NCG050148_COMPLETE FILE - HISTORICAL_20180615

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
Iv CC, C)5D I��
DOC TYPE
0"FIISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE
❑ c) 0 olll S
YYYYMMDD

Division of Energy, Mineral! & Land Resources
Land Quality Section/Stormwater Permitting Program
National Pollutant Discharge Elimination System
Environmental
Quality RESCISSION REQUEST FORM
FOR AGENCY USE ONLY
Date Received
Year
Month
Da
EOFIVED
A15ur
Please fill out and return this form if you no longer need to maintain your NPDES stormwater permit.
DENR-LAND QUALITY
STORMWATER PERMITTING
2} Enter the perrrtit number to which this request applies:
Individual Permit (orJ Certificate of Coverage
N I C 's 1 1 1 TTTI N C G C 5 0 1 4 8
2) Owner/Facility information: * Final correspondence will be mailed to the address noted below
Owner/Facility Name Edwards Brothers Malloy
Facility Contact Robie Mills
Street Address 900 Edwards Brothers DR
City
County
Telephone No.
Ullington State NC
Harnett E-mail Address
910 263-1355
Fax:
ZiP Code 27546
[e-mail]
3) Reason for rescission request (This is required information. Attach separate sheet if necessary):
0 Facility closed or is closing on 6/15/18 . All industrial activities have ceased such that no discharges of
stormwater are contaminated by exposure to industrial activities or materials.
❑ Facility sold to on . if the facility will continue operations under the new owner it
may be more appropriate to request an ownership change to reissue to permit to the new owner.
❑ Other:
4) Certification:
I, as an authorized representative, hereby request rescission of coverage under the NPDES Stormwater Permit,for the
subject facility. I am familiar with the information contained in this request and to the best of my knowledge and belief
such informatlon is true, complete and accurate.
Signature
/xv. -
Print or type name of person signing above
Please return this completed rescission request form to:
Revised 2018Jan1O
Date •�1 r�C���j _ r
Title
DEMLR - Stormwater Program
Dept. of Environmental Quality
1612 Mail Service Center
Raleigh, North Carolina 27699-1612

x� !

Division of Energy, Mineral & Land Resources
Land Quality SectionlStormwater Permitting Program
K. National Pollutant Discharge Elimination System
Environmental
Quality RESCISSION REQUEST FORM
FOR AGENCY USE ONLY
Date Received
Year
Month
Day
r2f
Please fill out and return this form if you no longer need to maintain your NPDES stormwater permit.
1) Enter the permit number to which this request applies: Ciehft,LAND OUALITY
Individual Permit (or) Certificate of CoveraMRMWAT - Rivll'fNNG
N I c I S I I I I I I I I N I C I G 0 5 0 1 14 9
2) Owner/Facility Information: * Final correspondence will be moiled to the address noted below
Owner/Facility Name Edwards Brothers Incorporated
Facility Contact
Street Address
City
County
Telephone No.
Robie Mills
900 Edwards Brothers Drive
Lillington
Harnett
910 263-1355
State NC ZIP Code 27546
E-mail Address
Fax:
3) Reason for rescission request (This is required information. Attach separate sheet if necessary):
❑✓ Facility closed or is closing on 6/15/18 . All industrial activities have ceased such that no discharges of
stormwater are contaminated by exposure to industrial activities or materials.
❑ Facility sold to
on . If the facility will continue operations under the new owner it
may be more appropriate to request an ownership change to reissue to permit to the new owner.
❑ Other:
4) Certification:
1, as an authorized representative, hereby request rescission of coverage under the NPDES Stormwater Permit for the
subject facility. I am familiar with the information contained in this request and to the best of my knowledge and belief
such information is�tfue, complete and accurate.
Signature
Robie Mills
Print or type name of person signing above
Please return this completed rescission request form to:
Date 1/11/2019
Maintenance Manager
Title
DEMLR - Stormwater Program
Dept. of Environmental Quality
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
Revised 2018Jan10

F
c'es fin. l IlM1�� �jv�f1 M
0-03
�C�

Lawyer, Mike
From: Lawyer, Mike
Sent: Friday, January 11, 2019 10:49 AM
To: [e-mail]'
Subject: stormwater permitting
Attachments: NPDES-Permit Rescission Form-20180110-DEMLR-SW.pdf
C- /0 WJ � drSSa�V�q
Ro bie,
Thanks for calling me back today and explaining the situation with the Edwards Brothers Company. As discussed, I have
attached a copy of the Rescission Request Form to get the permit coverage for Edwards Brothers rescinded. The
Certificate of Coverage for Edwards Brothers is NCG050148. I have also provided a link below about the industrial
stormwater program for the new companies that are planning to move in.
https:lldeg.nc.goylaboutldivisionslenergy-mineral-land-resourceslnpdes-industrial-stormwater
If there are any questions, please contact me.
Thanks,
Mike
Michael Lawyer, CPSWQ
Environmental Program Consultant
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
910 433-3394 office
mike. lawyer(dncdenr.gov
225 Green Street, Suite 714
Fayetteville, NC 28301
Nothing Compares_
K--`C--
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

Energy,:Mlneral &
Land Resources
ENVIRONMENTAL QUALITY
June 12, 2018
Edwards Brothers Inc
Attn: Jim Kinner
2500 S State St
Ann Arbor, MI 48106
ROY COOPER
Governor
MICHAEL S. R£GAN
secretary
WILLIAM E. (TOBY) VINSON, JR.,
lnterlm'Dirwror
Subject: NPDES Stormwater Permit Coverage Renewal COC #NCG050148
Dear Permittee:
For coverage'under Stormwater General Permit NCG050000, the Division of Energy, Mineral,
and Land Resources (DEMLR) is notifying you that your reissued Certificate of Coverage
(COC) is available. 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.)
You must access and print a copy of your new Certificate of Coverage (COC) via this website:
httt)s://edocs.deq.nc.gov/Fonns/SW,-COC-Renewal
Also, you must obtain a copy of the new NCG050000 General Permit from our website here:
htips:Hdeq;nc.ov/about/division'-s/ener-mine'ral-land-res6ufces/nodes=storm�vater!-gpLs. In
addition to the full permit, the 2018 print package on the website includes revised monitoring
forms.
The General Permit authorizes discharges of stormwater, and it specifies your obligations with
respect to discharge controls, management, monitoring, and record keeping. Please review the
new permit to familiarize yourself with all changes in the reissued permit. Significant changes
to the General Permit are outlined in documents available on the website above. Your
facility has six months from receipt of the permit to update your Stormwater Pollution
Prevention Plan (SPPP) to reflect any new permit requirements.
State of North Carolina I Environmental Quality G Energy, Mineral and Land Resources
512 N. Salisbury Street 1 1612 Mail Service Center f Raleigh, North Carolina 27699-1612
919 707 9200

How does the new General Permit affect Tier Status?
If vehicle maintenance activities (VMA) at your site trigger analytical monitoring, the first
sample period of your permit began on June 1, 2018. Tier 3 actions in Part IV of your permit
are triggered by benchmark' exceedances on four occasions beginning on the effective date of
this permit and do not countprior exceedances. Likewise; Tier 2 actions are triggered by two
consecutive benchmark exceedances beginning,on the effective date of this permit and do not
count prior exceedances. However, if your facility is' already in Tier 2 (monitoring stormwater
discharges monthly) or Tier 3, you must continue monthly.monitoring until relieved through
conditions of the permit or'by DEMLR staff approval.
When does electronic, DMR reporting start?
We recognize that many permittees under this permit do.not have activities that trigger analytical
monitoring. However, for those that do, note that permittees will receive notification when
our eDMR system is ready for registration to begin reporting monitoring data
electronically. We are setting up our database with final parameters and the outfalls that
permittees submitted on-line. If you have any questions about the status; please contact Bethany
Georgoulias at [phone].
Your coverage under the General Permit is transferable only through the specific action of
DEMLR. This permitdoes not affect the legal.requirements to.obtain.other permits which may
be required by the N.C. Department of Environmental Quality (DEQ),-nor does it relieve the
permittee from responsibility for compliance with any other applicable federal, state, or local
law, rule, standard, ordinance, order, judgment, or decree.
If you have any questions regarding this permit package please contact. the DEMLR Stormwater
Program at [phone].
Sincerely,
aW/Lare, j4atay
for William E. (Toby) Vinson, Jr., P.E., CPM
Interim Director, Division of Energy, Mineral and Land Resources
cc., S torm water: Program files
Slate of North Carolina I Environmental Quality I Energy; Mineral and hand Resources
512 N. Salisbury Street 1 1612 Mail Service Center I. Ralelgh, North Carolina 27699.1612
919 707 9200

Energy, Mineral.&
.Land Resaurees
ENVIRONMENTAL QUALITY
March 26, 2018
Jim Kinner
Edwards Brothers Inc
2500 S State St
Ann Arbor, MI 48106
ROY'COOPER
Ctiwernar'
MICHAEL S. REGAN
Secretary
WILKIAM E. (TOBY). VINSON, JR.
--;.int'rlrrrOieeetor
Subject: NPDES General Permit Renewal and Electronic Reporting Requirements
Edwards Brothers Incorporated
NPDES Permit Certificate of'Coverage (COC) Number: NCG050148
Dear NPDES Permittee:
The General Permit this facility is covered under expires on May 31, 2018. Our records indicate that
your annual fees are up to date; therefore, your coverage will be automatically renewed unless youm submit a rescission request for this permit. If you no longer need this permit, a rescission forcan be
found on our website: httlps://deg._nc'aov/about/divisions/energy-mineralziand-resources/npdes-
iridustrial-stormwater.
The Stormwater Program will post the draft General Permit for public.comment on our website above in
mid -April. The public comment period will conclude in mid -May, and the new General Permit is
scheduled to become effective on lune.1, 2018. Upon issuance of the final General Permit, you will be
sent instructions about obtaining your new Certificate of Coverage (COC).
Although renewed coverage -will be 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 April 30, 2018,
(2) You must submit stormwater outfall information on-line no later than May 18, 2018 in
preparation for electronic data monitoring report (eDMR) requirements.
Permit Contact Information
Please review the permit contact information we have in our database. You can do this via a link in the
Manage Information for an Existing Permit section of our website above. Ensure that Owner
Affiliation and Permit Contact are accurate, and that e-mail addresses are provided. Instructions for
updating contact information (including an on-line form) are available at:
httbs://dea.nc.gov/about/divisions/enerpv-mineral-land-resourceshPdes-industrial-stormwater.
State of North Carolina I Environmental Quality I Energy, Mineral and Land Resources
512 N. Salisbury Street 1 1612 Mail Service Center. 1 Raleigh, North Carolina 27699:1612
919 707 9200

Submitting,Qutfall information for E-Reporting
The U.S. Environmental Protection Agency (EPA) finalized the National Pollutant Discharge Elimination
System (NPDES) Electronic Reporting Rule in December 2015. The rule requires NPDES regulated
facilities to report certain information electronically, instead of filing written paper reports: EPA is
phasing in the requirements of the rule over a 5-year period. The first phase required regulated entities
to submit Data Monitoring Reports (DMRs) electronically starting on December 21, 2016.
We realize that deadline has passed, and EPA is aware that NC is working on expanding the State's
eDMR System (currently -available to-NPDES Wastewater Permit -holders) to include,5tormwater
Program DMR reporting. As soon as eDMR is available for your permit, we will notify you. In the
meantime, we must collect information about the discharge outfalls at your facility to prepare the
system to flow data to EPA as the new federal', rule mandates.
To Submit outfall information to DEQ: Go to the following website and enter the.discharge outfall
number, type of discharge, receiving water information, representative outfal_I status information, and
other details no later than May 18, 2018. The website will walk you through all steps.
The website is: https://dea.nc.gov/about(stormwater-program(stormwater outfalllcollection
For more information on electronic reporting to NC DEMLR, visit
http:l/_d_eg:hc.gav/about/divlsio"_ns/energV-mineral=land=resources/stormwater/ereporting-rule or
contact Bethany Georgoulias at [phone] or via email at [e-mail], or
contact Robert Patterson at [phone] or via email at r666;rt.p4tterson@ncdenr gov.
Sincerely,
a.-a-le.4v {.vn/y
Annette Lucas, P.E.
Supervisor, DEMLR Stormwater Program
Cc: Stormwater Program Permit File
Nothi q crn re§E>�
State of North Carolina l EnvironmentalQuallty I Energy;Mineral and Land Resources
512 N. Sallsbury Street 11612 Mail Service Center I Raleigh. North Carolina 27699-1612
919 707 9200

EDWARDS BROTHERS MALLOY�
established 1893
June 1S, 2017
Dear Mr. La Bounty,
In response to your letter dated June 8, 2017, 1 wanted to make you aware of several changes with our
company. Ron Stephenson, Maintenance Manager, is no longer employed. He is currently listed as the
primary contact. We merged with another company back in 2012, so our company name and contact
information needs to be updated. I have requested a form to update the company name and contact
information.
I have assumed the responsibilities of Maintenance Manager and was not aware of the (SSPP) until I
received a call from Mr. Lawyer requesting an inspection. I was totally caught by surprise when I
received his call. However, he was able to walk me through all of the steps to bring Edwards Brothers
Malloy, Inc. back up to regulation standards.
I will be putting in place annual training for three employees, including myself, for the (SSPP) per Part 11,
Section A, Item 8 of the NCGO50000 permit. A record of this training will be documented and ready for
review at the next inspection. I will also have a topography map with detailed fallout locations for both
buildings on file and available for the next inspection. I still have time to get my first qualitative
monitoring done, provided we have a measurable discharge in the month of June 2017 and thereafter.
Thank you for your and time consideration as we work to get these issues resolved.
Sincerely,
�4
Robie Mills
Maintenance Manager
,S U N 2 1 2017
800 Edwards Brothers Dr., P.O. Box 1027, Lillingfon, NC 27546-1027 0 p:910-893-2717 • f:910-893-8425 0 www.edwardsbrothersmallay.com

Energy, Mineral
and Land Resources
ENVIRONMENTAL QUALITY
June 8, 2017
CERTIFIED MAIL: 7012 3050 0001 9398 7072
RETURN RECEIPT REQUESTED
Edwards Brothers, Inc.
Attn: Robie Mills, Maintenance Manager
PO Box 1027
Lillington, NC 27546
Subject: NOTICE OF DEFICIENCY (NOD-2017-PC-0192)
NPDES Stormwater General Permit NCG050000
Edwards Brothers, Inc.
Certificate of Coverage NCG050148
Harnett County
Dear Mr. Mills:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
TRACY DAVIS
Director
JUN 2 1 2017
On June 7, 2017, Mike Lawyer, Environmental Program Consultant from the Fayetteville Regional Office of
the Division of Energy, Mineral and Land Resources (DEMLR), conducted a site inspection for the Edwards
Brothers, Inc. facility located at 800 Edwards Drive, Lillington, Harnett County, North Carolina. A copy of the
Compliance Inspection Report is enclosed for your review. The time and assistance provided by you during
the inspection is greatly appreciated. The site visit and file review revealed that the subject facility is covered
by NPDES Stormwater General Permit NCG050000 under Certificate of Coverage NCG050148. Permit
coverage authorizes the discharge of stormwater from the facility to receiving waters designated as an
unnamed tributary to the Cape Fear River, a Class WS-IV waterbody in the Cape Fear River Basin.
As a result of the site inspection, the following deficiencies are noted:
1) Stormwater Pollution Prevention Plan (SPPP)
A Stormwater Pollution Prevention Plan (SPPP) has been developed, however not properly implemented to
include documentation of annual employee training or an annual review/update per Part II, Section A, item 8
of the NCGO50000 permit. Also, a USGS topo map is not included with the SPPP and the facility's site map
does not contain the necessary detailed information per Part II, Section A, item 1(c) of the permit.
2) Qualitative Monitoring
Qualitative 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 deficiencies have
occurred as well as a Plan of Action to address these deficiencies.
State of North Carolina I Environmental Quality I Energy, Mineral and Land Resources
Fayetteville Regional Office 1 225 Green Street, Suite 714 1 Fayetteville, NC 28301
910-433-3300

Thank you for your attention to this matter. This office requires that the deficiencies, as noted above and
detailed in the enclosed inspection report, be properly resolved. Failure to resolve these deficiencies
could result in the issuance of a Notice of Violation, which is subject to a civil penalty assessment of
up to $25,000 per day for each violation. Should you have any questions regarding these matters, please
contact Mr. Lawyer or myself at [phone].
Sincerely,
Timothy L. Lal3o ty, PE
Regional Engineer
DEMLR
TLIm l
Enclosure
ec: Laura Alexander, Administrative Assistant - DEMLR, Stormwater Permitting Program
cc: FRO - DEMLR, Stormwater Files-NCG050148

Permit: NCG050148
SOC:
County: Harnett
Region: Fayetteville
Contact Person: Robie Mills
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
On -site representative
Related Permits:
Compliance Inspection Report
Effective: 06101/13 Expiration: 05/31/18 Owner: Edwards Brothers Inc
Effective: Expiration: Facility: Edwards Brothers Incorporated
800 Edwards Dr
Title: Maintenance Manager
Certification:
Robie Mills
Inspection Date: 06/07/2017 Entry Time: 09:20AM
Primary Inspector: Mike Lawyer
Secondary Inspector(s):
Lillington NC 27546
Phone: [phone] Ext.3261
Phone:
910-893-2717 ext 3261
Exit Time: 11:50AM
Phone: [phone] E417f1r
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Apparel/Printing/Paper/Leather/Rubber Stormwater Discharge COC
Facility Status: ❑ Compliant Not Compliant
Question Areas:
■ Storm Water
(See attachment summary)
Page: 1

permit: NCGO50148 Owner • Facility: Edwards Brothers Inc
Inspection Date: 06107/2017. Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Inspection conducted to determine compliance with the conditions of NPDES General Stormwater Permit NCG050000. Met
with Mr. Robie Mills, Maintenance Manager, who provided facility's Stormwater Pollution Prevention Plan (SPPP) and
available monitoring records for review. Facility's SPPP was developed in 2007 and contains all permit -required components
with the exceptions of a USGS topo map, documentation of annual employee training, and documentation of an annual
review/update per Part II, Section A, item 8 of the NCG050000 permit. Facility's site map does not contain all of the
necessary detailed information per Part II, Section A, item 1(c) of the permit. Available qualitative monitoring records indicate
monitoring was conducted for one of the facility's four stormwater discharge outfalls from 2007 through the first half of 2015.
There were no monitoring records for the remaining outfalls or for the second half of 2015 or first and second half of 2016.
After the records review, Mr. Mills provided a tour of the manufacturing process and then observations were made of the
facility's storm drains, stormwater discharge outfalls, loading/off-loading areas, as well as new and used pallet storage
areas. Facility's grounds appeared to be well maintained and there were no obvious indicators of pollution or impacts from
stormwater runoff. Mr. Mills was informed that a Notice of Deficiency would likely be issued due to the lack of some of the
required documentation in the SPPP and failure to conduct and document semi-annual visual monitoring at all stormwater
discharge outfalls during each monitoring period.
Page: 2

Permit: NCG050148 Owner - Facility: Edwards Brothers Inc
Inspection Date: 06/07/2017 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?
0 ❑ ❑ ❑
# Does the Plan include a General Location (USGS) map?
❑ ❑ ❑
# Does the Plan indude 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 altematives to current practices?
■ ❑ ❑ ❑
# Does the facility provide all necessary secondary containment?
❑ ❑ ❑
# Does the Plan include a BMP summary?
❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
0 ❑ ❑ ❑
# 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?
❑ M ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
0 ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
❑ 0 ❑ ❑
Comment: A USGS torso man needs to be added to the facility's SPPP. The site map needs more detailed
information per Part II, Section A, item 1(c) of the permit. Documentation of annual employee
training and an annual review/update per Part II, Section A, item S of the permit needs to be
added to the SPPP.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ❑ 0 ❑ ❑
Comment: Qualitative monitoring records from 2007 through the first half of 2015 for one of the facility's four
stormwater outfalls were available for review, _however there were no records for the remaining
outfalls or for the second half of 2015 or first and second half of 2016.
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? ❑ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ M ❑
Comment:
Permit and Outfalls Yos No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? 0 ❑ ❑ ❑
# Were all autfalls 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: There were no records indicating that an evaluation of the stormwater outfalls for the presence of
non-stormwater discharges has been conducted on an annual basis as required by the permit.
Page: 3

