NCS000528_NOD_20150206

Pat McCrory
Governor
LT
w
NCDENR
North Carolina Department of Environment and Natural Resources
February 6, 2015
CERTIFIED MAIL: 7010 3090 0001 3216 0214
RETURN RECEIPT REQUESTED
Premiere Fibers
Attn: Dewey Fulton
PO Box 8930
Bristol, VA 24203
Subject: NOTICE OF DEFICIENCY (NOD-2015-PC-0037)
Premiere Fibers
NPDES Stormwater Individual Permit-NCS000528
Anson County
Dear Mr. Fulton:
Donald R. van der Vaart
Secretary
On January 22, 2015, Mike Lawyer and Lori Britt from the Fayetteville Regional Office along with Julie
Ventaloro and Rick Riddle with the Stormwater Permitting Program of the Division of Energy, Mineral and
Land Resources, conducted a site inspection at the Premiere Fibers facility located at 10056 US Hwy 52 N,
Ansonville, Anson County, North Carolina. A copy of the Compliance Inspection Report is enclosed for your
review. Mr. Kevin Bowers, Technical Manager, and Mr. Ted Kalamatas, EHS Manager, were also present
during the inspection and their time and assistance is greatly appreciated. The site visit and file review
revealed that the subject facility is covered by NPDES Stormwater Individual Permit-NCS000528. Permit
coverage authorizes the discharge of stormwater from the facility to receiving waters designated as a UT
(unnamed tributary) to Buffalo Creek, a Class C stream 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.
Requested Response:
A written response is not requested at this time.
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] / Internet: http://portal.ncdenr.org/web/Ir/
An Equal Opportunity \ Affirmative Action Employer - 50% Recycled \ 10% Post Consumer Paper

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 Mr. Lawyer or myself at [phone].
Sincerely,
Brad Cole, PE
Regional Engineer
Land Quality Section
BC/m I
Enclosure
cc: Kevin Bowers, Technical Manager — Premiere Fibers (via e-mail)
Ted Kalamatas, EHS Manager— Premiere Fibers (via e-mail)
Bradley Bennett, Supervisor — Stormwater Permitting Program
FRO — Land Quality Section, Stormwater Files-NCS000528

Compliance Inspection Report
Permit: NCS000528 Effective: 04/01/09 Expiration: 03/31/14 Owner: Premiere Fibers
SOC: Effective: Expiration: Facility: Premiere Fibers
County: Anson 10056 US Hwy 52 N
Region: Fayetteville
Ansonville NC 2$007
Contact Person: Dewey Fulton Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
On -site representative
On -site representative
Related Permits:
Certification: Phone:
Kevin Bowers 704-826-8321
Ted Kalamatas 704-826-8321
Inspection Date: 01/22/2015 Entry Time: 01: PM
Primary Inspector: Mike LawyeriA��,�
Secondary Inspector(s):
Julie Ventaloro
Lori H Britt
Rick L Riddle
Reason for Inspection:
Routine
Permit Inspection Type:
Stormwater Discharge, Individual
Facility Status: ❑ Compliant 0 Not Compliant
Question Areas:
■ Storm Water
(See attachment summary)
Exit Time: 03:20PM
Phone: [phone]Q -A-72V
Phone
Phone
Inspection Type: Compliance Evaluation
Page:

Permit: NCS000528 Owner - Facility: Premiere Fibers
Inspection Date: 01/22/2015 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Current permit expired on March 31, 2014. Application for permit renewal has been submitted and is being processed with
renewed permit under draft review. Inspection conducted to determine compliance with conditions of current/expired permit.
Met with Kevin Bowers, Technical Manager, and Ted Kalamatas, EHS Manager. Reviewed facility's Stormwater Pollution
Prevention Plan (SPPP) and available monitoring records. The SPPP contained all permit -required components with the
exception of documentation of an annual review/update, which should include all items listed under Part II, Section A, item
7 of the current permit. Available analytical monitoring records showed several exceedances of the benchmark value for
TSS (Total Suspended Solids) at several outfalls possibly due to recent/on-going construction activities for a warehouse
addition. Although not triggered into monthly monitoring since exceedances of the TSS benchmark value were
non-consecutive, some additional sampling was conducted in April 2014 for TSS and pH. This sampling would not count for
the April -September 2014 monitoring period because it was conducted less than 60 days from the previous sampling event
and not all parameters were tested at all outfalls. Although permit coverage expired on March 31, 2014, the permit contains
language that states: "The applicant must continue semi-annual monitoring until the renewed permit is issued."
Observations were made of site conditions including the outfalls. Some suggestions were made to provide additional ground
cover or other BMPs in drainage areas where solids could be entering the storm drains/outfalls. It was also suggested to
verify the outfall numbering with the sampler and revise the site map as necessary.
Page: 2

Permit: NCS000528 Owner - Facility: Premiere Fibers
Inspection Date: 01/22/2015 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan?
0 0 EJ ❑
# Does the Plan include a General Location (USGS) map?
0 El El R
# Does the Plan include a "Narrative Description of Practices"?
N El El EJ
# Does the Plan include a detailed site map including outfall locations and drainage areas?
E ❑ 0 El
# Does the Plan include a list of significant spills occurring during the past 3 years?
® El
# Has the facility evaluated feasible alternatives to current practices?
E1:1 El
# Does the facility provide all necessary secondary containment?
# Does the Plan include a BMP summary?
E ❑ El EJ
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
M R El El
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
0 ❑
# Does the facility provide and document Employee Training?
0 El El El
# Does the Plan include a list of Responsible Party(s)?
0
# Is the Plan reviewed and updated annually?
El 0 El EJ
# Does the Plan include a Stormwater Facility Inspection Program?
0 El El ❑
Has the Stormwater Pollution Prevention Plan been implemented?
i
Comment: Plan needs documentation of an annual review/update to include an updated list of any
significant spills over the previous three years or notation that none have occurred and
re -certification that the stormwater outfalls have been evaluated for the presence of any
non-stormwater discharges.
Qualitative Monitorinq Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually?
Comment: Monitorinq per the conditions of the permit was not conducted for the period of April -September
2014.
Analytical Monitorinq Yes No NA NE
Has the facility conducted its Analytical monitoring? 0 0 E]
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
Comment: Monitorinq per the conditions of the permit was not conducted for the period of April -September
2014.
Permit and Outfalls
Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? ❑ El El N
# 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: See comment above regarding annual review/update.
Page: 3