NCG050340_COMPLETE FILE - HISTORICAL_20180601

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
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❑ MONITORING REPORTS
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Permit NCGO50340 =
tents History inspections Inddents Enfarcements Violations
Events Reg.Activties r Eff. Guidelines Affiliations r Reviewers
'Version:,.-0 Status: ctive
Permit Type: pareilPdnbngiPapertiBather/RubberStormwaterDischarge�COC ` �n
Permit Classification_ COC Primary Related Permit: IrICG0500QU
Program Category: NPOES SW Admin Region: Fayetteville ¢
Facility: Bulldog Hose Company; LLC Defarls County Harnett
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Land Resources Division OrEnergyj.Mincra'l-& FORAGENCYUSEOKY
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PERMIT ,:NAME1OWNERSHlP CHANGE FORM
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1. Please enter thepermit numl)er, fbi,which the change is requested.
NPDES Permit (or) -"Certificate of Coverage
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11. P"ifstatus gLi2i to ire�qiested change.
a. Permit issued16 (4 p#4nar,nO NjA,TIQNJ A L FQ14 &7
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Ill. Please provide the following' fio'r, the requested hangc(!e,v6'edpirmit).
a. Request for change ts'a'result'ofi. Qchange , iit.our�Aip of the facility
El Name ciia�­'f the facility or owner
if other please explain:
b. hrmit issued to (com
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NPOES PERMIT NAME/OWNERSHIP CHANGE FORM
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Page 2 of 2
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�.Requlred Items THIS APPLICATIC
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` `ARC INCOMPLETE O MISSING:
campleted'appliication is required for both amp
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The certifications below mitsf:be col
the new applicant in the case of 66
Applicant's. Certification is suiiicie'
PERMITTEE CERTIFICATION
attest that fhts;applieation t
complete to the best of my krtowledl
rettirn' incamJp/lct � /�
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loge and/or ownership change
'I transfer of arvnel a hip (suclf as relevant pages of a contract deed,.
for an ownership change request, Articles of incorporation are
iship_change.
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feted and signed by of the pari ut holder prior to the change, and
ership.change tequest:For a name change request, the signed
rrrlit holder prior to owrtersillp ci" own hip
hange):
i understand that if ail a hhh een'eviewed Ltd is'acc4ate-and
i req pm�ts of this application are not
min information is not included; tills application package will be
A
signetlim " ; 0. "" Date
APPLICANT CERTIFICATION 4 �6
11 attest that`this dppiication for a nalne/ownership change has bien reviewed and is accurate and
,complete to the Best of my knowledge: l understand that if ail requit ed rt5 of this application are hot, h'
" cotii feted -and it if all uii*d s arti infarmatiori is not inc#ud thts A l,cstlon" a will be
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Signature Date .....................y
PLEASE SENDXHI 'COWLETE'APPLICATION PACKAGE TO:
Division ofEnefq, Mlaeral'and Lama ltOatirces
Stonnwater Penn#fting PnWare
tt;12 NIO�Service Center ` ` "-
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lialelgh, North;CaroL� 27691-1612 � ....
Jam.27,2014
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Bill of Salt
This Bill of Sale (the "Bill of Sale"), dated as of February 28, 2018, is made, executed
and delivered by National Foam, Inc., a Delaware corporation (the "Seller"), for the benefit of
Puck Custom Enterprises, Inc., an Iowa corporation (the "Buyer" )_
I. KNOW ALL MEN BY THESE PRESENTS, that pursuant to the terms and subject to the
conditions of that certain Asset Purchase Agreement, dated as of February 19, 2018, by and
between the Seller and the Buyer (the "Agreement"), and for the consideration set forth
therein, the receipt and sufficiency of which are hereby acknowledged, the Seller dnes hereby
SELL, ASSIGN, TRANSFER, CONVEY and DELIVER to the Buyer, and the Buyer does
hereby purchase, acquire and assume, all of the Seller's right, title and interest to, in and
under the Purchased Assets, free and clear of all Encumbrances (other than Permitted
Encumbrances), effective as of 12:01 a.m., Eastern time, on the Closing Date (the "Effective
Time").
2. Capitalized terms used herein and not defined have the meanings ascribed to them in the
Agreement.
3. The Seiler hereby agrees from time to time, at the reasonable request of the Buyer, to use
commercially reasonable efforts to execute, acknowledge, deliver and file all such further
acts, deeds, bills of sale, transfers, assignments and conveyances, conveying and confirming
unto the Buyer all of the Purchased Assets.
4. Notwithstanding anything to the contrary contained herein, at the Effective Time, the Seller
shall not sell, convey, transfer, deliver or assign to the Buyer, and the Buyer shall not
purchase, acquire or accept from the Seller or any third parties, any of the Excluded Assets
which shall remain the exclusive property of the Seller or such third parties, as the case may
be.
5. This Bill of Sale is executed and delivered pursuant to the Agreement and is subject to and
with the benefit of the respective representations, warranties, covenants, agreements,
indemnities and other provisions of the Agreement, which terms are incorporated herein by
reference. The Seller and the Buyer acknowledge and agree that the representations,
warranties, covenants, agreements, indemnities and other provisions contained in the
Agreement shall not be superseded hereby but shall remain in full force and effect to the full
extent provided therein. In the event of any conflict or inconsistency between the terms of
the Agreement and the terms of this Bill of Sale, the terms of the Agreement shall govern.
6. This Bill of Sale shall be binding upon, and shall inure to the benefit of, the parties hereto
and their successors and permitted assigns.
7. This Bill of Sale shall be governed in all respects by the Laws of the State of Delaware,
without regard to the principles of conflicts of Laws that might otherwise be applicable.
EAST% I 5D942326 2