• 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 mailpiece,
or on the front if space permits.
1. Article Addressed to:
EDWAI 15S BROTHERS, INC.
ATTN: 1WBIE MILLS. IMAINT. MA
PO BOX 1027
ULI.,ING I'ON, NC 27546
❑ Agent
M-Addressee
Q. lde� by �nnt d !Pm¢y �C.�at� f Delivery
D. Is delivery dress /erent from item 17 ❑ Yes
If YES, enter delivery address below; ❑ No
3, service Type
39 Certified Mail ❑ Express Mail
❑ Registered ]K Return Receipt for Merchandise
© Insured Mail ❑ C.O.D.
4. Restricted Delivery? (Extra Fee) ❑ Yes
2. Article Number 1= 7p12 3�5(� []Clla� 9398 7�72
(Transfer from service Labe!), '
PS Form 3811. February!?? Domestic Return Receipt 102595•02-M-1540

UNITED STATES.fSTjLERVICE
1 X.11441 ' ..
17
r 2 4-
First-Class Mail
Postage & Fees Paid
USPS
Permit No. G-10
• Sender: Please print your name, address, and ZIP+4 in this box •
NCDEQ — DEMLR
ATTN: MIKE LAWYER jUN 1 5 2017
225 GREEN STREET; SUITE 714
FAYETTEVILLE NC 2830 1 -5095 L
TIHMINSUMUMIRUMMMMUMMMM

Energy. Mineral
and Land Resources
ENVIRONMENT AL QUA LIT
June 8, 2017
CERTIFIED MAIL: 7012 3050 0001 9398 7072
RETURN RECEIPT REQUESTED
Edwards Brothers, Inc.
Attn: Robie Mills, Maintenance Manager
PO Box 1027
Lillington, NC 27546
Subject: NOTICE OF DEFICIENCY (NOD-2017-PC-0192)
NPDES Stormwater General Permit NCG050000
Edwards Brothers, Inc.
Certificate of Coverage NCGO50148
Harnett County
Dear Mr. Mills:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
"RACY DAVIS
Director
On June 7, 2017, Mike Lawyer, Environmental Program Consultant from the Fayetteville Regional Office of
the Division of Energy, Mineral and Land Resources (DEMLR), conducted a site inspection for the Edwards
Brothers, Inc. facility located at 800 Edwards Drive, Lillington, Harnett County, North Carolina. A copy of the
Compliance Inspection Report is enclosed for your review. The time and assistance provided by you during
the inspection is greatly appreciated. The site visit and file review revealed that the subject facility is covered
by NPDES Stormwater General Permit NCGO50000 under Certificate of Coverage NCG050148. Permit
coverage authorizes the discharge of stormwater from the facility to receiving waters designated as an
unnamed tributary to the Cape Fear River, a Class WS-IV waterbody in the Cape Fear River Basin.
As a result of the site inspection, the following deficiencies are noted:
1) Stormwater Pollution Prevention Plan (SPPP)
A Stormwater Pollution Prevention Plan (SPPP) has been developed, however not properly implemented to
include documentation of annual employee training or an annual review/update per Part 11, Section A, item 8
of the NCGO50000 permit. Also, a USGS topo map is not included with the SPPP and the facility's site map
does not contain the necessary detailed information per Part II, Section A, item 1(c) of the permit.
2) Qualitative Monitoring
Qualitative 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 deficiencies have
occurred as well as a Plan of Action to address these deficiencies.
State of North Carolina I Enviroamentat Quality I Energy, Mineral and land Resources
Fayetteville Regional Office 1 225 Green Street, Suite 714 1 Fayetteville, NC 28301
410-433-3300

Thank you for your attention to this matter. This office requires that the deficiencies, as noted above and
detailed in the enclosed inspection report, be properly resolved. Failure to resolve these deficiencies
could result in the issuance of a Notice of Violation, which is subject to a civil penalty assessment of
up to $25,000 per day for each violation. Should you have any questions regarding these matters, please
contact Mr. Lawyer or myself at [phone].
Sincerely,
Timothy L. LaBo ty, PE
Regional Engineer
DEMLR
TL/m l
Enclosure
ec: Laura Alexander, Administrative Assistant - DEMLR, Stormwater Permitting Program
cc: FRO - DEMLR, Stormwater Files-NCG050148
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PS Form :i0 August 2006See
Reverse for Instructions

Permit: NCGO50148
SOC:
County: Harnett
Region: Fayetteville
Contact Person: Robie Mills
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s)
Compliance Inspection Report
Effective: 06/01/13 Expiration: 05/31/18 Owner : Edwards Brothers Inc
Effective: Expiration: Facility: Edwards Brothers Incorporated
800 Edwards Dr
Title: Maintenance Manager
Certification:
On -site representative Robie Mills
Related Permits:
Inspection Date: 06/0712017 EEntry Time: 09:20AM
Primary Inspector: Mike Lawyer
Secondary Inspector(s):
Lillington NC 27546
Phone: [phone] Ex0261
Phone:
910-893-2717 ext 3261
Exit Time: 11:50AM
Phone: [phone] EV_Z�
339`�
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: ApparellPrintinglPaper/Leather/Rubber Stormwater Discharge COC
Facility Status [] Compliant Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page: 1

Permit: NCGO50148 Owner - Facility: Edwards Brothers Inc
Inspection Date: 06/0712017 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Inspection conducted to determine compliance with the conditions of NPDES General Stormwater Permit NCG050000. Met
with Mr. Robie Mills, Maintenance Manager, who provided facility's Stormwater Pollution Prevention Plan (SPPP) and
available monitoring records for review. Facility's SPPP was developed in 2007 and contains all permit -required components
with the exceptions of a USGS topo map, documentation of annual employee training, and documentation of an annual
reviewlupdate per Part II, Section A, item 8 of the NCG050000 permit. Facility's site map does not contain all of the
necessary detailed information per Part II, Section A, item 1(c) of the permit. Available qualitative monitoring records indicate
monitoring was conducted for one of the facility's four stormwater discharge outfalls from 2007 through the first half of 2015.
There were no monitoring records for the remaining outfalls or for the second half of 2015 or first and second half of 2016.
After the records review, Mr. Mills provided a tour of the manufacturing process and then observations were made of the
facility's storm drains, stormwater discharge outfalls, Ioadingloff-loading areas, as well as new and used pallet storage
areas. Facility's grounds appeared to be well maintained and there were no obvious indicators of pollution or impacts from
stormwater runoff. Mr. Mills was informed that a Notice of Deficiency would likely be issued due to the lack of some of the
required documentation in the SPPP and failure to conduct and document semi-annual visual monitoring at all stormwater
discharge outfalls during each monitoring period.
Page: 2

permit: NCG050148 Owner - Facility: Edwafds Brothers Inc
Inspection Date: 06107/2017 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?
Cl ■ ❑ ❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
❑ E ❑ ❑
# Has the facility evaluated feasible altematives to current practices?
E ❑ ❑ ❑
# Does the facility provide ail necessary secondary containment?
0 ❑ ❑ ❑
# Does the Plan include a $MP summary?
E ❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
E ❑ ❑ ❑
# Does the Pian include a Preventative Maintenance and Good Housekeeping Plan?
N ❑ ❑ ❑
# Does the facility provide and document Employee Training?
❑ 0 ❑ ❑
# Does the Plan include a list of Responsible Pariy(s)?
❑ ❑ ❑
# Is the Plan reviewed and updated annually?
❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
0 ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
❑ E ❑ ❑
Comment: A USGS t000 map needs to be added to the facilitv's SPPP. The site map needs more detailed
information per Part II Section A item 1 c of the Permit. Documentation of annual employee
training and an annual review/update per -Part II, Section A, item 8 of the permit needs to be .
added to the SPPP.
Qualitative Monitoring
Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ❑ ®❑ ❑
Comment: Qualitative monitoring records from 2007 through the first half of 2015 for one of the facilitv's four
stormwater outfalls were available for review, however there were no records for the remaining
outfalls or for the second half of 2015 or first and second half of 2016.
Analytical Monitoring
Yes No NA NE
Has the facility conducted its Analytical monitonng? ❑ ❑ ■ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ 0 ❑
Comment:
Permit and Outfalls Yes No NA NE
# is a copy of the Permit and the Certificate of Coverage available at the site? ❑ ❑ ❑
# Were all outfalls observed during the inspection? ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ❑ ®❑ ❑
Comment: There were no records indicating that an evaluation of the stormwater outfalls for the presence of
non-stormwater discharges has been conducted on an annual basis as required by the permit,
Page. 3

Georgoulias, Bethany
From: [e-mail]
Sent: Wednesday, June 19, 2013 12:49 PM
To: SVC_DENR.stormwater
Subject: Confirmation for Renewal of DWQ Stormwater NPDES General Permit
** Do not reply to this e-mail as it is from an unmonitored mailbox. **
Thanks for renewing your permit using our on-line option. No further action is necessary. The new General
Permit is available for printing from our website at http://portal.nedenr.org/web/wg/sw/su/npdessw .
If you have questions, please contact Bethany Georgoulias at bethan3Lgeoraoulias a,ncdenr.gov phone (919)
807-6372 or Bradley Bennett at brad] ey. bennett(a_)ncdenr.gov phone [phone]. If you forgot to print your
Certificate of Coverage you can resubmit the data and print another copy.
This COC is issued 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 General Permit authorizes discharges of stormwater and specifies your obligations for discharge controls,
management, monitoring, reporting, and record keeping. Please review the new permit to familiarize yourself
with all of the changes. Parts III and IV contain the Standard Conditions, including Compliance and Liability,
Reporting, Monitoring and Records requirements; Operation and Maintenance obligations; and Definitions.
Your facility has six months from receipt of the COC to update its Stormwater Pollution Prevention Plan
(SPPP) to comply with changes in SPPP requirements. Other changes are effective immediately. Please note
that Tier 3 Actions (if applicable) are triggered by four benchmark exceedances beginning on the effective
date of the renewal permit and do not count prior exceedances. Please visit our website above to review the
new General Permit carefully.
Your coverage under the General Permit is transferable only through the specific action of DWQ. This permit
does not affect the legal requirements to obtain other permits which may be required by DENR, nor does it
relieve the permittee from responsibility for compliance with any other applicable federal, state, or local law,
rule, standard, ordinance, order, judgment, or decree.
CONFIRMATION DETAILS
Permit Number_:
Effective Date:
Expiration Date _' A --
Organization Name:
Facility Name:
Admin Region:
County Name: -
Regulated Activity:
Receiving Stream Name:
Receiving Stream Class:
..
Facility Address:
NCG050148
6111ZOW
zer3 --. ---
_ -- _
5/311�.A i
�__.._.._._._.. _,
Edwards Brothers Inc
Edwards Brothers Incorporated _
Fayetteville
"Harnett --- — -
ApparellLeather/Rubber/Printing/Mist manufacture
CAPE FEAR RIVER
WS-IV
Cape Fear,
800 Edwards Dr
59

f acilsty City .
Lillington _ 5
Facility State:
NC
FacilityM27546
--_- W-.. -
Affiliation Type:
Owner
Fax'Number
------- --- -- _ I
Work Phone Number:
[phone]
First -Name:
Ronald ;
Middle Name:
Last Name:
Stephenson
Email:
ron Stephensongedwardsbrothersmalloy.com
60

Georloulias, Bethany
From: Georgoulias, Bethany
Sent: Tuesday, May 28, 2013 1:13 PM
To:'[e-mail]'
Subject: NPDES Stormwater Permit COC Renewal Update
Dear Stormwater Permit On-line Renewal Contact:
We have sent the permit or owner contact person on record for Certificate of Coverage (COC) No. NCG050148, Ron
Stephenson, a unique PIN and instructions for renewing the COC on-line. You may be the same contact person that
received that information.
A complete permit package (General Permit, Monitoring Forms, Technical Bulletin) is available from our website at:
http://portal.ncdenr.org/web/wq/ws/su/2013-gps . We have also provided this website to the permit or owner contact
named above.
On that website, you will find revised summary reports of the contact affiliations and details we have on record for this
COC, Please search the corresponding PDF document for the COC number. We request that you help keep DWQ
updated with accurate permit contacts and e-mail addresses for this permit.
If you have any questions or concerns, please contact:
Bethany Georgoulias
e-mail: [e-mail]
phone: [phone]
or
Bradley Bennett
e-mail: brad) .bennett ncdenr. ov
Phone: [phone]
or
Bridget Munger
e-mail: [e-mail]
Phone: [phone]
Best regards,
The Stormwater Permitting Unit
Bethany Georgoulias
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
NEW Website: http://portal.ncdenr.org/web/wq/ws/su
E-mail correspondence to and from this address may be subject to the North Carolina Public
Records Law and may be disclosed to third parties.
207

AA
A*A
CEN
North Carolina Department of Environment and Natural Resources
Division of Water Qua€ity
Beverly Eaves Perdue. Coleen H. Sullins
Governor Director
September 9. 2009
Edwards Brothers Incorporated
Attn: Ken Buss, Operations Manager
PO Box 1027
Lillington, NC 27546
Subject: COMPLIANCE EVALUATION INSPECTION
Edwards Brothers, Inc.
NPDES Stormwater General Permit-NCGO50148
Harnett County
Dear Mr. Buss:
Dee Freeman
Secretary
On September 4, 2009, 1, Michael Lawyer from the Fayetteville Regional Office of the Division of
Water Quality, conducted a site inspection at the Edwards Brothers Incorporated facility located at 800 Edwards
Drive in Lillington, Harnett County, North Carolina. A copy of the Compliance Inspection Report is enclosed
for your review. Mr. Ron Stephenson, Assistant Operations Manager/Maintenance Manager, and Mr. Rich
Towler, Administration Manager, were also present during the inspection and their time and assistance is
greatly appreciated. Stormwater from this faculty drains to an unnamed tributary to the Cape Fear River, a Class
WS-1V stream 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-NCG050148.
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.
Yes ■ No ❑
2) Qualitative 11lonitoring
Qualitative monitoring has been conducted and recorded in accordance with permit requirements.
Yes ■ No ❑
Other Observations:
Please refer to the enclosed Compliance Inspection Report for additional comments and observations made
during the inspection.
Location: 225 Green Street. Suite 714. Fayetteville. North Carolina 28301
Phone, 910-433-33001 FAX: [phone] Customer Service: 1-877-623-6748
Internet, www,ncwaterquaiity.ore
Arl C;iIJI CI'JUNO I] LAfiirmM ve Action Fmin loye:
One
Not-th Cal-o 1 E t1a
Nalm,ally

Requested Response:
A response is not requested at this time.
Please be advised that violations of the NPDES General Permit are subject to a civil penalty
assessment of up to $25,000 per day for each violation. If you or your staff has any questions, comments, or
needs assistance with understanding; any aspect of your permit, please do not hesitate to contact me at (910)
433-3329.
Sincerely,
i
Michael Lawye
Environmental Specialist
Enclosure
cc: Ron Stephenson, Assist. Ops. Manager/Maint. Manager -Edwards Brothers, 'Inc. (via e-mail)
Rich Towler, Administration Manager -Edwards Brothers, Inc. (via e-mail)
FRO -Surface Water Protection
NPS-Assistance & Compliance Oversight Unit
n;aiinn, 225 Green Sties 1, Suite 714. Fayetteville, North Carolina 28301 011�
PY,one: M-433-33001 FAX: [phone] Customer Service 1.877-623-6748 ! V Orth Caro11 t1LL
nteinet:www.ncwaterpaliiyorg Are Equal Orportunity I.Affirmalive Action Employer A) ]tJ/ %]
+'u 1►'+ lly

Compliance Inspection Report
Permit: NCG050148 Effective: 06/01/08 Expiration: 05/31/13 Owner: Edwards Brothers Inc
SOC: Effective: Expiration: Facility: Edwards Brothers Incorporated
County: Harnett 800 Edwards Dr
Region: Fayetteville
Lillington NC 27546
Contact Person: Ken Buss Title: Operations Manager Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
On -site representative
On -site representative
Related Permits:
Rich Towler
Ron Stephenson
Certification:
Phone:
Phone: [phone]
Phone: [phone]
Inspection Date: 09/04/2009 Entry%Time:
01:00P M Exit Time: 02:20 PM
Primary Inspector: Mike Lawyer Phone: [phone]
✓✓ E xt_Z2.1?—
�
Belinda S. Henson Phone: [phone] ExL_7 U
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Apparel/Printing/Paper/Leather/Rubber Stormwater
Discharge COC
Facility Status: ■ Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page: 1

M
Permit: NCG050148 Owner - Facility: Edwards Brothers Inc
Inspection Date: 09/0412009 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Met with Mr. Ron Stephenson, Assistant Operations Manager/Maintenance Manager, and Mr. Rich Towler, Administration
Manager. A Stormwater Pollution Prevention Plan (SPPP) has been developed since the previous inspection. The SPPP
appeared to contain all permit -required components, but needs documentation of an annual review update. Oualitative
Monitoring has been performed at all drains/inlets throughout the property instead of at each individual outfall.
Suggestions were made regarding the proper documentation of monitoring and outfall locations were evaluated during the
inspection. At least four outfalls were identified and facility staff should confirm these locations through the use of facility
plans and/or visual observations. Since the previous inspection on January 25, 2007, which resulted in the issuance of a
Notice of Violation, facility has come into compliance with the conditions of the NCG050000 general stormwaler permit.
Page: 2

4
Permit: NCG050148 Owner - Facility: Edwards Brothers Inc
Inspection Date: 09/04/2009 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?
®
n
n
n
# Does the Plan include a General Location (USGS) map?
®
n
n
n
# Does the Plan include a "Narrative Description of Practices"?
■
n
n
n
# Does the Plan include a detailed site map including outfali 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
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? p n n n
# Does the facility provide and document Employee Training? ■ n n n
# Does the Plan include a list of Responsible Party(s)? p n n n
# Is the Plan reviewed and updated annually? n ■ n n
# Does the Plan include a Stormwater Facility Inspection Program?
■
n
n
n
Has the Stormwater Pollution Prevention Plan been implemented?
■
n
n
n
Comment: Facility's SPPP last updated in March 2007. Need to add section for annual
review/update.
Qualitative Monitoring
Yes
No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
■
n
n
n
Comment: Monitoring has been performed at all drains throughout the property.
Documentation should be revised to reflect individual outfalls.
Analytical Monitoring
Yes
No
NA
NE
Has the facility conducted its Analytical monitoring?
n
n
®
n
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
D
❑
®
n
Comment. -
Permit and Outfalls
Yes
No
NA
NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? ii n n n
# Were all outfalls observed during the inspection? n n n
# If the facility has representative outfall status, is it properly documented by the Division? n n p n
# Has the facility evaluated all illicit (non stormwater) discharges? ■ n n n
Page:3

Permit: NCG050148 Owner - Facility: Edwards Brothers Inc
Inspection Date: 09/04/2009 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Comment: At least four individual outfalls were identified during the inspection. Facility
personnel should follow through with outfall identification and monitoring.
Page: 4

