NCG090031_COMPLETE FILE - HISTORICAL_20180326

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT N0.
/v
DOC TYPE
HISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE
oo? d I 8 6 3d �
WYYMMDD

Energy, Mineral
and Land Resources
ENVIRONMENTAL QUALITY
March 26, 2018
Rockingham Group, LLC
Attn: Tom Sartorelli, Plant Manager
106 Enterprise Drive
Rockingham, NC 28379
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
WILLIAM E. (TOBY) VINSON, JR.
Interim Director
Subject: COMPLIANCE EVALUATION INSPECTION
NPDES Stormwater General Permit NCG090000
Rockingham Group, LLC
2136 Manufacturing, LLC, Certificate of Coverage NCGO90031
Richmond County
Dear Mr. Sartorelli:
On March 20, 2018, a site inspection was conducted for the 2135 Manufacturing, LLC facility located at 106
Enterprise Drive, Rockingham, Richmond County, North Carolina. A copy of the Compliance Inspection
Report is enclosed for your review. Mr. Kin Chaco, Maintenance Manager, was also present during the
inspection and his time and assistance is greatly appreciated. The site visit and file review revealed that the
subject facility is covered by NPDES Stormwater General Permit NCGO90000 under Certificate of Coverage
NCG090031. Permit coverage authorizes the discharge of stormwater from the facility to receiving waters
designated as an unnamed tributary to Cartledge Creek, 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 NCGO90000
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,
ichael Lawyer, CPSWQ
Environmental Program Consultant
DEMLR
Enclosure
ec: Stu Parks, Corporate EHS Director — CAI, Inc.
Kin Chaco, Maintenance Manager — 2135 Manufacturing, LLC ✓
cc: FRO — DEMLR, Stormwater Files-NCG090031
State of North Carolina I Environmental Quality I Energy, Mineral and Land Resources
Fayetteville Regional Office 122,5 Green Street, Suite 714 1 Fayetteville, NC 28301
910-433-3300

ComDliance Insoection Reoort
Permit: NCO090031 Effective: 11/16/17 Expiration: 10/31/18 Owner: Rockingham Group LLC
SOC: Effective: Expiration: Facility: 2135 Manufacturing, LLC
County: Richmond 106 Enterprise Dr
Region: Fayetteville
Rockingham NC 28379
Contact Person: Stu Parks Title: Corporate EHS Director Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
Certification: Phone:
On -Site Representative(s):
On -site representative Kin Chaco 910-895-5779
Related Permits:
Inspection Date: 03120/2018 Entry Time: 9:40AM Exit Time: 11:50AM
Primary. inspector: Mike Lawye Phone: [phone] F-xtV`
Secondary Inspectors}: 33 oyq
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Paints, Varnishes, Lacquers Stormwater Discharge CDC
Facility Status: Compliant ❑ Not Compliant
Question Arose:
Storm Water
(See attachment summary)
Page: 1

Permit: NCGO90031 Owner - Facility: Rockingham Group LLC
Inspection Gatos. 03/2012018 .. Inspection Type . Compliance Evaluation Beeson for Visit:- Routine
Inspection Summary:
Met with Kin Chaco, Maintenance Manager, who provided the facility's Stormwater Pollution Prevention Plan (SPPP) and
monitoring records for review. Facility's SPPP contains all permit -required components and is updated annually with respect
to employee training, any significant spills and non-stormwater certification. A revision to the detailed site map is needed to
reflect the recent addition of the "nitro" building and its associated stormwater discharge outfall, which brings the total
number of outfalls at the facility to three. Mr. Chaco was advised that the facility could apply for Representative Outfatl
Status (ROS), which would allow the facility to monitor just one of the three outfalls. A copy of the ROS request form will be
included with the inspection report. Monitoring records indicate that since the previous inspection on May a, 2016
semi-annual monitoring was conducted and recorded for the first and second half of 2017 and the first half of 2018, however
there were no monitoring records for the second half of 2016. According to Mr. Chaco, stormwater sampling was conducted.
in December 2016, but the contract lab was unable to pick up the sample for subsequent testing. Please note that in these
situations other arrangements should be made in order for monitoring to be completed, i.e. sample delivery by facility
personnel, shipment of samples to the lab, or utilizing another certified lab. Available monitoring records indicate no
exceedances of the benchmark values for the discharge characteristics of the permit. After the records review, observations
were made of facility operations, equipment storage area ("graveyard" j, secondary containment area for ASTs, and
stormwater discharge outfalls. At the time of inspection, the facility appeared to be well operated and maintained.
Page: 2

Permit: NGG090031 Owner - Facility: Rockingham Group LLC
Inspection Date: 0312012018 Inspection Type : Compliance Evaluation
i
Reason for Vlelt: Routine
r '
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"?
■ ❑ ❑ ❑
I
# 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 Stormwaler Facility Inspection Program?
■ ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
■ ❑ ❑ ❑
Comment:
gug,(Itative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ■ ❑ ❑ ❑
Comment:
Analytical Monitorina Yee No NA NE
Has the facility conducted Its Analytical monitoring? ■ ❑ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ ■ ❑
Comment:
Per uffalls Yes No NA_ NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? ■ ❑ ❑ ❑
# were all outfalla 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 &
,Land. Resources
ENVIRONMENTAL QUALITY
Paul Sartorelli
Rockingham Group LLC
106 Enterprise Dr
Rockingham, NC 28379
October 17, 2017
ROY COOPER
Cnvgrnnr
MICHAEL S-REGAN
SeeretaCy
TRAGY DAV[S,
171iectiir
Subject: NPDES General Permit Renewal and Electronic Reporting Requirements
2135 Manufacturing, LLC
NPDES Permit Certificate of Coverage (COC) Number: NCG090031
Dear NPDES Permittee:
The General Permit this facility is covered'under expires on October 31, 2017. Our records indicate that
your annual fees are up to date; therefore, your coverage will be automatically renewed unless you
submit a rescission request for this permit. If you no longer need this permit, a rescission form can be
found on our website (htto://eoo.el/BcgDP4).
The Stormwater Program plans to reissue this General Permit for one year with no changes. This
action has been posted for public comment on our website above (see the table of General Permits) and
published In area newspapers statewide, The public comment period for the reissuance action concludes
on November 1, 2017, and the new General Permit is scheduled to become effective on November 16,
2017. Upon issuance of the final General Permit, your coverage will be renewed for the one year
period. Instead of being mailed new Certificates of Coverage (COCs), each permittee should print off
the new General Permit Cover Page from our 5tormwater Program website (with revised effective and
expiration dates) after Issuance in mid -November.
Although the renewal process is automatic this year, two Items require your action:
(1) You must review your permit contact information and notify us of any changes no later
than November 15, 2017.
(2) You must submit outfall information on-line for this site in preparation for electronic data
monitoring report (eDMR) requirements no later than November 30, 2017.
Permit Contact Information
Please review the permit contact information we have in our database. You can do this by clicking on
the "review the permit contacts for your facility" link on the website above and entering your permit
COC number. Ensure that Owner Affiliation and Permit Contact are accurate, and that e-mail addresses
are provided. (Note that if you already did this recently, we may not have entered the changes yet.)
Nothing Compares_
.SState of Nlorth Carolina I Environmental Qualky, I'Ene gy, Mineral and Land Resources
512 N. Sallsbdei Street 1.1612 MAII Service Centre I ` Ra[e[gh, North'Cafollna 27699;1612
919 707 9200

To update contact information for your permit: You may simply e-mail us changes to contact
information, unless there is a change to the Owner Affiliation. Because Owner Affiliation is the person
legally responsible for the permit, we require a copy of the signed Owner Affiliation Change Form (on
our website) to make this change. Be aware that a change in company name or ownership requires a
different form (also on the website), so please contact us if you have questions about which form you
need. Changes to other contacts can be e-mailed to Laura Alexander at [e-mail].
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 November 30, 2017. The website will walk you through all steps.
The website is: https:/%deg.nc.gov/about/stormwater-programZstormwater-outfall-collection
For more information on EPA's NPDES Electronic Reporting Rule, visit
http://www2.el2a.gov/compliance/final-national-pollutant-discharge-elimination-system-npdes-
electronic-reporting-rule. For more information on electronic reporting to NC DEMLR, visit
http://deg.nc.gov/about/divisions/energy-mineral-land-resourceslstormwater/ereporting-rule or
contact Bethany Georgoulias at [phone] or via email at [e-mail], or
Robert Patterson at [phone] or via email at [e-mail].
Sincerely,
(/ oi*ve5m .4uz eC
Annette Lucas, P.E.
Supervisor, DEMLR Stormwater Program
Cc: Stormwater Program Permit File
Nothing Compares-,-,,-
State.ofNorth Carolina, I Environmental Quality, I Energy. Mineral and Land Resoumes
Sit N. Sallsbufy Street. j 1612 Midi Se- lcoe Center I R leigh. North Carolina'27699=1612
9197079.200

•
COATINGS,
Ca I ADHESIVES,
INKS
7 MARTEL WAY
GEORGETOWN, MA 01833
TEL: [phone]
FAX: (978) 352A519
June 3, 2016
Michael Lawyer, CPSWQ
Environmental Program Consultant -
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
225 Green Street, Suite 714
Fayetteville, NC 28301 JUN 13 2016
RE: Rockingham Group, LLC.
General Permit NCGO90000
Dear My Lawyer:
This letter addresses the deficiencies noted in your inspection letter report dated
May 9, 2106. We appreciated your candor and assistance during the inspection and
have implemented revised procedures to ensure future compliance with the
aforementioned General Permit.
The corrective actions for the noted deficiencies are as follows:
Deficiency: Qualitative Monitoring has not been conducted and recorded in
accordance with permit requirements.
Response: Although the Qualitative Monitoring Form was noted in our SPPP,
the completion of the form at each sampling effort was not conducted as
required. I have provided the form to our Maintenance Manager, responsible
for stormwater sampling, and reviewed the need to complete the form
pursuant to the permit requirements.
Deficiency: Analytical monitoring has not been conducted and recorded in
accordance with permit requirements.
Response: We agree that we missed the sampling event during the first
period of our newly received permit in 2014. 1 now have Outlook alerts to
remind me to notify the Maintenance Manager to conduct the sampling during
a suitable storm event. We also have our lab provide us with new sampling
kits at the time of sample pickup to ensure availability for the next sampling
period.
Other Observations:
Response: I have prepared a new annual certification form to address the
annual requirements in the General Permit. The form will be completed at the
time of review to more easily demonstrate compliance with the General

Responses to Stormwater NOD
Page 2 of 2
Permit requirements. The completed form will be kept with the SPPP. We will
ensure that we conduct the annual review within +1- 30 days of the plan
preparation date.
We have added a second stormwater discharge outfall as discussed
during the inspection. The SPPP plan and drawings have been updated and
additional sampling kits ordered for the next sampling event.
We will also be more timely in sending our sampling event DMRs as
discussed.
Again, thank you for your assistance during the inspection. Should you have any
questions or need further documentation, feel free to contact me.
Sincerely,
Robert A. Fricke
Corporate EHS Director
[e-mail]
978-352-4510
Cai KBE6iV S.

