4TW6 i�f IIAI f c. Person legally responsible for permit: /RhlR First / Ml / Last pi SrjIC4T Title '701 TOOTH K^IG Sr?,CZT Permit Holder Mailing Address /f YCTrJC V-T "-C nl e 0-1-Tot City state Zip (71o) of S-OYg7 Phone E-mail Address d. Facility name (discharge): �Q Nr 00,? CU(jA,74G C06 t XZNZ e. Facility address: 701 llaO r 8 K //I G S7KC— ET Address Fi-1 1 A/C- �?_?301 _ City tale "Lip f. Facility contact person: joc K I�`V �/ rS T First 1 Ml 1 Last Phone E-mail Address n� COP? Revised 712005 PERMIT NAME/OWNERSHIP CHANGE FOR,'VI Page 2 of 2 IV. Permit contact information: (if different from the person legally responsible for the permit) Permit contact: RUC K CN ( DUIS %~ First / Ml / Last DtK,cC TOE OF N. K, 4^1D S1rF.CTY Title 701 Sn 0W Ki 146 S7—kGC 7` Mailing Address f1yC7T d11_4c, nlC. aIJ4� city State Zip c 9r0 gy 3 - O y'79cke e U�1i00 ('yrrrJ 9a-tint . ('ors Phone F-mail Address V. Will the permitted facility continue to conduct the same industrial activities conducted prior to this ownership or name change? Yes ❑ No (please explain) VI. Required Items: THIS APPLICATION WILL BE RETURNED UNPROCESSED IF ITEMS ARE I N'COMPLETE OR MISSING: ❑ This completed application is required for both name change and/or ownership change requests. ❑ Legal documentation of the transfer of ownership (such as relevant pages of a contract deed, or a bill of sale) is required for an ownership change request. Articles of incorporation are not sufficient for an ownership change. The certifications below must be completed and signed by both the permit holder prior to the change, and the new applicant in the case of an ownership change request. For a name change request, the signed Applicant's Certification is sufficient. PERMITTEE CERTIFICATION (Permit holder prior to ownership change): I, , attest that this application for a name/ownership change has been reviewed and is accurate and complete to the best of my knowledge. I understand that if all required parts of this application are not completed and that if all required supporting information is not included, this application package will be returned as incomplete. Signature Dane APPLICANT CERTIFICATION: I, _ 7—Ane5—,A 23 i ER z*,Q iv t% _ , attest that this application for a name/ownership change has been reviewed and is accurate and complete to the best of my knowledge. I understand that if all required parts of this application are not completed and that if all required supporting information is not included, this application p aac will be returned as incomplete. A 9-3-oS) "7 Signature Datc PLEASE SEND THE COMPLETE APPLICATION PACKAGE TO: Division of Water Quality Surface Water Protection Section 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Revised 712005 of W A TFZ9 `Ot � 0 >_ y Mr. Mark Ingram Union Corrugating Company POB 229 Fayetteville, North Carolina 28302-0229 Dear Mr. Ingram: Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Coleen H. Sullins, Director Division of Water Quality Subject: Representative Outfall Status COC NCG030520 Union Corrugating Company Cumberland County The Division received your request for representative outfall status on October 15, 2007. Based on your request, and on confirming site visit from Mike Lawyer in DWQ`s Fayetteville Regional -Office, we are granting your request for representative outfall status for Outfall 001. Consequently, you will not have to provide analytical results from testing on the newly identified Outfall 002. Please note that you remain obligated to conduct qualitative monitoring (visual) for both outfalls. Please contact me with any comments or questions. Sincerely, �� ~ Ken Pickle DWQ Stormwater Permitting Unit (919)733-5083x584 ken.pickle(@ncmai1.net cc: Mike Lawyer, FRO DWQ Central Files SPU file NCG030520 NooehCarolina vatura!!y North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone (919) 733-7058 Customer Service Internet: www.ucwater uali .or Location: 512 N. Salisbury St. Raleigh, NC 27604 Fax (919) 733-9612 1-877-623-6748 An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper oF.WArF9 �b� QG _ J Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources November 1, 2007 Union Corrugating Company 701 S King St Fayetteville, NC 28301 Coleen H. Sullins, Director Division of Water Quality Subject: NPDES Stormwater Permit Coverage Renewal Union Corrugating Company COC Number NCG030520 Cumberland County Dear Permittee: In response to your renewal application for continued coverage under stormwater General Permit NGG030000 the Division of Water Quality (DWQ) is forwarding herewith the reissued stormwater General Permit. This permit is reissued pursuant to the requirements of North Carolina General Statute.143-215.1 and the Memorandum of Agreement between the state of North Carolina and the U.S. Environmental Protection Agency, dated December 