O�0F W A 7-, % G Michael P. Easley, Governor
William G, Ross Jr., secretary
7 North Carolina Department of Environment and Natural Resources
CO
p Alan W. Klimek, P.E. Director
Division of Water Quality
May 3, 2007
Edwards Brothers, Inc.
Attn: Kenneth C, Buss, NC Operation Manager/Corporate IT Manager
PO Box 1027
I.,illington, NC 27546-1027
SUBJECT: Facility Expansion/Permit Requirements
Dear Mr, Buss:
On April 30, 2007, our office received your letter concerning a planned expansion of your
facility in order to store large rolls of paper. In that letter, you inquired as to whether or not a revision to
your current stormwater permit would be necessary. On May 2, 2007, Mike Lawyer with this office
contacted you via telephone to discuss the details of the facility's expansion. During that conversation,
lie expressed that a permit revision or modification would not be necessary, however documentation of
the expansion including the increase in impervious surface area and revisions to your facility's site map
are required. Please refer to fart 11, Section A, Item 7 of the general permit, which states: "Plan
Amendment. The permittee shall amend the Plan whenever there is a change in design,
construction, operation, or maintenance which has a significant effect on the potential for the
discharge of pollutants to surface waters. The Stormwater Pollution Prevention Plan shall be
reviewed and updated on an annual basis." Based on this permit condition, your current Stormwater
Pollution Prevention Plan should be amended to reflect the construction of the additional square footage
to the facility and the site map should also be amended to show the exact. location of the expansion and
how it might affect stormwater drainage. Plan revisions are not required to be submitted, but should be
made available upon request by Division staff.
If you have any questions concerning this matter, or if this office can be of any further
assistance, please contact Mike Lawyer or myself at [phone],
Sincerely,
Belinda S. Henson
Regional Supervisor
Surface Water Protection Section
BSH: MLlml
cc: FRO -Surface Water Protection
NoonertJtCarolina
Naturally
North Carolina Division of Water Quality 225 Green Street -suite 714 Fayetteville, NC 28301 Phone [phone] Customer Service
Internet: www.uccvatert�uality.�re Fax [phone]
An Equal OpportunitylAflirmalive Action Employer — 50% Recycle00% Past Consumer Paper

REPLY TO:
8D0 EMAAOS DRIVEIP.O. BOX 1027AJWNGTON, NORTH CAAOUNA 27545-1027
FAX: 9 ln,8425
EDWARDS
BRDTHERS
N C 0 A F 0 R A T E 0
2500 SOUTH STATE STREETIPO BOX 10071ANN ARBOR, MICHIGAN 481 *1007
r
' APR 10
April 27, 2007
Ms. Belinda S. H,nsort
NCDENR
Regional Supervisor
Surface Water Protection Section
225 Green Street
Suite 714
Fayetteville, North Carolina 28301-5043
RE: Edwards Brothers, Inc.
NPDES Storm Water General Permit NCG050148
Dear Ms. Henson:
Edwards Brothers is a book manufacturing company located in Lillington where we print
and bind books for publishers across the United States. We are preparing to replace two
outdated production lines for binding books with a new finishing line that will serve the
duo purpose of binding both paperback and hardback books. In addition to replacing the
old production line we are planning to add 24,000 sq. fi. to our facility located at 800
Edwards Drive in Lillington. In the end the additional space will be used to store large
rolls of paper.
I do not believe the addition would require a new permit but I need to ask you to make
that determination before we proceed.
We are seeking Industrial Revenue Bond financing for the expansion. Will you please
make a determination as expediently as practical as to whether or not a revision to our
current permit is necessary?
ANN ARBOR • AUSTIN • BOSTON • CHICAGO • UWNGTON • NEW YORK
SAN FRANCISO • WASKNGTON, D.C.
BOOK MANUFACTURING SINCE 1893

Aw., N

I will need a formal response to send to the NC Department of Commerce and Mr. Rahul
Thaker.
Thank you for your assistance.
Sincer y,
Kenneth C. Buss
NC Operation Manager/Corporate IT Manager

w
REPLY TO: 1
600 EDWARDS DRNEPP.O. BOX 1027NWNGTON, NORTH CAROONA 27546-1027
FAX: 9*893.8425
February 9, 2007
Belinda S. Henson
NCDENR
Regional Supervisor
Surface Water Protection Section
225 Green Street
Suite 714
Fayetteville, North Carolina 28301-5043
'_1:11 13 2037
DWQ
WAR OS
BROTHERS
. N G O A P D R A T E D
25M SOJTH STATE STREETIPO BOX 10071ANN ARBOR, M1CHIGAN 006-1007
RE: Notice of Violation (NOV-2007-PC-0056)
Edwards Brothers, Inc.
NPDES Stormwater General Permit NCG050148
Harnett County
Dear Ms. Henson:
I am in receipt of your letter dated January 26, 2007, informing me of the fact Edwards
Brothers is in violation of permit conditions.
Immediately following the site visit by Mr. Lawyer, my staff took action to correct the
non-compliance areas.
In your letter of January 26, 2007, you ask that I respond within 30 days in writing
outlining our plan of action to address the items brought to light by Mr. Lawyer's visit to
our facility. The two items noted by Mr. Layer and our plan of action for each:
1) Stormwater Pollution Prevention Plan
We are in the process of creating the Stormwater Prevention Plan. We
expect to have the written plan in place by March 31, 2007.
ANN ARBOR • AUSTIN • BOSTON • CHICAGO • ULUNGTON • NEW YORK
SAN FRANCISO • WASHINGTON, D.C.
BOOK MANUFACTURING SINCE 1893

J

4.
2) Qualitative Monitoring
We have implemented a qualitative monitoring program with the
appropriate forms and procedures documented and necessary training
completed. We have also assigned individuals to perform the monitoring.
Given we are working diligently to resolve the violations quickly; I respectfully ask any
civil penalty be waived.
Sincere y,
enneth C. Buss
NC Operations Manager/Corporate IS Manager

%lichael F I?aslcy, ( imclnor
Wilhi lnl U R—s •lr, •tiecictary
North Carolina Dclxioniv.nl ofIsna'irc�unen(•;:�, Nrlunu( I<csotlrics
Ahn W. KIMIL,k, PA:, r)I I'4'C'iUl'
Di%isionciI'W:ao t tlality
January 26, 2007
CERTIFIED MAIL: 7001 2510 0006 9498 8978
RETURN RECEIPT REQUESTED
Ken Buss, Operations Manager
Edwards Brothers, Inc.
800 Edwards Drive
Lillington, NC 27546
Subject: NOTICE OF' VIOLATION (NOV-2007-PC-0056)
Edwards Brothers, Inc.
NPDES Stormwater General Permit-NCG050148
Harnett County
Dear Mr. Buss:
On January 25, 2007, Mike Lawyer from the Fayetteville Regional Office of tlic Division of
Water Quality conducted a site inspection for the Edwards Brothers, Inc. facility located at 800 Edwards
Drive in Lillington, Harnett County, North Carolina. A copy of the inspection report is al.lached lur your
review. Mr. Rich Towler, Operations Manager -Plant 2, and Mr. Terry Anderson, Maintew.mce and
Grounds Supervisor, were also present during the inspection and their time and assistance is ;greatly
appreciated. Stormwater from the facility drains to an unnamed tributary to the Cape Fear- River, ,1 Class
WS-IV 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-NCGt150148.
Accordingly, the following observations find/or permit conditions violations (please see the
attached addendum for information about your permit) were noted during the Division of Water Quality
inspection
1) Stormwater Pollution Prevention Plan SPPP
A Stormwater Pollution Prevention Plan (SPIT) has been developed, recorded, and properly
implemented.
11—Ves No®
2) (qualitative Monitorint
Qualitative monitoring has been conducted and recorded in accordance with permit requirements.
es❑ No®
n,
North(,'arolina
. d'1?atlrinll�
North Carolina Division oMiter Quality 225.0reen Street -Saito 714 Fayetteville, NC 2tt301 Phwit fl) 10) 433-33170 Customer Scrvice
Internet: wvcw.nctiva[crgtt;tli .ur Fax (4i0) 06-0707 1-X77-623•674.`;
An Equal Opportunity/Affirmative Acton Employer — 501% Recycled! 0% Post Consumer Paper

r
cc
117�-
� uJ F Il � C A L U S E—
CC Postage $
0—
Certliied Fee
Postmark
Return Receipt Fee Here
(Endorsement Required)
d
iO Restricted Delivery Fee
Q (Endorsement Required)
Total Posu Ken Buss, Operations Manager
ul Sent To
ru Edwards Brothers, Inc.
r-i Sfaet,- pt"n 800 Edwards Drive
co or PO Box Nc
O Ciry, State, Zl Lifl ington, NC 27546
`PS Form 3900, Januaty 2001
r

Page ?
Mr. BLISS
January 26, 2007
Other Observations:
Please refer to the inspection summary located on page 2 of the enclosed Compliance Inspection Report
for additional comments and observations made during the inspection.
Requested Restlonse:
You are asked to respond to this office, in writing, within 30 days from receipt of this report. Your
response should include a plan of action to address the aforementioned violations as well as a reasonable
time frame that you expect to be in full compliance with tite conditions of the general pertttit.
Thank you for your attention to this matter. This office requires that (lie violations, as
detailed above, be properly resolved. These violations and any future violations are subject to a
civil penalty assessment of up to $25,000 per day for each violation. Should you or your- staff have
any questions regarding these matters, please contact Mr. Lawyer or myself at (910) q;;- 300.
Sincerely,
Belinda S. Henson
Regional Supervisor
Surface Water Protection Section
BSH: MiJml
Attachments (2)
cc: Rich Towler, Operations Manager Plant 2-Edwards Brothers, Inc.
Terry Anderson, Maintenance and Grounds Supervisor -Edwards Brothers, Inc.
FRO -Surface Water Protection
NPS-Assistance & Compliance Oversight Unit
Water Quality Central Files

UNITED .STATES-PAST,1 .S111{CrE�
• Sender: Please print your name, address, and ZIP+41h"Mis box •
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
NCDENR 225 GREEN STREET -SUITE 714
FAYETTEVILLE, NC 28301-5043

Compliance Inspection Report
Permit: NCGO50148 Effective: 05/0,1/03 Expiration: 04/30/08 Owner: Edwards Brothers Inc
SOC: Effective: Expiration: Facility: Edwards Brothers Incorporated
County: Harnett 800 Edwards Dr
Region: Fayetteville
Lillington NC 21546
Contact Person: Ken Buss Phone: [phone]
Directions to Facility:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
On -site representative
On -site representative
Related Permits:
Rich Towler
Terry Anderson
Certification:
Inspection Date: 01125/2007 Entry Time: 10:00 AM
Primary Inspector: Mike Lawyer..
Secondary Inspector(s):
Exit Time: 11:00 AM
Phone:
Phone: [phone]
Phone: [phone]
Phone: [phone]
Ext 729-
E-9Zg
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Apparel/Printing/Paper/Leather/Rubber Stormwater
Discharge COC
Facility Status: ❑ Compliant ® Not Compliant
Question Areas:
® Storm Water
(See attachment summary)
Page: 1

Permit: NCGO50148 Owner - Facility: Edwards Brothers Inc
Inspection Date: 01/25/2007 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Inspection conducted with time and assistance provided by Mr. Terry Anderson, Maintenance and Grounds Supervisor,
and Mr. Rich Towlec, Operations Manager for Plant 2. Facility manufactures books and journals for various clients
including textbooks for schools. Exposure to stormwater is limited to wooden and plastic pallets, which are trucked in and
stored outside for subsequent loading and transporting of boxes of books. There are several storm drains located
throughout the property, some of which are interconnected and share a common outfall. During the inspection, four main
outfalls were identified that convey stormwater off the property to an unnamed tributary to the Cape Fear River, A
Stormwater Pollution Prevention Plan has not been developed for this facility and semi-annual visual monitoring of the
outfalls has not been conducted. Visual inspections of the facility's drum storage area, which is covered by a shelter, is
being performed and documentation is maintained concerning any leaks and/or spills.
Page: 2

Permit: NCGO5014B Owner - Facility: Edwards Brothers Inc
Inspection pate: 01/25/2007 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Yes
No
NA
HE
Does the site have a Stormwater Pollution Prevention Plan?
0
M
❑
0
# Does the Plan include a General Location (USGS) map?
n
n
n
# Does the Plan include a "Narrative Description of Practices"?
C!
n
n
M
# 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?
Cl
Cl
n M
# Does the facility provide all necessary secondary containment?
n
0
® D
# Does the Plan include a BMP summary?
n
Q
0
# 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?
n
n
n
# Does the facility provide and document Employee Training?
n
n
n
# Does the Plan include a list of Responsible Party(s)?
n
fl
0
# Is the Plan reviewed and updated annually?
n
n
n
# Does the Plan include a Stormwater Facility Inspection Program?
n
n
n
Has the Stormwater Pollution Prevention Plan been implemented?
❑
n
n
Comment: Facility has not developed an SWPPP.
Qualitative MOnitorinq
Yes
No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
❑
m
0
n
Comment: Visual monitoring has not been conducted.
Analytical Monitoring
Yes
No
NA
HE
Has the facility conducted its Analytical monitoring?
0
n
is
C3
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
n
O
®
n
Comment: Facility does not perform vehicle maintenance.
Permit and Outfalls
Yes
No
NAW
HE
# Is a copy of the Permit and the Certificate of Coverage available at the site?
0
n
0
# Were all outfalls observed during the inspection?
®
0
n
1)
# If the facility has representative outfall status, is it properly documented by the Division?
0
0
# Has the facility evaluated all illicit (non stormwater) discharges?
n
n
n
Comment:
Page: 3

ADDENDUM
The National Pollutant Discharge Elimination System (NPDES) program was established under- the
federal Clean Water Act and then delegated to the Division of Water Quality for irnplernentation in
North Carolina. The NPDES pen -witting program for stormwater discharges was established in 1990.
Phase I focuses on site and operations planning to reduce pollutant sources.
Through the NPDES permitting program industrial facilities that fall into one of the subject ten
categories are required to obtain permit coverage under a general permit or an individual permit,
depending upon the facilities SIC code and the industrial activity occurring at the facility. 'Where are
currently 19 active general stormwater permits in North Carolina. One condition that is applicable to
both the general permits and individual stormwater permits is the requirement to develop -,rnd implement
site -specific comprehensive stormwater pollution prevention plans (SPPP). These plans arc required to
include a comprehensive evaluation of the site and operations to reduce pollutant sources and prevent
Pollutant discharge.
Copies of the general permits and accompanying documents can be accessed from the following
webpage: http://h2o.cni-.state.nc.us/su/Forms_Documents.htm Permit teat, technical bulletins, discharge
monitoring forms, and a Notice of Intent [which is the application of for coverage undcr a NPDES
General Stormwater Permit] can be found at this web site.
The following items are a subset of permit requirements and are fisted to assist you and help bring your
attention to certain permitting issues, process and condition requirements Of your permit. That. said;
please see the above -mentioned web site in order to obtain a copy of the permit such that you may fully
comply with all the conditions therein. Failures to properly comply with conditions of the permit,
like those bulleted below, constitutes violations and arc subject to a civil penalty assessment of up
to $25,000.00 per day, per violation.
• Industrial facilities that fall into one of the subject ten categories are required to obtain permit
coverage under a general NPDES stormwater permit or an individual NPDES stormwater permit
• All persons desiring to have facilities covered by a General Permit must register with the
Division of Water Quality (DWQ) by the filing of a Notice of Intent (NOI) ;and Applicable Fees.
• This Notice of Intent (NO[) must be submitted and a Certificate of Coverage issued, prior to any
discharge of stormwater associated with the industrial activity, process wastewater, and/or- mine
dewatering.
• Once the Notice of Intent is received, DWQ will review and determine whether a Certificate of
Coverage (COC) may be issued. If this Certificate of Coverage is issued the facility is covered
by the General Permit. That is, the permittee is authorized to discharge stormwater, process
wastewater, and/or mine dewatering pursuant to the type of General Permit until the permit
expires or is modified or revoked.
• Any other point source discharge to surface water of the state is prohibited unless it is an
allowable non-stormwater discharge or is covered by another permit, authorization or approval.
• There are currently 19 active general permits. Permit conditions vary accordingly; however, most
of the permits have following condition requirements (you must read your entire permit to ensure
full compliance):
o Development and compliance with the Stormwater Pollution Prevention Plan
o Collection,'reporting, and recording of Analytical Monitoring

o Collection, reporting and recording of Qualitative :klonitorin-
o Collection, reporting and recording of Vehicle Maintenance Monitoring
o Records - Visual monitoring shall be documented and records maintained at the facility
along with the Stormwater Pollution Prevention Plan. Copies of the analytical monitoring
resLrlts shall also be maintained on -site. The Permittee shall retain records of all
monitoring information, including all calibration and maintenance records and all original
strip chart recordings for continuous monitoring instrumentation, and copies, ol'all reports
required by this general permit for a period of least S years for the date ol'the sample
measurement, report or application.
o Expiration - The permitter is not authorized to discharge after the expiration date of the
general permit. In order to receive autonialic authorization to discharge beyond the
expiration date, the permittee shall submit forms and fees as are requir'ecl by thCagcncy
authorized to issue permits no later than I80-days prior to expiration date. Any permitter
that has not requested renewal at least 180 days prior to expiration, or any permittee that
does not have a permit after the expiration and has not requested renewal at least 180
days prior to expiration, will be subject to enforcement. Failure to renew your hermit is
a violation.
o Transfer- The Certificate of Coverage (COC) issued pursuant to this general hermit is
not transferable to any person expect after notice to Lined approval by the Director. The.
Director may require modification or revocation and reissuance of the Certif-irate of
Coverage to change the name and incorporate; such other requirements as may be
necessary under the Clean Water Act. The Permit is NOT transferable.
o Name Change, Closure or Facility Ownership change - Permittee is required to notify the
Division in writing in the event the permitted facility is sold or closed. The Division of
Water Quality views changes of name or ownership as a modification that requires the
Director's approval and reissuance of the permit. Name and ownership changes required
you to complete a Name/ownership Change Form from the Division and mail it rack to
the Division of Water Quality along with all appropriate information.
o Proper Operation and Maintenance is a requirement of the permit.