Lawyer, Mike
From:
Robert Fricke <[e-mail]>
Sent:
Thursday, June 02, 2016 3:02 PM
To:
Lawyer, Mike
Subject:
SPPP Annual Cert
Attachments:
Annual SPPP Cert form 060216.pdf
Mike
I have completed the revisions to our plan and operating procedures. I developed this Annual
Certification Form and would like your opinion on using it to demonstrate the required certifications
per the General Permit.
Thanks.
Robert
Robert Fricke
Corporate EHS Director
CAI, Inc.
7 Martel Way
Georgetown, MA 01833
[e-mail]
978-352-4510

dp .;.
Annual Certification Form
kS_tormwaterjP.ailutlaniP.revent1on Plan
Review the SPPP. Make written revisions as required.
Yes No
Is the SPPP Feasibility Study applicable to current facility conditions.
Yes No
Are the SPPP BMPs applicable to current facility conditions.
Yes No
Review the SPPP figures. Make revisions as required.
Yes F No
An unallCertifica-tlons
Is there a signed SPPP Development & Implementation Certification
within the last 12 months.
Yes ❑ No ❑
Is there a signed Non -Storm Water Discharge Assessment &
Certification within the last 12 months.
Yes ❑ No ❑
Has the List of Significant Spills or Leaks been reviewed & updated
as required.
Yes ❑ No ❑
Stormwater Sam lin IRecords
Review the Qualitative Monitoring Forms. is there a completed form
for each stormwater dischar a sampling event and outfall.
Yes ❑ No ❑
Review the Semi -Annual Stormwater Discharge Monitoring Reports.
Is there a completed form for each sampling event and outfall.
Yes ❑ No ❑
Is the Annual Summary Data Monitoring Report & Update Data
Review Form have the latest round of sampl-ing results.
Yes ❑ No ❑
EStarffi 'water &jFaciIi-LT" s actions
Does the Maintenance Manager complete the Monthly Stormwater
Inspection Form as required.
Yes ❑ No ❑
Has the Annual Stormwater Inspection Form been completed within
last 12 months.
Yes ❑ No ❑
Trai'nin
Has the CAI Emergency Management Plan and SPPP with any of its
revisions (including SPPP forms) been reviewed with the
Maintenance Manager._
Yes ❑ No ❑
NecordIRetenti11 on
Are all stormwater records for the past five years available for review. Yes No
I certify that I have reviewed and found the SPPP, Feasibility Study, BMPs, and sampling
records are adequate, with any changes noted herein, are consistent with and applicable to
current facility conditions.
Signature Title Date

Energy, Mineral
and Land Resources
ENVIRONMENTAL QUALITY
May 9, 2016
CERTIFIED MAIL: 7009 3410 0001 6831 2148
RETURN RECEIPT REQUESTED
Rockingham Group, LLC
Attn: Robert Fricke, Corporate EHS Director
106 Enterprise Drive
Rockingham, NC 28379
PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Subject: NOTICE OF DEFICIENCY (NOD-2016-PC-0149)
NPDES Stormwater General Permit NCGO90000
Rockingham Group, LLC
2135 Manufacturing, LLC, Certificate of Coverage NCG090031
Richmond County
Dear Mr. Fricke:
Secierary
TRACY DAVIS
Director
On May 4, 2016, Mike Lawyer and Tim LaBounty from the Fayetteville Regional Office of the Division of
Energy, Mineral and Land Resources, conducted a site inspection for the 2135 Manufacturing, LLC facility
located at 106 Enterprise Drive in Rockingham, Richmond County, North Carolina. A copy of the Compliance
Inspection Report is enclosed for your review. Your time and assistance during the inspection is greatly
appreciated. The site visit and file review revealed that the subject facility is covered by NPDES Stormwater
General Permit NCG090000 under Certificate of Coverage NCG090031. Permit coverage authorizes the
discharge of stormwater from the facility to receiving waters designated as an unnamed tributary to
Cartledge Creek, a Class C water in the Yadkin -Pee Dee River Basin.
As a result of the site inspection, the following deficiencies are noted:
1) Qualitative Monitoring
Qualitative monitoring has not been conducted and recorded in accordance with permit requirements.
2) Analytical Monitorinq
Analytical monitoring has not been conducted and recorded in accordance with permit requirements.
Other Observations:
Please refer to the enclosed Compliance Inspection Report for additional comments and observations made
during the inspection.
Requested Response:
You are asked to respond to this office, in writing, within 30 calendar days from receipt of this notice. Your
written response should include a reasonable explanation as to why the aforementioned deficiencies have
occurred as well as a Plan of Action to prevent these deficiencies from recurring.
State of North Carolina I Environmental Quality I Energy, Mineral and Land Resources
Fayetteville Regional Off`ia 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, be
properly resolved. Failure to address these items 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 Mike Lawyer or myself at [phone].
Sincerely,
T' othy L. LaBevy,
Regional Engineer
TVml
Enclosure
cc: Bradley Bennett, Supervisor- Stormwater Permitting Program
FRO - DEMLR, Stormwater Files-NCG090031
1 ■ Complet-elttems 1, 2, and 3. Also complete
item'4 if Restdcted.Delivery Is desired.
a Print yourname 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 thelront If space permits.
1. Article Addressed to:
ROCK IN - HAM i ROUP, LLC
AT'I'N ROBER FRICKE, CO. EH I,[
106 EWERPR[ '[:''DRIVE
ROCKINGHAI 4 W 28379
'A. Signature
X ❑ Agent
❑ Addressee
8. a eivMM
led Name) C. D ales
Delivery
D. Is delivery address different from'Item 17 13
t ' if YES, enter delivery address below: L9'f+lo
J. MAY 13 2016
3. service Type
1XIDertifled�Malll © Prlorltyy-MallExpress"1
IT
Regl9tered', XRetum Recelpi',6 Merchandise`
❑ Insured Mall: kC];Collect on Delivery
4. Restricted Dellvero (bdra Fee) ❑ Yie,
2. Mclo Number 7009 3410 0001 6831 2148
t7MQsfer from service "D
PS Form 3811, July 2t)13 Domestic Return Receipt

Compliance Inspection Report
Permit: NCG090031 Effective: 05/09/14 Expiration: 10/31/17 Owner: Rockingham Group LLC
SOC: Effective: Expiration: Facility: 2135 Manufacturing, LLC
County: Richmond 106 Enterprise Dr
Region: Fayetteville
Rockingham NC 28379
Contact Person: Robert Fricke Title: Corporate EFTS Director Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
On -site representative Robert Fricke 978-352-4510
Related Permits:
Inspection Date: 05/04/2016 ntry Ti e: 9:30AM
Primary Inspector: Mike Lawye
Secondary Inspector(s):
Fxlt Time: 11:15AM
Phone: [phone]
Tim L LaBounty
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Paints, Varnishes, Lacquers Stormwater Discharge COC
Facility Status: [] Compliant Not Compliant
Question Areas:
Storm Water U.S. Postal
RECEIPT
cc i (Domestic . Insurance Coverage Provided)
r—lFor delivery
ms
(See attachment summary) ru �• rmation vlt;lt •� � � �
AL
do Poebw $
Cerd led Fee
ra Postmark
fl Return Receipt Fee Hera
O (Endorsement Roquttad)
C3 Restricted Delivery Fee
t (Endorsement Required) `
i :I- Total Postage & Fees $ 6�1 t
mEr
i
r ° fQOC� ivYxY (9 2Dd ! C
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Page: 1

permit: NCG000031 Owner - Facility: Rockingham Group LLC
Inspection Data: 0510412016 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Inspection conducted to ensure compliance with the conditions of General Permit NCGO90000. Permit coverage was issued
to the facility on May 9, 2014. Met with Robert Fricke, Corporate EHS Director, who provided a tour of the facility's
manufacturing and product storage areas. Observations were then made outside the facility including the used
equipmentP'graveyard" area, loading docks, secondary containment of ASTs as well as the stormwater collection system
and discharge outfall pipe. A secondary outfall, which is a grassed swale along the back of the facility, was also pointed out
and will be added to the monitoring schedule. A review of the facility's Stormwater Pollution Prevention Plan (SPPP) and
available monitoring records was conducted. Regarding the SPPP, additional documentation needs to be added concerning
the annual review and update to include all items listed under Part II, Section A, item 8 of the NCGO90000 permit.
Analytical monitoring records from the first and second half of 2015 were available for review and showed no exceedances of
the applicable benchmark values. Analytical monitoring was not performed during the second half of 2014, which was the
first sampling period after obtaining permit coverage. Qualitative monitoring per Part II, Section D of the NCGO90000 permit
has not been performed.
Page: 2

Permit: NCG090031 owner - Facility: Rockingham Group LLC
Inspection Data: 05/04/2016 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Analytical Monitoring Yves No NA NE
Has the facility conducted its Analytical monitoring? ❑ 0 ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ E ❑
Comment: Analytical monitoring was not conducted during the second half of 2014.
Permit and Outfalla 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? ❑ ❑ 0 ❑
# Has the facility evaluated all illicit (non stormwater) discharges? 0 ❑ ❑ ❑
Comment:
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? 0000
Comment: Qualitative monitoring has not been conducted and recorded in accordance with permit
conditions.
Stormwater Pollution Prevention Plan
Yss 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?
E ❑ ❑ ❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
N ❑ ❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
❑ ❑ ❑
# Does the facility provide all necessary secondary containment?
❑ ❑ ❑
# Does the Plan include a SMP summary?
❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
E ❑ ❑ ❑
# 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?
E ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
0 ❑ ❑ ❑
Page: 3

parM[t; NCGO90031 Owner - Facility; Rockingham Group LLC
Inspection Data: 05104/2016 Inspection Typo: Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan Yoe No NA NE
Comment:
Page: 4

Energy, Mineral
and Land Resources
ENVIRONMENTAL QUALITY
May 9, 2016
CERTIFIED MAIL: 7009 3410 0001 6831 2148
RETURN RECEIPT REQUESTED
Rockingham Group, LLC
Attn: Robert Fricke, Corporate EHS Director
106 Enterprise Drive
Rockingham, NC 28379
PAT MCCRORY
Govemor
DONALD R. VAN DER VAART
Subject: NOTICE OF DEFICIENCY (NOD-2016-PC-0149)
NPDES Stormwater General Permit NCGO90000
Rockingham Group, LLC
2135 Manufacturing, LLC, Certificate of Coverage NCG090031
Richmond County
Dear Mr. Fricke:
Secretary
TRACY DAVIS
Director
On May 4, 2016, Mike Lawyer and Tim LaBounty from the Fayetteville Regional Office of the Division of
Energy, Mineral and Land Resources, conducted a site inspection for the 2135 Manufacturing, LLC facility
located at 106 Enterprise Drive in Rockingham, Richmond County, North Carolina. A copy of the Compliance
Inspection Report is enclosed for your review. Your time and assistance during the inspection is greatly
appreciated. The site visit and file review revealed that the subject facility is covered by NPDES Stormwater
General Permit NCGO90000 under Certificate of Coverage NCG090031. Permit coverage authorizes the
discharge of stormwater from the facility to receiving waters designated as an unnamed tributary to
Cartledge Creek, a Class C water in the Yadkin -Pee Dee River Basin.
As a result of the site inspection, the following deficiencies are noted:
1) Qualitative Monitoring
Qualitative monitoring has not.been conducted and recorded in accordance with permit requirements.
2) Analytical Monitoring
Analytical monitoring has not been conducted and recorded in accordance with permit requirements.
Other Observations:
Please refer to the enclosed Compliance Inspection Report for additional comments and observations made
during the inspection.
Reguested 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 prevent these deficiencies from recurring.
State of Noah Carolina I Eavironmental Quality i Energy, Mineral and Land Resources
Fayetteville Regional Office 1 225 Green Street, Suite 714 1 Fayetteville, NC 29301
910.433-3300

r
Thank you for your attention to this matter. This office requires that the deficiencies, as noted above, be
properly resolved. Failure to address these items 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 Mike Lawyer or myself at [phone].
Sincerely,
T othy L. LaBey.
Regional Engineer
TLIm I
Enclosure
cc: Bradley Bennett, Supervisor - Stormwater Permitting Program
FRO - DEMLR, Stormwater Files-NCG090031

Compliance Inspection Report
Permit: NCG090031 Effective: 05/09/14 Expiration: 10/31/17 owner: Rockingham Group LLC
SOC: Effective: Expiration: Facility: 2135 Manufacturing, LLC
County: Richmond 106 Enterprise Dr
Region: Fayetteville
Rockingham NC 28379
Contact Person: Robert Fricke Title: Corporate EHS Director Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
Onate Representative(s):
On -site representative Robert Fricke 978-352-4510
Related Permits:
Inspection Date: 05/04/2016 Entry TI e: 09730AM
Primary Inspector: Mike Lawye
Secondary Inspectoris):
Exit Time: 11:15AM
Phone: [phone]—
Tim L LaBounty
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Paints, Varnishes, Lacquers Stormwater Discharge COC
Facility Status: ❑ Compliant . Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page: 1

