Document 6w9o0yyw3G9Jr9OygQ15ox9eo
* UNITED STATES
ENVIRONMENTAL
PROTECTION
AGENCY
REGION 1
BOSTON, MA 02109
Dated by Electronic Signature
February 14, 2024
Mr. Alan Plue
AJ Nonwovens - Hampton, LLC
11 Merrill Industrial Drive
Hampton, New Hampshire 03842
Re: Inspection of AJ Nonwovens, 11 Merrill Industrial Drive, Hampton, New Hampshire on December 7,
2023.
Dear Mr. Plue,
On December 7, 2023, the U.S. Environmental Protection Agency Region 1 (" EPA ") performed a multi-
media inspection at AJ Nonwovens located on Merrill Industrial Drive in Hampton, New Hampshire (the
" Facility " or " site ") regarding compliance with the Clean Water Act (" CWA "). A copy of the inspection
report is enclosed with this letter. EPA inspectors identified the following areas of concern during this
inspection. Within 30 calendar days of the receipt of this letter, submit a report detailing what actions
have been taken already, and what actions will be taken, to address these areas of concern to Damian
Bednarz of my staff at bednarz.damian@epa.gov.
1. Pretreatment Regulations (40 C.F.R. 403) - Permit ID NHPIU0008
A. AJ Nonwoven is permitted to discharge industrial wastewater to the Town of Hampton's
Publicly Owned Treatment Works (" POTW ") by the Town of Hampton under Industrial
Discharge Permit No. 2023-A (" Industrial Discharge Permit "). Part 1.D.10 of the Industrial
Discharge Permit prohibits the discharge of " any water from storm water flow that may leak
into pump station wet wells or tanks ". In addition, Part 1.G. of the Industrial Discharge
Permit states: " no sanitary sewer shall be used to receive and convey or dispose of any
storm or surface water, or any other uncontaminated or unpolluted discharge. " The Pump
Station # 2 access cover is situated at the bottom of a grass depression where stormwater
may pool and infiltrate around the access cover. As discussed during the facility inspection,
stormwater infiltrates via the access cover and is discharged to the POTW. Provide a plan or
report describing the actions taken to prevent stormwater from entering Pump Station # 2,
in compliance with the Industrial Discharge Permit for AJ Nonwovens.
2. Stormwater Regulations (40 C.F.R. 122.26) - - Multi - Sector General Permit (MSGP) ID NHR053211
A. The site map in the Facility's Storm Water Pollution Prevention Plan (" SWPPP ") depicts
Outfall 003 at an inlet structure north of the Manufacturing Building; however, the Notice
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of Intent (" NOI ") for the Facility identifies latitude and longitude coordinates of Outfall 003
at the discharge point of Drainage Area 4. Correct this discrepancy within the Facility's site
map to match the outfall location as identified in the NOI. Additionally, it was discussed that
quarterly stormwater assessments were conducted at the improper outfall location,
resulting in the consistent reporting of NODI code C: no discharge. Resume quarterly
stormwater assessments at the correct Outfall 003 location as defined in the Facility's NOI.
B. Section 2.1.2.2 of the MSGP (" Good Housekeeping ") requires that the Facility must keep
clean all areas that are potential source of pollutants, and that the Facility also must
perform good housekeeping measures to minimize pollutant discharges. Describe what
actions the Facility will take to address the deficiencies identified below:
a. EPA inspectors observed areas throughout the site to have accumulated fleck
material on paved areas near drains and stormwater outfall locations. Part 2.1.2.2.a.
of the MSGP requires permit holders to sweep or vacuum at regular intervals or,
alternatively, wash down the area and collect and / or treat, and properly dispose of
the washdown water.
b. EPA inspectors observed uncovered roll - off containers. Part 2.1.2.2.c. of the MSGP
requires permit holders to keep all dumpster lids closed when not in use. For
dumpsters and roll off boxes that do not have lids and could leak, ensure that
discharges have a control (e.g., secondary containment, treatment).
c. EPA inspectors observed raw, pre - processed plastic material stored outside, without
cover, on top of pallets. Part 2.1.2.2.d. of the MSGP requires that facilities that
handle pre - production plastic must implement control measures to eliminate
discharges of plastic in stormwater. Materials included in this requirement are
plastic resin pellets, powders, flakes, additives, regrind, scrap, waste, and recycling.
C. Within the Facility's Drainage Area 6, a discharge was observed leaving the site at the time
of the inspection which flowed west, towards the Drakes River. Submit a Change NOI to
reflect this discharge as an additional outfall. Identify in your response all pollution sources
within this drainage area and reflect these in the Facility's SWPPP.
D. Within the most northeastern area of Drainage Area 3 and closest to Lafayette Road, EPA
inspectors observed that the site's topography allows runoff from the materials storage
area and creates a flow path of discharge west into a wooded area. Correct the flow lines on
the SWPPP's site diagram.
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Technical questions and concerns may be directed to Damian Bednarz at (617) 918-1482 or via email at
bednarz.damian@epa.gov. Legal issues may be directed to Jeff Kopf, Senior Enforcement Counsel, at
(617) 918-1796.
Sincerely,
NEWTON
TEDDER
Digitally signed by
NEWTON TEDDER
Date: 2024.02.14
16:39:17 -05'00 '
Newton Tedder,
Acting Manager Water Compliance Section 1
Enforcement and Compliance Assurance Division
ENCLOSURES
1. Inspection Report for December 7, 2023, EPA Inspection
2. Stormwater photo log for December 7, 2023, EPA Inspection
3. AJ Nonwoven's Stormwater Pollution Prevention Plan, Site Drainage Plan
4. BOD, TSS & Ammonia Analytical Results
cc: Tracy L. Wood, NHDES
Jeff Kopf, US EPA
Damian Bednarz, US EPA
Shannon Shea, US EPA
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