6, 1983. The following information is included with your permit package: • A new Certificate of Coverage • A copy of stormwater General Permit NCG030000 • A copy of a Technical Bulletin for the General Permit • Five copies of the Discharge Monitoring Report (DMR) Form • Five copies of the Qualitative Monitoring Report Form The General Permit authorizes discharges of stormwater only, and it specifies your obligations with respect to stormwater discharge controls, management, monitoring, and record keeping. Please review the new permit to familiarize yourself with all the changes in the reissued permit. The more significant changes in the General Permit since your last Certificate of Coverage include the following: + Part I Section A — A new notation that the No Exposure Exclusion from permitting option may be available to the permittee. • Part I Section A — A new provision that facilities draining to 303(d) listed waters, or in watersheds with an approved TMDL, may not be eligible for renewed coverage under the General Permit. • Part II Section B Table 1 — An increased sampling frequency from once per year to twice per year. • Part ll Section B Table 3 — Benchmark concentrations now replace cutoff concentrations; the elimination of the option to avoid sampling based on cutoff concentrations. • Part II Section B — New provisions requiring the permittee to execute Tier One and Tier Two response actions, based on the first benchmark exceedence (Tier One) and the second consecutive benchmark exceedence (Tier Two). Tier Two requires that the permittee institute monthly monitoring instead of twice -per -year monitoring, until three consecutive monitoring events show no benchmark exceedences. + Part II Section B — A new provision that four exceedences of any particular benchmark will trigger increased DWQ involvement in the permittee's stormwater management and control actions. DWQ may direct the permittee to apply for an individual permit, or may direct the implementation or installation of specific stormwater control measures. DWQ received a number of comments on a series of general permits similar to this one. A full response to comments can be found at http:tlncwaterquality.org/suriindustrialgpinfo.htm. Some comments resulted in permit modifications, others are addressed in the response document or Fact Sheet. A few specific requests for clarification are addressed below. 1. What is the deadline for having a revised SPPP that reflects the provisions of the new General Permit? DWQ will require that the pemnittee have a revised, complete SPPP no later than six months after the date of issue of that permittee's new Certificate of Coverage. 2. Must analytical results be by a certified lab? What about pH measurements? All analytical results obtained to satisfy NPDES permit requirements must be certified, as directed in North Carolina regulations at 15A NCAC 2H .0800, and as administered by DWQ's Laboratory Section Certification Branch. This includes field pH measurements. Ow NorthCarolina Alatitrally North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone (919) 733-7015 Customer Service Internet h2o.enr.state.nc.uslsulstormwater.html 512 N. Salisbury St. Raleigh, NC 27604 FAX (919) 733-9612 1-877-623-6748 An Equal Opportunity/Affirmative Action Employer — 50% Recycledll0% Post Consumer Paper 1W STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY GENERAL PERMIT NO. NCG030000 CERTIFICATE OF COVERAGE No. NCG030520 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, Union Corrugating Company is hereby authorized to discharge stormwater from a facility located at Union Corrugating Company 701 S King St Fayetteville Cumberland County to receiving waters designated as CAPE FEAR RIVER, a Class C water in the Cape Fear River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, 11, III, IV, V, and VI of General Permit No. NCG030000 as attached. This certificate of coverage shall become effective November 1, 2007. This Certificate of Coverage shall remain in effect for the duration of the General Permit. Signed this day November 1, 2007. for Coleen H. Sullins, Director Division of Water Quality By Authority of the Environmental Management Commission C; ryryCO t . . 