J . _.
8. This Bill of Sale may be executed in any number of counterparts, each of which will be
deemed an original, but all of which together shall constitute one and the same instrument
and shall become effective when one or more counterparts have been signed by each Party
and delivered (by electronic communication, facsimile or otherwise) to the other Party.
[The remainder of this page has been lei blank intentionally.]
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Energy, Mineral
and Land Resources
ENVIRONMENTAL QUALITY
March 25, 2018
Bulldog Hose Company; LLC (National Foam, Inc.)
Attn: Russell Furtick, Plant Manager
141 Junny Road
Angier, NC 27501
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
WILLIAM E. (TOBY) VINSON, JR.
Interim Director
Subject: COMPLIANCE EVALUATION INSPECTION
NPDES Stormwater General Permit NCGO50000
Bulldog Hose Company; LLC (National Foam, Inc.)
Certificate of Coverage NCG050340
Harnett County
Dear Mr. Furtick:
On March 21, 2018, a site inspection was conducted for the Bulldog Hose Company, LLC (National Foam,
Inc.) facility located at 141 Junny Road, Angier, Harnett County, North Carolina. A copy of the Compliance
Inspection Report is enclosed for your review. Ms. Julie Pfeiffer, EH&S Coordinator, and Mr. David Graves,
Foam Plant Manager, were also present during the inspection and their time and assistance is greatly
appreciated. The site visit and file review revealed that the subject facility is covered by NRDES'Stormwater
General Permit NCG050000 under Certificate of Coverage NCG050340. Permit coverage authorizes the
discharge of stormwater from the facility to receiving waters designated as an unnamed tributary to Neilis
Creek (heals Creek), a Class WS-IV waterbody in the Cape Fear 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 $26,000 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].
Sincerely,
Michael Lawyer, CPSWQ
Environmental Program Consultant
DEMLR
Enclosure
ec: Julie Pfeiffer, EH&S Coordinator— Bulldog Hose Company, LLC (National Foam, Inc.)✓
David Graves, Foam Plant Manager — National Foam, Inc. ✓
M. FRO — DEMLR, Stormwater Files-NCG050340
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

Compliance
Inspection Report
Permit: NGG050340 Effective: 06/01/13
Expiration: 05/31/18 Owner:
National Foam Inc
SOC: Effective:
Expiration: Facility:
National Foam, Inc.
County: Harnett
141 Junny Rd
Region: Fayetteville
Angier NC 27501
Contact Person: Julie Pfeiffer
Title: EH&S Coordinator
Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Certification:
Phone:
Secondary ORC(s):
On -Site Representative(s):
On -site representative
Julie Pfeiffer
919-331-6099
On -site representative
David Graves
919-331-6099
Related Permits:
Inspection Date: 03/21/2018 Entry Time: 01:30PM Exit Time: 03:50PM
Primary Inspector: Mike Lawyer Phone: [phone] Ex�'
Secondary Inspector(s): n
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Apparel/PrintinglPaper/Leather/Rubber Stormwater Discharge COC
Facility Status: Compliant Not Compliant
Question Areas:
® storm water
(See attachment summary)
Page: 1

Permit: NCG050340 Owner - Facility: National Foam Inc
__.. Inspection Date:. 03/2112018 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Met with Julie Pfeiffer, EHBS Coordinator, and David Graves, Foam Plant Manager. Facility recently changed ownership to
Bulldog Hose Company, LLC. Ms. Pfeiffer has been provided with the Stormwater Permit Name/Ownership Change Form to
be completed, signed and submitted in order to update the ownership and facility name change. Made observations of site
conditions. Since the previous inspection conducted on August 30, 2016, secondary containment has been provided in the
form of shipping containers with liners for the multiple totes, drums, etc. of manufactured liquid products that are stored
outside. During the inspection, additional stormwater discharge outfalls were identified, which need to be added to the
semi-annual qualitative (visual) monitoring schedule as discussed with Ms. Pfeiffer. Reviewed the facility's Stormwater
Pollution Prevention Plan (SPPP) and visual monitoring records for the second half of 2016, first and second half of 2017,
and first half of 2018, Facility's SPPP contains all permit -required components and is updated annually with respect to
employee training, any significant spills, and non-stormwater certification. Some revisions are needed to the facility's site
map and to the SPPP to reflect new ownership/facility name. At the time of inspection, facility appeared to be well operated
and maintained.
Page: 2

Permit: NCG050340 owner - Facility: National Foam Inc
Inspection Date: 03/21/2018 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan
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?
# 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?
# Does the Plan include a Stormwater Facility Inspection Program?
Has the Stormwater Pollution Prevention Plan been implemented?
Comment:
Qualitative Monitoring
Has the facility conducted its Qualitative Monitoring semi-annually?
Comment:
Analytical Monitoring
Has the facility conducted its Analytical monitoring?
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
Comment:
Permit and Outfalls
# 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:
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ ❑
■❑❑❑
■❑❑❑
■ ❑❑❑
■❑❑❑
■❑❑❑
■❑❑❑
■❑❑❑
■❑❑❑
■❑❑❑
■❑❑❑
■❑❑❑
Yes No NA NE
■❑❑❑
Yes No NA NE
❑ ❑ N ❑
❑❑■❑
Yes No NA NE
■❑❑❑
❑ ❑ ❑
❑ ❑ ❑
Page: 3

NFV
NATIONAL FOAM
September 12, 2016
NC Division of Energy, Mineral and Land Resources
Fayetteville Regional Office
225 Green Street, Suite 714
Fayetteville, NC 28301
Subject: Notice of Deficiency (NOD-2016-PC-0402)
NPDES Stormwater General Permit NCG05000
National Foam, Inc., Certificate of Coverage NCG050340
Harnett County
Dear Mr. La Bounty,
C 1V L)
SEP 2 6 2616
DE&WE17EVILLE �,EGIOP�AL OFFICE
This letter is in response to the stormwater permit deficiency identified by Mike Lawyer during his site
visit on August 30, 2016. Mr. Lawyer found that our site failed to provide required secondary
containment around bulk storage of liquid materials which consisted of multiple containers in close
proximity with an aggregate capacity of more than 1320 gallons. National Foam regrets this deficiency
and intends to comply fully with the conditions of the permit.
As background information, National Foam recently completed the move of our firefighting foam
production facility from West Chester, PA to our NC site here in Angier. Since then, we have been
working to establish our operating procedures, to rationalize inventory levels, and to implement all the
necessary EH&S controls. We had focused on making sure all the SARA 313 and other environmentally
hazardous liquid containers we have on site were sufficiently contained. Unfortunately, during this
process, we overlooked the sentence in the permit which specifies secondary containment is required
for multiple in close proximity with a combined capacity of 1320 gallons or more. Now that we are
aware of this requirement, we will install the secondary containment necessary for compliance with the
permit.
We have considered the most economical and efficient method of providing secondary containment for
the large quantity of containers that we maintain on site. Our plan is to extend the existing concrete
curbing along the back side of the parking lot. The height of this existing curb will also need to be raised
in order to provide sufficient capacity for the largest single container plus the 25 year, 24 hour rainfall
amount of 7 inches. In addition, similar curbing will need to be installed for the concrete storage pad on
the southwest side of the foam plant building. The first step to designing all the necessary curbing for
effective secondary containment will be a survey of the area with elevations of the existing curbs,
parking lot, and concrete pads. This survey will determine the feasibility of curbing in both locations