Permit: NCGO90031 Owner - Faclllty: Rockingham Group LLC
Inspection Date: 05104/2016 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Inspection conducted to ensure compliance with the conditions of General Permit NCG090000. Permit coverage was issued
to the facility on May 9, 2014. Met with Robert Fricke, Corporate EMS Director, who provided a tour of the facility's
manufacturing and product storage areas. Observations were then made outside the facility including the used
equipmenV'graveyard" area, loading docks, secondary containment of ASTs as well as the stormwater collection system
and discharge outfall pipe. A secondary outfall, which is a grassed swale along the back of the facility, was also pointed out
and will be added to the monitoring schedule. A review of the facility's Stormwater Pollution Prevention Plan (SPPP) and
available monitoring records was conducted.. Regarding the SPPP, additional documentation needs to be added concerning
the annual review and update to include all items listed under Part II, Section A, item 8 of the NCG090000 permit.
Analytical monitoring records from the first and second half of 2015 were available for review and showed no exceedances of
the applicable benchmark values. Analytical monitoring was not performed during the second half of 2014, which was the
first sampling period after obtaining permit coverage. Qualitative monitoring per Part II, Section D of the NCGO90000 permit
has not been performed.
Page: 2

Permit: NCGO90031 Owner • Fae ty: Rockinghem Group LLC
Inspection Date: 05/04/2016 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Analytical Monitoring Yea No NA NE
Has the facility conducted its Analytical monitoring? ❑0 Cl ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ ■ ❑
Comment: Analytical monitoring was not conducted during the second half of 2014_
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:
Qualitativo Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ❑ 0 ❑ ❑
Comment: Qualitative monitoring has not been conducted and recorded in accordance with permit
Conditions.
Stormwater Pollution Prevention Plan
Yea No_NA Ns
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"?
0 ❑ ❑ ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
M ❑ ❑ ❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
0 ❑ ❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
■ ❑ ❑ ❑
# 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 Plan?
❑ ❑ ❑
# Does the facility provide and document Employee Training?
M ❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
0 ❑ ❑ ❑
# Is the Plan reviewed and updated annually?
0 ❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
❑ ❑ ❑
Page: 3

Permit: NCG090031 Owner - Facility: Rockingham Group LLC
Inspection Date: 05/04/2016 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan Joe No NA NE
Comment:
Page: 4

Fiza-
CCDENR.
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarla, III
Governor Secretary
n / �,f/ �, _n /_ ��- May 9, 2014
Mr. jl�k�r~t u"' I` ev a�+�
Rockingham Group, LLC
106 Enterprise Drive
Rockingham, NC 28379
Dear Mr. Sartorelli:
Subject: General Permit No. NCG090000
Rockingham Group, LLC
COC No. NCG090031
Richmond County,
M AY 1 4 2014
1n accordance with your application for a discharge permit received on April 29, 2014,
we are forwarding herewith the subject certificate of coverage (COC) 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 October 15, 2007 (or as
subsequently amended).
Please take notice that this certificate of coverage is not transferable except upon
approval of the Division of Energy, Mineral, and Land Resources. The Division of Energy,
Mineral, and Land Resources 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 Energy, Mineral, and Land Resources, the Coastal Area
Management Act, or any other federal or local government permit that may be required.
Division of Energy, Mineral, and Land Resources
Energy Section - Geological Survey Section - Land Quality Section
1612 Mail Service Center, Raleigh, North Carolina 27699-1612.919-707-92001 FAX: [phone]
512 North Salisbury Street, Raleigh, North Carolina 27604 - Internet: htto://oortal.ncdenr.orglweb/Ir/
An Equal Opportunity 1 Affirmative Action Employer — 50% Recycled 110% Post Consumer Paper

If you have any questions concerning this permit, please contact Julie Ventaloro at telephone
number [phone] or by email iulie,ventaloro�7a�, ncdenr,gov,
Sincerely,
ORIGINALes,1W,
GNEO SI.
for Tracy E, CPM, Director
Division of Energy, Mineral and Land Resources
cc: Fayetteville Regional Office, B. Cole
Central Files
Stormwater Permitting Program Files

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF ENERGY, MINERAL, AND LAND RESOURCES
GENERAL PERMIT NO. NCG090000
CERTIFICATE OF COVERAGE No. NCG090031
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,
Rockingham Group, LLC
is hereby authorized to discharge stormwater from a facility located at
2135 Manufacturing, LLC
106 Enterprise Drive
Rockingham
Richmond County
to receiving waters designated as unnamed tributary to Cartledge Creek, a class C water in the
Yadkin River Basin, in accordance with the effluent limitations, monitoring requirements, and
other conditions set forth in Parts 1,11, III, and IV of General Permit No. NCG090000 as
attached.
This certificate of coverage shall became effective May 9, 2014.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day May 9, 2014.
ORIGINAL SIGNED fll
KEN PICKLE
for Tracy E. Davis, P.E., Director
Division of Energy, Mineral, and Land Resources
By the Authority -of the Environmental Management Commission

NCG090031
Map Scale 1 r24,000
Rockingham Group, LLC
2135 Manufacturing, LLC
Latitude: 340 57' 47" N
Longitude: 790 48' 17" W
County: Richmond
Receiving Stream: UT to Cartledge Creek
Index No: 13-35.
Stream Class: C
Sub -basin: 03-07-16 (Yadkin River Basin)
Facility Location

Lawyer, Mike
From:
Lawyer, Mike
Sent:
Friday, May 09, 2014 9:27 AM
To:
Ventaloro, Julie
Cc:
Cole, Brad
Subject:
RE: Review Request NCG090031 Rockingham Group
Hey Julie. I agree that the receiving stream is a UT to Cartledge Creek and I'm OK with issuing the COC.
Thanks,
Mike
Michael Lawyer, CPSWQ
Environmental Specialist
NCDENR — Division of Energy, Mineral and Land Resources
Land Quality Section
Fayetteville Regional Office
P: [phone]
F: [phone]
e-mail: [e-mail]
E-mail correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.
From: Ventaloro, Julie
Sent: Wednesday, May 07, 2014 9:56 AM
To: Lawyer, Mike
Cc: Cole, Brad
Subject: Review Request NCG090031 Rockingham Group
Hi Mike,
We've received an NOi for a new facility in your region.
NCG090031— Rockingham Group -- 2135 Manufacturing in Richmond County. The site discharge stormwater at one
point to UT to Cartledge Creek (I think this is where the discharge would ultimately end up, but could you confirm?). The
NOI is attached, along with a copy of a March 28, 2014 letter from Tracy Davis denying their request for No
Exposure. Mike, since you've already inspected the site, I'm assuming you're okay with issuing this COC, but please
confirm anyway.
Thanks!
Julie Ventaloro
Stormwater Permitting Program
NC Division of Energy, Mineral, and Land Resources
16112 Mail Service Center, Raleigh, NC 27699-1612
Phone: [phone] ' Fax: [phone]
Website: http:Ilwatersupplywatershed.nc.gov

E-mail correspondence to and from this address may he subject to the !North Carolina Public Records Law and may he disclosed to third
parties.

Ventaloro, Julie
From:
Lawyer, Mike
Sent:
Friday, May 09, 2014 9:27 AM
To:
Ventaloro, Julie
Cc:
Cole, Brad
Subject:
RE: Review Request NCGO90031 Rockingham Group
Hey Julie. I agree that the receiving stream is a UT to Cartledge Creek and I'm OK with issuing the COC.
Thanks,
Mike
Michael Lawyer, CPSWQ
Environmental Specialist
NCDENR — Division of Energy, Mineral and Land Resources
Land Quality Section
Fayetteville Regional Office
P: [phone]
F: [phone]
e-mail: [e-mail]
E-mail correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.
From: Ventaloro, Julie
Sent: Wednesday, May 07, 2014 9:56 AM
To: Lawyer, Mike
Cc: Cole, Brad
Subject: Review Request NCG090031 Rockingham Group
Hi Mike,
We've received an NOI for a new facility In your region.
NCG090031-- Rockingham Group — 2135 Manufacturing In Richmond County. The site discharge stormwater at one
point to UT to Cartledge Creek (I think this is where the discharge would ultimately end up, but could you confirm?). The
NOI is attached, along with a copy of a March 28, 2014 letter from Tracy Davis denying their request for No Exposure.
Mike, since you've already inspected the site, I'm assuming you're okay with issuing this COC, but please confirm
anyway.
Thanksl
Julie Ventaloro
Stormwater Permitting Prt:>gmm
NC Division of knurly, Mineral, and Land Resources
z61z Mail Service Center, Raleigh, NC 27699-6.2
Phone: [phone] F' tx: (gig) 807-649•1
Wcbsitc: httl:1/watersttnplvwatershed.nc.gQv
&mail correspondence to and from this arldress may he subject to the North Carolina Public Records Law rind may be disclosed to third
portae;s.

w
•
COATINGS,
Cal ADHESIVES,
INKS
7 MARTEL WAY
GEORGETOWN, MA 01833
TEL: [phone]
FAX: [phone]
April 16, 2014
Stormwater Permitting Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, NIC 27699-1617
RE: Notice of Intent
2135 Manufacturing — Rockingham
To Whom It May Concern:
Enclosed find our Notice of Intent to obtain General Permit NCGO90000 for
stormwater discharges associated with industrial activities for the above referenced
facility pursuant to instructions from Mr. Mike Lawyer of your Department as attached.
Should you have any questions, request additional information, or need to arrange
for a site visit, please contact me.
Sin rely
r �-
Robert A. Fricke
Corporate EHS Director
r [e-mail]
978-352-4510 (office)
617-538-2407 (mobile)
Enclosure

0
Divisloin of Water Quality / Surface Water Protection
Section
NODE R
National Pollutant Discharge Elimination System
,
NCGO90000 1)'nWuY0
NglICE QF INTEW.
National Pollutant Discharge Elimination System application for coverage under
NCGOOOOOO:
STORMWATER DISCHARGES associated with activities classified so:
SIC (Standard Industrial Classification) 205 Paints, Varnishes, Lacquers, Enamels, and Allied Products
.�— For questions, lease contact the DWO CON/co area. Seepage 4,
(Please print or type)
1) Mailing address of ownerloperator (mfsfress to whjgh 61) Dermlt coriggligndence 1jilI be rnallhm:
Name
Street Address
City
Telephone No.
2) Looatlon of facility producing discharge:
Facility Name
Facility Contact
Street Address
City
County
Telephone No.
Email
3) Physical Location Information:
Please provtde a narrative description of how tin gel to the faellity (use street names, state road numbers, and
distance and direction from a roadway Intersection). Route 74 to Business Route 74 east towards Rockingham
Tunr left onto Silver Grove Church Road. Travel 112 mile, turn right onto Enter rise Drive. Facility on right.
(A copy of a county map or USGS quad sheet with facility cleady locatod must be oubmitlod with Ih1a E4)p1leatlon.)
4) Latltude 34° 57' 47.09" Longitude 790 48' 17.96" (deg, min, see)
5) This NPDEt3 Permit Application applies Ito which of the following:
® New or Proposed Facility
© Existing
6) Standard Industrial Classification:
Date operation Is to begin ,_,_Aril 2013
Provide the 4-digit Standard Industrial Classification Code (SIC Code) that describes the primary industrial
activity at this facility
SIC Code: ? 8 9 3
Page 1 of 4
SWU•224-071408 Last revised 7114108
k11�
1
1+4 '
i
i
t
L 1
aaurh I