1 CD �< oe K.ogpo s. Michael F. Easley. Governor William G. Ross Jr., Secretary Nonh Carolina Depanment of Environment and Natural Resources Alan W. Klimek. P.E. Director Division of water Quality SURFACE WATER PROTECTION SECTION PERMIT NAME/OWNERSHIP CHANGE FORM 1. Please enter the permit number for which the change is requested. NPDES Pert -nit (or) Certificate of Coverage N I C N I C C, 3 10 15 2• l� 11. Permit status prier to status change. a. Pen -nit issued to (company name): r(� NiGid w`iR�%frf1�l11r� b. Person legally responsible for permit: PVV U l5 r irst I MI /1 Last enexal M 70I;1�t11Y Pe nit Holder Mailing Addresstx�t eit+e� k NC, DE - --j City State ;Gip Phone f�`` Fax c. Facility name (discharge): u lb-i L.f► T1A5 lU! pah)y d. Facility address: wl SA Iqj �tl Address S/ ! City State lip e. Facility contact person: VJU, ❑9G1 ( 10) q6 04 1 Firs[ I M1 / Last Phone Ill. Please provide the following for the requested change (revised permit). a. Request for change is a result of: ❑ Change in ownership of the facility Narne. change of t facility or owner If ocher please e-> plain:(�ft6&5 ON&A, - b. Permit isstted to (company name): 61cloi Mfg/4 1i c. Person legally responsible for permit: Jiti ieo" First I MI ! Last �ra�NT U Title Permit Holder Address Cailing City State ( �r0) �83 og79 Zip d. Facility name (discharge): Phone E-mail A ess V% l f�ilFT Y e. Facility address: 701 5 '�. la Address 111 City ], 5[atc Zipf. Facility contact person: q> 1 a M Fi t / M] ! Last { 9to) qg3- rj 72 <Zg7 MM0fAM aVIIAMCOM Phone j E-mail Addrgs. (. -Q)". Revised 712005 PERMIT NAME/OWNERSHIP CHANGE FORM Page 2 of 2 IV. Permit contact information: (if different from the person legally responsible for the permit) Permit contact: Title 11 h4ailin Address t � vl JnVIC k1 City State Zip c M3- �h7q . Z�� m1MMM 116 oftyaIr t,� � Phone E-mail.A dress V. Will the permitted facility continue to conduct the same industrial activities conducted prior to this ownership or name change? Yes © No (please explain) \'l. Required items: THIS APPLICATION WILL BE RETURNED UNPROCESSED IF ITEMS ARE INCOMPLETE OR MISSING: ❑ This completed application is required for both name change and/or ownership change requests. ❑ Legal documentation of the transfer of ownership (such as relevant pages of a contract deed, or a bill of sale) is required for an ownership change request. Articles of incorporation are not sufficient for an ownership change. The certifications below- must be completed and signed by A2± the permit holder prior to the change, and the new applicant in the case of an ownership change request. For a name change request, the signed Applicant's Certification is sufficient. PERMITTEE CERTIFICATION (Permit holder prio,-lo ownership change): 1. f 4v�'N A,-lifv.�✓ &-*—J , attest that this application for a name/ownership change has been reviewed and is accurate and complete to the best of my knowledge. I understand that if all required parts of this application are not completed and that if all required supporting information is not included, this application package will be returne as incomplete. �-7 Signature Date APPLICANT CERTIFICATION: 1, D'eim65 attest that this application for a name/ownership change has been reviewed and is accurate and complete to the best of my knowledge. I understand that if all required parts of this application are not completed and that if all required supporting infonnation is not included, this application pa age will be returned as incomplete. Signature PLEASE SEND THE COMPLETE APPLICATION PACKAGE TO: Division of Water Quality Surface Water Protection Section 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Revised 7/2005 Union Corrugating P.O. Box 229, Fayetteville, i�C 28302-0229 Phone (910) 483-0479. Ext. 247 Fax (910) 486-861 5 October 10, 2007 Mr. Ken Pickle NC Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 CERTIFIED MAIL 7006 0100 0004 1735 7027 RETURN RECEIPT REQUESTED Mr. Pickle: As communicated on 10/09/2007 via email to you, Union Corrugating Company ( "UCC"} is reporting a 2"1 stormwater outfall on its site at 701 South King Street in Fayetteville, UCC will immediately update its SPPP and all monitoring and sampling applications as currently applied to the current Outfall #1 as outlined in our Certificate of Coverage NCG030520. Maps are being constructed in AutoCad and will reflect the added Outfall. UCC is requesting that representative outfall status be applied at our site and designated at Outfal1 001. Regarding qualifications at Outfal1 002: There are no dryers, ovens, tenter frames, kilns, paint booths, furnaces, or plating baths on the site. There are no roof vents, The plant is not air conditioned — thus there are no roof drains. The only "opening" to the rear of the building is an exit for trucks. Regarding debris and oil, there are no processes in the plant that generate that material. We have only 1 chemical in the plant and it is sprayed in a mist form onto metal panels that are produced, wrapped, and shipped on a covered trailer. Regarding basic sweeping, there is a compactor out in the "front" of that portion of the building where the trash cans are dumped. Mr. Lawyer viewed this entire area during his visit to our site on October 5, 2007. Regarding "reason to believe that the pollutant constituents, and total pollutant load, and the potential exposure" , the Outfall 001 is at the end of the only piped storm water