� NJ A L4F Michael F. Easley, Governor
`OHO 9QG William G. Ross Jr„ Secretary
North Carolina Department of Environment and Natural Resources
7 Alan W. Klimek, P.E. Director
]_ Division of Water Quality
❑ `C
April 28, 2003
i
Ken Buss
Edwards Brothers Incorporated s APR 3 0 200
800 Edwards Drive
Lillington, NC 27546 , „ r
f-;V
Subject: NPDES Stormwater Permit Renewal L�
Edwards Brothers incorporated
COC Number NCGO50148
Harnett County
Dear Permittee:
In response to your renewal application for continued coverage under general permit NCG050000, 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 General Stormwater Permit NCG050000
• A copy of the Analytical Monitoring Form (DMR)
• A copy of the Qualitative! Monitoring Form
A copy of a Technical Bulletin for the general permit
Your coverage under this general permit is not transferable except after notice to DWQ. The Division
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 Department of
Environment and Natural Resources, or relieve the permittee from responsibility for compliance with any
other applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or decree.
If you have any questions regarding this permit package please contact Aisha Lau of the Central Office
Stormwater and General Permits Unit at [phone], ext. 578.
Sincerely,
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
cc: Central Files
Stormwater & General Permits Unit Files
Fayetteville Regional Office
NCDEPIR
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1 800 623-7748

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG050000
'CERTIFICATE OF COVERAGE No. NCGO50148
'• ---- .. 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,
Edwards Brothers Inc
is hereby authorized to discharge stormwater from a facility located at
Edwards Brothers Incorporated
800 Edwards Dr
Lillington
Harnett County
to receiving waters designated as a UT to the Cape Fear River, a class WS-IV stream, in the
Cape Fear River Basin in accordance with the effluent limitations, monitoring requirements, and
other conditions set forth in Parts I, II, 111, IV, V, and VI of General Permit No. NCG050000 as
attached.
This certificate of coverage shall become effective May 1, 2003.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day April 28, 2003.
for Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

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, P.E. Director
10/24/2002
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
EDWARDS BROTHERS INCORPORATED
2500 S STATE ST
ANN ARBOR, MI 48106
Dear Permittee:
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: NOTICE OF VIOLATION
FAILURE TO SUBMIT RENEWAL APPLICATION
EDWARDS BROTHERS INCORPORATED
NCG050000
COC NUMBER NCGO50148
HARNETT COUNTY
This letter is to inform you that, as of the date of this letter, the Division of Water Quality has not received a
renewal request for the subject permit certificate of coverage. This is.a violation of NCGS § 143.215.1 (c)(1) which
states "All applications shall be filed with the commission at least 180 days in advance of the date on which it is
desired to commence the discharge of wastes or the date on which an existing permit expires, as the case may be".
Any permittee that has not requested renewal at least 180 days prior to expiration or permittee that does not have a
permit after the expiration and has not requested renewal at least 180 days prior to expiration, will be subjected to
enforcement procedures as provided in NCGS § 143-215.6 and 33 USC 1251 et. seq.
In order to prevent continued, escalated action, including the assessment of civil penalties you must submit a
completed permit coverage renewal application to the attention of the "Stormwater and General Permits Unit" at
the letterhead address within ten (10) days of your receipt of this letter (renewal application enclosed). if the
subject discharge has been terminated, please complete the enclosed rescission request form. A valid reason for
requesting rescission is required, incomplete forms will be returned and you will still be subject to possible
escalated action. Mailing instructions for submitting rescission request are listed on the bottom of the form. You
will be notified when the rescission process has been completed.
Thank you for your prompt attention to this situation. If you have any questions regarding this matter, please
contact Aisha Lau of the central office Stormwater and General Permits Unit at 919-733-5083, ext. 578.
Sincerely,
for Alan W. Klimek, P.E.
Director, Division of Water Quality
cc: Stormwater and General Permits Unit Files
Central Files
Fayetteville Regional Office
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Septenther 4, 2002
JIM KINNf R
LDWARDS BROTHERS INCORPORATED
2500 S STATE ST
ANN ARBOR. MI 48106
Alan W. Klimek, P.E., Director
Division of Water duality
F
I
SEA 1 Q 2(�
Suhject: NPDES Storrnwater Permit Coverage Renewal
Ed%vards Brothers Incorporated
COC Number NCC-050148
Harnett County
Dear Perrnittec:
Your facility is Cu1'r'Crttly CovCrcd lUr stormwater discharge under General Permit NC6050000. This hermit expires
on March 31, 2003. The Division staf' is currently in the Process of rewriting this purnlit and iS SChedulcd to have
the permit reissued by early spring of 2003. Once the permit is reissued. your facility would he eligible for
continued covermIC under the reissued permit.
ht order to assure your continued coverage under [tic general permit. you must apply to the Division of- Water
Quality ([7WQ) leer renewal of your permit coverage. To make this renewal process easier. we are infortning you in
advance that your perntil coverage will he expiring. Inclosed you will find a I-erntit Coverage Renewal;
Application Fornt. The application must he completed and returned by Octohu' 2. 2002 in order to assure
Continued Coverage under [hc general permit. Duc to stal7,md hu(hld COn.CtraIlltS. letters confirnling our receipt of
the completed application Will not he sent.
1"a111.11-C to request renewal within the thne period specified, may result in ❑ civil :isscssnient of at least $250.00.
Larger penalties ntay he assessed dupending on the (Ielincluency of [he request. Discharge ol'stornnvater from your
facility without Covc1`110c under a valid stormwater NPDES permit would constitute a violation of NCGS 143-215.1
and could result in assessments of civil penalties of up to $10.000 per clay.
Please note that rcccnl federal legislation has extended the "no exposure exclusion to all operators of industrial
facilities in any ol'the 1 I cate4,orics o1-"storn water discharges associated with industrial activily," (except
construction activities). Ifyou t'CCI your facility Can certify a condition ol, "no exposure", i.C. the facility industrial
materials and operations arc not exposed to stormwater, you Can apply for [lie no exposure exclusion. For additional
information contact the Central Office Storntwater Staff mcinher listed below or check the stormwater & General
Permits Unit Web Site at http://li2o.cnr,state,nC.us/su/stornlwater.litntl
If the subject stormwater discharge to waters of the state has been terminated. please complete the enclosed
Rescission Request Fortin. Mailing instructions are listed on file bottom of -the form. You will he notified when [frc
rescission process has hccn Connpleted.
If you have any questions regarding the permit renewal procedures plctlsu contact Ricky Revels of the Fayetteville
Rcuional Office at 910-486-1541 or Aisha Lau of the Central Oflicc stormwater Unit al [phone], cxt. 578
Sincerely.
Bradley Bennet(, Supervisor
slorolwatcr and General Permits Unit
cc: Central Files
Stornnvalcr and Generai Permits Unit Files
Fayetteville Regional ( liTice
ern
NCDENR
N. C. Division o1 Water Quatily 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1- 800-623.7748

�k�
State of Notch Carolina
Department of Environment
and Natural Resources N194A,
Division of Water Quality 4 • •
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary E N F 1
A. Preston Howard, Jr., P.E., Director
April 30, 1998 � � ®
WILLIAM BOGEN MAY 0 6 1998
EDWARDS BROTHERS INC.
2500 S STATE ST. _
ANN ARBOR, MI 48106 FAYM. F\1' 1« - `=
Subject: Reissued Stormwater General Permit for Certificate of Coverage No. NCG050148
Harnett County
Dear Permittee:
In response to your renewal application for continued coverage under the subject permit, 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 North Carolina and the US Environmental Protection agency
dated December 6, 1983.
The following information is included with your permit package:
■ A copy of the stormwater general permit.
■ A Stormwater Pollution Prevention Plan Certification Form. This form certifies that you have
developed and implemented the Stormwater Pollution Prevention Plan (SPPP) required in your
permit. This form must be completed and returned to the Division within 30 days of receipt of
this letter. DO NOT send the SPPP with the signed form.
■ Five copies of Analytical Monitoring forms.
■ Five copies of Qualitative Monitoring forms.
■ A copy of a Technical Bulletin on the stormwater program which outlines program components
and addresses frequently asked questions.
■ A corrected Certificate of Coverage if you indicated a name or address change on the Renewal
Form returned to the Division.
Your certificate of coverage is not transferable except after notice to DWQ. 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
DWQ or permits required by the Division of Land Resources, Division of Air Quality, Coastal Area
Management Act or any other Federal or Local governmental permits that may be required.
If you have any questions concerning this permit or other attached documents, please contact the
Stormwater and General Permits Unit at telephone number [phone]
Sincerely,
foA. Preston Howard, Jr., P. E.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

State of North Carolina
Department of Environment,
`Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
November 12, 1993
Mr. Robert B Lacoste
Edwards Brothers Inc.
2500 S State St.
Ann Arbor, MI 48106
Subject: General Permit No. NCG050000
Edwards Brothers Inc.
COC NCG050148
Harnett County
Dear Mr. Lacoste:
In accordance with your application for discharge permit received on October 13, 1993, 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
December 6, 1983.
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 Environmental Management. The Division of Environmental Management 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 Environmental Management 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 Mr. Bill Mills at telephone number 919/733-
5083.
Sine ffrt Gal Signed ?:
Coleen H. Sullins
A. Preston Howard, Jr., P. E.
cc: Fayetteville Regional Office
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
_#. _..._ ►1C I IIII
STORMWATER DISCHARGES
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,
Edwards Brothers, Inc.
is hereby authorized to discharge stormwater from a facility located at
Edwards Brothers, Inc.
800 Edwards Drive
Lillington
Harnett County
to receiving waters designated as an unnamed tributary to the Cape Fear River in the Cape Fear River Basin
in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts 1, 11, 11I
and IV of General Permit No. NCG050000 as attached.
This Certificate of Coverage shall become effective November 12, 1993,
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this date November 12, 1993.
Original Signed By
Coleen H. Sullins
A. Preston Howard, Jr., P.E., Director
Division of Environmental Management
By Authority of the Environmental Management Commission

1.178
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5254 IV SE FAYETTEVILLE 25 M).
SCALE 1:24 000
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MN_ 1000 1000 2000 3000 4000 5000 6000 7000 FEET
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116 MILS I.16 CONTOUR INTERVAL 10 FEET
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EJTM GRID AND 1987 MAGNETIC NORTH
DECLINATION AT CENTER OF SHEET THIS MAP COMPLIES WITH NATIONAL MAP ACCURACY STANDARDS
FOR SALE BY U. S. GEOLOGICAL SURVEY
DENVER, COLORADO 80225, OR RESTON, VIRGINIA 22092
A FOLDER DESCRIBING TOPOGRAPHIC MAPS AND SYMBOLS IS AVAILABLE ON REQUEST

FACILITY r., f••r. .•�jD W A}zDs
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SUS Elk."3iN 05 - o(p- 0'-
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STREAM CLASS
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DISCHARGE CLASSY
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EXPIRATION DATE
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STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
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DOC TYPE
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❑ MONITORING REPORTS
DOC DATE
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Lawyer, Mike
From: Chris Fowler <[e-mail]>
Sent: Wednesday, December 05, 2018 11:21 AM
To: Lawyer, Mike
Subject: RE: [External] Storm water outfall
Yes the cleanup has been completed. The cause of the malfunction was determined to be a bad o-ring. The plan moving
forward is to install a manual valve and auxiliary air supply to be able to open the valve.
Chris Fowler
Facilities/Environmental Coordinator ORC
Von Drehle Corporation
126 1" Street
Cordova, NC 28330
Main 910-410-9131
Office 910410-1313
Cell 910-995-0740
From: Lawyer, Mike <[e-mail]>
Sent: Wednesday, December 5, 2018 11:18 AM
To: Chris Fowler <[e-mail]>; La Bounty, Tim L <[e-mail]>
Cc: Justin Dawkins <[e-mail]>
Subject: RE: [External] Storm water outfall
Chris,
I have been out of the office for the past couple weeks dealing with a family medical issue, but I'm back at the office as
of today. I appreciate the notification and details regarding the release. Sounds like there was no impact to surface
waters. I will print out your e-mail for the -file. Has the response/cleanup been completed? Also, has the cause of the
process valve malfunction been determined and what, if any, procedures have been implemented to prevent such a
malfunction from recurring?
Thanks,
Mike
Michael Lawyer, CPSWQ
Environmental Program Consultant
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
910 433-3394 office
mike. lawyer(a)ncdenr.gov
225 Green Street, Suite 714
Fayetteville, NC 28301

mom
rill othlng • I
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Chris Fowler <[e-mail]>
Sent: Monday, November 26, 2018 10:32 AM
To: Lawyer, Mike <[e-mail]>; La Bounty, Tim L <[e-mail]>
Cc: Justin Dawkins <iustin.dawkinsevondrehle.com>
Subject: [External] Storm water outfall
All
On Thursday 11/22/2018 the mill had a process valve malfunction allowing approximately between 500 and
1000 gallons of water into the storm water drain. The water ran into the sediment pond owned by Von Drehle and into
an onsite dry pond bed that is now covered with trees and vegetation. The discharge site is approximately 100 yards
from the nearest body of water. We are pumping out the remaining water in the pond and returning to our water
treatment system as well as cleaning up from the parking lot any remaining residuals from the run off. I have attached
pictures of the sediment pons and the remaining water to be removed. Please let me know if there are any questions or
concerns.
Thanks
Chris Fowler
Facilities/Environmental Coordinator ORC
Von Drehle Corporation
126 111 Street
Cordova, NC 28330
Main 910-410-9131
Office 910410-1313
Cell 910-995-0740
This email has been scanned for spam and viruses. Click here to report this email as spam.

Lawyer, Mike
From:
Chris Fowler <[e-mail]>
Sent:
Monday, November 26, 2018 10:32 AM
To:
Lawyer, Mike; LaBounty, Tim L
Cc:
Justin Dawkins
Subject:
[External] Storm water outfall
Attachments:
D2466B3C.JPG; 35295AOD.JPG; F83FCOAA.JPG
Follow lip Flag: Follow up
Flag Status: Flagged
All
On Thursday 11/22/2018 the mill had a process valve malfunction allowing approximately between 500 and
1000 gallons of water into the storm water drain. The water ran into the sediment pond owned by Von Drehle and into
an onsite dry pond bed that is now covered with trees and vegetation. The discharge site is approximately 100 yards
from the nearest body of water. We are pumping out the remaining water in the pond and returning to our water
treatment system as well as cleaning up from the parking lot any remaining residuals from the run off. I have attached
pictures of the sediment pons and the remaining water to be removed. Please let me know if there are any questions or
concerns.
Thanks
Chris Fowler
Facilities/Environmental Coordinator ORC
Von Drehle Corporation
126 1" Street
Cordova, NC 28330
Main 910-410-9131
Office 910410-1313
Cell 910-995-0740

r , �
ROY COOPER
Governor
?, a
MICHAEL S. REGAN
Secretary
Energy, Mineral WILLIAM E. (TOBY) VINSON, 1R.
and Land Resources Interim Director
ENVIRONMENTAL QUALITY
April 27, 2018
Von Drehle Corporation
Attn: Justin Dawkins, Plant Manager
126 1It Street
Cordova, NC 28330
Subject: COMPLIANCE EVALUATION INSPECTION
NPDES Stormwater General Permit NCGO50000
Von Drehle Corporation
Von Drehle Cordova, LLC, Certificate of Coverage NCG050152
Richmond County
Dear Mr. Dawkins:
On April 25, 2018, a site inspection was conducted for the Von Drehle Cordova, LLC facility located at 126
1st Street, Cordova, Richmond County, North Carolina. A copy of the Compliance Inspection Report is
enclosed for your review. The time and assistance provided during the inspection by yourself and Mr. Chris
Fowler, Facilities and Environmental Coordinator, is greatly appreciated. The site visit and file review
revealed that the subject facility is covered by NPDES Stormwater General Permit NCG050000 under
Certificate of Coverage NCG050152. Permit coverage authorizes the discharge of stormwater from the
facility to receiving waters designated as Hitchcock Creek (Midway Pond, Steeles Mill Pond), a Class C
waterbody in the Yadkin -Pee Dee River Basin.
As a result of the inspection, the facility was found to be in compliance with the conditions of the NCG050000
permit. Please refer to the enclosed Compliance Inspection Report for additional comments and
observations made during the inspection.
Please be advised that violations of the NPDES Stormwater General Permit are subject to a civil
penalty assessment of up to $25,000 per day for each violation. If you or your staff have any questions,
comments, or needs assistance with understanding any aspect of your permit, please contact me at (910)`
433-3394 or by e-mail at [e-mail].
Sincerel ,
Michael Lawyer, CPSWQ
Environmental Program Consultant
DEMLR
Enclosure
cc: FRO — DEMLR, Stormwater Files
State of North Carolina I Fatvironmenial Quality 1 Energy, Mineral and Land Resources
Fayetteville Regional Office 1 225 Green Street, Suite 714 1 Fayetteville, NC 28301
910-433-3300

Compliance Inspection Report
Permit: NCGO50152 Effective: 06/01113 Expiration: 05/31118 Owner : Von Drehle Corporation
SOC: Effective: Expiration: Facility: Von Drehle Cordova, LLC
County: Richmond 126 First St
Region: Fayetteville
Cordova NC 28330
Contact Person: Justin Dawkins Title: Plant Manager Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Certification: Phone:
On -site representative Justin Dawkins 910-410-9131
On -site representative Christopher C Fowler 910410-1313
Related Permits:
Inspection Date: 04/2512018 EntryTime: 10:15AM Exit Time: 11:17AM
Primary Inspector: Mike Lawyer�c�x^ Phone: [phone] Exj.12� Secondary Inspector(s): 2 3 rr1
Reason for Inspection: Follow-up Inspection Type: Compliance Evaluation
Permit Inspection Type: Apparel/Printing/Paper/Leather/Rubber Stormwater Discharge COG
Facility Status: Compliant Not Compliant
Question Areas:
® Storm water
(See attachment summary)
Page: 1

Permit: NCGO50152 Owner - Facility: Von Drehle Corporation
Inspection Date: 04125/201B Inspection Type : Compliance Evaluation Reason for Visit: Follow-up
Inspection Summary:
Inspection conducted as follow-up to the previous inspection conducted on March 8, 2017, which resulted in the issuance of
a Notice of Violation for failure to conduct and record Qualitative Monitoring in accordance with permit conditions. Met with
Justin Dawkins, Plant Manager, and Chris Fowler, Facilities and Environmental Coordinator. Records indicate that
semi-annual Qualitative Monitoring has been conducted since the previous inspection at the facility's two stormwater
discharge outfalls in the first and second half of 2017 as well as the first half of 2018. Facility's Stormwater Pollution
Prevention Plan has been reviewed and updated per the conditions of the permit. Observations were made -of site conditions
including several storm drains with filters, stormwater discharge outfalls and the waste sludge area. At the time of
inspection, facility appeared to be well maintained and has come into compliance with the conditions of the NCG050000
permit.
Page: 2

Permit: NCGO50152 Owner - Facility: Von Drehle Corporation
Inspection Date: 04/25/2018 Inspection Type : Compliance Evaluation Reason for Visit: Follow-up
Stormwater Pollution Prevention Plan
Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan?
®❑ ❑ ❑
# Does the Plan include a General Location (USGS) map?
■ ❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
® ❑ ❑ ❑
# 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?
M ❑ ❑ ❑
# Does the facility provide all necessary secondary containment?
E ❑ ❑ ❑
# Does the Plan include a 13MP summary?
®. ❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
®❑ ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
❑ ❑ ❑
# Does the facility provide and document Employee Training?
® ❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
® ❑ ❑ ❑
# Is the Plan reviewed and updated annually?
® ❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
❑ ❑ ❑
Comment
Qualitative Monitoring
Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ®❑ ❑ ❑
Comment:
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? ❑ 1-10 ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ 0 ❑
Comment:
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? E ❑ ❑ ❑
# Were all outfalls observed during the inspection? ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ® ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ®❑ ❑ ❑
Comment:
Page: 3

Energy. Mineral &
rand Resources
ENVIRONMENTAL QUALITY
March 26, 2018
Raymond Von Drehle
Von Drehle Corporation
612 Third Ave Ne
Hickory, NC 286015164
ROY COOPER
Governor
MICHAEL S. REGAN
secretary
WILLIAM E. (TOBY) VINSON, JR.
Interim Director
Subject: NPDES General Permit Renewal and Electronic Reporting Requirements
Von Drehle Cordova, LLC
NPDES Permit Certificate of Coverage (COC) Number: NCGO50152
Dear NPDES Permittee:
The General Permit this facility is covered under expires on May 31, 2018. 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: https://deg.nc.gov/about/divisions/enerpy-mineral-land-resources/npdes-
industrial-stormwater.
The Stormwater Program will post the draft General Permit for public comment on our website above in
mid -April. The public comment period will conclude in mid -May, and the new General Permit is
scheduled to become effective on June 1, 2018. Upon issuance of the final General Permit, you will be
sent instructions about obtaining your new Certificate of Coverage (COC).
Although renewed coverage will be 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 April 30, 2018.
(2) You must submit stormwater outfall information on-line no later than May 18, 2018 in
preparation for electronic data monitoring report (eDMR) requirements.
Permit Contact Information
Please review the permit contact information we have in our database. You can do this via a link in the
Manage Information for an Existing Permit section of our website above. Ensure that Owner
Affiliation and Permit Contact are accurate, and that e-mail addresses are provided. Instructions for
updating contact information (including an on-line form) are available at:
https:lldeg.nc.gov/about/divisions/energy-mineral-land-resource lnpdes-industrial-stormwater.
State aENorth Carolina I Environmental Quality I Energy, Mineral and Land Resources
512 N. Salisbury Street 11612 Mail Service Center I Raleigh. North Carolina 27699-1612
919 707 9200

Submitting Outfall Information for E-Reporting,
The U.S. Environmental Protection Agency (EPA) finalized the National Pollutant Discharge Elimination
System (NPDES) Electronic Reporting Rule in December 2015. The rule requires NPDES regulated
facilities to report certain information electronically, instead of filing written paper reports. EPA is
phasing in the requirements of the rule over a 5-year period. The first phase required regulated entities
to submit Data Monitoring Reports (DMRs) electronically starting on December 21, 2016.
We realize that deadline has passed, and EPA is aware that NC is working on expanding the State's
eDMR System (currently,available to NPDES Wastewater Permit -holders) to include Stormwater
Program DMR reporting. As soon as eDMR is available for your permit, we will notify you. In the
meantime, we must collect information about the discharge outfalls at your facility to prepare the
system to flow data to EPA as the new federal rule mandates.
To submit outfall information to DEQ: Go to the following website and enter the discharge outfall
number, type of discharge, receiving water information, representative outfall status information, and
other details no later than May 18, 2018. The website will walk you through all steps.
The website is: https://deg.nc.gov/about/stormwater-program/stormwater-outfall-collection
For more information on electronic reporting to NC DEMLR, visit
http:/Zde�ov/about/divisions/energy-mineral-land-resources/stormwater/ereport!ng-rule or
contact Bethany Georgoulias at [phone] or via email at [e-mail]_, or
contact Robert Patterson at [phone] or via email [e-mail].
Cc: Stormwater Program Permit File
Sincerely,
Annette Lucas, P.E.
Supervisor, DEMLR Stormwater Program
Nothing Compares��
State orNorth Carolina I Environmental Quality I Energy, Mineral and Land Resources
512 N. Salisbury Street 1 1612 Mail Service Center I Raleigh, North Carolina 2764*1612
919 707 Q200