NCGO90000 N.O.I.
7) Provide a brief narrative description of the types of industrial activities and products manufactured at
this facility: Mix & blend printing ink
8) Discharge points / Receiving waters:
How many discharge points (ditches, pipes, channels, etc.) convey stormwater from the property?
What is the name of the body or bodies of water (creek, stream, river, lake, etc.) that the facility stormwater
discharges and up in? Pee DM.Rlypir
Receiving water classification: Class C
Is this a 303(d) listed stream? No Has a TMQL been approved for this watershed? No
If the site stormwater discharges to a separate storm sewer system, name the operator of the separate storm
sewer system (e.g. City of Raleigh municipai storm sewer). NA
9) Does this faculty have any other NPDES permits?
® No
0 Yes
If yes, list the permit numbers for all current NPDES permits for this facility:
10) Does this facility have any Non-Olscharge permits (ex: recycle permit)?
® No
❑ Yes
it yes, list the permit numbers for all current Non -Discharge permits for this facility:
11) Does this facility employ any best management practices for stormwater control?
❑ No
M Yes (Show any structural BMPs on the site diagram.)
If yes, please briefly describe: Secondary containment for tank farm. Only clean pallets stored outside.^
Only, cleaned used equipment stored outside.
12) Does this facility have a Stormwater Pollution Prevention Plan?
❑ No
® Yes
If yes, when was it implemented? April 2014 y
13) Are vehicle maintenance activities occurring at this facility?
® No ❑ Yes
14) Hazardous Waste:
a) Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility?
M No ❑ Yes
b) Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous waste generated per month) of
hazardous waste?
❑ No M Yes
c) Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste generated per month) of
hazardous waste?
® No ❑ Yes
Page 2 of 4
swu•224-071408 Lest rewsed 1/1410a

NCGO90000 N.01
d) Is hazardous waste stored in the 100-year flood plain?
DO No 0 Yes If yes, include information to demonstrate protection from flooding.
e) If you answered yes to questions b. or c., please provide the following information:
Type(s) of waste:
How is material stored
Where is material stored:____,
How many disposal shipments per year:
Name of transport I disposal vendor: N
Vendor address:
15) Certification:
North Carolina General Statute 143.215.6B (1) provides that:
Any person who knowingly makes ah7talso sialemeni, rapresenlalion, or caAiticallon in any application, record, report,
plan, or olhor documem tiled or required to be maintained under this Article or a cute implomenling this Article; or who
knovAngly makes a false statement of a material tact In a wlemnking proceeding or oontosted case under this Article. or
who falsities, tampers with, or knowingly fenders inaccurate any recording or monitoring device or method required to be
operatod or maintained under this Articia or rules of the Commission Implementing this Article shell be guilty of a Class
2 misdemeanor which may include a line not to exceed tan Thousand dollars ($10,000).
I hereby request coverage under the referenced General Permit. I understand that coverage under this permit
will constitute the permit requirements for the discharges) and is enforceable in the same manner as an
individual permit.
I certify that I am familiar with the information contained in this application and that to the best of my
knowledge and belief such information is truo, complete, and accurate.
Printed Name of Person
Title: Corporate E�
Robert A. Fricke
Notice of Intent must be accompanied by a cheak or money order for $100.00 made payable to:
NCDENR
Page 3 of 4
swu•224-07 $408 last revised 7/1401

s
NCGO90000 N.0.1.
MZT47%T' RM
This application will be returned as Incomplete unless all of file following items have been included:
0 Check for $100 made payable to NCDENR
4T0 This completed application and all supporting documents
Z A site diagram showing, at a minimum, (existing or proposed):
(a) outline of drainage areas, (b) stormwater management structures, (c) location of stormwater outlalls
corresponding to the drainage areas, (d) runoff conveyance features, (e) areas where materials are stored,
(1) impervious areas, (g) site property lines,
Q1 Copy of county map or USGS quad sheet wlfh location of facility clearly marked on map
Mall the entire package to:
Stormwater Permitting Unit
Division of Water duality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
No
The submission of this document does not guarantee coverage under the NPDES General Permlt.
For quesfions, please contact the DW Regional Office for your area.
Asheville Office ......
[phone]
Fayetteville Office ...
[phone]
Mooresville Office ...
[phone]
Raleigh Office ........
[phone]
Washington Office ...(252)
946-6461
Wilmington Office ...
[phone]
Winston-Salem ......
[phone]
Central Office .........(919)
807-6300
69'iT1r) KINFi6ld:1
Page 4 of 4
Last revised 7114108

2135 Manufacturing, LLC.
106 Enterprise Drive
Rockingham, NC 28379
Latitude 340 57' 47.09"
Longtitude 790 48' 17.96"

NOIRK
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarla, III
Governor Secretary
March 28, 2014
CAI
Attn: Robert A. Fricke, Corporate EHS Director
7 Martel Way
Georgetown, MA 01833
Subject: Denial of No Exposure Certification NCGNE0999
Rockingham Group, LLC / 2135 Manufacturing, LI-C
Richmond County
Dear Mr. Fricke:
The Division of Energy, Mineral and Land Resources has reviewed your submittal of the No Exposure
Certification for Exclusion from NPDES Stormwater Permitting form, which was received on March 7, 2014.
The Division is unable to concur with your certification of no exposure.
Based on an inspection of your facility on March 25, 2014 by Mike Lawyer with the Fayetteville Regional
Office, industrial activities or materials on your site either are exposed, or have the potential to be exposed.
The Division cannot grant your requested exemption from permit coverage when industrial activities or
materials are exposed or have the potential to be exposed. Based on the type of industrial activities
occurring at the facility and the used equipment that Is stored and exposed in the "graveyard", you are asked
to complete and submit the enclosed Notice of Intent application for coverage under the NCGO90000
General Stormwater Permit.
1f you have any questions or concerns, please contact Mike lawyer at [phone] or by e-mail at
m ike.lawyer ®ncdenr,gov.
Sincerely,
far Tracy E. Davis, PE, CPM
Enclosure
PC: FRO - Land Quality Section, Stormwater Files (w/o enclosure)
Stormwater Permitting Program, No Exposure Files (w/o enclosure)
Division of Energy, Mineral, and Land Resources
Land Quality Section
Fayetleville Regional Office, 225 Green Street - Suite 714, Fayetteville, North Ca(Ona 28301
Phone: [phone] f FAX: [phone] / lnternei: bUR;([portal,ncdenr.ofglwetLlr1
An Equal Opportunity 1 Affirmative Action Employer - 50% Recycled 110% Post Consumer Paper

I
A
OdYSCIdACd _
SITE PLAN 2135 Manufacturing, LLC. OMOUP. INC.
W Rockingham, North Carolina
�i

COATINGS,
Cal ADHESIVES,
INKS
7 MARTEL WAY
GEORGETOWN, MA 01833
TEL: [phone]
FAX [phone]
April 16, 2014
Stormwater Permitting Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
RE:. Notice of Intent
2135 Manufacturing - Rockingham
To Whom. It May Concern:
Enclosed find our Notice of Intent to obtain General Permit NCG090000 for
stormwater discharges associated with industrial activities for the above referenced
facility pursuant to instructions from Mr. Mike Lawyer of your Department as attached.
Should you have any questions, request additional information, or need to arrange
for a site visit, please contact me.
Sinc rely,
Robert A. Fricke
Corporate EHS Director
rafrickeCa calinkxom ; _- . - -
978-352-4510 (office)
617-538-2407 (mobile)
Enclosure

Division of Water Quality 1 Surface Water Protection nem
Section U3 ! °►
���� CarliSaldat
NCDENRNational Pollutant Discharge Elimination System Check A° U
vsm. Cyq,m► i]rrw�v+n ar � U d _ ..... _
NCGO90000 1( +�vry
NOTIGINIONT APR 9. 4 2014
National Pollutant Discharge Elimination System application for coverage under Goner I P irmit
NCGO90000: DLjpK-. IAfq "�-"' I t.
�r'3rarx:h i
STORMWATER DISCHARGES associated with activities classified so: Tn,r
SIC (Standard Industrial Classification) 285 Paints, Varnishes, Lacquers, Enamels, and Allied Products
For questions, please contact the D WO Regional Office for your area. See page 4.
(Please print or type)
_ 1) Melling address of owner/operator (oddrutio whLh gll n rMit ggrMIggndenagIg II be hailed):
Name Rockingham Gr6up, LLC.
Street Address 106 EaMpiise lOrJye
City Ro_cking_ham _ _ - _ State INC ZIP Code 28379
M _ Telephone No. 910-895-5779 TT Fax: [phone] -
2) location of facility producing discharge:
Facility Name
Facility Contact .
Street Address
Pity. _
County
Telephone No.
Email
3) Physical location Information:
Please provide -a narrative description of how to gat to the facility (use street names, state road numbers, and
distance and direction from a roadway intersection). Route 74 to Business Route:74 East towards Rockingham
Tunr left onto Sllver Grove Church Road. Travel W mile, turn right onto Enterprise Drive. Facility on right,
(A cagy of a county map or USGS quad sheet vdth faculty clearly located must be'submkted With this 401callon.)
4) Latitude 340 57' 47.09" Longitude 790 48' 17.96" (dog, min, see)
5) This NPDES Permit Application applies to which of the following:
® New or Proposed Facility Bate operation is to begin April 2013 _
0 Existing
6) Standard Industrial Classification:
Provide the 4-digit Standard Industrial Classification Code (SIC Code) that describes the primary industrial
activity at this facility
SIC Code: 2 8 9 3
Page 1 of 4
M-224-071408 Last revised 711toe

NCGO90000 N.O.I.
7) Provide a brief narrative description of the types of Industrial activities and products manufactured at
this facility: Mix &_blend_printing ink_ T
0) Discharge points 1 Receiving waters:
How many discharge points (ditches, pipes, channels_ etc.) convey stormwater from the property?
What is the name of the body or bodies of water (creek, stream, river, lake, etc.) that the facility stormwater
discharges end up in? _ _Eae Dee River
Receiving water classification: Class C
Is this a 303(d) listed stream? No Has a TMDL been approved for this watershed? No
If the site stormwater discharges to a separate storm sewer system, name the operator of the separate storm
sewer system (e.g. City of Raleigh municipal storm sewer). NA
9) Does this facility have any other NPOES permits?
® No
❑ Yes
If yes, list the permit numbers for all current NPDES permits for this facility:
10) Does this iecility have any Non -Discharge permits (ex: recycle permit)?
® No
❑ Yes
It yes, list the permit numbers for all current Non -Discharge permits for this facility: _
11) Does this facility employ any best management practices for stormwater control?
❑ No
® Yes (Show any structural BMPs an the site diagram.)
If yes, please briefly describe: Seconds containment for tank farm. Only clean pallets stored outside.
Onlv cleaned used eauiDment stored outside.
12) Does this facility have a stormwater Pollution Prevention Plan?
❑ No
® Yes
If yes, when was It implemented? April 2014
13) Are vehicle maintenance activities occurring at this facility?
IN No ❑ Yes
14) Hazardous waste:
a) Is this facility a Hazardous Waste Treatment, Storage, or Disposal Faculty?
® No ❑ Yes
b) Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous waste generated per month) of
hazardous waste?
❑ No 0 Yes
c) is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste generated per month) of
hazardous waste?
® No i ❑ Yes +
Page 2 of 4
swu-224-071408 Last revised 7I14MB

NCC3090000 N.O.I.
d) Is hazardous waste stored in the 100-year flood plain?
® No ©Yes if yes, include information to demonstrate protection from flooding.
e) if you answered yes to questions b. or c., please provide the following information:
Type(s)-of waste;
Mow is material stored:
Where is material stored:
How many disposal shipments per year:
Name of transport / disposal vendor:
Vendor address:
15) Certification:
North Carolina General Statute 143-215.88 (1) provides that:
Any person who knowingly makes shylalse statement, representation, or certification In any application, record, report,
plan, or other document filed or required to be maintained under this Article or a rule implamenling this Article; or who
kn*whVW makes a false statement of a material fact in a rulamaking proceeding or oontasted case under this Article; or
who falsities, tampers with, or knowingty renders inaccurate any recording or monitoring device or method required to be
operated at maintained under this Mete or rules of the Commission implementing this Article shall be guilty of a (lass
2 misdemeanor which may include a fine not to exceed ten thousand dollars ($10,000).
I hereby request coverage under the referenced General Permit. I understand that coverage under this permit
will constitute the permit requirements for the discharge(s) and is enforceable in the same manner as an
individual permit.
i certify that I am familiar with the information contained in this application and that to the best of my
knowledge and belief such information Is true, complete, and accurate.
Printed Name of Person Signing: Robert A. Fricke w_
Title: Corporate EHS _Director. _._._.
- Notice of Intent must be accompanied by a check or money order for $100.00 made payable to:
NCDENR
Page 3 of 4
swu-224-071408 last revised 7111108