NATIONAL FOAM
while providing much needed info regarding natural flows across the affected areas. Once the survey is
complete, we will need to determine the specific areas that can be curbed along with the required curb
heights for these areas. Some of the areas may need to be compartmentalized in order to prevent
flooding adjacent storage areas. We will also investigate the possibility of grated entrances to the
containment areas in an effort to eliminate catching excessive amounts of stormwater. Once a working
design is established, project costs will be estimated so that a capital appropriation request can be
written and submitted to corporate. Once corporate allocates the funds, the facility can proceed with
installation of the required secondary containment structures. This entire process is expected to take
anywhere from six to nine months from startto completion.
We welcome any input your department may have regarding containment area design and best
practices for effective management of containment areas. Compliance is definitely a priority for our
facility so we plan to work diligently getting the project proposal through corporate review and
installation. Should you have any questions regarding this matter, please contact Ms. Julie Pfeiffer at
919-639-6151 X2284 or myself at X2286.
Sincerely,
Rusty Furtick
Plant Manager
National Foam, Inc.

■ 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 mailplece,
or on the frorif.if space permits.
Article Addressed to:
NA-I'IUNAI_ FOAM.
A FI'N: RI)SSI I_l_ I=lilZTlCK, Pi.AN] kl
I= I Jl_1NNY RU!, I)
AN(:iIER. NC'%T{?1
Agent
X ❑ Addressee
B. Received by (Printed Name) C. Date of Delivery
D. Is delivery address different from item 1? ❑ Yes
If YES, enter
er delivery address below: o No
�R- SEP 8 2016
3. Service Type I l
rK Certified Mail- 0 Priority Mail ExpreseL
❑ Registered U Return Receipt for Merchandise
0 Insured Mail Ca Collect on Delivery
a. Restricted Delivery? (Extra Fee) ❑ Yes
2. Article Number 7009 3 410 0001 6831 2209
,FFransfer from service !abet)
PS Form 3811, July 2013 Domestic Return Receipt

UNITED STATES-R 9414 fqfICE First -Class Mail
Posla a A Fees Paid
-2-75 USPY
06 - ZSEP '16 Permit No. G-10
Sendef: Rle-as-e print your name, address, and ZIP+40 in this box"
ATTN: 'HiMC) ! !I Y I. 1--3iWUNI-1-Y. RH_'G1(.),.N'-A1_ NEFR
S i`�I+'A SIJI I F
FAYF-T-1 I..
II I I I I I I I I I I I I - I i I , I I I j I I F I I I j I I I I I I I I I I I I I I I I I I I I I I F I I I , I I , I I I I I

Energy. Mineral
and Land Resources
ENVIRONMENTAL QUALITY
September 1, 2016
CERTIFIED MAIL: 7009 3410 0001 6831 2209
RETURN RECEIPT REQUESTED
National Foam, Inc.
Attn: Russell Furtick, Plant Manager
141 Junny Road
Angier, NC 27501
Subject: NOTICE OF DEFICIENCY (NOD-2016-PC-0402)
NPDES Stormwater General Permit NCG050000
National Foam, Inc., Certificate of Coverage NCG050340
Harnett County
Dear Mr. Furtick:
PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Secretary
TRACY DAVIS
Director
On August 30, 2016, 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
National Foam, Inc: facility located at 141 Junny Road in Angier, Harnett County, North Carolina. A copy of
the Compliance Inspection Report is enclosed for your review. Ms, Julie Pfeiffer, EH&S Coordinator, was
also present during the inspection and her time and assistance 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 NCG050340. Permit coverage authorizes the discharge of stormwater from the
facility to receiving waters designated as an unnamed tributary to Neills Creek (Neals Creek), a Class WS-IV
water in the Cape Fear River Basin.
As a result of the site inspection, the following deficiency is noted:
1) Secondary Containment Requirements
Required secondary containment is not provided around all bulk storage of liquid materials per the conditions
of the NCG050000 permit.
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 deficiency has
occurred as well as a Plan of Action with reasonable timeframe to address this deficiency.
State of North Carolina I Environmenial 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 deficiency, as noted above and
detailed in the enclosed inspection report, be properly resolved. Failure to address the deficiency
could result in the issuance of a Notice of Violation, which is subject to a civif penalty assessment of
up to $25,000 per day for each violation. Should you have any questions regarding this matter, please
contact Mr. Lawyer or myself at [phone].
TUm I
Enclosure
ec:
cc:
Sincerely,
4
Timothy L. LaBoun y, PE
Regional Engineer
DEMLR
Julie Pfeiffer, EH&S Coordinator — National Foam, Inc.
Bradley Bennett, Program Manager — DEMLR, Stormwater Permitting Program
Laura Alexander, Administrative Assistant — DEMLR, Stormwater Permitting Program
FRO — DEMLR, Stormwater Files-NCG050340
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Permit: NCGO50340
SOC:
County: Harnett
Region: Fayetteville
Contact Person: Julie Pfeiffer
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
On -site representative
Related Permits:
Compliance Inspection Report
Effective: 06/01/13 Expiration: 05/31/18 Owner: National Foam Inc
Effective: Expiration: Facility: National Foam, Inc.
141 Junny Rd
Angier NC 27501
Title: EH&S Coordinator Phone: [phone] Ext.2284
Certification: Phone:
Julie Pfeiffer 919-639-6151 ext 228,
Inspection Date: 08/30/2016 Time: 10:15AM Exit Time: 12:20PM
Primary Inspector: Mike Lawyer Ent Phone: [phone]Q EXt.q%91'
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: ApparellPrintinglPaperlLeather/Rubber Stormwater Discharge COC
Facility Status: [] Compliani Not Compliant
Question Areas:
E Storm water
(See attachment summary)
Page: 1

permit; NCGO50340 Owner - Facility:NatienalFoamInc
Inspection Date: 08130/2016 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Met with Ms. Julie Pfeiffer, EH&S Coordinator, An overview of the permit requirements was conducted prior to reviewing the
facility's Stormwater Pollution Prevention Plan (SPPP) and Qualitative Monitoring records. Facility's SPPP contains all
permit -required components and is updated annually in accordance with Part 11, Section A, item 8 of the permit.
Semi-annual Qualitative (visual) Monitoring records from 2011 through the first half of 2016 were available for review.
According to Ms. Pfeiffer, some vehicle and equipment maintenance is conducted onsite, however the facility uses less
than 55 gallons of new motor oil and/or hydraulic oil per month. Therefore, analytical monitoring of stormwater discharges is
not applicable for this facility. After the records review, observations were made around the outside of the facility including
the storm drains, stormwater discharge outfall, loading/off-loading areas and storage areas. During these observations, it
was noted that a secondary containment structure was not provided around the storage areas of multiple totes, drums and
buckets of manufactured liquid products. The requirements for secondary containment were reviewed with Ms. Pfeiffer,
which include the bulk storage of liquid materials where multiple above ground storage containers are located in close
proximity to each other and have a total combined storage capacity of greater than 1,320 gallons. Secondary containment
is defined in the permit as; "Spill containment for the contents of the single largest tank within the containment structure
plus sufficient freeboard to allow for the 25-year, 24-hour storm event." To be compliant with the NCG050000 permit,
appropriate secondary containment must be provided for all above ground storage tanks and containers that meet the
applicable requirements.
Page: 2