line that has catch basins fed from all roof drains and the entire north and south parking lots. Finally, regarding Total Toxic Organics, Union Corrugating Company does not perform any metal finishing operations as defined by 40 CFR 433.10, nor manufacture semiconductors, electronic crystals, nor cathode ray tubes. Please let me know what additional steps must be taken to process our request for the representative outfall status. Thank you. Sincerely, Mark Ingram Corporate Maintenance Manager niktinLIrain0ao l.com Attachment: 2 pages with photos cc: :Mike Lawyer, NCDWQ Fayetteville Office <via email> Mr. Jim Biermann, President, Union Corrugating Company Re: Second Outfall t Subject: Re: Second Outfall From: Ken Pickle <ken.pickle@ncmail.net> Date: Tue, 09 Oct 2007 14:17:17 -0400 To: Mark Ingram <MIngram@unioneorrugating.com> CC: iiiike.lawyer@ncniall.net ncniail.net Hi Mark, I've reviewed the photos and the site layout sketch. Here's how I see your next steps. I've included a little backtracking on the material we covered together last more just uo keep us together. a) While your coverage under General Permit NCGO3000C via Certificate of Coverage NCG030520 has officially expired, your renewal request was timely, and the only delay so far, has been at my end in DWQ. Please continue to abide by the provisions of your expired General Permit (a copy is available on our website), until we issue yo;-- a n %, Certificate of Coverage (1 expect nit 1111107.) b) DWQ believes that where industrial sites can achieve no exposure to stormwater, that is by far the most environmentally protective approach for the health of North Carolina's waters. Where that has not been achieved, we provide for stormwater discharge permit coverage (which was in effect for Union Corrugating via Certificate of Coverage NCG030520), and which constitutes the bulk of our administrative work here in the Stormwater Permitting Unit of DWQ. Since you are not currently eligible for the no exposure exclusion, your path forward, is thorough continued permit coverage. If, in the future, it makes sense for you to achieve no exposure conditions, we can certainly rescind your permit, and provide you with the No Exposure Exclusion from permitting. c) With regard to the discovery of a second stormwater outfall you have two obligations under your permit. First is to amend your Stormwater Pollution Prevention Plan (SPPP) to reflect the location of the outfall -- I've not seen your SPPP, but you certainly need to at least update the site map that shows all the ourfalls. The SPPP is a required part of permit compliance, but just as significantly for you, it is intended to be the key management tool enabling you to be aware of , and to actively manage, the stormwater issues on your site. The second obligation imposed by your permit is the annual sampling of the second outfall, along with the sampling of your first outfall, which I presume you were already aware of. d) Now, as to the obligation to sample the second outfall. I'm sure Mike relayed to you that you can petition us in the Stormwater Permitting Unit for "representative outfall status" for outfall 001, your current monitoring point as per the sketch. If we grant representative outfall status for 001, then your obligation to sample the newly discovered outfall (let's call it 002) is waived, and consequently your monitoring costs are roughly cut in half. Your request to us should provide us a reason to believe that the pollutant constituents, and total pollutnat load, and the potential for exposure in 002 is accurately reflected already if you sample just 001. Typically we will accept an argument based on historical samples (probably not your case), or based on your report that the industrial activities and the potential exposure to stormwater in the drainage area of 002 are similar to, or perhaps less significant than, those activities and potential exposures in the drainage area to 001. From your sketch, it appears that 002 receives runoff from a grassed area, and the roof of a portion of the manufacturing facility. It generally appears that representative outfall status is justified in your case. However, from this distance, I would offer the following qualifications: Do you have dryers, or ovens, or tenter frames, or kilns, or paint booths, or furnaces, or plating baths, etc. with stacks that penetrate the portion of the roof that drains to 002? If so, then there may be pollutant condensation or deposition on the roof that drains to 002. You know your process, and I don't. But, if those things are present in the drainage area of 002, but not present to as great an extent in the drainage area of 001, then we don't have a basis for saying that the two drainage areas are sufficiently similar in potential exposure to grant representat-ve outfall status. 