NCG020715_NOV Response_20201105

CW1
Triangle Brick
6523 NC Highway 55
October 28, 2020 Durham, NC 27713
Durham:[phone]
Raleigh: [phone]
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Toll Free:800-672-8547
North Carolina Department of Fax:[phone]
Environmental Quality
Fayetteville Regional Office
Division of Energy, Mineral and Land
Resources
225 Green Street,Suite 714 DEQ- ATHEVILLE RFUNALOFFIGI
Fayetteville, North Carolina 28301
Attention: Timothy L. La Bounty, PE
Regional Engineer
Reference: NOTICE OF VIOLATION (NOV-2020-PC-0440)
NPDES Stormwater General Permit NCG020000
Triangle Brick Company-Wadesboro Plant, Certificate of Coverage NCG020715
Anson County
Dear Mr. LaBounty:
It is with great regret that Triangle Brick Company, Wadesboro Plant was determined out of
compliance in reference to NOV-2020-PC-0440. Please accept my apology for our violations of permit
conditions in reference to our Stormwater Pollution Prevention Plan (SWPPP), Qualitative
Monitoring,and Analytical Monitoring. As a new plant manager with limited exposure to our SWPPP,
the guidelines of compliance were not clear to me. I understand this is my responsibility and take
pollution of any type very seriously.
On 10/26/2020, 1 met with Senior Engineer, David W. Wasiela, PE with ERM NC, Inc. to evaluate our
SWPPP and facility grounds. Below is the list of action items that are being addressed in reference
to our evaluation;
1) We will install a fixed "V" notch weir plate at outfall 1 with graduated flow markings to aid in
visual recording of Daily Flow Rates measured in Cubic Feet per Second. This will also enable
sampling from exact location for each sampling event.
2) In lieu of our current inspection in reference to pH testing, as suggested by Melissa Joyner,
Environmental Specialist, DEMLR, we have ordered and received a field pH meter and
calibrated solutions of 4.01 pH, 7.01 pH and 10.01 pH for calibration. Testing and recording
pH of all outfalls sampled will occur every sampling period within 15 minutes of sampling, as
well as recording in the Wastewater Annual Summary Discharge Report by March 1st of each
year.
3) Outfall's 2 and 3 will be viewed every sampling period, in the unlikely event of discharge they
will be sampled as well. Otherwise these outfalls will be recorded as "No Flow" within 30
days of the sampling period in the monitoring reports and recorded in the Stormwater Annual
-- -- - Summary Discharge Report by March 1st of each year.

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4) SWPPP site plan is being updated to illustrate drainage areas for each of the storm water
outfalls; Outfall #s 1, 2 and 3.
5) With previous exceedances of turbidity NTU samples,we will sample quarterly in accordance
with Tables 7 and 8 of the NPDES General Permit NCG020000. We will sample outfall 1 on
our property at weir plate discharge, upstream of outfall 1 where Grindstone Branch crosses
Hwy. 52 N. (.3 miles south of the access road to Outfall 1), and downstream of outfall 1 at I'
Goulds Fork Creek at the bridge on Lockhart Road. Melissa Joyner and I verbally discussed
upstream and downstream sampling on 10/27/2020 and this is the method we determined
would be best practice to achieve our goal of collecting accurate sampling data.
6) We will perform a comprehensive site evaluation semi-annually to inspect storm water
control measures, outfalls, identify any new sources of potential pollutants and review
SWPPP for needed updates. I have been provided (by ERM) a form that I will use to record
and file semi-annually in the SWPPP.
7) Conduct annual personnel training onsite for 2020 and record in the SWPPP.
8) Update SWPPP team members and contacts to reflect current personnel.
9) Update the list of significant spills in the SWPPP indicating that no spills have occurred, and
maintain.
In closing, I want to assure you that our goal as a company is to be compliant in reference to all
environmental affairs, governmentally and self-regulated.
Sincerely,
TRIANGLE BRICK COMPANY
David A. Gibson
Director of Manufacturing, Wadesboro Facility
Original: Timothy L. LaBounty, PE, Regional Engineer(via US Mail, certified)
cc: Melissa Joyner, Environmental Specialist, DEMLR (via email)
Howard P. Brown, President,Triangle Brick Co. (via email)
David W. Wasiela, P.E., ERM NC. (via email)
Edward M. Dutch, Assistant Dir. Of Mfg. (via email)
Tommy A. Meggs II, Kiln Supervisor,Triangle Brick Co. (via email)