Permit: NCGO50340 Owner - Facility: Nafionai Foam Inc
Inspection Date: 06/30/2016 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitonng? ❑ ❑ E ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ N ❑
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? N ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ 0 ❑
# 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? i ❑ ❑ ❑
Comment:
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?
N Cl ❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
E ❑ ❑ ❑
# 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?
❑ ❑ ❑
# Does the facility provide all necessary secondary containment?
❑ ❑ ❑
# Does the Plan include a 13MP summary?
❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
0 ❑ ❑ ❑
# 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)?
0 ❑ ❑ ❑
# 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 ❑ ❑ ❑
Page: 3

Permit: NCG050340 Owner - Facility: National Foam Inc
Inspection Date: 08/30/2016 Inspection Type : Compliance Evaluation Reason For Visit: Routine
Stormwater Pollution Prevention Plan
Comment: Secondary containment is not provided around finshed product storage areas which contain
multiple totes, drums and buckets of manufactured liquid products in close proximity with a
combined storage capacity of greater than 1,320 gallons.
Yes No NA NE
Page: 4

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i. .'k
Energy. Mineral
and Land Resources
ENVIRONMENTAL OVAUTY
September 1, 2016
CERTIFIED MAIL: 7009 3410 0001 6831 2209
RETURN RECEIPT REQUESTED
National Foam, Inc.
Attn: Russell Furtick, Plant Manager
141 Junny Road
Angier, NC 27501
Subject: NOTICE OF DEFICIENCY (NOD-2016-PC-0402)
NPDES Stormwater General Permit NCG050000
National Foam, Inc., Certificate of Coverage NCGO50340
Harnett County
Dear Mr. Furtick:
PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Secretary
TRACY DAVIS
Director
On August 30, 2016, 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
National Foam, Inc. facility located at 141 Junny Road in Angier, Harnett County, North Carolina. A copy of
the Compliance Inspection Report is enclosed for your review. Ms. Julie Pfeiffer, EH&S Coordinator, was
also present during the inspection and her time and assistance 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 NCG050340. Permit coverage authorizes the discharge of stormwater from the
facility to receiving waters designated as an unnamed tributary to Neills Creek (Neals Creek), a Class WS-IV
water in the Cape Fear River Basin.
As a result of the site inspection, the following deficiency is noted:
1) Secondary Containment Requirements
Required secondary containment is not provided around all bulk storage of liquid materials per the conditions
of the NCG050000 permit.
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 clays from receipt of this notice. Your
written response should include a reasonable explanation as to why the aforementioned deficiency has
occurred as well as a Plan of Action with reasonable timeframe to address this deficiency.
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

.I -
Thank you for your attention to this matter. This office requires that the deficiency, as noted above and
detailed in the enclosed inspection report, be properly resolved. Failure to address the deficiency
could result in the issuance of a Notice of Violation, which is subject to a civil penalty assessment of
up to $25,000 per day for each violation. Should you have any questions regarding this matter, please
contact Mr. Lawyer or myself at [phone].
Sincerely,
Timothy L. LaBoun y, PE
Regional Engineer
DEMLR
TUml
Enclosure
ec: Julie Pfeiffer, EH&S Coordinator- National Foam, Inc/
Bradley Bennett, Program Manager- DEMLR, Stormwater Permitting Program
Laura Alexander, Administrative Assistant - DEMLR, Stormwater Permitting Program ✓
cc: FRO - DEMLR, Stormwater Files-NCG050340

Compliance Inspection Report
Permit: NCG050340 Effective: 06/01/13 Expiration: 05/31/18 Owner: National Foam Inc
SOC: Effective: Expiration: Facility: National Foam, Inc.
County: Harnett 141 Junny Rd
Region: Fayetteville
Angier NC 27501
Contact Person: Julie Pfeiffer Title: EH&S Coordinator Phone: [phone] Ext.2284
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
On -site representative Julie Pfeiffer 919-639-6151 ext 228,
Related Permits:
Inspection Date: 08/30/2016 En Time: 10:15AM Exit Time: 12:20PM
Primary Inspector: Mike Lawyer Phone: [phone]Q.Ej:-, '
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:
N Storm Water
(See attachment summary)
Page: 1

Permit: NCG050340 Owner • Facility: National Foam Inc
Inspection Date: 08/30/2016 Inspection Type :Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Met with Ms. Julie Pfeiffer, EH&S Coordinator. An overview of the permit requirements was conducted prior to reviewing the
facility's Stormwater Pollution Prevention P€an (SPPP) and Qualitative Monitoring records. Facility's SPPP contains all
permit -required components and is updated annually in accordance with Part II, Section A, item 8 of the permit.
Semi-annual Qualitative (visual) Monitoring records from 2011 through the first half of 2016 were available for review.
According to Ms. Pfeiffer, some vehicle and equipment maintenance is conducted onsite, however the facility uses less
than 55 gallons of new motor oil and/or hydraulic oil per month. Therefore, analytical monitoring of stormwater discharges is
not applicable for this facility. After the records review, observations were made around the outside of the facility including
the storm drains, stormwater discharge outfail, loading/off-loading areas and storage areas. During these observations, it
was noted that a secondary containment structure was not provided around the storage areas of multiple totes, drums and
buckets of manufactured liquid products. The requirements for secondary containment were reviewed with Ms. Pfeiffer,
which include the bulk storage of liquid materials where multiple above ground storage containers are located in close
proximity to each other and have a total combined storage capacity of greater than 1,320 gallons. Secondary containment
is defined in the permit as; "Spill containment for the contents of the single largest tank within the containment structure
plus sufficient freeboard to allow for the 25-year, 24-hour storm event." To be compliant with the NCG050000 permit,
appropriate secondary containment must be provided for all above ground storage tanks and containers that meet the
applicable requirements.
Page: 2