1 of 2 10/19/2007 9:26 Ah1 Re: Second Outfill We will also rely on Mike's input in this decision, since he has been to your facility, and seen the conditions there. Another qualification: It appears that maybe the long eastern wall of the building is the "back" wall. Do you have condensate lines other discharges out the back wall? Does your SOP include sweeping cuttings and oil and debris out the back door into the grassed area draining to 002? Etc. My point is that we still have to have your assertion that the two drainage areas are similar in industrial activity, exposure of materials, and potential for pollution, in order to grant representative outfall status. we do it all the time, so I'm not trying to dissuade you from it, I just want you to understand how we look at it. e) And finally, the new provisions of NCG030000 are in development right now, today. As I reported to you in September, a draft is posted on our website. There have been changes to the old NCG030000, and there will be changes to the posted draft, but the posted draft is pretty close to the final product that we should have nit 11/1/07. I urge you to review the draft to see what your new obligations will be under NCG03. Briefly, the significant requirements of the new•NCG03 are: - t:,;ice pef year sampli. g for Pb, pH, O&G, TSS, and Total Toxic Organics - expensive testing for Total Toxic Organics, or development of a Solvent Management Plan, for certain subcategories in NCG03 - development of a SPPP, including the 9 elements listed in the permit - accelerated testing requirements (monthly instead of semiannually) in the event that a benchmark value is exceeded two consecutive times for the same parameter. - at this point in development of the new permit, it's likely that we will identify the first sampling period as January - June 2008. Ken Mark Ingram wrote: Ken: Mike Lawyer from the Fayetteville NCDWQ office came out here at my request <your advice> last Friday to look over our permit, program, and site. We were hoping maybe for a full exemption but some outside containers of scrap will result in that not an option. We reviewed sampling forms and talked about the impending permit and language. On our tour around the back of the building i showed him a 2nd out -Fall. I don't know why it is not list on a sketch or itemized. It collects rainfall from part of the roof and a grassed area. I've imported the pictures into a Powerpoint file so I could explain them. I want to make sure that Union Corrugating is fully disclosing of its operation and that there are no issues. Mike Lawyer said something about sampling from just one coins if we had it titled as a representative point <I forgot the exact terminology>. He recommended I contact you first. I've copied him just for clarification. Can you give me some instructions on what to do regarding any modifications and then going forward? Thanks, Mark Ingram Corporate Maintenance Manager Union Corrugating Company (910) 483-0479, ext. 247 nf' 10/19/2007 9:26 ANI r ti 17 i< STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT r AND NATURAL RESOURCES DIVISION OF WATER QUALITY FAX (919) 733-9612 ;Facsimile transmittal _ To: Mark Ingram, Union Corrugating Co. Fax: (910) 486-8615 From: Ken Pickle, Stormwater Permitting Unit, Date: September 26, 2007 Division of Water Quality Phone: (919) 733-5083 ext. 584 Pages: 3 E-mail: Ken. pickle@ncmail.net Urgent For review Please comment Per your request FYI, no action Please recycle Subject: Duplicate Certificate of Coverage for NCG030520 Dear Mr. Ingram, Please find attached duplicates of our January 16, 2004, transmittal letter and your Certificate of Coverage for the Fayetteville facility. In answer to your questions by email today, Yes, your Certificate of Coverage, NCG030520, is evidence that you have been granted coverage under the stormwater General Permit NCG030000. Please note that Cumberland County does not have any regulatory jurisdiction with respect to this permit. While I expect that the folks there are knowledgeable about stormwater, and that your visit with them will be beneficial, only DWQ can provide you authoritative interpretation of your coverage under our NPDES program. Again, you might want to also talk with Mike Lawyer in DWQ's Fayetteville Regional Office. Please contact me with any other questions. Ken Pickle DWQ Stormwater Permitting Unit (919) 733-5983 State of North Carolina Department of Environment and Natural Resources Division of Water Quality Michael F. Easley, Governor William G. Ross Jr., Secretary Alan W. Klimek, Director January t0.2004 Mr. Steve Saunders Union Corrugating Company 701 South King Street Fayetteville. North Carolina 28301 Subject: General Permit No. NCG030000 Union Corrugating Company COC NCG030520 Cumberland County Dear Mr, Saunders: In accordance with your