Lawyer, Mike
From: Chris Fowler <[e-mail]>
Sent: tTuesday, Nl5—rch`21; 2017-8:00-Am.7
To: Lawyer, Mike
Cc: Justin Dawkins; Michael Bryant
Subject: RE: stormwater inspection
Attachments: Scan.pdf
Thanks again for your help and for the information you provided. Attached_is_my-response to the NOV? Please let me
know if you need anything further.
Thanks
Chris Fowler
Land Application ORC
von Drehle Corporation
Office [phone]
Cell [phone]
From: Lawyer, Mike [mailto:[e-mail]]
Sent: Tuesday, March 14, 2017 1:09 PM
To: Justin Dawkins; Chris Fowler
Subject: stormwater inspection
Justin & Chris,
I appreciate everyone's time and assistance during my stormwater inspection last week. Our office is issuing a Notice of
Violation of permit conditions based on the lack of qualitative (visual) monitoring records as discussed during the
inspection and detailed further in the attached report.
Also attached is a copy of the stormwater Permit Ownership Affiliation Designation Form. This form is used to update
affiliations (responsible official, contact person, etc.) as opposed to a change in the name or actual ownership of the
company. If there will be a name and/or ownership change, then use the form titled Stormwater Permit
Name/Ownership Change Form, which is also attached.
In addition, I have attached a copy of the rules concerning mobile car washing operations, which would also apply to
pressure washing activities, and the rules pertaining to reclaimed water use.
If there are any questions or concerns, please contact me.
Mike
Michael Lawyer, CPSWQ
Environmental Program Consultant
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality

910 433-3394 office
mike. [e-mail]
225 Green Street, Suite 714
Fayetteville, NC 28301
.: =7 Nothing Compares
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

March 14, 2017
Mr. Lawyer,
I received your email today regarding the NOV as well as the Owner Affiliation Designation form. As we
discussed in your visit I am the environmental and facilities coordinator for the Cordova operation. 1
have been with the company for ten years and have been responsible for land application for a year and
have been assigned the responsibility of storm water this year. During the time from your 2012 visit until
now there has been quite a bit of turnover at our facility. We had three EH5 managers and two plant
managers during this time. Mrs. Penny Wallace was responsible for doing the inspections and turning
them in to the EH5 director and later on the plant manager at the time. Unfortunately those records
could not be located after those parties were no longer employed by von Drehle. Moving forward 1 will
have sole responsibility for record keeping and permit compliance. As an additional measure to prevent
a loss of information in the future I will be writing a process that will detail how the records are kept
where they are located and a brief summary of the processes used to maintain the storm water system
at the mill. This information will be incorporated into our SWPPP. Thank for your time and please let me
know if there is anything else you need.
Sincerely,
Chris Fowler
Facilities -Environmental Coordinator

NCDENR
Nome Cu " Dawn —E-T oK
EMnwar.Mn+T MID Nx 1 - FiC90l es
Division of Energy, Mineral and Land Resources
Land Quality Section / Stormwater Permitting Program
National Pollutant Discharge Elimination System (NPDES)
PERMIT OWNER AFFILIATION DESIGNATION FORM
(Individual Legally Responsible for Permit)
Use this form if there has been:
FOR AGENCY USE ONLY
Date Received
Year
Month
Da
NO CHANGE in facility ownership or facility name, but the individual
who is legally responsible for the permit has changed.
If the name of the facility has changed, or if the ownership of the facility has changed,
do NOT use this form. Instead, you must fill out a Name -Ownership Change Form
and submit the completed form with all required documentation.
What does "legally responsible individual" mean?
The person is either:
a
• the responsible corporate officer (for a corporation); ' ,
• the principle executive officer or ranking elected official (for a municipality, state, raI pr other public
agency);
( ,1�Y
• the general partner or proprietor (for a partnership or sole proprietorship);
• or, the duly authorized representative of one of the above.
1) Enter the permit number for which this change in Legally Responsible Individual ("Owner Affiliation")
applies:
Individual Permit (or) Certificate of Coverage
N I C I S 16 1S-j 01 o p 0 I N I C 1 G 0-50/ I S Z
2) Facility Information:
Facility name: 1/4J,U /)12e#44 C-1P/1�-/2 11 r/o/J
Company/Owner Organization: _ 162,(, /D40,y66 e--X /-+!sJ24
Facility address: 2z '-
Address
City State Zip /
To find the current legally responsible person associated with your permit, go to this website:
http://portal.ncdenr.orp-/web/ir/sw-permit-contacts and run the Permit Contact Summary Report.
3) OLD OWNER AFFILIATION that should be removed:
Previous legally responsible individual: /Z/1 `f j--oiv o 1/?N 0/1&
First M] Last
4) NEW OWNER AFFILIATION (legally responsible for the permit):
Person legally responsible for this permit:
EVS r ira 0 l) 4 Cv 4I& S
First [ Last
SWU-0WNERAFFI L-25Ju1y2fl 14
Page i of 2

NPDES Stormwater Permit OWNER AFFILATION DESIGNATION Form
(if no Facility NarnelOwnership Change)
Title
ILL /sr 5T�Fyri
Mailing Address
Co200v4 AiC 2 g33c)
City State Zip
Telephone E-mail Address
( I--,) y;o 51
Fax Number
S) Reason for this change:
A result of: Employee or management change
❑ Inappropriate or incorrect designation before
❑ Other
If other please explain:
The certification below must be completed and signed by the permit holder.
PERMITTEE CERTIFICATION.
I, :J:zS't �� �K r� S , attest that this application for this change in Owner Affiliation
(person legally responsible for the permit) has been reviewed and is accurate and complete to the best of my
knowledge. I understand that if all required parts of this form are not completed, this change may not be
pro
ce d.
Signature Date
PLEASE SEND THE COMPLETED FORM TO:
Division of Energy, Mineral and Land Resources
Stormwater Permitting Program
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
For more information or staff contacts, please tali 919-707-9220 or visit the website at:
http://portal.nedenr.orjz/web/lr/stormwater
Page 2 of 2
SW U-0WNE RAFF IL-25July2014

■ 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 mailpiece,
or on the front if space permits.
Article Addressed to:
VON DRE14LE CORPORATION
ATTN: JUSTIN DAWKINS, PLANT
126 1ST STREET
CORDOVA, NC 28330
❑ Agent
❑ Addressee
B. Re eive by ed N } C. Date of Delivery
D. Is deli ery ad ress different f m item ? ❑ Yes
If YES, enter delivery addreA below: 1 ❑ No 1
AGER {
LIAR 1 7 2017
3. Service Type
,i(Certified Mail6 ❑ Priority Mall Express"'
❑ Reglstered Return Receipt for Merchandise
❑ Insured Mail ❑ Collect on Delivery
4. Restricted Delivery? (Extra Fee) ❑ Yes
2. Micle Number 7012 3050 0001 9398 7041
(Transfer from service label)
PS Form 3811, July 2013 Domestic Return Receipt

UNITED STATES'PQSTAL'! ER ICE
5 _- 2-1 r
First -Class Mail
Postage & Fees Paid
USPS .
Permit No. G-10
• Sender: Please print your name, address, and ZIP+4® in this box*
NCDI Q - 1)1-7 vMLR
ATTN: TIMOTHY L. LaBOUNTY, REGIONAL ENGINEER
225 GREEN STREET, SUITE 714 ��� D V E
FAYI-•TTEVILLE, NC 2930I
MAR 17 z017
DEQ-FAYET;-VIL LE REGIONAL OFF
11"II'It'1I11I1I1111i1'111111111111,1,11111I,II1+110110)II,III,I

Energy, Mineral
and Land Resources
ENVIRONMENTAL QUALITY
March 10, 2017
CERTIFIED MAIL: 7012 3050 0001 9398 7041
RETURN RECEIPT REQUESTED
Von Drehle Corporation
Attn: Justin Dawkins, Plant Manager
126 1 st Street
Cordova, NC 28330
Subject: NOTICE OF VIOLATION (NOV-2017-PC-0146)
NPDES Stormwater General Permit NCG050000
Von Drehle Corporation
Von Drehle Cordova, LLC, Certificate of Coverage NCGO50152
Richmond County
Dear Mr. Dawkins:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
TRACY DAVIS
Director
On March 8, 2017, Mike Lawyer, Environmental Program Consultant from the Fayetteville Regional Office of
the Division of Energy, Mineral and Land Resources (DEMLR), conducted a site inspection for the Von
Drehle Cordova, LLC facility located at 126 1st Street, Cordova, Richmond County, North Carolina. A copy of
the Compliance Inspection Report is enclosed for your review. Along with yourself, Mr. Chris Fowler,
Facilities & Environmental Coordinator, and Mr. Michael Bryant, Regional Safety Manager, were also present
during the inspection and all of your time and assistance is greatly appreciated. The site visit and file review
revealed that the subject facility is covered by NPDES Stormwater General Permit NGG050000 under
Certificate of Coverage NCG050152. Permit coverage authorizes the discharge of stormwater from the
facility to receiving waters designated as Hitchcock Creek (Midway Pond, Steeles Mill Pond), a Class C
waterbody in the Yadkin -Pee Dee River Basin.
As a result of the site inspection, the following violation of permit conditions is noted:
1) Qualitative Monitoring
Qualitative 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 violation has
occurred as well as a Plan of Action to prevent this violation from re -occurring.
State of North Carolina I Environmental Quality I Energy, Mineral and Land Resources
Fayetteville Regional Office 1 225 Green Street, Suite 714 I Fayetteville, NC 28301
910-433-3300

Thank you for your attention to this matter. This office requires that the violation, as detailed above, be
properly resolved. This violation and any future violations are subject to a civil penalty assessment
of up to $25,000 per day for each violation. Should you have any questions regarding these matters,
please contact Mike Lawyer or myself at [phone].
Sincerely,
Ti othy L. LaBounty, PE
Regional Engineer
DEMLR
T1Jm l
Enclosure
ec: Chris Fowler, Facilities & Environmental Coordinator — Von Drehle Cordova, LLC
Laura Alexander, Administrative Assistant — DEMLR, Stormwater Permitting Program
cc: FRO — DEMLR, Stormwater Files-NCG050152
Postal
CERTIFIED MAIL,.
RECEIPT
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(DomesticOnly,, Insurance
Coverage Provided)
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Compliance Inspection Report
Permit: NCGO50152 Effective: 06/01/13 Expiration: 05/31/18 Owner: Von Drehle Corporation
SOC: Effective: Expiration: Facility: Von Drehle Cordova, LLC
County: Richmond 126 First St
Region: Fayetteville
Cordova NC 28330
Contact Person: Justin Dawkins Title: Plant Manager Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Certification: Phone:
On -site representative Justin Dawkins 910-410-9131
On -site representative Michael Bryant
On -site representative Christopher C Fowler 910-410-1313
Related Permits:
Inspection pate: 03/08/2017 Entry Time: 1 0AM Exit Time: 12:30PM
Primary Inspector: Mike Lawyee Phone: [phone] Ext-7-29—
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Apparel/Printing/Paper/Leather/Rubber Stormwater Discharge COC
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page: 1

Per,it: NCGO50152 Owner- Facility: Von Drehle Corporation
Inspection Date: 03108/2017 Inspection Type : Compliance Evaluabon Reason for Visit: Routine
Inspection Summary:
Met with Justin Dawkins, Plant Manager, Chris Fowler, Facilities & Environmental Coordinator, and Michael Bryant,
Regional Safety Manager, Reviewed facility's Stormwater Pollution Prevention Plan (SPPP) and available Qualitative
Monitoring records. The SPPP appeared to contain all permit -required components with some minor revisions needed as
discussed during the inspection. Monitoring records under the current permit cycle covered only the second half of 2013
and second half of 2016 for the facility's two outfalls. No documentation of monitoring was avalable for 2014, 2015 or first
half of 2016. After the records review, observations of site conditions were made including: several of the site's storm drains
all of which contain filter socks under the grates to help capture solids and other debris; the waste sludge area, which is
swept twice daily; and the facility's two stormwater discharge outfalis. A tour of the manufacturing process was also
conducted. During the exit interview, a discussion was held concerning compliance with the monitoring conditions of the
NCG050000 stormwater permit and that a Notice of Violation would likely be issued due to the lack of monitoring records,
which was a compliance issue for the previous two inspections conducted in 2008 and 2012.
Page: 2

Permit: NCGO50152 Owner - Facility: Von Drenle Corporation
Inspection Rate: 03/0812017 Inspection Type ;Compliance Evaluation Reason for Visit: Routine
Analytical Monitoring Yes No NA NF
Has the facility conducted its Analytical monitoring? ❑ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ M ❑
Comment: Facility does not meet the requirements in the NCGO50000 permit for having to conduct_
Analytical Monitoring.
Permit and Outfalls Yes No NA NE
# is a copy of the Permit and the Certificate of Coverage available at the site? 0 ❑ ❑ ❑
# Were all outfalls observed during the inspection? E ❑ ❑ ❑
# If the facility has representative outfail status, is it properly documented by the Division? ❑ ❑ ■ ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ■ ❑ ❑ ❑
Comment:
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ❑ ■ ❑ ❑
Comment: No documentation of Qualitative Monitoring conducted for 2014, 2015 or first half of 2016.
Stormwater Pollution Prevention Plan
Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan?
0 ❑ ❑ ❑
# Does the Plan include a General Location (USGS) map?
❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
N ❑ ❑ ❑
# 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?
. ❑ ❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
0 ❑ ❑ ❑
# Does the facility provide all necessary secondary containment?
❑ ❑ ❑
# Does the Plan include a BMP summary?
❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■ ❑ ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
❑ ❑ ❑
# Does the facility provide and document Employee Training?
❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
❑ ❑ ❑
# Is the Plan reviewed and updated annually?
0 ❑ ❑ ❑
# Does the Plan include a Stormwaler Facility Inspection Program?
0 ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
0 ❑ ❑ ❑
Page: 3

permit: NCG050152 Owner - Facility: Von Drehle Corporation
Inspection Date: 03/08/2017 Inspection Type : Comptiance Evaluation Reason for Visit: - Routine
Stormwater Pollution Prevention Plan Yes No NA NE
Comment:
Page: 4

Georgoulias, Bethany
From: [e-mail]
Sent: Tuesday, May 28, 2013 12:02 PM
To: SVCDENR.stormwater
Subject: Confirmation for Renewal of DWQ Stormwater NPDES General Permit
** Do not reply to this e-mail as it is from an unmonitored mailbox. **
Thanks for renewing your permit using our on-line option. No further action is necessary. The new General
Permit is available for printing from our website at http://portal.nedenr.org/web/wq/sw/su/npdessw,
If you have questions, please contact Bethany Georgoulias at [e-mail] a,ncdenr.gov phone (919)
807-6372 or Bradley Bennett at brad ley. bennett,anederingov phone [phone]. If you forgot to print your
Certificate of Coverage you can resubmit the data and print another copy.
This COC is issued 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 General Permit authorizes discharges of stormwater and specifies your obligations for discharge controls,
management, monitoring, reporting, and record keeping. Please review the new permit to familiarize yourself
with all of the changes. Parts III and IV contain the Standard Conditions, including Compliance and Liability,
Reporting, Monitoring and Records requirements; Operation and Maintenance obligations; and Definitions.
Your facility has six months from receipt of the COC to update its Stormwater Pollution Prevention Plan
(SPPP) to comply with changes in SPPP requirements. Other changes are effective immediately. Please note
that Tier 3 Actions (if applicable) are triggered by four benchmark exceedances beginning on the effective
date of the renewal permit and do not count prior exceedances. Please visit our website above to review the
new General Permit carefully.
Your coverage under the General Permit is transferable only through the specific action of DWQ. This permit
does not affect the legal requirements to obtain other permits which may be required by DENR, nor does it
relieve the permittee from responsibility for compliance with any other applicable federal, state, or local law,
rule, standard, ordinance, order, judgment, or decree.
CONFIRMATION DETAILS
Permit Number: NCG050152
Effective Date: �o �J�Zd 13
Expiration Date: S�3 I ?err S
Organization Name: Von Drehle Corporation
Facility Name: _ Von Drehle Cordova, LLC _ I
Admin Region: Fayetteville _
Coun Name: Richmond _
Regulated Activity: AppareULeather/Rubber/Printing/Misc manufacture
Receiving Stream Name'. Hitchcock Creek (Roberdel Lake)
Receiving Stream Class: WS-III;CA
Basin: Yadkin
Facility Address: 126 First St
401

Facili.y CCity: _ Cordova
First Name: ; -, — - ------Raymond — --- - --- —
Middle Name:
Last Name: - Von Drehle`_
Email: rvondrehle@,vondrehle.com
402

Lawyer, Mike
From: Dan Scott [[e-mail]]
Sent: Thursday, May 31, 2012 3:04 PM
To: Lawyer, Mike
Cc: Randy Bergman-, Joe Pankratz; Raymond von Drehle
Subject: VDC Cordova NOV/Inspection Report - Response
Attachments: Von Drehle Cordova 4-19-12 - NOV.pdf
Importance: High
Sensitivity: Confidential
I am writing in response to the your NOV/Inspection Report dated May 1, 2012. In this report you reference one
violation regarding NPDES Storm water Permit-NC050000, Certificate-NCG050152. Please find this detailed in the table
below with our response:
Violation
Response
Qualitative monitoring has not been conducted and
During the period leading up to and since your inspection
recorded in accordance with permit requirements (further
we have searched hard copy and electronic files in an
reference is made to the period 2009, 2010, and first half
attempt to find the records of monitoring for the period
of 2011)
indicated in your report. As you note some records were
later found. We've also interviewed long term employees
at the site to determine if this activity was performed. Our
employees at the site did report that they occasionally
observed this being conducted by the EHS Manager
previously employed at this location. However, we have
not been successful in locating the associated
documentation of these events. Unfortunately this person
is no longer employed by or associated with our company.
Regarding the matter of this NOV and the management of our Storm -water Pollution Prevention Plan, we ask that you
please consider the following important points:
Over the past year our company has realized opportunities such as this to improve our Environmental, Health
and Safety Management Systems. As a result we've committed additional resources and placed an experienced
professional into the position of Director of EHS last September. His responsibility is to ensure compliance to
these and other regulatory requirements.
As a result of this you will recall that our SWPPP was completely rewritten and now addresses all the violations
and concerns reported by you at your previous site inspection. These included the evaluation of feasible
alternatives to current practices, TMDL of receiving waters, annual review and update of the plan, facility .
inspection program, qualitative monitoring and evaluation of non storm water discharges. It also includes
additional forms and other documents to facilitate the management of required information in support of
compliance with the Permit.
Since the assignment of this new resource all the proper monitoring has been conducted and documented as
required in the Permit.
To improve the management of records we have developed a list of all EHS records associated with the
operation of this site. This list includes the name of the record, the location of the record, the person
responsible for the record and the retention period. In addition, we've put in place a periodic audit to ensure
these records are maintained as specified in the Records Master List.