Permit: NCG050340 Owner • Facility: National Foam Inc
Inspection Date: 08/3012016 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? ❑ ❑ 0 ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ E ❑
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? ❑ ❑ S ❑
# Has the facility evaluated all illicit (non stormwater) discharges? M ❑ ❑ ❑
Comment:
Qualitative Monitorinq Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ' ■ ❑ ❑ ❑
Comment:
Stormwater Pollution Prevention Plan
Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan?
E ❑ ❑ ❑
# Does the Plan include a General Location (USGS) map?
0 ❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
■ ❑ ❑ ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
E ❑ ❑ ❑
# 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?
0 ❑ ❑ ❑
# Does the facility provide all necessary secondary containment?
❑ M ❑ ❑
# 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 Ptan?
E ❑ ❑ ❑
# 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?
0 ❑ ❑ ❑
Page: 3

,V,
Permit: NCG050340 Owner - Fatuity: National Foam Inc
Inspection Date: 08/30/2016 Inspection Type : Compiiance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Comment: Secondarycontainment is not provided around finshed product storage areas which contain
multiple totes, drums and buckets of manufactured liquid products in close proximity with -a
combined storage capacity of greater
ter than 13agallons.
Yes No NA NE
Page: 4

► �r ;� Division of Water Quality / Surface Water Protection
r
G "= National Pollutant Discharge Elimination System
NCDENR
"' N' —0 WnPt" F4 or PERMIT NAME/OWNERSHIP CHANGE FORM
Ermrt°r+Hcnr .Ho H�w..� Rewunces
N- F
FOR AGENCY USE ONLY
Date Received
Year Month
I Da
I. Please enter the permit number for which the change is requested.
NPDES Permit (or) Certificate of Coverage
0 1 5 0 3 4 1 0
H Permit status prior to requested change.
a. Permit issued to (company name): National Foam
b. Person legally responsible for permit: Rusty M Furtick
First MI Last
Plant Manager
Title
141. Junny Road
Permit Holder Mailing Address
Angier NC 27501
City State Zip
[phone] [phone]
Phone Fax
c. Facility name (discharge): Kidde Fire Fighting, Inc. _
d. Facility address: 141 Junny Road
__.. Address
Angier NC 27501
City State Zip
e. Facility contact person: Julie L Pfeiffer 919-639-6151
First / Ml / Last Phone
III. Please provide the following for the requested change (revised permit).
a. Request for change is a result of: ® Change in ownership of the facility
❑ Name change of the facility or owner
If other please explain:
b. Permit issued to (company name):
c. Person legally responsible for permit:
d. Facility name (discharge):
c. Facility address:
f. Facility contact person:
National Foam, Inc.
Rusty M Furtick
First MI Last
Plant ManaL-er
Title
141 Junny Road
Permit Holder Mailing Address
Angier
NC
27501
City
_
State
Zip
919-639.6151
[e-mail]
Phone
E-mail Address
National Foam, Inc.
141 Junn Road
Address
Angier
NC
27501
City
State
Zip
Julie
L
Pfeiffer
First till Last
[phone] [e-mail]
Phone E-mail Address
Revised 2012Apr23

NPDES PERMIT NAME/OWNERSHIP CHANGE FORM
Page 2 of 2
IV. Permit contact information (if different from the person legally responsible for the permit)
Permit contact: Julie L Pfeiffer
First M l Last
EH&S Coordinator
Title
141 Junny Road
Mailing Address
Angier NC 2750I
City ^ State Zip
[phone] [e-mail]
Phone E-mail Address
V Will the permitted facility continue to conduct the same industrial activities conducted prior
to this ownership or name change?
® Yes
❑ No (please explain)
VI Required Items: THIS APPLICATION WILL BE RETURNED UNPROCESSED IF ITEMS
ARE INCOMPLETE OR MISSING:
® This completed application is required for both name change and/or ownership change
requests.
® Legal documentation of the transfer of ownership (such as relevant pages of a contract deed,
or a bill of sale) is required for an ownership change request. Articles of incorporation are
not sufficient for an ownership change.
The certifications below must be completed and signed by both the permit holder prior to the change, and
the new applicant in the case of an ownership change request. For a name change request, the signed
Applicant's Certification is sufficient.
PERMITTEE CERTIFICATION (Permit holder prior to ownership change):
I, Russel Furtick, attest that this application for a name/ownership change has been reviewed and is accurate
and complete to the best of my knowledge. I understand that if all required parts of this application are not
completed and that if all required supporting information is not included, this application package will be
returned as complete.
9-3-I3
Signature Date
APPLICANT CERTIFICATION
1, Russell Furtick, attest that this application for a name/ownership change has been reviewed and is
accurate and complete to the best of my knowledge. I understand that if all required parts of this
application e not completed and that if all required supporting information is not included, this application
package I be returned as ine mplete.
9-3-13
Signature
Date
PLEASE SEND THE COMPLETE APPLICATION PACKAGE TO:
Division of Water Quality
Surface Water Protection Section
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Revised 7/2008

Defaware
the First State
PAGE 1
I, JEFFREY W _ BULLOCK, SECRETARY OF STATE OF THE STATE OF
DELAWARE, DO HEREBY CERTIFY THE ATTACHED IS A TRUE AND CORRECT
COPY OF THE CERTIFICATE OF AMENDMENT OF "EUROSTAR US TRADECO
INC.", CHANGING ITS NAME FROM "EUROSTAR US TRADECO INC." TO
"NATIONAL FOAM, INC.", FILED IN THIS OFFICE ON THE THIRD DAY OF
JULY, A.D. 2013, AT 5 O'CLOCK P.M,
A FILED COPY OF THIS CERTIFICATE HAS BEEN FORWARDED TO THE
NEW CASTLE COUNTY RECORDER OF DEEDS.
5305356 8100
130848358
You may verify this certificate online
at aozp.delaware.gov/authver.shtml
Jeffrey W. Bullock, Secretary of State
AUTHEN C TION: 0563449
DATE: 07-05-13

