NCG030251_Rescission Request Letter_20211130

Via Email
November 22, 2021
NC Department of Environmental Quality
Division of Energy, Mineral, and Land Resources
2090 US 70 Highway
Swannanoa, NC 28778
Attn: Mr. Mack Granger
Re: Permit Rescission Request
and Filing New Notice of Intent
Watts Regulator Co.
Spindale, NC
H&H Proiect No. WWT-009
Dear Mack:
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SMARTER ENVIRONMENTAL SOLLmONS
RECU&ED
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STORMWATER PERMITTING
Hart & Hickman, PC (H&H) is providing this letter to request rescission of the National
Pollutant Discharge Elimination System (NPDES) Stormwater Permit NCG030251 for the Watts
Regulator Co. (Watts) facility in Spindale, NC (Figure 2). Historically, the Watts facility
operated as a manufacturer of plumbing articles under Standard Industrial Classification (SIC)
code 3432 [Plumbing Fixture Fittings and Trim]. As such, the facility received coverage under
the Stormwater General Permit No. NCG030000, "Metal Fabrication." Manufacturing activities
no longer occur at the site, other than light assembly of finished parts, and the facility now
primarily operates under SIC code 4225 [General Warehousing and Storage]. This group of SIC
codes is applicable to Stormwater General Permit No. NCG060000, "Warehousing, Food and
Kindred."
Under the current permit (NCG030251), the Watts facility is required to conduct analytical
monitoring of stormwater discharge at Outfalls 001, 002, 003, 004, 005, 006, and 007. However,
the western portion of the Site including the discharge areas for Outfalls 006 and 007 are leased
to another tenant, who is responsible for applying for a separate NPDES stormwater permit.
Additionally, in a letter dated November 1, 2021 (attached), the North Carolina Division of
Energy, Mineral and Land Resources (NC DEMLR) granted Representative Outfall Status to
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Mr. Mack Granger
November 22, 2021
Page 2
Outfall 003 at the facility following a site inspection on October 21, 2021. It has been
determined that the drainage area for Outfall 003 is sufficiently similar to the drainage area for
Outfall 002 such that analytical monitoring of stormwater `at Outfall 003 is represented by
discharge at Outfall 002, and analytical monitoring of Outfall 003 is no longer required.
In summary, as metal fabricating operationsare no longer conducted at the Watts facility, H&H
on behalf of Watts respectfully requests rescission of coverage under Stormwater Permit No.
NCG030251 as provided on the attached Rescission Request Form. Additionally, H&H
respectfully requests the issuing of a new Certificate of Coverage for monitoring of Outfalls 001,
002, 004; and 005 under General Permit No. NCG060000 through the filing of the attached
Notice of Intent.
Should you have any questions or need any additional information, please feel free to contact
10-OW
Sincerely,
Hart & Hickman, PC
Alrx a. -
Gregory Kanellis, PE
Project Manager
Attachments
Cc: Mr. Brad Bowen, Watts (via email)
Ms. Tiffany Crosby, Watts (via email)
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