• The proper maintenance, care and order of outside areas and storm water management equipment is being
conducted as evidenced in your site inspection and report. In addition all other requirements are noted as being
in 100%compliance.
• There are no reports from within our community of storm water runoff from our operations having a negative
impact on the natural resources of the State, to public health or to private property.
• There is no information to indicate an effect on the ground or surface water quality.
+ Our company has not realized any financial gain or competitive advantage because of this.
+ I'd like to also point out that the von Drehle Corporation has committed itself to compliance with all regulatory
requirements. These matters are a priority and are regularly discussed by our leadership and site management.
We are working hard at all our locations to make improvements in our EHS Management Systems.
In closing, I want to express our sincere appreciation for your inspection/consultation and the improvement
opportunities you have pointed out.
Kindest regards,
Dan Scott
Dan Scott
Director of Environmental Health & Safety
von Drehle Corporation
612 Third Avenue NE
Hickory, NC 28601-5164
www.vondrehle.com
From: Lawyer, Mike [mailtQ:[e-mail]]
Sent: Friday, May 04, 2012 11:26 AM
To: Dan Scott
Subject: NOV/inspection report
Dan,
Attached is a copy of the Notice of Violation and inspection report for your files.
Mike
Michael Lawyer, CPSWQ
Environmental Specialist
NCDENR-Division of Water Quality
Surface Water Protection Section
Fayetteville Regional Office
Direct: [phone]
Main: [phone]
Fax: [phone]
e-mail: [e-mail]

■ Complete Items 1, 2, and 3. Also complete
4 If Restricted Delivery is desired.
■ Print your name and address on the reverse
so that we can return the card to you.
LA-SigItem
B.
■ Attach this card to the back of the mallpiece,
or oiithe front If space permits.
D. s d iv
If YES,
1. Artloleltic�eessed to: r,
V0N'Q*REHLE COR1'(.)RA,r[ON ;}
ATL '9HAYMOND VON DREHLF=
O.
612 FIM R-D AVENUE NF:
ram.:
1iI('K( .Y, NC 28601
❑ Agent
❑ Addressee
C. Date of Delivery
r address from Item I? ❑ Yes
It Very add�p low: ❑ No
',
3. service L—; 4-
XCertMed OqmpmwMail
❑ Registered Retum Receipt for Merchandlso
❑ Insured Mall ❑ C.O.D.
4. Restricted Delivery? (Extra Fee) ❑ yes
2. Articleumber 7009 0820 DO©O 2474 1,81r7
{Transfer
from se-1-la6e1J
PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540

UNITED STATES POSTAL SERVICE
First -Class Mail
Postag
USPSe & Fees Paid
Permit No. G-10
• Sender: Please print your name, address, and ZIP+4 in this box •
NC DEPT OF ENVIRONMENT & NATURAL RESOURCES
DIVISION OF WATER QUALITY
ATTN: MIKE LAWYER 225 GREEN ST, SUITE 714 DENR-FRO
FAYETTEVILLE NC 28301-5043
MAY 0 4 2012
I I J I Ili Ilk llH Ill I l I I,]H l!J ill I F J l ill$ ill ill 11 I I i I ill I ill

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P.E.
Governor Director
May 1, 2012
CERTIFIED MAIL: 7009 OB20 0000 2474 1817
RETURN RECEIPT REQUESTED
Von Drehle Corporation
Attn: Raymond Von Drehle, CEO
612 Third Avenue NE
Hickory, NC 28601
Subject: NOTICE OF VIOLATION (NOV-2012-PC-0159)
RECOMMENDATION FOR ENFORCEMENT
Von Drehle Corporation
Von Drehle Cordova, COC-NCGO50152
NPDES Stormwater General Perm it -NC G050000
Richmond County
Dear Mr. Von Drehle:
Dee Freeman
Secretary
On April 19, 2012, Mike Lawyer, Environmental Specialist from the Fayetteville Regional Office of the Division of
Water Quality, conducted a site inspection for the Von Drehle Cordova facility located at 126 First Street,
Cordova, Richmond County, North Carolina. A copy of the Compliance Inspection Report is enclosed for your
review. Mr. Dan Scott, Director of Environmental Health & Safety, was also present during the inspection and his
time and assistance is greatly appreciated. Permit coverage authorizes the discharge of stormwater from the
facility to receiving waters designated as Hitchcock Creek, a Class WS-II1;CA waterbody in the Yadkin -Pee Dee
River Basin, However, this should be corrected upon permit coverage renewal to accurately reflect the
appropriate segment of Hitchcock Creek (From dam at Roberdel Lake to Pee Dee River), which receives
stormwater discharges from the subject facility and is currently classified as a Class C waterbody. The site visit
and file review revealed that the subject facility is covered by NPDES Stormwater General Perm it-NCGO50000,
Certificate of Coverage-NCG050152.
As a result of the site inspection, the following permit condition violation is noted:
Qualitative Monitoring
Qualitative 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 violation has occurred as
well as a Plan of Action to prevent this violation from re -occurring.
Location: 225 Green Street, Suite 714, Fayetteville, North Carolina 28301
Phone: [phone] FAX [phone] Customer Service: 1.877-623-6748
Internet: http:llportal.ncdenr.orglweblwq
One
NorthCarolitia
An Equal apoorlunity 1 Atirmalive Aclion Employer

Thank you for your attention to this matter. This Office is considering sending a recommendation for enforcement
to the Director of the Division of Water Quality regarding this issue. Your above -mentioned response to this
correspondence will be considered in this process. This office requires that the violation, as detailed above,
be properly resolved. This violation and any future violations are subject to a civil penalty assessment of
up to $25,000 per day, per violation. Should you have any questions or concerns, please contact Mr. Lawyer or
myself at [phone].
Belinda S. Henson
Regional Supervisor
Surface Water Protection Section
BSH: MLlml
Enclosure
cc: Dan Scott, Director of Environmental Health & Safety -Von Drehle Cordova (via e-mail)
FRO -Surface Water Protection
Katie Merritt-WBS Compliance & Permits Unit
DWQ Central Files
LFor
S. Postal Service,,.,
ERTIFIED MAIL m RECEIPT
mestic Mall Only; No Insurance Coverage Provided)
delivery information visit our website at www.usps.coma
( f fI C I A i
©
Certified Fee
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0
Retum Receipt Fee
Postmark
C3
(Endorsement Required)
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C3
Restdcled Dellvory Fee
C3(Endorsement
Requlred)
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Total Postage 8 Fees
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PS Form 3800.August2006 U (fJ W See Roverse lor Instructions

Permit: NCG050152
SOC:
County: Richmond
Region: Fayetteville
Compliance Inspection Report
Effective: 10/22/10 Expiration: 05/31/13 Owner: Von Drehle Corporation
Effective: Expiration: Facility: Von Drehle Cordova, LLC
126 First St
Contact Person: Dan Scott
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
On -site representative Dan Scott
Related Permits:
Title: Dir. of Env. Health & Safet
Certification
Cordova NC 28330
Phone:
Inspection Date: 04/19/2012 Entry Time: 10-00 AM Exit Time: 11:50 AM
Primary Inspector: Mike Lawyer Phone: [phone]
Ex�
5 etor(s): 33a�
&jcWX_, -: Belinda S Henson ► "","" Phone: [phone] Ext,72r
Reason for Inspection: Routine Inspection Type: Compliance Evaluation 33Z io
Permit Inspection Type: Apparel/PrintinglPaperlLeather/Rubber Stormwater
Discharge COC
Facility Status: n Compliant ■ Not Compliant
Question Areas:
■ Storm Water
(See attachment summary)
Phone:
Phone:
Page: 1

Permit: NCG050152 Owner - Facility: Von Orehle Corporation
Inspection Date: 04/19/2012 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Previous inspection conducted on 1/9/08 resulted in the issuance of a Notice of Violation for failure to conduct and
document semi-annual Qualitative Monitoring as required by the NCG050000 general permit. Previous inspection report
also noted missing components in the facility's SWPPP. Met with Mr. Dan Scott, Director of Environmental Health &
Safety, on 4/19/12 to ensure compliance with all permit conditions. Mr. Scott provided revised/updated SWPPP for review,
which now contains all permit -required components. Work has been completed since previous inspection to install
stormwater collection system and consolidate the facility's multiple outfalls that were discharging directly into Hitchcock
Creek behind the plant into one discharge point. Facility also has a stormwater detention basin with outlet structure
located beside the plant giving the facility a total of two outfalls. Available records at the time of inspection showed visual
monitoring event conducted in November 2011 for the facility's two outfalls. Copies of visual monitoring records from 2008
were received via e-mail on 4/30/12. Documentation of visual monitoring conducted in 2009, 2010 and first half of 2011
could not be produced.
Page. 2

Permit: NCGO50152 Owner - Facility: Von Drehle Corporation
Inspection bate: 04/19/2012 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 In
# Does the Ran include a General Location (USGS) map?
■
n
n n
# Does the Plan include a "Narrative Description of Practices"?
■
n
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 spits occurring during the past 3 years?
■
n
n n
# Has the facility evaluated feasible alternatives to current practices?
■
n
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 Spifl Prevention and Response Plan (SPRP)?
■
n
n n
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
■
n
n ❑
# Does the facility provide and document Employee Training?
■
n
n In
# Does the Plan include a list of Responsible Party(s)?
■
n
n n
# Is the Plan reviewed and updated annually?
MOOD
# Does the Plan include a Stormwater Facility Inspection Program?
■
n
n , n
Has the Stormwater Pollution Prevention Plan been implemented?
■
n
In n
Comment:
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? n ® n n
Comment: Monitoring record available at time of inspection for November 2011 and
copies of records sent via e-mail for 2008, however no documentation of monitoring
conducted in 2009, 2010, or first half of 2011.
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? n n ■ n
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? In n ■
-- Comment:
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? ■ n n n
# Were all outfalls observed during the inspection? ■ n n n
# If the facility has representative outfall status, is it properly documented by the Division? n n ■
# Has the facility evaluated all illicit (non stormwater) discharges? ■ n n n
Page: 3

Permit: NCG050152 Owner - Facility: Von Drehle Corporation
Inspection Date: 04/19/2012 Inspection Type: Compiiance Evaluation Reason for Visit: Routine
Comment:
Page: 4

Lawyer, Mike
From: Dan Scott [[e-mail]]
Sent: Monday, April 30, 2012 1:14 PM
To: Lawyer, Mike
Subject: von Drehle Corporation Cordova Storm water Records
Attachments: Stormwater Monitoring and Certification Records 2008.pdf
As follow up to your inspection at our Cordova Operations I have searched the site records for monitoring information
have been successful in finding the attached records from 2008 that were not included in your review. Please contact
me any time with questions about this information.
Regards,
Dan Scott
Director of Environmental Health & Safety
von Drehle Corporation
612 Third Avenue NE
Hickory, NC 28601-5164
www.vondrehle.com

Stormwater Discharge OutfaIl (SDO)
Qualitative Monitoring Report
Permit No.: NlCI66IQI-IoIalo lUl or Certificate of Coverage No.: NIC/GlQlsl�s /L/SIo21
Facility Name: �7 e-en R
County: Phone No_ 9 \ p -- -'4 10 -- q t3 j
Inspector:
Date of Inspection:
By this signature, I certify that thisj_epors accurate and complete to the best of my knowledge:
(Signature of Permitiee or
I. . Outfall Description
Outfall No. Structure (pipe, ditch_, etc.),
Receiving Stream:
Describe the industrial activities that occur within the outfall drainage area:
2. Color
Describe the color of the discharge using basic colors (red, brown, blue, etc_) and tint (light, medium,
dark) as descriptors: 5;kg q-0 e, �.
Odor
Describe any distinct odors that the discharge may have (i.e., smells strongly of oil, weak chlorine odor,
etc.) go O_CLE _
4. Clarity
Choose the number which best describes the clarity of the discharge where 1 is clear and 10 is very
cloudy:
3
SWU-242-020705
Page 1
10

S. Floating Solids
Choose the number which best describes the amount of floating solids in the stonmwater discharge where
1 is no solids and 10 is the surface covered with floating solids:
2 3 4 5 6 7 8 9 10
6. Suspended Solids
Choose the number which best describes the amount of suspended solids in the stormwater discharge
where 1 is no solids and 10 is extremely muddy:
1 2 C3` 4 5 6 7 8 9 10
7. Foam
Is there any foam in the stonmwater discharge? Yes CED
8. Oil Sheen
Is there an oil sheen in the stormwater discharge? Yes No
9. Deposition at Outfall
Is there deposition of material (sediment, etc.) at or inunediately below the outfall? Yes No
10. Erosion at Outfall
Is there erosion at or immediately below the outfall? Yes �-
11. Other Obvious Indicators of Stormwater Pollution
List and describe
Note: Low clarity, high solids, and/or the presence of foam, oil sheen, deposition or erosion may be
indicative of conditions that warrant further investigation and corrective action.
Page 2
S VU-242-020705

Stormwater Discharge Outfall (SDO)
Qualitative Monitoring Report
Permit No.: NIC16Io /S l6lo/QIQI or Certificate of Coverage No.: NICIGI�fS /o%I sl.� 1
Facility Name:
County: 'K;c_� ("n"d PAone No. C (O �IlO -_Q [ L-
Inspector: 'r l u•
Date of Inspection:;3
By this signature, I certify thg61S)re,0At is accurate and complete to the best of my knowledge:
(Signature of Peruuittee
Outfall Description
Outfall No. C2Structure (pipe, ditch, etc.) 'y p
Receiving Stream:
Describe the industrial activities that occur within the outfall drainage area:
N-, ra v, c, kla l c ,.! arc--
2. Color
Describe the color of the discharge using basic colors (red, brown, blue, etc.) and tint (light, medium,
dark) as descriptors: L
3. Odor
Describe any distinct odors that the discharge may have (i.e., smells strongly of oil, weak chlorine odor,
etc-) Kn _.c'ioC` _
4. Clarity
Choose the number which best describes the clarity of the discharge where 1 is clear and 10 is very
cloudy:
3 4 5 6 7 8 9 10
Page 1
5 W U-243-020705

5. Floating Solids
Choose the number which best describes the amount of floating solids in the stormwater discharge where
I is no solids and 10 is the surface covered with floating solids:
2 3 4 5 6 7 8 9 10
.6. Suspended Solids
Choose the number which best describes the amount of suspended solids in the stormwater discharge
where I is no solids and 10 is extremely muddy:
1 2 4 5 6 7 8 9 10
7. Foam
Is there any foam in the stormwater discharge? Yes No
8. Oil Sheen
Is there an oil sheen in the stormwater discharge? Yes
9. Deposition at Outfali
Is there deposition of material (sediment, etc.) at or immediately below the outfalI? Yes No
10. Erosion at Outfall
Is there erosion at or immediately below the outfall? Yes Leo
] ] . Other Obvious Indicators of Stormwater Pollution
List and describe
Note: Low clarity, high solids, and/or the presence of foam, oil sheen, deposition or erosion maybe
indicative of conditions that warrant further investigation and corrective action.
Page 2
5 WU-242-020705

Stormwater Discharge Outfall (SDO)
Qualitative Monitoring Report
Permit No.: NICI o Q /S /a /o /v /o 1 or Certificate of Coverage No.: NICIG/a Is /d 11 Is I- I
Facility Name: f q .
County: _ �" c IN �n 5'n� r-i" _ .Phone No.
Inspector:
Date of Inspection: -7 - -3 - n
By this signature, I certify that 's re� is accurate and complete to the best of my knowledge:
-, " 7 ��
(Signature of Permittee or
1. Outfall Description
Outfall No. -:? Structure (pipe, ditch, etc.) ;
Receiving Stream:
Describe the industrial activities that occur within the outfall drainage area:
cL%� v- us -r c AL,,
2. Color
Describe the color of the' discharge using basic colors (red, brown, blue, etc.) and tint (light, medium,
dark) as descriptors: k" Lo v's
Odor
Describe any distinct odors that the discharge may have (i.e., smells strongly of oil, weak chlorine odor,
etc.) cy _ , C)r inc
4. Clarity
Choose the number which best describes the clarity of the discharge where 1 is clear and 10 is very
cloudy:
Page 1
SWU-242-020705
10

5. Floating Solids
Choose the number which best describes the amount of floating solids in the stormwater discharge where
1 is no solids and I0 is the surface covered with floating solids:
2 3 4 5 6 7 8 9 10
6. Suspended Solids
Choose the number which best describes the amount of suspended solids in the stormwater discharge
where 1 is no solids and 10 is extremely muddy:
1 2 (ZE�) 4 5 6 7 8 9 10
7. Foam
Is there any foam in the stormwater discharge? Yes No
8. Oil Sheen
Is there an oil sheen in the stormwater discharge? Yes
9. Deposition at Outfall
Is there deposition of material (sediment, etc.) at or immediately below the outfall7
10. Erosion at Outfall
Is there erosion at or immediately below the outfall? Yeses
11. Other Obvious Indicators of Stormwater Pollution
List and describe
Yes p
Note: Low clarity, high solids, and/or the presence of foam, oil sheen, deposition or erosion may be
indicative of conditions that warrant further investigation and corrective action.
Page 2
S WU-242.020705

Stormwater Discharge Outfall (SDO)
Qualitative Monitoring Report
Permit No.: NICI W cal 1 u /o /Qla I or Certificate of Coverage No.: NICIGIo / E/ g /LI sl�l
Facility Name: V e
County: R: c L,.ti.p... r Phone No. 9 10 - t.C]' 4 1'?1
Inspector: ToJA
Date of Inspection: 1! ' 10 - of oa ,tr
By this signature, I certi4eVatAo'report is accurate and complete to the best of my knowledge:
(Signature of Permittee or Designee)
1. Outfall Description
Outfall No. _I Structure (pipe, ditch, etc.) p
Receiving Stream:
Describe the industrial activities that occur within the outfall drainage area:
2. Color
Describe the color of the'discharge using basic colors (red, brown, blue, etc.) and tint (light, medium,
dark) as descriptors: rlln e-(:c ct%a q r— n eg+rnW
3. Odor
Describe any distinct odors that the discharge may have (i.e., smells strongly of oil, weak chlorine odor,
etc.) M I A
4. Clarity
Choose the number which best describes the clarity of the discharge where 1 is clear and 10 is very
cloudy:
1 2 3 4 5 6 7 S 9 10
Page 1
S WU-242-020705

5. Floating Solids
Choose the number which best describes the amount of floating solids in the stonnwater discharge where
1 is no solids and 10 is the surface covered with floating solids: IV
n
1 2 3 4 5 6 7 8 9 10
.6. Suspended Solids
Choose the number which best describes the amount of suspended solids in the stormwater discharge
where 1 is no solids and 10 is extremely muddy: N I
1 2 3 4 5 6 7 8 9 10
7. Foam
Is there any foam in the stormwater discharge?
8. Oil Sheen
Is there an oil sheen in the stormwater discharge?
Yes No �ja d�SG-Se
Yes No No ct;s c�a�5
9. Deposition at Outfall
Is there deposition of material (sediment, etc.) at or immediately below the outfall? Yes No
10. Erosion at Outfall
Is there erosion at or immediately below the outfall? Yes �o �
11. Other Obvious Indicators of Stormwater Pollution
List and describe
Note: Low clarity, high solids, and/or the presence of foam, oil sheen, deposition or erosion may be
indicative of conditions that warrant further investigation and corrective action.
Page 2
5 WU-242-020705

Stormwater Discharge OutfalI (SDO)
Qualitative Monitoring Report
Pemvt No.: NlCI C�/Q /s J�s/Qlrr/ a 1 or Certificate of Coverage No.: NIC/GJo I�IQILII�I
Facility Naive: Von preJ.ls Corp,
County. �isSesno++�! Phone No. ''10 - 441 o - 4 i 31
Inspector: I �lrt' 9' {)L, --.^
Date of Inspection: er -10 - pg
By this signature, I certify that t1 ;hpgff is accurate and complete to the best of my knowledge:
(Signature of Permittee or
1. Outfall ➢escripYion
Outfall No. Structure (pipe, ditch, etc.) ; t��
Receiving Stream:
Describe the industrial activities that occur within the outfall drainage area:
1.l - ! i ss w* &�eAr...��c`c 4ceGr` Q
2. Color
Describe the color of the' discharge using basic colors (red, brown, blue, etc_) and tint (light, medium,
dark) as descriptors: Mcz- A &c—"rc P_ 0A + 10; i n' ,�o - .
3. Odor
Describe any distinct odors that the discharge may have (i.e., smells strongly of oil, weals chlorine odor,
etc.) N l A
4. Clarity
Choose the number which best describes the clarity of the discharge where I is clear and 10 is very
cloudy: KtA
2
S WU-242-020705
Page 1
10