S .
2135 Manufacturing, LLC.
106 Enterprise Drive
Rockingham, NC 28379
Latitude 340 57' 47.09"
Longtitude 790 48' 17.96"

FIFWFA
K DENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
March 28, 2014
CAI
Attn: Robert A. Fricke, Corporate EHS Director
7 Martel Way
Georgetown, MA 01833
John E. Skvaria, Ili
Secretary
Subject: Denial of No Exposure Certification NCGNE0999 ' '
Rockingham Group, LLC / 2135 Manufacturing, LI_C -
Richmond County
Dear Mr. Fricke:
The Division of Energy, Mineral and Land Resources has reviewed your submittal of the No Exposure
Certification for Exclusion from NPDES Stormwater Permitting form, which was received on March 7, 2014.
The Division is unable to concur with your certification of no exposure.
Based -on an inspection of your facility on March 25, 2014 by Mike Lawyer with the Fayetteville Regional
Office, industrial activities or materials on your site either are exposed, or have the'potential to be exposed.
- The Division cannot grant your requested exemption from permit coverage when industrial activities or
materials are exposed or have the potential to be exposed. Based on the type of industrial activities
_ :occurring at the facility and the used equipment That is stored and exposed.in'the "graveyard", you are asked
:. la complete and submit the enclosed Notice of Intent -application for coverage under the NCGO90000
General Stormwater Permit.
If you have any questions or concerns; please contact Mike Lawyer at [phone] or by email at
mike.lawyer Onedenr.gov.
r _ Sincerely,
for Tracy E. Davis, PE, CPM
Enclosure
CC. FRO - Land Quality Section, Stormwater Files (w/o enclosure)
Stormwater Permitting Program, No Exposure Flies (w/o enclosure)
Division of Energy, Mineral, and Land Resources
Land Duality Section
Fayetteville Regional Office, 225 Green Street - Suite 714, Fayetteville, North Carolina 28301
Phone: [phone] FAX: [phone] Internet: b al nl;9enr.oM&V bllrl
An Equal Opportunity 1 Affirmative Action Employer - 50% Recycled 110% Post Consumer Paper

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Central Files: APS _ SWP
11 /25/2014
Permit Number NCGO80931 Permit Tracking Slip
Program Category
Status Project Type
NPDES SW
In draft New Project
Permit Typo
Version Permit Classification
Transportation wNehicle MaintenancelPetroleum Bulk/Oil Water Separator Stormwater
COC
Discharge COC
Primary Reviewer
Permit Contact Affiliation
larry.wade
coastal SWRulo RECEIVED
Permitted Flow
Facility
DEC 0 9 2014
CENTRAL FILES
DWR SECTION
Facility Name Major/Minor Region
ABF Freight Minor Fayetteville
Location Address County
226 Sanders St Cumberland
Facility Contact Affiliation
Hope Mills NC 28348 Chris Palke
226 Sanders St
Owner Hope Mills NC 28348
Owner Name Owner Type
ABF Freight System Inc Non-Govemment
Owner Affiliation
Michael K. Rogers
PO Box 10048
Dates/Events Fort Smith AR 72917004
Scheduled
Orig Issue App Received Draft Initiated issuance Public Notice Issue Effective Expiration
12/1 /2014 10/27/2014 11 /25/2014 12/1/2014 12/1 /2014 10131 /2017
Regulated Activities Requested /Received Events
Transportation with vehicle maintenance RO staff report received 11/24/14
RO staff report requested 10/29114
O utfa I I 100
Waterbody Name Streamindex Number Current Class Subbasln
Rockfish Creek 18-31-(23) C 03-06-15

KNEW
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
Mr. Murray Babb
ABF Freight Systems, Inc.
P. 0. Box 10048
Fort Smith AR 72917-0048
Dear Mr. Babb:
John E. Skvada, III
Secretary
December 1, 2014
Subject: General Permit No. NCGO80000
ABF Freight - Fayetteville
COC NCGO80931
Cumberland County.
. In accordance with your application for a discharge permit received on October
27, 2014, 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 143-21S.1 and the Memorandum of
Agreement between North Carolina and the US Environmental Protection Agency
dated October 15, 2007 (or as subsequently amended).
Please take notice that this certificate of coverage is not transferable except
after notice to the Division of Energy Mineral & Land Resources (DEMLR). If the facility
changes ownership or is closed, DEMLR may require modification, revocation, or
reissuance of the certificate of coverage.
This permit does not affect the owners legal obligation to obtain other permits
which may be required by DEMLR, or permits required any other federal, state, or local
governmental authorities.
If you have any questions concerning this permit, please contact Larry Wade PE
at telephone number [phone], or email at larry.wade(-ncdenr.goy.
Sincerely,
for Tracy E. Davis, P.E.
cc: Fayetteville Regional Office
Central Files
Stormwater Permitting Program Files
Division of Energy, Mineral, and Land Resources
Energy Section - Geological Survey Section - Land Quality Section
1612 Mail Service Center, Raleigh, North Carolina 27699-1612.919-707-92001 FAX: [phone]
512 North Salisbury Street, Raleigh, North Carolina 27604 - Internet: http://portal.nodenr.org/web/Ir/
An Equal Opportunity 1 Affirmative Action Employer — 50% Recycled 110% Post Consumer Paper

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF ENERGY, MINERAL AND LAND RESOURCES
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,
ABF Freight Systems, Inc.
is hereby authorized to discharge stormwater from a facility located at
ABF Freight
226 Saunders Street
Fayetteville
Cumberland County
to receiving waters designated as Rockfish Creek, a class C water in the Cape Fear River
Basin, in accordance with the effluent limitations, monitoring requirements, and other
conditions set forth in Parts 1, 11, 111, IV, V, and VI of General Permit No. NCG080000 as
attached.
This certificate of coverage shall become effective December 1, 2014.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day December 1, 2014.
for Tracy E. Davis, P.E., CPM
Director, Division of Energy, Mineral and Land Resources
By the Authority of the Environmental Management Commission

0
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12
0811431 11 ARFFroiahtSvcto
ISCINNILV ILKJE-:AILIL

Wade, Larry
From: Lawyer, Mike
Sent: Monday, November 24, 2014 9:31 AM
To: Wade,. Larry
Subject: RE: NCG080931 ABF Freight Systems, Inc.
Categories: Red Category
Larry,
I have made several attempts over the past few weeks to contact facility personnel about meeting at the site to go over
their application and discuss permit conditions. There is no answer or voicemail option when I call the facility and I have
not received a reply to an e-mail I sent to the facility contact on November 11`h
Let's go ahead and issue permit coverage.
Thanks,
Mike
Michael Lawyer, CPSWQ
Environmental Specialist
NCDENR —Division of Energy, Mineral and Land Resources
Land Quality Section
Fayetteville Regional Office
P: [phone]
F: [phone]
e-mail: [e-mail]
E-mail correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.
From: Wade, Larry
Sent: Wednesday, October 29, 2014 1:32 PM
To: Lawyer, Mike
Subject: NCG080931 ABF Freight Systems, Inc.
Hello Mike,
Find attached to NO[ for the subject facility.
Please review the information and let me know if you have any concerns issuing a permit.
Thanks,
Larry W. Wade PE Telephone: [phone]
Fax: [phone]
Stormwater Permitting Program
North Carolina Department of Environment & Natural Resources
Division of Energy Mineral and Land Resources

Division of Water Quality 1 Surface Water Protection
Section
NCDENRNational
Pollutant Discharge Elimination System
NQWf C-0—. DuMR Ln or
E.VIRONme+T.RO N"�R£'J RC£]
NCG080000
FOR AGENCY USE ONLY
Date Received
Year
Month
Da
Certificate of Cove e
Ch otut
Pe it As4ned to
WoLew
NOTICE OF INTENT
National Pollutant Discharge Elimination System application for coverage under General Permit
NCG080000:
STORMWATER DISCHARGES from Vehicle Maintenance Areas (including vehicle rehabilitation,
mechanical repairs, painting, fueling, lubrication, and equipment cleaning operations areE
with activities classified as:
SIC 40 (Standard Industrial Classification) Railroad Transportation
SIC 41 Local and Suburban Transit and Interurban Highway Passenger Transportatio2 4 2014
SIC 42 Motor Freight Transportation and Warehousing (except SIC 4221-4225) WA R KSOURI
SIC 43 United States Postal Service ERM1TTi
The following activities are also included:
• Other industrial activities where the vehicle maintenance area(s) is the only area requiring permitting
• Petroleum Bulk Stations and Terminals (SIC 6171) with total petroleum site storage capacity of less than 1
million gallons
• Stormwater discharges from oil water separators and/or from secondary containment structures
associated with petroleum storage facilities with less than 1 million gallons of total petroleum site storage
capacity.
• Discharges associated with vehicle maintenance operations at activities, which are otherwise designated
on a case -by -case basis for permitting.
For questions, please contact the DWQ Regional Office for your area. See page 4.
(Please print or type)
1) Mailing address of ownerloperator (address to which all correspondence. will be mailed):
Name ABF Freight Systems Inc.
Street Address P O Box 10048
City Fort Smith State AR ZIP Code 72917-0048
Telephone No. 479 785 8639 Fax: [phone]
2) Location of facility producing discharge:
Facility Name ABF Freight
Facility Contact Chris Palke
Street Address 226 Sanders Street
City Fayetteville State NC ZIP Code 28348
County Cumberland
Telephone No. 910-424-5055 Fax: [phone]
Email
[e-mail]
Page 1 of 4
SWU-223-071408•. Last revised 7114108

IL+ C111 1111111mem
3) Physical Location Information:
Please provide a narrative description of how to get to the facility (use street names, state road numbers, and
distance and direction from a roadway intersection). From 1-95 South, take Exit 41 for N Carolina 59
Toward Hope MillslParkton. Keep right at fork, follow signs for NC 59 NI Hope Mills Parkton. Turn
right onto NC 59 North. Take the first right onto Marracco Drive. Turn right onto Sanders street.
Destination will be on the right.
(A copy of a county map or USGS quad sheet with facility clearly located must be submitted with this application)
4) Latitude 34° 57 ' 21.9018 " N Longitude 78° 55 ' 6.3192 W" (deg, min, sec)
5) This NPDES Permit Application applies to which of the following:
❑ New or Proposed Facility Date operation is to begin
X Existing
6) Standard Industrial Classification:
Provide the 4-digit Standard Industrial Classification Code (SIC Code) that describes the primary industrial
activity at this facility
SIC Code: 4 2 1 3
7) Provide a brief narrative description of the types of industrial activities and products manufactured at
facility: The facility is a motor freight terminal. It consists of a load inglunloading dock and a storage.
8) Discharge points / Receiving waters:
How many discharge points (ditches, pipes, channels, etc.) convey stormwater from the property? 2
What is the name of the body or bodies of water (creek, stream, river, lake, etc.) that the facility stormwater
discharges end up in? Rockfish Creek
Receiving water classification: —C
Is this a 303(d) listed stream? No Has a TMDL been approved for this watershed? no
If the site stormwater discharges to a separate storm sewer system, name the operator of the separate storm
sewer system (e.g. City of Raleigh municipal storm sewer). Fayetteville municipal sewer system
9) Does this facility have any other NPDES permits?
X No
❑ Yes
If yes, list the permit numbers for all current NPDES permits for this facility:
10) Does this facility have any Non -Discharge permits (ex: recycle permit)?
X No
❑ Yes
If yes, list the permit numbers for all current Non -Discharge permits for this facility:
11) Does this facility employ any best management practices for stormwater control?
❑ No
X Yes (Show any structural BMPs on the site diagram.)
If yes, please briefly describe: BMPs include the use of gravel parking areas, berths grading or
curbing to prevent run-off, keeping containers closed, inspecting storage areas regularly, avoiding transfers
during precipitation events, and prompt clean-up of any spills that may occur.
Page 2 of 4
SWU-223-071408 Last revised 7114108

