NC0006190_9-27-2019 CEI Response_20200130

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NC DEQ - DIVISION OF WATER RESOURCES
610 EAST CENTER AVENUE SUITE 301
MOORESVILLE NC 28115
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Telephone [phone]
Fax [phone]
Maiden, North Carolina 28650
I AM WRITING THIS LETTER IN REPONSE TO THE NOTICE OF VIOLATIONS WE RECEIVED
AFTER YOU COMPLETED THE COMPLIANCE EVALUATION INSPECTION ON SEPTEMBER 27, 2019.
FIRST OF ALL, I WOULD LIKE TO THANK YOU FOR ALL YOUR HELP AND COOPORATION WITH
SOUTH FORK INDUSTRIES WASTE WATER FACILITY. I ALSO WANT TO ASSURE YOU WE WILL BE
DOING EVERYTHING POSSIBLE TO RESPOND TO AND REPAIR EVERYTHING CONTAINED IN THE
REPORT. AS YOU KNOW WE ARE FAIRLY NEW AT RUNNING THIS TYPE WASTEWATER FACILITY
BUT HAVE TRIED TO EMPLOYEE PROPER PERSONEL TO INSURE PROPER OPERATIONAL
PROCEDURES.
SOUTH FORK INDUSTRIES PERSONNEL HAVE MADE STRIDES IN ASSURING THAT ALL
TESTING AND REQUIRED PAPERWORK HAS BEEN DONE IN TIMELY MANNER, WITH PROPER
PROCEDURES, AND RECORD STORING.AFTER THOROUGHLY GOING THROUGH THE REPORT I
THINK WE HAVE FAILED IN PREVENTATIVE MAINTENANCE PROCEDURES. I AM NOT MAKING
ANY EXCUSES FOR THIS BUT WE HAVE SPENT THE LAST THREE YEARS MOVING OUR
OPERATIONS FROM OUR LINCOLNTON LOCATION TO THE MAIDEN FACILITY. WE ALSO HAVE
ADDED MANY PIECES OF NEW EQUIPMENT TO MEET OUR PRODUCTION DEMANDS. WE HAVE
BEEN DOING MAJOR REPAIRS TO ALL AREAS OF THE FACILITY INCLUDING OUR WASTEWATER
FACILTY.BUT WE HAVE LOTS OF WORK STILL TO COMPLETE.
I HAVE NEGLECTED TO ENSURE PROPER WASTEWATER FACILITY PREVENTATIVE
MAINTENANCE, BUT WILL INSURE YOU WE WILL NO LONGER DO SO. I WILL LIST BELOW ITEMS
THAT WE HAVE REPAIRED AND A PLAN TO ADDRESS ALL ITEMS IN THE REPORT. DUE TO COLD
WEATHER AND THE AMOUNT OF RAIN WE HAVE HAD, SOME OF THESE ITEMS MAY TAKE A FEW
MONTHS TO COMPLETE AND SOME A FEW WEEKS. BUT WE HAVE MADE ALL THE ITEMS A
PRIORITY FOR OUR FACILITY AND OUR PERSONEL.