5. Floating Solids
Choose the number which best describes the amount of floating solids in the stormwater discharge where
1 is no solids and 10 is the surface covered with floating solids: NIA
1 2 3 4 5 6 7 8 9 i�� 10
.6. Suspended Solids
Choose the number which best describes the amount of suspended solids in the stormwater discharge
where 1 is no. solids and 10 is extremely muddy:
1 2 3 4 5 6 7 8 9 16
7, Foam
Is there any foam in the stormwater discharge? Yes o �(,SG�•o.TS
8. Oil Sheen
Is there an oil sheen in the stormwater discharge? Yes No t4c d�s��-o.r3
9. Deposition at Outfall
Is there deposition of material (sediment, etc.) at or immediately below the outfall?
10. Erosion at Outfall
Is there erosion at or immediately below the outfall? Yes
11. Other Obvious Indicators of Stormwater Pollution
List and describe
Yes
t�v d�stk%anj C_
Note: Low clarity, high solids, and/or the presence of foam, oil sheen, deposition or erosion may be
indicative of conditions that warrant further investigation and corrective action.
Page 2
SWU-242-020705

Stormwatelr Discharge Outfall (SDO)
Qualitative Monitoring Report
In
Permit No_: NIC/f�. I c�l�IQl�l�l�l or Certificate of Coverage No.: N/C/G/o /S'1Q1_L1_r1.L1
Facility Name:' Aor, rgth e 5,A2r-p
County: Q.r Phone No. ql-0 - 410 - 9 1 ?1
Inspector: odd �,06;"
Date of Jnspection: y_ - j o - o S;-
By this signature, I certify report is accurate and complete to the best of my knowledge:
(Signature of
or Designee)
I. Outfall Description
Outfall No. Structure (pipe, ditch, etc.) [�
Receiving Stream:
Describe the industrial activities that occur within the outfall drainage area:
a cllt&ring
2. Color
Describe the color of tbe' discharge using basic colors (red, brown, blue, etc.) and tint (light, medium,
dark) as descriptors: gc] e-Us e"�p
3. Odor
Describe any distinct odors that the discharge may have (i.e., smells strongly of oil, weak chlorine odor,
etc.) NA
4. Clarity
Choose the number which best describes the clarity of the discharge where 1 is clear and 10 is very
cloudy: 1 +M
2 3 4 5 6 7 8 9 10
Page I
S WU-242-020705

5. Floating Solids
Choose the number which best describes the amount of floating solids in the stormvvater discharge where
l is no solids and 10 is the surface covered with floating solids:
1 2 3 4 5 6 7 8 9 10
6. Suspended Solids
Choose the number which best describes the amount of suspended solids in the stormwater discharge
where 1 is no solids and 10 is extremely muddy: �l I
1 2 3 4 5 6 7 f 8 9 10
7. Foam
Is there any foam in the stormwater discharge?
8. Oil Sheen
Is there an oil sheen in the stonnwater discharge?
Yes No
�a JiSc-[-'v'r5e-
Yes
�U 'u5cLOJ3 L--
9. Deposition at Outfall
Is there deposition of material (sediment, etc.) at or immediately below the outfall?
10. Erosion at Outfall
Is there erosion at or immediately below the outfall? Yes
11. Other Obvious Indicators of Stormwater Pollution
List and describe
Yes
lye, d('s cr-&s�r--
Note: Low clarity, high solids, and/or the presence of foam, oil sheen, deposition or erosion may be
indicative of conditions that warrant further investigation and corrective action.
Page 2
5 WU-242-020705

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
Oetobel- 2-1,1010 DENR-FRO
Mr. Raymond Von Drehle, CEO
OCT 2 8 2010
Von Drchlc Cordova LLC DWO
612 Third Ave NE
Hickory, NC 28601
Subject: NPDES Stormwater Permit Coverage Renewal
Von Drehle Cordova LLC
COC Number NCG050152
Richmond County
Dear Pennittee:
In response to your renewal applicar ion for continued coverage under Stonnwater General Permit NCG050000
received August 31, 2010, the Division of' Water Quality (DWQ) is forwarding herewith the reissued Certificate of
Coverage and 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, datcd October 15, 2007 (or as subsequently amended.)
The following informatics is included with your permit package:
• A new Certificate of Coverage
• A copy of the stormwater General Permit
• A copy of a Technical Bulletin for the General Permit
• Five copies of the Discharge Monitoring Report (DMR) Form
• Five copies of the Annual Discharge Monitoring Report Form (if applicable)
• hive 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 changes in the reissued permit. Significant changes to the General Permit are
outlined in the attached Technical Bulletin.
Your coverage under the General Permit is transferable only through the specific action of DWQ.
Wetlands and Stormwater Branch
1617 Mail Service Center, Raleigh, Noah Carolina-7699 1617
Location: 512 N, Salisbury 51. Ralegh, North Carolina 27604
Phone: [phone] FAX: [phone] Cuslomei Service: 1-877-623-6748
Intel www.newaterquality org
An Equal Opoonungg 1 Alfirmarive Action Employer
ORe
North Carolina
Natrtrally

e
This pen -nit does not affect the legal requirements to obtain other permits which may he required by DENR, nor
does it relieve the permittee from responsibility for compliance with any other applicable federal, state, or local law,
rule, standard, ordinance, order, judgment, or decree.
If you have any questions regarding this permit package please contact the DWQ Stormwater Pennitting Unit at
919-807-b300,
Sincerely,
r
or Coleen 1-1, Sullins
cc; DWQ Central Files
Stonnwater Permitting Unit Niles
Fayetteville Regional Office

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT" NO. NCGO50000
CERTIFICA'rE OF COVERAGE No. NCG050152
STORMWATER DISCI-IAIZGES
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,
VON DREHLE CORDOVA LLC
is hereby authorized to discharge stormwatcr froni.a facility located at
Von Drehle Cordova L-LC
126 First Street
Cordova, NC
Richmond County
to receiving waters designated as Hitchcock Creek, a class WS-111; CA waterbody in the Yadkin -Pee Dee
River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set
forth in Parts I, II, 111, IV, V, and VI of the General Permit as attached.
This certificate of coverage shall become effective October 22, 2010.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day October 22, 20 10.
41 r'&
fi)r Coleen 1-1. Sullins, Director
Division of Water Quality
F: y Authority of the Environmental Management Conunission

STATE OF NORTH CAROLINA
DEPARTMENT OF ENV IRON MENI' AND NATURAL RESOURCES
DIVISION OI, WATER QUALITY
4:,ENERA1, PERNIFF NO. NCGO50000
CERTIFICATE OF COVERAGE No. NCGO50152
STORMWATE-R DISCHARGES
NA'FIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision oi'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,
VON DREI-ILL CORDOVA LLC
is hereby authorized to discharge stormwater from a facility located at
Von Drchle Cordova LLC
126 First Street
Cordova, NC
Richmond County
to receiving waters designated as Hitchcock Creek, a class WS-III; CA watcrbody in the Yadkin -Pee Dee
River Basin in accordance with thc effluent limitations, monitoring requirements, and other conditions set
forth in Parts 1; 11, III, IV, V, and VI of the General Permit as attached.
This certificate of coverage shall l:ccome effective October 22, 2010.
This Certificate of Coverage shall remain in effect for the duration of the General Pennit.
Signed this day October 22, 2010.
fur Coleen H. Sullins, Director
Division of Water Quality
13:y Authority of the Environmental Management Commission

ok'NAT�'q Permit Coverage
,
;q_ Renewal Application Form
National Pollutant Discharge Elimination System Certificate of Coverage Number
Stormwater General Permit NCG050000 NCGO50152
The following is the information currently in our database for your.faciiity. Please review this information carefully and make all
corrections/ additions as necessary in the space provided to the right of the current information.
Owner Affiliation Information
Owner / Organization Name:
Owner Contact:
kailing Address:
Phone Number:
Fax Number:
E-mail address:
Facility Contact Information
Facility Name.
Facility Physical Address:
Facility Contact:
Mailing Address:
Phone Number:
Fax Number:
E-mail address:
Permit Contact Information
Permit Contact:
Mailing Address:
Phone Number:
Fax Number:
E-mail address:
Discharge Information
Receiving Stream:
Stream Class:
Basin.
Sub -Basin:
Number of OutFalls:
* Reissued Permit will be mailed to the owner address
Von Drehle Cordova LLC
Raymond Von Drehle, CEO
612 Third Ave Ne
Hickory, NC 286015164
828-322-1805 Ext.
828-322-4145
[e-mail]
Laurel Hill Paper Co
126 First St
Cordova, NC 28330
126 First St
Cordova,NC 28330
910-997-4526 Ext.
910-997-7530
_qi ­
PO Box 159
Cordova, NC 28330
910-997-4526 Ext.
910-895-0734
Hitchcock Creek (Roberdel Lake)
WS-III;CA
Yadkin River Basin
03-07-16
A
s
r
� { r
.,mr-
FAW-firk 'ME
TZ4t.
r M +
■.
a
Impaired WaterslTMDL: Does this facility discharge to waters listed as impaired or waters with a finalized TMDL? ❑ Yes 1$ No
( formformation on these watersreferto http.Ilh2o.enr.state.nc.us/su/Impaired Waters TMDLI )
Facility/Activity Changes Please describe below any changes to your facility or activities since issuance of your permit. Attached a
separate sheet if necessary.
CERTIFICATION
I certify that I am familiar with the info
such information is true._cemDlete and_
application and that to the best of my
Signature % Date
Print or type name of person signing above Title
Please return this completed renewal application form to: SW General Permit Coverage RenewalStormwater Permitting Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
C
nd 'belief
N
0
M

� VON ®RE ®■I_ LE
CORPORATION
r�
To: SW General Permit Coverage Renewal
From: Todd Robinson —Von Dreh le Corporation
Date: August 26, 2010
Subject: SW Permit Renewal
910/410-9131
FAX [phone]
Upon review of our Storm Water permit I discovered that the permit, COC# NCG050152,
had not been renewed back in 2008. The VonDrehle Corporation purchased the facility in
May of 2007. The renewal letter was received on October 25, 2007. The letter stated
that the renewal information needed to be returned by November30, 2007 in order to
renew the permit. At the time the letter was received the corporation was continuing to
re -staff the facility. The renewal letter was lost or missed in the change of personal.
have called and discussed the situation with Mike Lawyer from the Division of Water
Quality, he verified that the permit was not active but also stated that The VonDrehle
Corporation has been paying our annual fee since 2007. Mr. Lawyer said for us to go
ahead and complete the renewal form and submit it to your attention. Attached you will
find the updated renewal form. If you have any questions please call me at 410-9192 or
e-mail any concerns or question to [e-mail].
Todd Robinson
Quality/EH&S Manager
VonDrehle Corporation
Cordova, NC
126 1st 5treet 0 Cordova, N.C. 28330

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Label/Receipt Number: 7001 2510 0006 9498 8152
Status: Delivered
Your item was delivered at 2:19 PM on January 25, 2008 in CORDOVA,
NC 28330,
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ilttp:Htrkcnfrm 1.smi.usps.com/PTSIntemetWeb/InterLabellnquiry.do 1 /28/2008

VCONDItENLE
CORPORATION
800/438-363 !
828/322-1 805
To: Belinda S. Henson & Mike Lawyer FAX [phone]
From: Todd Robinson, Quality, EH&S Manager — Von Drehle Corporation
Subject: Response for Notice of Violation (NOV-2008-PC-0059) pE1vvRR, RD
Date: February 21, 2008 FEB't 5 20
DWQ
Dear Ms. Henson,
On January 23, 2008 1 received your official Notice of Violation (NOV-2008-PC-0059). As noted in the
document we, at the Cordova Operation, had 6 areas of violation. Those violations were as follows:
• The facility did not have an updated Stormwater Pollution Prevention Plan (SPPP). The last copy
of the SPPP was several years old.
• The facility's SPPP was missing component of a feasibility study.
• The facility's SPPP was missing component for an inspection program.
• No records were available to show qualitative monitoring.
• The facility's SPPP was missing component for evaluation of Illicit (non stormwater) discharges.
• The facility's SPPP was missing component for an annual review program for the entire SPPP.
We are currently having the SPPP updated by an outside engineering firm. The firm was sent a copy of
the violation report with instructions for the necessary corrections. As of January 20, 20081 did receive
a rough draft of the new SPPP. Once I have reviewed the draft any correction s will be sent back to the
engineering firm for addition into the plan.•.,The completed plan will be finalized by March 28, 2008
The finalized SPPP will include sections to address the missing components:
• Feasibility Study — the plan will list all options that were evaluated and reasons why they were
not feasible.
• Inspection Program — the plan will include time frames for inspection and will note how many
inspections per year will be performed.
• Evaluation of Illicit Discharges —the plan will list all source of possible illicit discharges and
describe how they are contained within the process.
• Annual Review Program —the plan will an annual review completion date along with who needs
to be involved with the review of the SPPP.
Finally, the plan will include a written procedure for recording and filing of all Qualitative Inspections
performed. This will completed according to the terms within the above mentioned Inspection Program
which will be added to the SPPP,
have included a copy of your original Notice of Violation. If you have any questions please call or
Sincerely,
Todd Robinson
Phone:[phone] E-mail: todd.robinson@vondrehle.c�am
612 Third Avenue NE - Hickory, N.C. 28601.5164

0�0� W A rFRQG Michael F. Easley, Governor
1 William If Ross Jr , Secretary
09 North Carolina Department of Envirnrrment and Natural Resources
-�
Q DWG)L
Y Coleen H. Sullins, Director
Division of Water Quality
January 23, 2008
CERTIFIED MAIL: 7001 2510 0006 9498 8152
RETURN RECEIPT REQUESTED
Alan Hogan
Von Drehle Corporation
126 First Street
Cordova, NC 28330
Subject: NOTICE OF VIOLATION (NOV-2008-PC-0059)
Von Drehle Corporation
Von Drehle Cordova, LLC
NPDES Stormwater General Permit-NCG050152
Richmond County
Dear Mr. Hogan:
On January 9, 2008, Mike Lawyer from the Fayetteville Regional Office of the Division of
Water Quality, conducted a site inspection for the Von Drehle Cordova, LLC facility located at 126 First
Street in Cordova, Richmond County, North Carolina. A copy of the inspection report is enclosed for
your review. Mr. Todd Robinson, Quality/EH&S Manager, and Mr. Doug Bailey, Engineering Manager,
were also present during the inspection and their time and assistance is greatly appreciated. Stormwater
from the facility drains to Hitchcock Creek, a Class C water located in the Yadkin -Pee Dee River Basin.
The site visit and file review revealed that the subject facility is covered by NPDES Stormwater General
Permit-NCG050152.
Accordingly, the following observations and/or permit conditions violations (please see the
attached addendum for information about your permit) 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.
[Yes e No ❑ (see comments within enclosed inspection repord
2) Qualitative Monitoring
Qualitative monitoring has been conducted and recorded in accordance with pen -nit requirements.
es ❑ No ■
Onc
No thCarohna
Naturally
North Carolina Division nl' Wa1cr Qualify 225 Green Street -Suite 714 Fayetteville, NC 29301 Phone [phone] Customer Service
Internet: wwu.ncwatcwoahl .nr Fax [phone]
An Equal OpporiunitylAtfirmative Action Employer - 50% Recycled110% Post Consumer Paper

l
14
Page 2 ' - " *t`
Mr. Hogan
January 23, 2008
Other Observations:
Please refer to the enclosed Compliance Inspection Report for additional comments and observations.
Requested Response:
You are asked to respond to tills office, in writing, within 30 calendar days from receipt of this report.
Your response should include a plan of action to address the aforementioned violation (lack of
Qualitative Monitoring), comments made in the inspection summary, as well as a reasonable time frame
that you expect to be in full compliance with the conditions of the general permit.
Thank you for your attention to this matter. This office requires that the violation, as detailed
above, be properly resolved. This violation and any future violations are subject to a civil penalty
assessment of up to $25,000 per day for each violation. Should you have any questions regarding
these matters, please contact Mike Lawyer or myself at [phone].
Sincerely,
Belinda S. Henson
Regional Supervisor
Surface Water Protection Section
BSH: ML/ml
Enclosures (2)
cc: PRO -Surface Water Protection
NPS-Assistance & Compliance Oversight Unit
JI
,
-a I OFF0C�AL
USCo
Postage
fT
$
Cr Certified Fee
Postmark
Return Recelpt Fee
Here
O (Endorsement Requlred)
t7 Restricted Delivery Fee
© (Endorsement Required)
C=1 a Total Poste Alan Flogiln
rru Sent To Voll Drehle; Col•horatlO11
Vp W 126 First Street
p or PO Box No
1:1c,'ry,"srere,zrl Cordova, NC 28330
I
T

■ Complete items 1, 2, and 3. Also complete A.
item 4 if Restricted Delivery is desired.
■ Print your name and address on the reverse
so that we can return the card to you. B.
■ Attach this card to the back of the mailpiece,
or on the front if space permits.
Article Addressed to:
Alan 'HOL91)
Vol, corporation
126 F I rst Street
Cordova, NC 28` 0
• ❑Agent
LA'' ❑ Addressee
by (Printed Name) C. Date of Delivery
from item t? ❑ Yes
ss below: ❑ No
JAN 2 2a4�
3. Service Type
CertiflZ Mall Exp Mail
❑ ❑ m Receipt for Merchandise
4. Restr tted r7y? Ptra Fee) ❑ yes
2. Article Number
(transfer from service k eW , 7 0 01 2 510 0 0 0 6' 9498 81:5 2'
PS Form 3811, February 2004 Domestic Return Receipt 102595-02-WI540

UN[TEE)-S-TATFS-R A vC Ta..�.. Rt
sr ,,� ,4�s,.1r�r.�,: i��.rrPfts#Classl
�taqP.
• Sender: Please print your name, address, and ZIP+4 in this box •
�s[y h10RTN CAROIINA OGPARjMENT OF
2 5 GRE NFS.I RESTu AND TE 714F50UFiCFS
FAYEjTEVILLE. NC 28301-`�`t3 e.� 1