NCGO8OOOO N.O.I.
12) Does this facility have a Stormwater Pollution Prevention Plan?
❑ No
X Yes
If yes, when was it implemented?
13) Are vehicle maintenance activities occurring at this facility?
No X Yes
14) Hazardous Waste:
a) Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility?
X No ❑ Yes
b) Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous waste generated per month) of
hazardous waste?
X No ❑ Yes
c) Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste generated per month) of
hazardous waste?
X No ❑ Yes
d) Is hazardous waste stored in the 100-year flood plain?
X No ❑ Yes If yes, include information to demonstrate protection from flooding.
e) If you -answered yes to questions b. or c., please provide the following information:
Type(s) of waste:
How is material stored:
Where is material stored:
How many disposal shipments per year:
Name of transport 1 disposal vendor:
Vendor address:
15) Certification:
North Carolina General Statute 143-215.6E (1) provides that:
Any person who knowingly makes any false statement, representation, or certification in any application, record, report,
plan, or other document filed or required to be maintained under this Article or a rule implementing this Article; or who
knowingly makes a false statement of a material fact in a rulemaking proceeding or contested case under this Article; or
who falsifies, tampers with, or knowingly renders inaccurate any recording or monitoring device or method required to be
operated or maintained under this Article or rules of the Commission implementing this Article shall be guilty of a Class
2 misdemeanor which may include a fine not to exceed ten thousand dollars ($10,000).
I hereby request coverage under the referenced General Permit. I understand that coverage under this permit
will constitute the permit requirements for the discharge(s) and is enforceable in the same manner as an
individual permit.
I certify that I am familiar with the information contained in this application and that to the best of my
knowledge and belief such information is true, complete, and accurate.
Printed Name
Title: V+ru
Page 3 of 4
SWU-223.071408 Last revised 7114108

NCG080000 N.4.1.
Notice of Intent must be accompanied by a check or money order for $100.00 made payable to:
NCDENR
Final Checklist
This application will be returned as incomplete unless all of the following items have been included:
Check for $100 made payable to NCDENR
NV"- This completed application and all supporting documents
M�-� A site diagram showing, at a minimum, (existing or proposed):
(a) outline of drainage areas, (b) stormwater management structures, (c) location of stormwater outfalls
corresponding to the drainage areas, (d) runoff conveyance features, (e) areas where materials are stored,
(f) impervious areas, (g) site property lines.
6a----- Copy of county map or USGS quad sheet with location of facility clearly marked on map
Mail the entire package to:
Stormwater Permitting Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Note
The submission of this document does not guarantee coverage under the NPDES General Permit.
For questions, please contact the DWQ Regional Office for your area.
M Regional Office Contact Information:
Asheville Office ......
[phone]
Fayetteville Office...
[phone]
Mooresville Office ...
[phone]
Raleigh Office ........
[phone]
Washington Office ...(252)
946-6481
Wilmington Office...
[phone]
Winston-Salem ......
[phone]
Central Office .........(919)
807-6300
Page 4 of 4
SWU-223-071408 Last revised 7114108

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ABFFREIGHT .SYSTEM, INC.
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226 SANDERS 6TREET
HOPE MILLS, NORTH CAROLINA
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M
Wade, Larry
From: Lawyer, Mike
Sent: Monday, November 24, 2014 9:31 AM
To: Wade,. Larry
Subject: RE: NCG080931 ABF Freight Systems, Inc.
Categories: Red Category
Larry,
I have made several attempts over the past few weeks to contact facility personnel about meeting at the site to go over
their application and discuss permit conditions. There is no answer or voicemail option when I call the he
and I have
not received a reply to an e-mail I sent to the facility contact on November 11tn
Let's go ahead and issue permit coverage.
Thanks,.
Mike
Michael Lawyer, CPSWQ
Environmental Specialist
NCDENR —Division of Energy, Mineral and Land Resources
Land Quality Section
Fayetteville Regional Office
P: [phone]
F: [phone]
e-mail: mike. [e-mail]
E-mail correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.
From: Wade, Larry
Sent: Wednesday, October 29, 2014 1:32 PM
To: Lawyer, Mike
Subject: NCG080931 ABF Freight Systems, Inc.
Mello Mike,
Find attached to NOI for the subject facility.
Please review the information and let me know if you have any concerns issuing a permit.
Thanks,
Larry W. Wade PE Telephone: [phone]
Fax: [phone]
Stormwater Permitting Program
North Carolina Department of Environment & Natural Resources
Division of Energy Mineral and Land Resources

Permit Number NCGO90031
Program Category
NPIDES SW
Permit Type
Paints, Varnishes, Lacquers Stormwater Discharge COC
Primary Reviewer
RECEIVED
julle.ventelaro "
MAY 12 2014
Coastal SWRule
CENTRAL FILES
Permitted Flow
DWQ/BOG
Facility
Central Files: APS _ SWP
519/2014
Permit Tracking Slip
Status Project Type
In review New Project
Version Permit Classification
COC
Penmlt Contact Affiliation
Facility Name MajorlMlnor Region
2135 Manufacturing, LLC Minor Fayetteville
Locatlon Address County
106 Enterprise Or Richmond
Facility Contact Affiliation
Rockingham NC 28379 Tom. Sartorelll
106 Enterprise Or
Owner Rockingham NC 28379
Owner Name Owner Type
Rockingham Group LLC Non -Government
Owner Affiliation
Paul Sartarelli
106 Enterprise Or
DateslEvents Rockingham NC 28379
Scheduled
Orlg Issue App Received Draft Initiated Issuance Public Notice Issue Effective Expiration
4/29/2014 05-09.2,0/y 0S.'0q-iay /0-31-2,01'7
Regulated Activities Requested /Received Events
Printing and publishing RO staff report received 519114
RO staff report requested 517114
Outfall - 001
Waterbody Name Streamindex Number Current Class Subbasin
Cartledge Creek 13-35 C 03-07-16

A�,E� �.r`'. a
CCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarla, III
Governor Secretary
May 9, 2014
Mr. Paul Sartorelli
Rockingham Group, LLC
106 Enterprise Drive
Rockingham, NC 28379
Subject: General Permit No. NCG090000
Rockingham Group, LLC
COC No. NCG090031
Richmond County
Dear Mr. Sartorelli:
In accordance with your application for a discharge permit received on April 29, 2014,
we are forwarding herewith the subject certificate of coverage (COC) 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 October 15, 2007 (or as
subsequently amended).
Please take notice that this certificate of coverage is not transferable except upon
approval of the Division of Energy, Mineral, and Land Resources. The Division of Energy,
Mineral, and Land Resources 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 Energy, Mineral, and Land Resources, the Coastal Area
Management Act, or any other federal or local government permit that may be required.
Division of Energy, Mineral, and Land Resources
Energy Section - Geological Survey Section - Land Quality Section
1612 Mail Service Center, Raleigh, North Carolina 27699-1612 a 919-707-92001 FAX; 919-715-8801
612 North Salisbury Street, Raleigh, North Carolina 27604 - Internet: httg;IloortaI.ncdenr.orglweblirl
An Equal Opportunity 1 Affirmative Action Employer — 50% Recycled 110% Post Consumer paper

If you have any questions concerning this permit, please contact Julie Ventaloro at telephone
number [phone] or by email j�lie.ventaloroCr ncdenr.gov.
Sincerely,
11-011
for Tracy E. Davis, RE., CPM, Director
Division of Energy, Mineral and Land Resources
cc: Fayetteville Regional Office, B. Cole
Central Files
Stormwater Permitting Program Piles

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF ENERGY, MINERAL, AND LAND RESOURCES
GENERAL PERMIT NO. NCG090000
CERTIFICATE OF COVERAGE No. NCG090031
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,
Rockingham Group, LLC
is hereby authorized to discharge stormwater from a facility located at
2135 Manufacturing, LLC
106 Enterprise Drive
Rockingham
Richmond County
to receiving waters designated as unnamed tributary to Cartledge Creek, a class C water in the
Yadkin 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. NCG090000 as
attached.
This certificate of coverage shall become effective May 9, 2014.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day May 9, 2014.
for Tracy E, Davis, P,E., Director
Division of Energy, Mineral, and Land Resources
By the Authority of the Environmental Management Commission

NCG090031
Map Scale 1:24,000
Rockingham Group, LLC,
2135 Manufacturing, LLC
Latitude: 340 57' 47" N
Longitude: 790,48' 17" W
County: Richmond
Receiving Stream: UT to Cartledge Creek
Index No: 13-35
Stream Class: C
Sub -basin: 03-07-16 (Yadkin River Basin)
Facility Location.

•
COATINGS,
Cal ADHESIVES,
INKS
7 MARTEL WAY
GEORGETOWN, MA 01833
TEL: [phone]
FAX: [phone]
April 16, 2014
Stormwater Permitting Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: Notice of Intent
2135 Manufacturing — Rockingham
To Whom It May Concern:
Enclosed find our Notice of Intent to obtain General Permit NCGO90000 for
stormwater discharges associated with industrial activities for the above referenced
facility pursuant to instructions from Mr. Mike Lawyer of your Department as attached.
Should you have any questions, request additional information, or need to arrange
for a site visit, please contact me.
Sinc rely,
Robert A. Fricke
Corporate EHS Director
[e-mail]
978-352-4510 (office)
617-538-2407 (mobile)
Enclosure

'IVA
Division of Water Quality / Surface Water Protection
Section]
NCDENRNational
Pollutant Discharge Elimination System
.,.,� � KWWA
NCGO90000 \61p l u vv
NOTICE QE INTENT
National Pollutant Discharge Elimination System application for coverage under
NCGONOOO:
,h
STORMWATER DISCHARGES associated with activities classified as:
SIC (Standard Industrial Classification) 285 Paints, Varnishes, Lacquers, Enamels, and Allied Products
._.__ For questions, please contact the AWO Regional Office for your srea. See page 4.
(Please print or type)
1) Mailing address of owner/operator (af eso to wbM all twmtt conysnondenoe will be mailed]:
Name
Street Address
City
Telephone No.
Rockingham Group, LLC.
2) Location of facility producing discharge:
Fatality Name
Facility Contact
Street Address
City
County
Telephone No.
Email
2135 Manufacturing, LLC.
Tom Sartorelli Plant Manager
106 nterorise Drive
State NC ZIP Code 28379
Fax: [phone]
State ILL, ZIP Code
-ichmond
910-895-5779 Fax: [phone]
[e-mail]
3) Physical Location Information:
Please provide a narrative description of how to gat to the facility (use street names, state road numbers, and
distance and direction from a roadway intersection), Route 74 to Business Route 74 East towards Rockingham
Tunr left onto Silver Grove Church Road. Travel 112 mile, turn right onto Enterprise Drive. Facility on right.
(A copy of a onunty map or USES quad sheet with facility clearly located crust be submitted wlth thts rpolcatlon.)
4) Latitude 340 57' 47.09" Longitude 790 48' 17.96" (deg, min, sec)
5) This NPDES Permit Application applies to which of the following:
® New or Proposed Facility
© Existing
6) Standard Industrial Classification:
Date operation is to begin April 2013
Provide the 4-digit Standard Industrial Classification Code (SIC Code) that describes the primary industrial
activity at this facility
sic Code: 2 8 9 3
Page 1 of 4
5WV224-071408 Last ravtsed 7l14=