1. WE NOW HAVE THREE AERATORS OPERATIONAL IN BASIN NUMBER ONE AND NUMBER
TWO. WE HAVE ALSO HAVE ORDERED ANOTHER MOTOR AND MIXER TO HAVE A SPARE
READY TO REPLACE ANY AERATOR FAILURES IN THE FUTURE.WE WILL DO SO IN AN
URGENT MANNER IN WHEN REQUIRED IN THE FUTURE.
2. DUE TO THE WET AREA SURROUNDING THE STORM DRAIN WE WILL HAVE TO WAIT TIL
DRIER CONDITIONS TO DO PROPER REPAIRS. WE HAVE TEMPORARILY ADDED SOME
DIRT, HAY, AND NETTING TO THE AREA TO SLOW THE EROSION DOWN. WHEN
CONDITIONS ALLOW, WE WILL ADD MORE DIRT, GRAVEL AND ROCK TO THE AREA TO
CONTROL FUTURE EROSION IN THE AREA OF STORM DRAIN. 1 WILL SEND PICTURES
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3. WE THINK THAT WE NEED TO KEEP THE DUMPSTER AT THE BAR SCREEN AREA BUT DO
AGREE THAT BETTER CONTAINMENT NEEDS DO BE DONE. WE BUILT A CONTAINMENT
WALL AROUND THE DUMPSTER BUT FAILED TO SEAL THE AREA FOR PROPER
CONTAINMENT. SEALER REQUIRES WARMER WEATHER TO APPLY. WE HAVE
SURROUNDED THE AREA WITH ABSORBTION MATERIAL WE WILL MONITOR DAILY
UNTIL AREA PROPERLY SEALED FOR CONTAINMENT. IF AFTER COMPLETED YOU DO NOT
CONSIDER IT CORRECT, WE WILL EXPLORE ALTERNATIVE OPTIONS BUT THIS PROCEDURE
WAS INSTALLED AND BEING USED BY DELTA APPAREL AS PART OF BAR SCREENING
PROCESS AND LINT CONTAINMENT.
4. THE SECONDARY CONTAINMENT AREA FOR THE HYDROGEN PEROXIDE IS IN NEED OF
MANY REPAIRS. WE HAVE NOT USED THE BRINE TANKS AND HAVE NO PLANS TO DO SO
AT THIS TIME. OUR PLANS FOR THE CONTAINMENT AREA IS TO REPAIR CRACKS IN
WALLS. SEAL ALL WALLS AND AREA INSIDE WALLS AND FLOOR WITH CHEMICAL
RESISTANT SEALER THAT WILL CONTAIN ANY SPILLS IF FUTURE. THIS PROCESS ALSO
REQUIRES WARMER WEATHER. WE NEED TEMPERATURES IN THE 60 DEGREE RANGE TO
GET PROPER APPLICATION AND SEALING PROPERTIES. WE WILL DO THESES REPAIRES AS
SOON AS WEATHER ALLOWS. I WILL SEND PICTURES OF REPAIRES AS SOON AS
AVAILABLE. AS TO THE SMALL AMOUNTS OF RESIDUAL BUBBLING OF PEROXIDE IN THE
AREA, WE HAVE COMPLETED REPAIRS AND CLEANING OF AREA. THIS WAS FROM SMALL
LEAK AT PUMP WHEN PUMP IN OPERATION. THE VALVE IN QUESTIONS HAS A LOCK OUT
DEVICE AND IS SECURED IN THE CLOSED POSITION TO ONLY BE OPENED BY PROPER
PERSONEL.
5. DONALD BURKEY OUR WASTEWATER ORC HAS CONTACTED AN OUTSIDE VEDOR TO
PROVIDE US WITH ESTIMATES FOR REPAIRING ITEMS LISTED IN THE CLARIFYING AND
WEIR AREAS. ONCE WE RECEIVE THE ESTIMATES AND RECOMMENDED REPAIRES, I WILL
INFORM YOU OF THE RESPONSE AND OUR PLANS FOR REPAIRES. WE WILL DO
NECESSARY REPAIRES IN A TIMELY MANNER AS REQUIRED IN OUR PERMIT.

I HOPE THIS LETTER ASSURES YOU THAT SOUTH FORK INDUSTRIES INC. TAKES THIS NOTICE
OF VIOLATION VERY SERIOUSLY AND WILL MAKE ALL EFFORTS TO REMMEDY ALL ITEMS IN
AS TIMELY MANNER AS ALLOWED BY CONDITIONS AT THIS TIME. IF YOU FIND ANY ITEMS
LISTED AND REPONDED TO INSUFECIANT PLEASE CONTACT ME AT
EVERETTE SOUTHFORKIND.COM OR 828-428-9921
AGAIN, THANK YOU FOR YOUR ASSISTANCE.
EVERETTE OWENS PLANT MANAGER