application for discharge permit received on December 29, 2003, we are forwarding herewith the subject certificate of coverage to discharge under the subject state - NPDES. general permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215. t and the Memorandum of Agreement between North Carolina and the US Environmental Protection agency dated May 9, 1994 (or as subsequently amended). If any parts, measurement frequencies, or sampling requirements contained in this permit are unacceptable to you, you have the right to request an individual permit 'by submitting an individual permit application. Unless such demand is made, this certificate of coverage shall be final and binding - Please take notice that this certificate of coverage is not transferable except after notice to the Division of Water Quality. The Division of Water Quality may require modification or revocation and reissuance of the certificate of coverage. This permit -does not affect the legal requirements to obtain other permits which may be required by the Division of Water Quality or permits required by the Division of Land Resources, Coastal Area Management Act, or any other Federal or Local governmental permit that may be required. If you have any questions concerning this permit, please contact Ken Pickle at telephone number (919) 733-5083 ext. 584. srncerel ORIGIl AL SIGNED BY WILLIAM C. MILLS Alan W. Klimek. P. E, cc: Fayetteville Regional Office Central Files Slormwater and General Permits Unit ] files 5WU-25,).n1 HX11 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone 919-733.5083 FAX 919-733-9919 An Equal Opportunity Atlirmative Action Employer 50% recycled/ 10% post -consumer paper STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY GENERAL PERMIT NO. NCG030000 CERTIFICA`I`E OF COVERAGE No. NCG030520 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, Union Corrugating Company is hereby authorized to discharge stormwater from a facility located at Union Corrugating Company 701 South King Street Fayetteville. North Carolina Cumberland County to receiving waters designated as Cape Fear River, a class C water in the Cape Fear River Basin in accordance with the effluent limitations, monitoring*requirements, and other conditions set forth in Parts I, 1I,111, IV. V, and VI of General Permit No. NCG030000 as attached. This certificate of coverage shall become effective January 16, 2004. This Certificate of Coverage shall remain in effect for the duration of the General Permit. Signed this day JanuarV 16. 2004. ORIGINAL SIGNED BY VlLVAMl C. MILLS Alan W. Klimek, Director Division of Witter Quality By Authority of the Environmental Managcment Commission RE: Union Corrugating Company , Subject: RE: Union Corrugating Company From: "Mark Ingram" <M1ngram@umoncorrugating.com> Date: Wed, 26 Sep 2007 08:41:12 -0400 To: "Ken Pickle" <ken.pickle@ncmail.net> Thank you very much for the information. You can fax the Certificate of Coverage to my attention at 910-486-8615. Is the Certificate of Coverage just my specific application(s) of the General Permit NCG030000? Seems our last EHS guy had a consultant doing all of the monitoring and I actually did that in the past for Black & Decker, so I'm trying to drill down to all of the answers. I know very well the County Stormwater Manager Greg Caison and thought I might swing by and see him - taking my permit and what you fax to me. Thanks again, Mark Ingram Corporate Maintenance Manager Union Corrugating Company - - Original Message ----- From: Ken Pickle [mailto:ken.pickle@ncmail.net] Sent: Wednesday, September 26, 2007 7:46 AM To: Mark Ingram Subject: Re: Union Corrugating Company Mark, I apologize for the delay. I see from my telephone log that we exchanged telephone voice messages on September 6, but I don't have notes on a subsequent conversation. Can you refresh me on our conversation? a) I can send you a copy of your expired Certificate of Coverage, NCG030520, if that is what we spoke about. If so, please send me a fax number so that I can send that to you. b) As to updates on the public comment version of the draft permits, the public comment period closed September 14. In the next two weeks we will be reviewing comments, and amending the draft General Permit NCG030000 to incorporate selected comments. Right now I anticipate that a new General Permit will be issued nit October 19, 2007, maybe sooner. c) Our database shows that Union Corrugating has already applied for renewal of coverage under the General Permit, and we will begin processing the renewals (including yours) in the second half of October. At that time you will receive your new COC, NCG030520. d) I'm not aware of any DWQ or NCSU training for implementation of a site's Stormwater Pollution Prevention Plan. I know that frequently when consultants are the authors of a SPPP