I
State of Delaware
Secretary of State'
Division of Corporations
Delivered 05.24 FM 0710312013
FILED 05:00 PM 0710312013
SRV 130848358 - 5305356 FILE
CERTIFICATE OF AMENDMENT OF CERTIFICATE OF TNCO"OR.ATION
OF EUROSTAR US TRADECO INC.
rune, 2013
EUROSTAR US 'IRADLCO INC, (the " o ora i '% a corporation organized
and existing wider the General Corporation Law of the State of Delaware, hereby
certifies as follows;
I. This Certificate of Amendment (the "Certificate of Arnerrdrnent") amends the
provisions of the Corporation's Certificate of Incorporation filed with the Secretary of
State on March 19, 20B (the "Certificate of IncoMorstion").
2. Article FIRST of the Certificate of Incorporation is hereby amended and restated
in its entirety as follows:
FIRST; The name of the corporation is:
National Foam, Inc, (the "Corporation")
3. This amendment was duly adopted in accordance with the provisions of Srctions
228 and 242 of the General Corporation Law of the State of Delaware,
4. All other provisions of the Certificate of Incorporation shall remain in full force
and effect.
5, The foregoing aniendmem was approved by unanimous written consent of the
Board of Directors of the Corporation in accordance with Section 141(f) of the General
Corporation Law of the State of Delaware and submitted to the sole stockholder of the
Corporation for approval. Thereafter, the sole stockholder of the Corporation approved
the foregoing amendment by written consent in accordance with Section 228 of the
General Corporation Law of the State of Delaware.
(Slgt:ature Page Follows)
EMTU $9196 18.1

TN W17NESS WtVRRROF, the Corporation has caused this Certificate of Amendment to
he signed this C day of June, 2013.
rized Offsccr
Name: c —Qa&Vi 64r�Ah
Title: (J� cm�/
2HAST\SSN9616. S

"= NORTH CAROLINA
�Department of the Secretary of State
To all whom these presents shall come, Greetings:
I, Elaine F. Marshall, Secretary of State of the State of North Carolina, do hereby certify
the following and hereto attached to be a true copy of
APPLICATION FOR CERTIFICATE OF AUTHORITY
X0
NATIONAL FOAM, INC.
the original of which was filed in this office on the 9th day of July, 2013.
IN WITNESS WHEREOF, I have hereunto set my
hand and affixed my official sea[ at the City of
Raleigh, this 9th day of fuly, 2013.
Scan to verify online.
CertiffcationA C201318900708-1 Reference# C201318900708-1 Pagc: I of 4 Secretary of State
Verify this certificate online at www-secretary.state.nc,us/Verification

C201318900708
SOSID: 1326929
Date Filed: 71912013 9:59:00 AM
Elaine F. MarshalI
North Carolina Secretary of State
201318900708
State of North Corollas
Department of the Secretary of State
APPLICATION FOR CERTIFICATE OF AUTHORITY
Pursuant to §55-15-03 of the General Statutes ofNorth Carolina, the undersigned corporation hereby applies for a Certificate of
Authority to Transact bwJmm in the Stale of North Carolina, and For that purpose submits the following:
1. The name of th a corporation Is National Foarn, T130. _; and Iftho corporate name is
unavailable for use in the 8 into of North Carolina, the name the carporedon wishes to use is:
2. The state or country tinder whose laws the corporation was organtud is: Delaware
3. The date of incaiporation was March 19, 2013 ; its period of duration Is: PeMetaal
4. Principal office inforrna0on: (5disci either a or 8.) .
a. ❑ The corporation has a principal office.
no street address and county of tho principal office of the corporation Is -
Number and Street
City, State, Zip Cade - ----- - -County
The maiiing address, ►frU erent from the street address, of the principal office of the corporation Is:
tL ® The earporation does not have a princtpal office,
5. The street address and county of the registered office in the State of North Carolina is,
Number and Street 150 Fayetteville StiW413ox_1011
City, State, Zip Code Raleigh, North Carolina Z7601 County Waite
6. The mailing address, Ifdtf)'erenifiont (lie street address, of the registered office in the Slate of North Carolina is:
7. The name or the registamd agent In the StateofNarth Carolina is: CT Corporatloa System
8, The names, tltI o.% and usual business addresses of the current officers of the corporation are (attach if necessary);
Hama Mk )tus—h 1.9isAddrss
Paui'4;rHIkuns President 141 Junny Road, Angier, NC 27501
JasonCbsuttn _ ChicfFitiancialOfiica141Junny_Road,An ierzNC27501-
-Rus7 Furtick Secretary 141 Junny Road, Angier, NC 27501
9, Attached is a Certificate of Existence (or document of similar import) duly authenticated by the Secretary of State or other
ofitoial having euotody o f corporate reoords In the stato or country ofincorporation, The Cart flCate a1'.Exlstence must be
an orizinal and less than six months old
CORPORATIONS DIVISION P. 0,13OX 29622 R AT.E10K NC 27626-0622
(Revised January. 2002) (F'orrrrA-09)
Nall -tonne Icrr,amo,r,.
Certifleadong C2111318900708-1 Referenceu C20131890t1708- Page: 2 of

C201318900708
APPWCAT7ON FOR CERTIFICATE OF AMONTY
Pogo 2
10. If the corporation Is required to use a fictitious name in order to iramact buslness in this State, a copy of the rdnlution of its
board of directors, certl tied by its secretary, adoptie:g the fictitious creme is attached,
11. This application willl+l��bc effectivo upon filing, unless a delayed date andlor time is specified:
This is the L day of � } m4 g , 26
? it6nal. Foam, Inc.
Name of Co t7oa
signatufie .
Type or Print, Nama and Tom' t!e
Chief Financial officer
NOTLS:
1. Filing tee is i25O. This document must be filed with the Secretary of State.
CORPORATIONS DIVISION P. O. BOX 29622 RALE[Cill, NC 27626-0622
(ReYixvd gnuwY, 2002) (Form B-09)
K02)-HY mar CT$p--0,h.
CertitUntion# C201318900708-1 Reference# C201318900708- Page: 3 of 3

C201318900708
11
Delaware
qhe First Stag
PAGE I
I, JEFFREY W.'BULLOCK, SECRETARY OF STATE OF THE STATE OF
DELAWARE, DO HEREBY CERTIFY "NATIONAL FOAM, INC." IS DULY
INCORPORATED UNDER THE LAWS OF THE STAVE OF DELAWARE AND IS IN
GOOD STANDING AND HAS A LEGAL CORPORATE EXISTENCE SO FAR AS THE
RECORDS OF THIS OFFICE SHOW, AS OF THE FIFTH DAY OF JULY, A.D.
2013.
AND I DO HEREBY FURTHER CERTIFY THAT TAE FRANCHISE TAXES
HAVE NOT BEEN ASSESSED TO DATE.
$305356 8300
130950160
You may verity this certificate online
at core.delatrarv.yav/authvar.aht�at
jerrrey W. Bullock, Secretary of5tate
AUTHE C TION: 0564392
DATE: 07-05-13
Certtflcatlun# C201318900708-1 ttefereaceg C201318900708- Page: 4 of 4