NCGO900DO N.O.I.
7) Provide a brief narrative description of the types of Industrial activities and products manufactured at
this facility: Mix_& blend printing ink T _�
B) Discharge points / Receiving waters:
How many discharge points (ditches, pipes, channels, etc.) convey stormwater from the property? 1
What is the name of the body or bodies of water (creek, stream, river, lake, etc.) that the facility stormwater
discharges end up in? fee Dee -River
Receiving water classification: Class C _
Is this a 303(d) listed stream? No Has a TMaL been approved for this watershed? No
If the site stormwater discharges to a separate storm sewer system, name the operator of the separate storm
sewer system (e.g. City of Raleigh municipal storm sewer). __NA
9) Does this facility have any other NPDES permits?
(M No
1:1 Yes
If yes, list the permit numbers for all current NPDE:S permits for this facility:
10) Does this facility have any Non -Discharge permits (ex: recycle permit)?
9 No
❑ Yes
If yes, list the permit numbers for all current Non -Discharge permits for this facility:
11) Does this facility employ any best management practices for stormwater control?
❑ No
® Yes (Show any structural BMPs on the silo diagram.)
If yes, please brieflydescribe: ___ Secondary_ containment for tank farm. Only clean pallets stored outslde.
Only cleaned used equipment stored outside.
12) Does this tacillty have a 5tormwaler Pollution Prevention Plan?
❑ No
® Yes
If yes, when wash implemented? April 2014
13) Are vehicle maintenance activities occurring at this facility?
® No ❑ Yes
14) Hazardous Waste:
a) Is this facility a Hazardous Waste Treatment, Storage, or Disposal Faciiity?
IN No ❑ Yes
b) Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous waste generated per month) of
hazardous waste?
❑ No ® Yes
c) Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste generated per month) of
hazardous waste?
® No ❑ Yes
Page 2 of 4
SW U-224-071408 last revised 7/14108

NCGO90000 N.O.I.
d) Is hazardous waste stored in the 100-year flood plain?
® No ❑ Yes If yes, include information to demonstrate protection from flooding.
e) If you answered yes to questions b. or c., please provide the following information:
Typo(s) of waste:
How Is material stored:
Where is material stored:
How many disposal shipments per year:
Name of transport / disposal vendor:
Vendor address:
15) Certification:
North Carolina General Statute 143.215.8E (1) provides that:
Any person who knowingly makes ah7falee statement, representation, or cardficatlon in any application, record, report,
plan, or other document filed or required to be maintained under this Article or a rule Implementing this Article; or who
knowingty makes a false statement of a material last in a rulamaking proceeding or oontested case under this Article: or
who falsifies, tampers with, or knowingly renders inaccurate any recording or monitoring device or method required to be
operated or maintained under this Article or rules of the Commission Implementing this Article shall be guilty of a Class
2 misdemeanor which may include a fine not to errcoad ten thousand dollars ($10.000).
I hereby request coverage under the referenced General Permit. I understand that coverage under this permit
will constitute the permit requirements for the disCharge(s) and is enforceable In the same manner as an
individual permit.
I certify that I am familiar with the information contained in this application and that to the best of my
knowledge and belief such information is true, complete, and accurate.
Printed Name of Person Signing: Robert A. Fricke
Title: Corporate EHS D ector. _ �W
Applicant)
( ate igrnedj
Notice of Intent must be accompanied by a check or money order for $100.00 made payable to:
NCCfENR
Page 3 of 4
SWU-224-071406 last reWsad 711410E

NCGO90000 N.O.I.
Final Checklist
This application will be returned as incomplete unless all of the following items have been included:
X Check for $100 made payable to NGDRNR
N This completed application and all supporting documents
® A site diagram showing, at a minimum, (existing or proposed):
(a) outline of drainage areas, (b) stormwater management structures, (c) location of stormwater oudalls
corresponding to the drainage areas, (d) runoff conveyance features, (e) areas where materials are stored,
(f) Impervious areas, (g) site property tines.
Q Copy of county map or USGS quad sheet with location of facility clearly marked on map
Mall the entire package to:
stormwater Permitting Unit
Division of Water Quatity
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Note
The submission of this document does not guarantee coverage under the NPDSS General Permit.
For questions, please contact the DWO Regional Office for your area.
DWQ Realonal Off lee Contact Information;
Asheville Office ......
[phone]
Fayetteville Office ...
[phone]
Mooresville Office ...
[phone]
Raleigh Office ........
[phone]
Washington Office ...(252)
946-6481
Wilmington Office ...
[phone]
Winston-Salem ......
[phone]
Central Office .........(919)
807-6300
Page 4 of 4
5WU•224-071408 Last revised 7114108

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NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
March 28, 2014
CAI
Attn: Robert A. Fricke, Corporate EHS Director
7 Martel Way -
Georgetown, MA 01833
Subject: Denial of No Exposure Certification NCGNE0999
Rockingham Group, LLC / 2136 Manulacturing, LLC
Richmond County
Dear Mr. Fricke:
John E, Skvaria, III
Secretary
The Division of Energy, Mineral and Land Resources has reviewed your submittal of the No Exposure
Certification for Exclusion from NPDES Stormwater Permitting form, which was received on March 7, 2014.
The Division is unable to concur with your certification of no exposure.
Based on an inspection of your facility on Mach 25, 2014 by Mike Lawyer with the Fayetteville Regional
Office, industrial activities or materials on your site either are exposed, or have the potential to be exposed.
The Division cannot grant your requested exemption from permit coverage when industrial activities or
materials are exposed or have the potential to be exposed. Based on the type of industrial activities
occurring at the facility and the used equipment that is stored and exposed in the "graveyard", you are asked
to complete and submit the enclosed Notice of Intent application for coverage under the NCGO90000
General Stormwater Permit.
If you have any questions or concerns, please contact Mike Lawyer at [phone] or by e-mail at
mike.lawyer®ncdenr.gov.
Sincerely,
for Tracy E. Davis, PE, GPM
Enclosure
cc: FRO - Land Quality Section, Stormwater Files (wfo enclosure)
Stormwater Permitting Program, No Exposure Files (w/o enclosure)
Division of Energy, Mineral, and Land Resources
Land Quality Section
Fayetteville Regional Office, 225 Green Street - Suite 714, Fayetteville, North Carolina 28301
Phone: 910-M-33001 FAX: [phone] / Internet: htbAbortalmcdenr.a ebAd
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CCaENR
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarla, I
Governor Secretary
March 28, 2014
CAI
Attn: Robert A. Fricke, Corporate EHS Director
7 Martel Way
Georgetown, MA 01833
Subject: Denial of No Exposure Certification NCGNE0999
Rockingham Group, LLC 12135 Manufacturing, LLC
Richmond County
Dear Mr. Fricke:
The Division of Energy, Mineral and Land Resources has reviewed your submittal of the No Exposure
Certification for Exclusion from NPOES Stormwater Permitting form, which was received on March 7, 2014.
The Division is unable to concur with your certification of no exposure.
Based on an inspection of your facility on March 25, 2014 by Mike Lawyer with the Fayetteville Regional
Office, industrial activities or materials on your site either are exposed, or have the potential to be exposed.
The Division cannot grant your requested exemption from permit coverage when industrial activities or
materials are exposed or have the potential to be exposed. Based on the type of industrial activities
occurring at the facility and the used equipment that is stored and exposed in the "graveyard", you are asked
to complete and submit the enclosed Notice of Intent application for coverage under the NCG090000
General Stormwater Permit.
If you have any questions or concerns, please contact Mike Lawyer at [phone] or by e-mail at
mike.lawyer® ncdenr.gov.
Sincerely,
for Tracy E. Davis, PE, C P M
Enclosure
cc: FRO - Land Quality Section, Stormwater Files (w/o enclosure)
Stormwater Permitting Program, No Exposure Files (w/o enclosure)
Division of Energy, Mineral, and Land Resources
Land Quality Section
Fayetteville Regional Office, 225 Green Street - Suite 714, Fayetteville, North Carolina 28301
Phone: [phone] FAX: [phone] / lnternet: http_//Portal.ncdenr.ora/web/Ir/
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Compliance Inspection Report
Permit: NCGNE0999 Effective:
SOC: Effective:
County: Richmond
Region: Fayetteville
Contact Person: Tom Sartorelli
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
On -site representative Robert Fricke
Related Permits:
Expiration: Owner: Rockingham Group LLC
Expiration: Facility: 2135 Manufacturing, LLC
106 Enterprise Dr
Title:
Inspection Date: 03/26/2014 Entry Time: 10:00 AM
Primary Inspector: Mike Lawyer/
Secondary Inspector(s):
Rockingham NC 28379
Phone: [phone]
Certification:
Exit Time: 10:45 AM
Phone:
Phone: [phone]
Phone: [phone]
E-9
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, No Exposure Certificate
Facility Status: ❑ Compliant ■ Not Compliant
Question Areas:
E Miscellaneous Questions E Misc
(See attachment summary)
Page: 1

Permit: NCGNE0999 Owner - Facility: Rockingham Group LLC
Inspection Date: 0312512014 Inspection Type. Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Met with Robert Fricke, Corporate EHS Director. Made observations of site conditions. Facility stores used tanks and
other equipment outside in "graveyard" therefore does not qualify for no exposure. A denial letter along with NOI for
coverage under the NCG090000 General Permit being sent to applicant.
Misc
Is the facility compliant?
Comment: Used equipment stored outside in "graveyard". Does not qualify for no
exposure.
Yes No NA NE
Cl ■ ❑ Q
Page: 2

g rTA4 (Je.,
IFA
Division of Energy, Mineral, and Land Resources
NCDENR National Pollutant Discharge Elimination System
Noe,., C�u. -Den,w,w w NO EXPOSURE CERTIFICATION for Exclusion
EXn� Iwo NhllN Rew nc"
FOR AGENCY USE ONLY
Date Received
Year Month
Da
I'l03
�-
Cedficate of Cnvera o
aTT
NCGNE0000
MAR 142414
NO EXPOSURE CERTIFICATION
National Pollutant Discharge Elimination System application for exclusion from a Stormwater Permit based
on NO EXPOSURE: - J
Submission of this No Exposure Certification constitutes notification that your facility does not require a
permit for storm water discharges associated with industrial activity In the State of North Carolina because
It qualifies for a no exposure exclusion. A condition of no exposure at an Industrial facility means all
Industrial materials and activities are protected by a storm resistant shelter (with some exceptions) to
prevent exposure to rain, snow, snowmelt, and/or runoff.
For permitted facilities In North Carolina, DEMLR must approve your application for No
Exposure Certification before this exclusion Is effective. Until you are Issued a No
Exposure Certification and your NPDES permit Is rescinded, your facility must continue
to abide by the terms and conditions of the current permit.
Industrial materials or activities Include, but are not limited to: material handling equipment or activities,
Industrial machinery, raw materials, Intermediate products, by-products, final products, or waste products.
Material handling activities Include the storage, loading and unloading, transportation, or conveyance of
any raw material, Intermediate product, final product or waste product. A storm resistant shelter Is not
required for the following Industrial materials and activities: drums, barrels, tanks, and similar containers
that are tightly sealed, provided those containers are not deteriorated and do not leak. "Sealed" means
banded or otherwise secured and with locked or non -operational taps or valves; adequately maintained
vehicles used In material handling; and final products, other than products that would be mobilized In
Stormwater discharges (e.g., rock salt).
A No Exposure Certification must be provided for each facility quallfying for the no exposure exclusion. In
addition, the exclusion from NPDES permitting Is available on a facility -wide basis only —not for Individual
outfells. If any Industrial activities or materials are, or will be, exposed to precipitation, the facility Is not
eligible for the no exposure exclusion. By signing and submitting this No Exposure Certification form, you
certify that a condition of no exposure exists at this facility or site and are obligated to comply with the
terms and conditions of 40 CFR 122.26(g).
For questions, please contact the DEMLR Regional Office for your area. (See page 6)
(Please print or type)
1) Mailing address of owner/operator (address to which all certification correspondence will be mailed):
Name Rockingham Group, LLC.
Contact Paul Sartorelli, Treasurer
Street Address
City
Telephone No.
Email
S W U-N E-21 Feb2014
978 352-4510
pauli_caiink.com
Page 1 of 7
State NC ZIP Code 28379
Fax: [phone]