that they will train the client's staff in the implementation of the SPPP. Alternatively, you might contact DWQ's Fayetteville Regional Office at (910) 433-3300 and request that DWQ staff inspect your facility for compliance with the conditions of the permit. That is training of a sort, and would alert you to the specific intent of the permit and your obligations under it. Of course, the new permit to be issued in October will have some 1 of 2 9/26/2007 2:50 PM RE: Union Corrugating Company differences, so it might be better to wait until we have finally published the revised permit. Ken Mark Ingram wrote: Ken: We talked last week about general permits for Union Corrugating Company. I downloaded a draft of the proposed permit and the current one. I think you said we had some specific certificate or something you were going to email to me? I haven't received anything yet. Any updates on this information you can provide me would be helpful. Also, any minor training classes for our type of user coming up? I checked NC State's site and haven't found anything. Thanks, Mark Ingram Corporate Maintenance Manager Union Corrugating Company (910) 483-0479, ext. 247 2 of 2 9/26/2007 2:50 PM State of North Carolina Department of Environment and Natural Resources Division of Water Quality Michael F. Easley, Governor William G. Ross Jr., Secretary Alan W. Klimek, Director Janrtary 16.20(K Mr. Steve Saunders Union Corrugating (.'0111p-any 701 South King Strect Fayelteville. North Carolina 1-8301 Subject: General Permit No. NCG030000 Union Corrugating Company COC NCG030520 Cumberland County Dear Mr- Saunders: In accordance with your application for discharge permit received on December 29, 2003, we are forwarding herewith the subject certificate of coverage to discharge under the subject state - NPDES general permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the US Environmental Protection aclency dated May 9, 1994 (or as subsequently amended). if any parts, measurement frequencies, or sampling requirements contained in this permit are unacceptable to you, you have the right to request an individual permit"by submitting an individual permit application. Unless such demand is made, this certificate of coverage shall be [inai and binding. Please take notice that this certificate of coverage is not transferable except after notice to the Division of Water Quality. The Division of Water Quality may require modification or revocation and reissuance of the certificate of coverage. This permit does not affect the legal requirements to obtain other permits which may be required by the Division of Water Quality or permits required by the Division of Land Resources. Coastal Area Management Act, or any other Federal or Local governmental permit that may be requircd. If you have any questions concerning this permit, please contact Ken Pickle at telephone number (919) 733-5083 ext. 584. SiORINAL SIGNED BY WILLIAM C. MILLS Alan W. Klimek- P. E. cc: Fayetteville Regional Office Central Files Storrnwater and General Permits Unit Files SWO-259.01 1e01 1617 Mail Service Center, Raleigh, Forth Carolina 27699-1617 Telephone 919-733-5083 FAX 919-733-9919 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% past-consurner paper fat , AN 4 SO` i!. ILI SEA 3 it is r All C A P-s r , v A 14 owl 1 Lug j '4L P',M 0. _v- din If( 018�� 'T il, L > not! too I, r-fMR-1. T9 (R ,71Y. -A TO RIF A "�j ed AU h&Z" __ Au qk,, xq;w !j l> INS, "MMO, W; Y 1j" JP b �Ak N. A ty, Y" x J d A rgeSite-F-NCG0305Z,4 "N i owl' is Jowl. A. j JO 5 NX lu a '-7 C7� 2, PL i 04 p sonIV vv N, Copyright (C) 1997. Maplech, Inc. 0 • aj A�� Fayetteville RESULTS Month Year REMENT Copper Lead Zinc pH Oil/Grease Total Suspended Solids HEM .0071mg/L 0.03mg/L 0.067mglL 6.0 - 9.0 15mglL 100mg1L or 50 mglL4 October 2014 0.023 0.0071 0.23 nla 1.55 November 2014 fVO` e ..n _ FLQW `, '' N_okFlow : . December 2014 0.01 0.006 0.234 7 1.2 13.8 January 2015 i ZNO r ;FLOW e 4 No Flow Februa 2015 0.033 0.445 0.033 6.6 <5.00 84 March 2015 April 2015 0.008 <0.0015 0.227 5.8 <5.00 33.4 May 2016 0.006 <0.00150 0.104 7.2 11.6 9.5 June 2015 0.019 <0.00300 0.174 6.8 <5.00 35.4 June Front Bldg 2015 0.249 r une North Bldg 2015 0.06 June Back Bldg 2015 0.25 July 2015 August 2015 September 2015 October 2015 November 2015 December 2015 • 150 pl. DWsAW Fuel 250 9;W, K&WAM 500 QRL Kwosom 250 gal. Kerosene BAY-2 COIL STORAGE SPW KA OLnT-Akt TO CREEK BAY-1 D MAINT. ' N-f:�7 0.1 4 LOADING AND METAL FORMING SHOP ccS FtEaEVNG AREA 9- A-z-54- (2) 55 gal. Drums Dilmar 141 Solvers' . . .......... A (4) 55 ga Drums Takta 46 Hydr. ON OFFICE MAIN OFFICE SHOP PARKM LOT) STORAGE PARKING LOT CVJ .......... ....... ............. :.D.I. ..... ..... ..... . ..... ............. ........ . ................. ENTRYi IDJ. ass ENTRY2 State of North Carolina ����_��� ` � o Department of Environment and Natural Resources FEB 2 4 2005 Division of Water Quality r Michael F. Easley, Governor 0 NCDENR William G. Ross Jr., Secretary NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES Alan W. Klimek, Director January 16.2004 Mr. Steve Saunders Union Corrugating Company 701 South King Strect Fayetteville, North Carolina 28 301 Subject: General Permit No. NCG030000 Union Corrugating Company COC NCG030520 Cumberland County Dear Mr. Saunders: In accordance with your application for discharge permit received on December 29, 2003, we are forwarding herewith the subject certificate of coverage to discharge under the subject state - NPDES general permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the US Environmental Protection agency dated May 9, 1994 (or as subsequently amended). If any parts, measurement frequencies, or sampling requirements contained in this permit are unacceptable to you, you have the right to request an individual permit 'by submitting an individual permit application. Unless such demand is made, this certificate of coverage shall be final and binding. Please take notice that this certificate of coverage is not transferable except after notice to the Division of Water Quality. The Division of Water Quality may require modification or revocation and reissuance of the certificate of coverage. This permit does not affect the legal requirements to obtain other permits which may be required by the Division of Water Quality or permits required by the Division of Land Resources, Coastal Area Management Act, or any other Federal or Local governmental permit that may be required. If you have any questions conceming this permit, please contact Ken Pickle at telephone number (919) 733-5083 ext. 584, StORINAL SIGNED BY WILLIAM G. MILLS Alan W. Klimek, P. E. cc: Fayetteville Regional Office Central Files Stormwater and General Permits Unit Files S W U-?39-01 1001 1617 Mail Service Center, Raleigh, Forth Carolina 27699-1617 Telephone 919-733-5053 FAX 919-733-9919 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper Qa n -M-T- i 1, F.al f f �t30 , 10, :-Ji - ((;;pt,j, CO L M!y 4b, 0 10-0-1 87 ol • - 4 At 1•.4 i'l 4y A41 Wwr ivt cerl ilk; IV ......... It, IiN�— ��ot' 1A jj qW. io,3004u �V, 'fj IN, ps il a at To} , N Vll zv ev n:, N 8' W Copynclht (C) 1997. Maptech, Inc. State of North Carolina Department of Environment and Natural Resources Division of Water Quality Michael F. Easley, Governor William G. Ross Jr., Secretary Alan W. Klimek, Director \Ir. Ste vc Saunders Union Corrugating Company 701 South King Street Fayetteville. North Carolina 28301 Dear Mr, Saunders: i f •? .� � -fir. t,;x Nd i 2 � s: DEPARTMENT OF NoRTH ENVIRO- Subject: General Permit No. NCG030000 Union Corrugating Company COC NCG030520 Cumberland County In accordance with your application for discharge permit received on December 29, 2003, we are forwarding herewith the subject certificate of coverage to discharge under the subject state - NPDES general permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the US Environmental Protection agency dated May 9, 1994 (or as subsequently amended). If any parts, measurement frequencies, or sampling requirements contained in this permit are unacceptable to you, you have the right to request an individual permit by submitting in individual permit application. Unless such demand is made, this certificate of coverage shall be final and binding. Please take notice that this certificate of coverage is not transferable except after notice to the Division of Water Quality. The Division of Water Quality may require Modification or revocation and reissuance of the certificate of coverage. This permit does not affect the legal requirements to obtain other permits which may be required by the Division of Water Quality or permits required by the Division of land Resources. Coastal Area Management Act, or any other Federal or Local goveraintental permit that may be required. If you have any questions concerning this permit, please contact Ken Pickle at telephone number (919) 733-5083 ext. 584. Sincerely, ORIGINAL SIGNED BY WILLIAM C. MILLS Alan W. Klimek. P. E. cc: Fayetteville Regional Office Central Files Siorrinvater and General Permits Unit Files S tirU-2i4�p1 IfHll 1617 Nail Service Center. Raleigh, North Carolina 27699-1617 Telephone 919-733-5083 FAX 919-733-9919 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper ism too 9_J Y V ALM v NO R jw,� C;c ek-., ag�,;tv 3- %� I Z, L off -two, J "'e, ;W',Vk 7W, �r jggq *2 1 F-7 A "A rip. Af.; -e-tt ROW` I _tt_ ': - �71 "PH Zf 0 4 0 We 14 1. cif �f _o7 Wh it *7f%� pn7_ ,G ..... n-t .-;:;f V; -j A . 1*= K, T 4 -1a AJr J; Si ':F Sit NCG03D,5Z n Mw wo, c ht AL- N- f 7'. 'CR. f 1 ui s IN , 7� . :R 1 1. Rioul )!opt 1, 7A: CS' I" IVIO . k;4 k %A IN Copyright (C) 199t MaOIL-Ch, InC