Georgoulias, Bethany
From: [e-mail]
Sent: Wednesday, June 19, 2013 5:40 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.ncdeiu-.org/wcb/wq/sw/su/npdessw .
If you have questions, please contact Bethany Georgoulias at bethany_.georpoulias.cr,ncdenr.L;ov phone (919)
807-6372 or Bradley Bennett at bradlev.bennett u.ncdenr.aov 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 I II 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:
Organization Name:
Facility Name:
Admin Region:
County Name:
Regulated Activity:
Receiving Stream Name:
Receiving Stream Class:
Basin:
Facility Address:
NCG050340
513112,� Ze) I
National Foam
Kidde Fire Fighting, Inc.
Fayetteville
Harnett
Apparel/Leather/Rubber/PrintinglMisc manufacture
Neills Creek (Heals Creek)
WS-IV
Cape Fear
141 .funny Rd

Facility City. -
Facility State:
Facility Zip: -
Affiliation Type:
Fax Number:
Work Phone Number
First Name:
Middle Name:
Last Name:
Email:
Angier
NC
27501
Owner
[phone]
[phone]
Russell
Furtick
iLilie.pfeifferRkidde-fire:com
2

w a r�9PG
Ir
Michael F. Briley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Colecn H. Sullins. Director
Division of Waler Quality
Russell Furtick
Kidde Fire Fighting, Inc.
141 Junny Road
Angier, NC 27501
September 19, 2008
Subject: COMPLIANCE EVALUATION INSPECTION
National Foam
Kidde Fire Fighting, Inc.
NPDES Stormwater General Permit-NCG050340
Harnett Countv
Dear Mr. Furtick:
On September 16, 2008, 1, Michael Lawyer from the Fayetteville Regional Office of the Division
of Water Quality, conducted a site inspection at the Kidde Fire Fighting, Inc. facility located at 141
Junny Road in Harnett County, North Carolina. A copy of the Compliance Inspection Report is enclosed
for your review. Mr. Jeff Phillips, EH&S Coordinator/Project Engineer was also present during the
inspection and his time and assistance is greatly appreciated. Stormwater from this facility drains to the
City of Angier's Municipal Separate Storm Sewer System and an unnamed tributary to Neills Creek, a
Class WS-IV stream located in the Cape Fear River Basin. The site visit and file review revealed that the
subject facility is covered by NPDES Ston-nwater General Permit-NCG050340.
Accordingly, the following observations were noted during the Division of Water Quality
inspection:
1) Stormwater Pollution Prevention Plan (SPPP)
A Stormwater Pollution Prevention Plan (SPPP) has been developed, recorded, and properly
implemented,
es ■ No ❑
2) Qualitative Monitoring
Qualitative monitoring has been conducted and recorded in accordance with permit requirements.
Yes ■ No ❑
Other Observations:
As discussed during the inspection, secondary containment needs to be provided around the condensate
storage tanks located at the back of the facility. Also, some minor revisions need to be made to the
Stormwater Pollution Prevention Plan. Please refer to the enclosed Compliance Inspection Report for
additional comments and observations made during the inspection.
Nne
olihCarolina
Naturally
Norlli Carolina Division of Water Quality 225 Green Street, Suite 714 Fayetteville, NC 28301-5043 Phone [phone] Customer service
Internet: www.rtcwaterquality-or>? Fax [phone]
An Equal Opportunity/Affirmative Action Employer — 50% Recycled110% Post Consumer Paper

Please be advised that violations of th_e NPDES General Permit are subject to a civil
penalty assessment of up to 525,000 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 [phone].
Sincere y,
Michael Lawyer
Environmental Specialist
Enclosure
cc: Jeff Phillips, EH&S Coordinator/Project Engineer (same address)
FRO -Surface Water Protection
NPS-Assistance & Compliance Oversight Unit
Water Quality Central Files

Compliance Inspection Report
Permit: NCGO50340 Effective: 06/01/08 Expiration: 05/31/13 Owner: National Foam
SOC: Effective: Expiration: Facility: Kidde Fire Fighting, Inc.
County: Harnett 141 Junny Rd
Region: Fayetteville
Angier NC 27501
Contact Person: Russell Furtick Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
On -site representative
On -site representative
Related Permits:
Russell Furtick
Jeff Phillips
Certification
Phone:
Phone: [phone]
Phone: [phone]
Inspection Date: 09116/2008 Ent Time: 09:35 AM Exit Time: 11:45 AM
Primary Inspector: Mike Lawyer Phone: [phone]---3300
see* trimy
Belinda S Henson Phone: [phone] ExL7-7.&-
3324.
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Apparel/Printing/Paper/Leather/Rubber Stormwater
Discharge COC
Facility Status: ■ Compliant D Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page: 1

Permit: NCGO50340 Owner - Facility: National Foam
Inspection Date: 09/16/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Met with Mr. Jeff Phillips, EHBS Coordinator/Project Engineer, who provided a tour of the facility and relayed'the various
operations and processes. Facility manufactures rubber and woven fabric hoses for primarily the fire fighting industry. Two
above -ground storage tanks have recently been installed to capture and recycle water that is used in conjunction with
detergents to aid in the manufacturing process. At the time of inspection, it was observed that the tanks were leaking due
to malfunctioning float controls for the pumps. The tanks are located within a three -wall structure, which is allowing the
leaking water/detergent mixture with a small amount of foam on the surface to exit onto the ground and enter a wooded
area. Mr. Phillips was advised to add a fourth wall to provide complete secondary containment. The facility also has a
10,000-gallon above -ground diesel fuel tank, which according to Mr. Phillips is double -walled. A stormwater basin is
present behind the facility that receives all stormwater runoff from around the buildings and the loading dock. Although the
basin itself is heavily vegetated, access to the outfall pipe is usually maintained through mowing of the berm that
separates the two sides of the basin. As relayed to Mr. Phillips, access to the outfall pipe should be maintained on a
regular basis so that the permit -required monitoring schedule can be kept. After the tour of the facility and observations of
the stormwater drainage and outfall system, a review was conducted of the facility's Storm Water Pollution Prevention
Plan (SWPPP) and visual monitoring records. The SWPPP is very well detailed, yet easy to follow and needs only some
minor revisions concerning the new visual monitoring requirements. Records of visual monitoring were available for the
previous few years.
Page: 2