ADDENDUM
The National Pollutant Discharge Elimination System (NPDES) program was established under the
federal Clean Water Act and then delegated to the Division of Water Quality for implementation in
North Carolina. The NPDES permitting program for stormwater discharges was established in 1990.
Phase I focuses on site and operations planning to reduce pollutant sources.
Through the NPDES permitting program industrial facilities that fall into one of the subject ten
categories are required to obtain permit coverage under a general permit or an individual permit,
depending upon the facilities SIC code and the industrial activity occurring at the facility. There are
currently 19 active general stormwater permits in North Carolina. One condition that is applicable to
both the general permits and individual stormwater pen -nits is the requirement to develop and implement
site -specific comprehensive stormwater pollution prevention plans (SPPP). These plans are required to
include a comprehensive evaluation of the site and operations to reduce pollutant sources and prevent
pollutant discharge.
Copies of the general pen -nits and accompanying documents can be accessed from the following
webpage: http://112o.enr.state.nc.us/su/Fonns_Documents.htm Pen -nit text, technical bulletins, discharge
monitoring forms, and a Notice of Intent [which is the application of for coverage under a NPDES
General Stormwater Permit] can be found at this web site.
The following items are a subset of pen -nit requirements and are listed to assist you and help bring your
attention to certain permitting issues, process and condition requirements of your permit. That said;
please see the above -mentioned web site in order to obtain a copy of the permit such that you may fully
comply with all the conditions therein. Failures to properly comply with conditions of the permit,
like those bulleted below, constitutes violations and are subject to a civil penalty assessment of up
to $25,000.00 per day, per violation.
• Industrial facilities that fall into one of the subject ten categories are required to obtain permit
coverage under a general NPDES stormwater pen -nit or an individual NPDES stormwater permit
• All persons desiring to have facilities covered by a General Permit must register with the
Division of Water Quality (DWQ) by the filing of a Notice of Intent (NOI) and Applicable Fees.
• This Notice of Intent (NOI) must be submitted and a Certificate of Coverage issued prior to any
discharge of stonnwater associated with the industrial activity, process wastewater, and/or mine
dewatering.
• Once the Notice of Intent is received, DWQ will review and determine whether a Certificate of
Coverage (COC) may be issued. If this Certificate of Coverage is issued the facility is covered
by the General Pen -nit. That is, the permittee is authorized to discharge stormwater, process
wastewater, and/or mine dewatering pursuant to the type of General Pen -nit until the permit
expires or is modified or revoked.
• Any other point source discharge to surface water of the state is prohibited unless it is an
allowable non-stonnwater discharge or is covered by another permit, authorization or approval.
• There are currently 19 active general permits. Permit conditions vary accordingly; however, most
of the permits have following condition requirements (you must read your entire permit to ensure
full compliance):
o Development and compliance with the Stormwater Pollution Prevention Plan
o Collection, reporting, and recording of Analytical Monitoring

o Collection, reporting and recording of Qualitative Monitoring
o Collection, reporting and recording of Vehicle Maintenance Monitoring
o Records -- Visual monitoring shall be documented and records maintained at the facility
along with the Stonnwater Pollution Prevention Plan. Copies of the analytical monitoring
results shall also be maintained on -site. The Permittee shall retain records of all
monitoring information, including all calibration and maintenance records and all original
strip chart recordings for continuous monitoring instrumentation, and copies of all reports
required by this general permit for a period of least 5 years for the date of the sample
measurement, report or application.
o Expiration -- The pennittee is not authorized to discharge after the expiration date of the
general permit. In order to receive automatic authorization to discharge beyond the
expiration date, the permittee shall submit forms and fees as are required by the agency
authorized to issue permits no later than 180-days prior to expiration date. Any permittee
that has not requested renewal at least 180 days prior to expiration, or any permittee that
does not have a permit after the expiration -and has not requested renewal at least 180
days prior to expiration, will be subject to enforcement. Failure to renew your permit is
a violation.
o Transfer —The Certificate of Coverage (COC) issued pursuant to this general permit is
not transferable to any person expect after notice to and approval by the Director. The
Director may require modification or revocation and reissuance of the Certificate of
Coverage to change the name and incorporate such other requirements as may be
necessary under the Clean Water Act. The Permit is NOT transferable.
o Name Change, Closure or Facility Ownership change — Permittee is required to notify the
Division in writing in the event the permitted facility is sold or closed. The Division of
Water Quality views changes of name or ownership as a modification that requires the
Director's approval and reissuance of the permit. Name and ownership changes required
you to complete a Name/ownership Change Form from the Division and mail it back to
the Division of Water Quality along with all appropriate information.
- o Proper Operation and Maintenance is a requirement of the permit.

r
Compliance Inspection Report
Permit: NCGO50152 Effective: 05/01/03 Expiration: 04/30/08
SOC: Effective: Expiration:
County: Richmond
Region: Fayetteville
Contact Person: Alan Hogan Title:
Directions to Facility:
System Classifications:
Primary ORC: Certification:
Secondary ORC(s):
On -Site Representative(s):
On -site representative Todd Robinson
On -site representative Doug Bailey
Related Permits:
Owner: Von Drehle Cordova LLC
Facility: Von Drehle Cordova, LLC
126 First St
Cordova NC 28330
Phone: [phone]
Phone:
Phone: [phone]
Phone: [phone]
Inspection Date: 0110912008 ry T' e: 01:2 PM Exit Time: 04:15 PM
Primary Inspector: Mike Lawyera En Phone: 91OA33-3300
Ex�Z2.
n �3Z`i
AV,Pr..t.I`; Belinda S Henson �Y1•C'��.% x'��`I �'�'r Phone: [phone] Ex;.72e
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
33ZG
Permit Inspection Type: Apparel/Printing/Paper/Leather/Rubber Stormwater
Discharge COC
Facility Status: ❑ Compliant ■ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page: 1

Permit: NCG050152 Owner - Facility: Von Drehle Cordova LLC
Inspection Date: 01/09/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Compliance inspection conducted with time and assistance provided by Mr. Todd Robinson, Quality/EH&S Manager, and
Mr. Doug Bailey, Engineering Manager. The Von Drehle Corporation purchased the facility from the Laurel Hill Paper
Company in May 2007 and transferred ownership and responsibility of permit coverage shortly thereafter. Facility
manufactures toilet tissue from recycled paper scrap including magazines, thin cardboard containers, etc. The scrap
paper is shredded and all inks and dyes are removed through a chemical process producing a pulp that can then be
formed into tissue. The final product is shipped on large rolls to the customer. This is the same manufacturing process
performed by the previous owner. Work is currently being conducted to "cleanup" the grounds of the facility as well as
regrade and pave the loading/unloading area. Upgrades to the site's stormwater drainage system is also being considered
as it has apparently been neglected over the years. A Stormwater Pollution Prevention Plan (SPPP) that had been
developed by the previous owner was onsite and available for review. It was apparent that the SPPP had not been
reviewed and updated since its development a few years ago. Also, it was missing the component of a feasibility study
and an inspection program. The facility's SPPP is currently being reviewed by a consultant for subsequent revisions,
which should address these missing components. No records were available to show that qualitative monitoring has been
conducted at the facility's outfalls by either the previous or current owner. No onsite vehicle maintenance is conducted at
this facility relieving the permittee from performing analytical monitoring. A copy of the Certificate of Coverage and current
permit was available onsite.
Page: 2

r
Permit: NCG050152 Owner - Facility: Von Drehle Cordova LLC
Inspection Date: 01/09/2008 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Yes
No
NA NE.
Does the site have a Stormwater Pollution Prevention Plan?
■
❑
❑ ❑
# Does the Plan include a General Location (USGS) map?
■
❑
❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
■
❑
❑ ❑
# 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?
■
❑
Cl ❑
# Has the facility evaluated feasible alternatives to current practices?
❑
■
Cl ❑
# Does the facility provide all necessary secondary containment?
■
❑
❑ ❑
# Does the Plan include a BMP summary?
■
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?
■
❑
❑ ❑
# 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?
❑
■
❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
❑
■
❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
■
Cl
❑ ❑
Comment: With new ownership, work is currently being conducted outside the plant to
regrade, pave and clean up areas that were neglected by the previous owners. Also, the
facility's SPPP, which applied to the previous ownership is being actively reviewed and
updated as needed. Components that are included in the facility's SPPP, such as
employee training and providing secondary containment, have been implemented, but
revisions need to be made to the SPPP to include all permit -required items.
Qualitative Monitoring
Yes
No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
❑
■
❑
❑
Comment: There are no records of visual monitoring from previous years under prior
ownership and no monitoring has been conducted since new ownership.
Analytical Monitoring
Yes
No
NA
NE
Has the facility conducted its Analytical monitoring?
❑
❑
■
❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
❑
Cl
❑
Comment:
Permit and Outfalls
Yes
No
NA
NE
# Is a copy of the Permit and the Certificate of Coverage available at the site?
■
❑
1113
# Were all outfalls observed during the inspection?
■
❑
❑
❑
Page: 3

Permit: NCG050152 Owner - Facility: Von Drehle Cordova LLC
Inspection Date: 01/09/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine
# If the facility has representative outfall status, is it properly documented by the Division? 0 ❑ n Q
# Has the facility evaluated all illicit (non stormwater) discharges?
Comment: Facility's outdated SPPP does not contain any reference to the evaluation
of non-stormwater discharges. Due to overgrowth of vegetation along the stream bank,
some of the facility's outfalls could not be found.
El ■ ❑ ❑
Page: 4

Ct�o� W A rFi4QG Michael R Easley, Governor
y William G. Ross Jr., Secretary
FNFINorth Carolina Department of Environment and Natural Resources
Q QC O Coleen H. Sullins, Director
1 3 2007
Division of Water Quality
D�
r Q October 15, 2007
Mr. Raymond von Drehle
Von Drehle Corp.
126 First Street
Hickory, NC 28601-5164
Subject: NPDES General Permit NCGO50000
Certificate of Coverage NCG050152
Von Drehle Corp.
Formerly Laurel Hill Paper Co.
Richmond County
Dear Mr. von Drehle:
Division personnel have reviewed and approved your request to transfer coverage under the General Permit,
received on July 17, 2007.
Please find enclosed the revised Certificate of Coverage. The terms and conditions contained in the General
Permit remain unchanged and in full effect. This revised Certificate of Coverage is issued under the requirements
of North Carolina General Statutes 143-215.1 and the Memorandum of Agreement between North Carolina and
the U.S. Environmental Protection Agency.
If you have any questions, please contact the Stormwater Permitting Unit at [phone], extension 502.
Sincerely,
(;RIGINAL SIGNED By
,KFZ4 PICKLE
Coleen H. Sullins
cc: DWQ Central Files
Fayetteville Regional Office
Stormwater Permitting Unit
One
N rthCarulina
Nattind y
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: h2o.enr.state.nc.us 512 N. Salisbury St, Raleigh, NC 27604 FAX [phone]
An Equal Cpportunity/Affirmati a Action Employer— 50% Recycled110% Post Consumer Paper

or
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCGO50000
CERTIFICATE OF COVERAGE No. NCGO50152
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215. I, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended,
VON DREHLE CORPORATION
is hereby authorized to discharge stormwater from a facility located at
VON DREHLE CORPORATION
126 FIRST STREET
CORDOVA
RICHMOND COUNTY
to receiving waters designated as Hillcock Creek, a class C stream, in the Yadkin Pee -Dee River Basin in
accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts
I_ ll_ 111, IV, V. and VI of General Permit No. NCG050000 as attached.
This certificate of coverage shall become effective October 15, 2007.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day October 15, 2007. ORIGINAL SIGNED 8V
KEN PICKLE
Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission

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Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
April 28, 2003
Alan Hogan
Laurel Hill Paper Co
PO Box 159
Cordova, NC 2833C
Alan W. Klimek, P.E. Director
Division of Water Quality
APR 3 0 200
Subject: NPDES Stormwater Permit Renewal
Laurel Hill Paper Co
COC Number NCGO50152
Richmond County
Dear Permittee:
In response to your renewal application for continued coverage under general permit NCG050000, 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 General Stormwater Permit NCG050000
• A copy of the Analytical Monitoring Form (DMR)
• A copy of the Qualitativel Monitoring Form
• A copy of a Technical Bulletin for the general permit
Your coverage under this general permit is not transferable except after notice to DWQ. The Division
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 Department of
Environment and Natural Resources, or relieve the permittee from responsibility for compliance with any
other applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or decree.
If you have any questions regarding this permit package please contact Aisha Lau of the Central Office
Stormwater and General Permits Unit at [phone], ext. 578.
Sincerely,
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
cc: Central Files
Stormwater & General Permits Unit Files
Fayetteville Regional Office
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone]
14COEC R
Customer Service
1 800 623-7748

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG050000
'CERTIFICATE OF COVERAGE No. NCG050152
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,
Laurel Hill Paper Company
is hereby authorized to discharge stormwater from a facility located at
Laurel Hill Paper Co
126 First St
Cordova
Richmond County
to receiving waters designated as Hitchcock Creek, a class C stream, in the Yadkin - Pee Dee
River Basin in accordance with the effluent limitations, monitoring requirements, and other
conditions set forth in Parts I, II, III, IV, V, and VI of General Permit No. NCG050000 as
attached.
This certificate of coverage shall become effective May 1, 2003.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day April 28, 2003.
for Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
September 4, 2(x)2
ALAN HOGAN
LAUREL HILL PAPEIZ CO
PO BOX 159
CORDOVA. NC 28330
Alan W. Klimek, P.E., Director
Division of Water Quality
i
EEP 1 200?
Suh,jccl: NPDI S Siorrnwater Permit Coverage Renewal
Laurel Hill Paper Co
COC Number NCG050152
Richmond Countv
Dear Perrnittee:
Your facility iS Currently covered for stormwater discharge under General Permit NCG050000. This permit expires
un March 31. 2003. The Division staff iS Currently in the proccsS of rCwt-Inn, lhiS permit and is scheduled to havC
the permit rCissucd by early Spring of 2003. Once the permit is rcissucd, your facility would be CligiblC for
Continued CnveralIC under the rcissucd permit.
In order to assure your continued coverage undcr the general permit, you must apply to the Division of Water
Quality (DWQ) for renewal ol' your permit coveraue. To make; this renewal process easier, we arc inliorming. you in
advance that your permit cuvcraoc will he expiring. Enclosed you will fined a Pern►it Coverage Renewal
Application Form. The application roust he conipleiel and returned by October 2, 2002 in order to assure
continued coverage under the general permit. 17ue to staff and budget constraints. letters Confirming, our receipt ol-
the completed application will not he sent.
Failure to request rcncwal within the time period specified, entry result in a civil assessment of at ]Cast $250,00.
Largcr penalties ilia), be assessed depending on the delinquency of the request. Discharge ol'storrnwater Iron your
facility without covCrattC undcr a valid storniwatcr NPDES permit would constilule a violation of NCGS 143-215.1
and could result in asscssntentS of civil penaltieS of up 10 $10,000 per day.
Please note that recent I'edcral legislation has extended the "no C.xpasure C.XCluSion" to all operators of industrial
facilities in any of the I I categories of "storm water discharges associated with industrial activity," (except
construction activities). I1' you feel your facility can certify a condition of "nil exposure i.e. (lie facility industrial
materials and operations are not Cxposed to Sun'rnwatCr, you Carr apply for the no exposure exclusion_ For additional
information contact the Central Office Storrnwatur Staff rncrnher listed below or check the Sturniwater &, General
Permits Unit Web Site at Itttp://li2o.cnr.suite.iie.tis/su/storrnwaler.htnnl
If the Sub.JCCI stornnwater discharge to waters of the state has been terminated. please complete the enclosed
Rescission Request Form. Mailings instructions are listed On the hottont of the form. You will he notified when the
rescission process has been Conipletcel.
If you have any questions regarding the permit renewal procedurCS please contact Ricky Revels of the 17,aycttcville
Regional Office at 910-486-I541 or Aisha Lau of the Central Office Slormwater Unit at [phone]. ext. 574
Sincerely,
Bradley Bennett, Supervisor
St ormwater and General Permits Unit
cc: Central Files
Sto►rn)W,tttr and General Permits Unit files
Fayetteville Regional {.)flicc ©��
'N
NCDENR
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1-800-623-7748

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
A 'l"V
LT.!WA
T4 j gA
James B. Hunt, Jr., Governor dft
Wayne McDevitt, Secretary � YCE1
A. Preston Howard, Jr., P.E., Director I�
April 30, 1998
ALAN HOGAN t_i.aV 0 6 1998
LAUREL HILL PAPER CO
PO BOX 159
CORDOVA, NC 28330 F'AYETTE!1pU -
REG. OFF
Subject: Reissued Stormwater General Permit for Certificate of Coverage No. NCG050152
Richmond County
Dear Permittee:
In response to your renewal application for continued coverage under the subject permit, 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 North Carolina and the US Environmental Protection agency
dated December 6, 1983.
The following information is included with your permit package:
in A copy of the stormwater general permit.
■ A Stormwater Pollution Prevention Plan Certification Form. This form certifies that you have
developed and implemented the Stormwater Pollution Prevention Plan (SPPP) required in your
permit. This form must be completed and returned to the Division within 30 days of receipt of
Ns letter. DO NOT send the SPPP with the signed form.
■ Five copies of Analytical Monitoring forms.
mi Five copies of Qualitative Monitoring forms.
■ A copy of a Technical Bulletin on the stormwater program which outlines program components
and addresses frequently asked questions.
■ A corrected Certificate of Coverage if you indicated a name or address change on the Renewal
Form returned to the Division.
Your certificate of coverage is not transferable except after notice to DWQ. 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
DWQ or permits required by the Division of Land Resources, Division of Air Quality, Coastal Area
Management Act or any other Federal or Local governmental permits that may be required.
If you have any questions concerning this permit or other attached documents, please contact the
Stormwater and General Permits Unit at telephone number [phone]
Sincerely,
f o A. Preston Howard, Jr., P. E.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/.10% post -consumer paper

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
DIVISION OF WATER QUALITY `
GENERAL PERMIT NO. NCG050000
CERTIFICATE OF COVERAGE NO. NCG050152
STORMWATER DISCHARGES
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,
LAUREL HILL PAPER CO
is herby authorized to discharge stormwater from a facility located at:
126 FIRST STREET
CORDOVA,NC
RICHMOND COUNTY
to receiving waters designated as Hitchcock Creek in the Yadkin -Pee Dee 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. NCG050000 as attached.
This Certificate of Coverage shall become effective May 1, 1998.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day April 30,1998
f or A. Preston Howard, Jr., P.E., Director
Division of Water Quality
By Authorization of the Environmental Management Commission

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
,Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
Alan Hogan
Laurel Hill Paper Co
P.O.Box 159, Ledbetter St
Cordova, NC 28330
Dear Alan Hogan:
1
October 21, 1994 ','R r �I 26 '1 1
FAYCRIEVl LE RE(k OFFICE
Subject: General Permit No. NCG050000
Laurel Hill Paper Co
COC NCG050152
Richmond County
In accordance with your application for discharge permit received on 10/29/93, 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 14-3-215 .1 and the
Memorandum of Agreement between North Carolina and the US Environmental Protection agency dated
December 6, 1983.
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 Environmental Management. The Division of Environmental Management 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 Environmental Management 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 question concerning this permit, please contact Mr. Steve Ulmer at telephone number
919/733-5083.
Sincerely, �".
originai siud y
David A. Goodrich
A. Preston Howard, Jr, F.E.
cc: Fayetteville Regional Office
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
- GENERAL ,PERMIT NO. NCGO50000
CERTIFICATE OF COVERAGE NO. NCGO50I52
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215. I, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management COrnrllissl011, and the
Federal Water Pollution Control Act, as amended,
Laurel Hill Paper Company
is hereby authorized to discharge stormwater from a facility located at
Ledbetter Street
Cordova
Richmond County
to receiving waters designated as Hitchcock Creel: in die Yadkin -Pee River Basin
in accordmlce. wide the effluent limiE< bons, monitoring requirements, and other conditions set forth in Parts I, 11, 111
and IV of General Permit No. NCG050000 as attached.
This Certificate of Coverage shall become effective October 21, 1994.
This Certif kale of Coverage shall remain in effect for the duration of the General Permit.
Signed this date October 21, 1994.
originay Ml nnr� R1J
A. Preston Howard, Jr., P.E., Director
Division of Environmental Management
By Authority of the Envil-onmental Management Commission

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State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
October 21, 1994
Alan Hogan
Laurel Hill Paper Co
P.O.Box 159, Ledbetter St
Cordova, NC 28330
Subject: General Permit No. NCG050000
Laurel Hill Paper Co
COC NCG050152
Richmond County
Dear Alan Hogan:
In accordance with your application for discharge permit received on 10/29/93, we are forwarding
- herewith -the subject certificate of coverage- to- dischargeunder 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
December 6, 1983.
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 Environmental Management. The Division of Environmental Management 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 Environmental Management 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 question concerning this permit, please contact Mr. Steve Ulmer at telephone number
919/733-5083.
Sincerely, g
-t3ed Y
A. Preston Howard, Jr. P.E.
cc: Fayetteville Regional Office
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVSION OF ENVIRONMENTAL MANAGEMENT
GENERAL PERMIT NO. NCG050000
ERTIFICATE OF QQVERAGE NO. N G050152
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARCzE 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,
Laurel Hill Paper Company
is hereby authorized to discharge stormwater from a facility located at
Ledbetter Street
Cordova
Richmond County
to receiving waters designated as Hitchcock Creek in the Yadkin -Pee 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. NCGO50000 as attached.
This Certificate of Coverage shall become effective October 21, 1994.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this date October 21, 1994.
pt git'ta4 Sig'1t`" By
QaVfd ;f it-cii
A. Preston Howard, Jr., P.E., Director
Division of Environmental Management
By Authority of the Environmental Management Commission

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