NCGNEOOOO No Exposure Certification
2) Location of facility producing discharge:
Facility Name 2135 Manufacturing, LLC.
Facility Contact Tom Sartorelli, Plant Manager
Facility Street Address 106 Enterprise Drive
City Rockingham state NC ZIP Code 28379
County Richmond
Telephone No. 910 895-5779 Fax: [phone]
Email tsartorelli(a-)-caiink.com
3) Physical location information:
Please provide a narrative description of how to get to the facility (use street names, state road numbers, and
distance and direction from a roadway intersection). Route 74 East to Business Route 74 East towards Rockingham.
Turn left onto Silver Grove Church Road. Travel 112 mile, turn onto Enterprise Drive. Facility on right.
(A copy of a map with the facility clearly located on it should be included with the certification application.)
4) Is the facility located on Native American Lands? ❑ Yes ® No
5) Is this a Federal facility? ❑ Yes ® No
B) Latitude 340 57' 47.09" Longitude 790 48' 17.96" (deg., min., seconds)
7) This NPDES No Exposure Exclusion application applies to which of the following:
® New or Proposed Facility
❑ Existing
Date operation is to begin
Date operation began 04/2013
❑ Renewal of existing No Exposure Certification No.: NCGNE
8) Was this facility or site ever covered under an NPDES Stormwater Permit? ❑ Yes ® No
If yes, what is the NPDES Permit Number?
9) Standard Industrial Classification:
Provide the 4 digit Standard Industrial Classification Code (SIC Code) that describes the primary industrial
activity at this facility
SIC Code: 2 8 9 3
10) Provide a brief description of the types of Industrial activities and products produced at this facility:
Mix and blend printing inks.
11) Does this facility have any Non -Discharge permits (ex: recycle permits)?
® No
❑ Yes
If yes, list the permit numbers for all current Non -Discharge permits for this facility:
Page 2 of 7
S W U-N E-21 Feb2014

NCGNE0000 No Exposure Certification
Exposure Checklists (12. - 14.)
12) Are any of the following materials or activities exposed to precipitation, now or in the foreseeable
future? (Please check either "Yes" or "No.") If you answer "Yes" to any of these items, you are not
eligible for the no exposure exclusion.
a. Using, storing, or cleaning industrial machinery or equipment, and areas where ❑ Yes ® No
residuals from using, storing or cleaning Industrial machinery or equipment remain
and are exposed to stormwater
b. Materials or residuals on the ground or in stormwater inlets from spillslleaks ❑ Yes ® No
G. Materials or products from past industrial activity
❑ Yes
® No
d. Material handling equipment (except adequately maintained vehicles)
❑ Yes
® No
e. Materials or products during loading/unloading or transporting activities
❑ Yes
® No
f. Materials or products stored outdoors (except final products intended for outside
❑ Yes
® No
use [e.g., new cars] where exposure to stormwater does not result in the discharge
of pollutants)
g. Materials contained in open, deteriorated or leaking storage drums, barrels, tanks,
❑ Yes
® No
and similar containers
h. Materials or products handled/stored on roads or railways owned or maintained by
❑ Yes
® No
the discharger
I. Waste material (except waste in covered, non -leaking containers [e.g., dumpsters])
❑ Yes
® No
]. Application or disposal of process wastewater (unless otherwise permitted)
❑ Yes
® No
k. Particulate matter or visible deposits of residuals from roof stacks and/or vents not ❑ Yes ® No
otherwise regulated (i.e., under an air quality control permit) and evident in the
stormwater outflow
I. Empty containers that previously contained materials that are not properly stored ❑ Yes ® No
(i.e., not closed and stored upside down to prevent precipitation accumulation)
m. For any exterior ASTs, as well as drums, barrels, tanks, and similar containers ❑ Yes ® No
stored outside, has the facility had any releases in the past three (3) years?
13) Above Ground Storage Tanks (ASTs): if you answer "No" to any of the following Items, you are not
eligible for the no exposure exclusion.
a. Are exterior ASTs and piping free of rust, damaged or weathered coating, pits, or ® Yes ❑ No ❑ NIA
deterioration, or evidence of leaks?
b. Is secondary containment provided for all exterior ASTO It so, is it free of any ® Yes ❑ No ❑ NIA
cracks, holes, or evidence of leaks, and are drain valves maintained locked shut?
Page 3 of 7
SWU•NE-21 Feb2014

NCGNE0000 No Exposure Certification
14) Secondary Containment: If you answer "No" to any of the following Items, you are not eligible for the
no exposure exclusion.
a. Is secondary containment provided for all single above ground storage
containers (including drums, barrels, etc.) with a capacity of more than 660-
gallons?
b. Is secondary containment provided for above ground storage containers stored
In close proximity to each other with a combined capacity of more than 1,320-
gallons?
c. Is secondary containment provided for Title III Section 313 Superfund
Amendments and Reauthorization Act (SARA) water priority chemicals"?
d. Is secondary containment provided for hazardous substances" designated in 40
CFR §116?
e. Are release valves on all secondary containment structures locked?
15) Hazardous Waste:
a. is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility?
b. Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous waste
generated per month) of hazardous waste?
c. Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste
generated per month) of hazardous waste?
If you answered yes to questions b. or c., please provide the following information:
Type(s) of waste: Waste Printing Ink
How is material stored: Stored in drums
Where is material stored: In Warehouse
How many disposal shipments per year: 2-3/year _
Name of transport 1 disposal vendor: Veolla Environmental Services
Vendor address: 126 Commercial Drive, Mooresville, NC 28115
Footnotes to Questions 14) c. & d.
❑ Yes ❑ No ® NIA
® Yes ❑ No ❑ NIA
❑ Yes ❑ No ® NIA
❑ Yes ❑ No ® NIA
❑ Yes ❑ No ® NIA
❑ Yes ® No
® Yes ❑ No
❑ Yes ® No
"Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require
secondary containment. However, some exceptions may be made for de minimis amounts of certain substances,
and/or other qualifiers, as described in the exemptions from reporting requirements of Title ill SARA 313 in 40 CFR
§372,38,
"Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require
secondary containment. However, some exceptions may be made for amounts less than the Reportable Quantities
of the hazardous substances listed In 40 CFR §117.3.
Page 4 of 7
S W U-N E•21 Feb2014

NCGNE0000 No Exposure Certification
16) Other information: If you answer "Yes" to any of the following Items, you might not be eligible for the
no exposure exclusion. A more In-depth evaluation of the site circumstances may be required.
a. Does your facility store used, recycled, or otherwise reclaimed pallets outside? ® Yes ❑ No
b. Does your facility have coal piles on site?
❑ Yes ® No
c. Does your facility store other fuel sources outside in piles, such as wood chips,
❑ Yes ® No
sawdust, etc.?
d. Does your facility have air emissions associated with its Industrial activity (e.g.,
® Yes ❑ No
degreasing operations, plating, painting and metal finishing)? If so, describe the
industrial activity: Mixing &blending printing ink. ^
e. If you answered yes to d., are those emissions permitted by an Air Quality Permit?
❑ Yes ® No ❑ NIA
Please specify: Received NCDENR permit exemption letter.
f. Please list any other environmental program permits (federal, state, etc.) not
specified earlier in this application (such as Hazardous Waste Permits, etc.):
Permit: NC0991302617 Program: Hazardous Waste SQG
Permit: Program:
Permit: Program:
Permit: Program:
Permit: Program:
Permit: Program:
Permit: Program:
Page 5 of 7
SWU-NE-21 Feb2014

NCGNEOOOO No Exposure Certification
17) Certification:
I certify under penalty of law that I have read and understand the eligibility requirements for claiming a condition of "no
exposure" and obtaining an exclusion from NPDES stormwater permitting.
I certify under penalty of law that there are no discharges of stormwater contaminated by exposure to industrial activities
or materials from the industrial facility or site identified in this document (except as allowed under 40 CFR 122,26(g)(2)).
I understand that I am obligated to annually seIf -certifyNo x osure and, if requested, submit the re -certification to
DEMLR or the operator of the local municipal separate storm sewer system (MS4) into which the facility discharges (where
applicable). I understand that I must allow the North Carolina Division of Energy, Mineral, and Land Resources (DEMI-R),
or MS4 operator where the discharge is into the local MS4, to perform inspections to confirm the condition of no exposure
and to make such inspection reports publicly available upon request.
In the event that the site no longer qualifies for a No Exposure Exclusion, I understand that I must obtain coverage under
an NPDES permit prior Jo any pointis . Additionally, I certify under penalty of
law that this document and all attachments were prepared under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my
inquiry of the person or parsons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is to the best of my knowledge and belief true, accurate and complete. I am aware
that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for
knowing violations.
I certify that I am familiar with the information contained in this application and that to the best of my knowledge and belief
such information is true, complete, and accurate.
Printed Name of Person Sig
Title: Cor or tte EF
&11-dbf4
(Signature of Applicant)
Robert A. Fricke
03/05/2014
(Date Signed)
Please note: This application for the No Exposure Exclusion Is subject to approval by the
NCDENR Regional Office prior to Issuance. The Regional Office may Inspect your facility for
compliance with no exposure conditions prior to that approval. The Regional Office may also
Inspect your facility at any time In the future for compliance with the No Exposure Exclusion. _
North Carolina General Statute 143-215.6 B(I) provides that:
Any person who knowingly makes any false statement, representation, or certification in any application, record, report, plan, or other
document filed or required to be maintained under this Article or a rule implementing this Article; or who knowingly makes a false
statement of a material tact In a rulemaking proceeding or contested case under this Article; or who falsifies, tampers with, or knowingly
renders Inaccurate any recording or monitoring device or method required to be operated or maintained under this Article or rules of the
(Environmental Managementl Commission Implementing this Article shall be guilty of a Class 2 misdemeanor which may include a fine
not to exceed ten thousand dollars ($10,000).
There 1s currently no fee for a No Exposure Exclusion.
Page 6 of 7
SWU-NE-21 Feb2014

NCGNE0000 No Exposure Certification
Final Checklist
This application should Include the following Items:
® This completed application and all supporting documentation.
® A map with the location of the facility clearly marked.
❑ If the site currently has an NPDE=S Stormwater Permit, be sure to indicate the permit number in Question 8.
Mall the entire package to:
Stormwater Permitting Program
Division of Energy, Mineral, and Land Resources
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
Note
The submission of this document does not guarantee the Issuance of a No Exposure Exclusion.
For questions, please contact the DEMLR Regional Office for your area.
DEMLR Re lonal Office Contact -information:
Asheville Office ......
[phone]
Fayetteville Office ...
[phone]
Mooresville Office ...
[phone]
Raleigh Office ........
[phone]
Washington Office ...(252)
946-6481
Wilmington Office ...
[phone]
Winston-Salem ......
[phone]
Central Office .........(919)
807-6300
Page 7 of 7
SWU-NE-21 FO2014

•
COATINGS,
Ca I ADHESIVES,
INKS
7 MARTEL WAY
GEORGETOWN, MA 01833
TEL: [phone]
FAX: [phone]
March 5, 2014
Stormwater Permitting Program
Division of Energy, Mineral & Land Resources
1612 Mail Service Center
Raleigh, NC 27699-1612
RE. Stormwater No Exposure Certification
2135 Manufacturing — Rockingham
To Whom It May Concern:
R19@[RUW[E00
MAR 7 2014
V"6X"DS AND STORMWA ER BMNCH
Enclosed find our No Exposure Certification for Exclusion from an NPDES permit for
stormwater discharges associated with industrial activities for the above referenced
facility.
Should you have any questions, request additional information, or arrange for a site
visit, please contact me.
Sincerely,
WaZz
Robert A. Fricke
Corporate EHS Director
rafricke(ftaiink.com
978-352-4510 (office)
617-538-2407 (mobile)

v MO1 1
5-.�1
January 6, 2014
To Whom it May Concern:
CaCOATINGS,
I ADHESIVES,
INKS
7 MARTEL WAY
GEORGETOWN. MA OI B33
TEL: [phone] ❑
FAX: (B76( 352,4515
www.ceiink.com
The undersigned, hereby authorizes Robert A. Fricke, Corporate EHS Director, to act on
our behalf in all manners relating to compliance, notification, application, and reporting
where allowed under applicable federal, state and local statutes and regulations,
including signing of all documents relating to such matters for CAI and its wholly -owned
corporate entities. Any and all acts carried out by Mr. Fricke on our behalf shall have the
same affect as acts of our own.
This authorization is valid until further written notice from CAI, Inc.
Sincerely,
Vince Sartorelli
President