Permit: NCGO50340 Owner - Facility: National Foam
Inspection Date: 09/16/2008 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?
■
n
n
in
# Does the Plan include a General Location (USGS) map?
■
n
in
n
# Does the Plan include a "Narrative Description of Practices"?
■
n
n
n
# Does the i 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
o
n
# Does the facility provide all necessary secondary containment?
❑
■
n
n
# Does the Plan include a BMP summary?
■
o
n
n
# Does the Plan include a Spill Prevention and Response Plan (Si
■
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
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?
■
in
n
in
Comment: Secondary containment needs to be completed around the new
condensate storage tanks located behind the facility.
Qualitative Monitoring
Yes
No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
■
n
n
n
Comment:
Analytical Monitoring
Yes
No
NA
NE
Has the facility conducted its Analytical monitoring?
in
in
■
❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
n
n
■
n
Comment: Vehicle maintenance is not conducted at this facility and the permit does
not require analytical monitoring otherwise,
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 property documented by the Division?
in
in
■
❑
# Has the facility evaluated all illicit (non stormwater) discharges?
■
n
n
n
Page: 3

Permit: NCG050340 Owner - Facility: National Foam
Inspection Date: 09/16/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Comment: Facility has one outfall coming from a basin that receives stormwater runoff
from all areas.
Page: 4

WA7F9
4
f � r
mow. -i
..don —
June 17, 2005
Mr. Russell Furtick
Kidde Fire Fighting, Inc.
141 Junny Road
Angier, North Carolina 27501
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
Subject: General Permit No. NCG050000
National Foam—Kidde Fire Fighting,
Inc.
COC No. NCGO50340
Harnett County
Dear Mr. Furtick:
In accordance with your application for a discharge permit received on June 3, 2005, we
are forwarding herewith the subject certificate of coverage to discharge under the subject state -
NPDES general permit. This permit is issued pursuant to the requirements of North Carolina
General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the
US Environmental Protection Agency dated May 9, 1994 (or as subsequently amended).
Please take notice that this certificate of coverage is not transferable except after notice to
the Division of Water Quality. The Division of Water Quality may require modification or
revocation and reissuance of the certificate of coverage.
This permit does not affect the legal requirements to obtain other permits which may be
required by the Division of Water Quality or permits required by the Division of Land
Resources, Coastal Area Management Act or any other federal or local governmental permit that
may be required.
If you have any questions concerning this permit, please contact Bethany Georgoulias at
telephone number [phone] ext. 529.
cc: Fayetteville Regional Office)
Central Files
Stormwater Permitting Unit Files
Mr. Dennis Liddy, National Foam
Sincerely,
ORiGENAL SiGNED BY
BRADLEY BENNETT
Alan W. Klimek, P.E.
RECEIVED
JUN 21 2005
DENR - FAYEf ULLE REGIONAL OFFICE
Wpo Carolina
Naturally
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 Opportunity/Affirmative Action Employer— 50% Recycledl10% Post Consumer Paper

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCGO50000
CERTIFICATE OF COVERAGE No. NCGO50340
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,
National Foam
is hereby authorized to discharge stormwater from a facility located at
Kidde Fire Fighting, Inc.
141 Junny Road
Angier
Harnett County
to the City of Angier's Municipal Separate Storm Sewer System (MS4) and to receiving waters
designated as an unnamed tributary to Neills, a class WS-IV water in the Cape Fear River Basin,
in accordance with the effluent limitations, monitoring requirements, and other conditions set
forth in Parts I, I1, III, IV, V, and VI of General Permit No. NCG050000 as attached.
This certificate of coverage shall become effective June 17, 2005.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day June 17, 2005. opl
iGiNAj
BRADLEY BENNETT
for Alan W. Klimek, P.E., Director
Division of Water Quality
By the Authority of the Environmental Management Commission

L06ATION MAP:
� Latitude: 35'31'10" Longitude: 78°44'18" NCG050340 Facility
County: Angier, NC National Foam—Kidde Location
Stream Class: WS-lV Fire Fighting, Inc.
Receiving Stream: UT to Neills Creek
Sub -basin: 03-06-07 (Cape Fear River Basin) [JVotf%L IF ICAIE 1:id,000

ire "
NCG050340
National Foam—Kidde Fire Fighting, Inc.
rev. 6/ 15/05
June 14, 2005
B. Georgoulias
Summary
This facility submitted a Notice of Intent to be covered under General Permit NCG050000 (Rubber &
Miscellaneous Products). The stormwater discharge drains to the City of Angier's MS4, into a UT to
Neills Creek, a Class WS-IV stream in the Cape Fear River Basin. This facility is located in
Harnett County, handled by the Fayetteville Regional Office.
Application review
a) The permit application has been signed and sufficiently completed. Yes.
b) The SIC code accurately describes this facility's activities and is covered by this general
permit. Yes. SIC: 3052 (Rubber and Plastics Hose and Belting). Facility
manufactures woven, plastic, and rubber hose. Process includes textile and extrusion
equipment.
c) Does this facility have other permits? No.
d) Hazardous Waste Activities? Yes — ?
Applicant indicated this is a hazardous waste treatment, storage, or disposal facility.
Per company contact (Rusty Furtick, 919-639-6151, ext. 2218) on 6/ 15/05:
Not a hazardous waste generator —the facility does have a small quantity haz waste
permit because it sometimes conducts tests with Reference Fuel B (jet fuel) for
government contracts (not often); however, rather than disposing of it (the reason for
getting the HW permit), the company would now have it recycled instead. Only
purchase 5 gal at a time. No significant hazardous waste concerns at this site.
e) Regional Office input requested: 6/9/2005 (via e-mail to R. Revels at FRO)
RO Approval received: 6/9/2005 (attached)
g) Application approved? Yes.
Phone Logs
Phoned company contact (Rusty Furtick, 639-6151) on 6/15/05 re: haz waste.

Re: NO[ frsm National Foam
Subject: Re: NOI from National Foam
From: Ricky Revels <Ricky.Revel [e-mail]>
Date: Thu, 09 Jun 2005 15:10:52 -0400
To: Bethany Georgoulias<[e-mail]>
Bethany,
The FRO has no concerns at this time. Please issue COC to the facility.
Signed,
Ricky Revels
Bethany Georgoulias wrote:
Hi Ricky,
We've received an NOT from National Foam for Kidde Fire Fighting, Inc. in Angier
(Harnett Co.), for coverage under stormwater general permit NCG05 (Rubber & Misc.
Products). They manufacture woven, plastic, and rubber hose. A copy of the NOT is
attached. (Note - the applicant noted on the form that this facility was a
hazardous waste treatment, storage, or disposal facility, but not a hazardous waste
generator.) Does the FRO have any concerns with issuing a COC for this facility?
Thanks,
BG
1 of 1 6/9/2005 3:17 PM

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