Greenville Utilities Comments on NCG110000

May 17, 2023
Ms. Brittany Cook (via email)
Mr. Isaiah Reed
NCDEQ— Division of Energy, Mineral, and Land Resources
1612 Mail Service Center
Raleigh, NC 27699-1612
Subject: Greenville Utilities Commission Comments - Draft NPDES General Permit for
Treatment Works (NCG110000)
Ms. Cook and Mr. Reed:
Greenville Utilities Commission (GUC) appreciates the opportunity to comment on the North
Carolina Department of Environmental Quality Division of Energy, Mineral, and Land Resources'
(DEMLR's) proposed reissuance of the General Permit to Discharge Stormwater from Treatment
Works under the National Pollutant Discharge Elimination System for Treatment Works, Permit
NCG110000 (Draft GP).
GUC became aware of the revised NCG11 Draft and reached out to DEMLR on May 11, 2023 to
inquire about our copy of the draft permit. We were unaware of the significant changes in the
revised draft permit due to lack of DEMLR outreach and stakeholder engagement. The Permit is
set to become effective June 1, 2023. This short notice does not allow GUC significant time to
thoroughly assess the impacts of the new requirements and to assess the resources necessary to
fully comply with NCG11 upon issuance.
Please find herewith GUC's comments on the Draft NCG110000 permit.
Part B-5 Evaluation of Stormwater Outfalls - GUC is of the opinion the current requirement to
perform Qualitative Monitoring of our outfalls fulfills the purpose of the requirement to evaluate
all stormwater outfalls on an annual basis for the presence of non- stormwater discharges.
Further, language in the draft requests one to identify the source and to include a summary
statement. This is an over- reaching expectation that we would have the resources to properly
identify the source of a non-stormwater discharge and to evaluate the environmental
significance of such. GUC is greatly concerned to provide a summary along with a signed
certification statement of the evaluation. GUC is requesting this language be removed as it
provides no additional benefit to the current monitoring strategies.
Part B-10—Solvent Management Plan Without stakeholder engagement, DEMLR has
developed a new requirement that is not applicable to Treatment Works. Wastewater
Treatment Facilities only use solvents in small quantities. The current version of NCG11 (via Part

II.A.1 and II.A.2) already requires that owners identify potential pollutants and inspect the
facility to ensure they are not reaching the stormwater system. This requirement is unsuitable
and will force reallocation of resources to an endeavor that will yield no appreciable pollution
prevention results. The requirement to make a certification that no solvents have been
"...exposed to rainfall or stormwater runoff..." with each discharge monitoring report is
problematic. GUC respectfully requests that Part B-10(and all associated language throughout
the permit) be removed.
Part B-11 - Preventative Maintenance and Good Housekeeping Program The current version of
NCG11 says that the Preventative Maintenance and Good Housekeeping Program "...shall
establish schedules of inspections, maintenance, and housekeeping activities..." and is adequate
for the protection and prevention of non-stormwater discharges. The requirement to establish
a program which includes (a)—(c) would increasing the workload of our staff without providing
any evidence that suggests the current approach is lacking. GUC requests the clear and concise
language of the current NCG11 (Part II.A.4) be retained.
Part B-16-Annual On-Line SWPPP Certification An annual on-line certification is unnecessary.
GUC maintains this certification on site, and it is available for inspection by DEMLR. Other
permit-required documentation is maintained on site, not requiring annual submittal. As with
other requirements in this Draft Permit, this needlessly adds to the administrative workload for
GUC and creates more opportunities for non-compliance and provides no further protection to
the waters of NC. GUC requests that Part B-16(and all associated language throughout the
permit) be removed.
Part C-6—C8- Bypass, Upsets, and Required Notice for Bypass and Upset-These sections are
unclear as to the definition of"Stormwater Treatment Facilities". Do these sections apply to
those permittees which have Stormwater Control Measures or apply to all? Bypass and Upset
language typically apply to industrial pretreatment and/or Wastewater Treatment Facilities. In
the realm of Stormwater, GUC does not have "treatment" to bypass and therefore Upset would
not apply. GUC is requesting these sections to be removed or for the language to modified in
such a way that permittees understand the applicability of these sections.
Part E—Analytical Monitoring of Stormwater Discharges -GUC disagrees analytical monitoring
is warranted as it provides little to no additional environmental benefit. The draft will be in
effect June 1, 2023, which provides GUC with little time to evaluate the Operational/Financial
Costs incurred by what we feel is unnecessary. E-1 (d) requires sampling in specified quarters,
one of which is April 1-June 30. We would be pressed for time to collect two samples in the
second quarter. GUC has a duty to wisely use ratepayer dollars to fund work, which includes the
use of staff time. The current staff is minimal with no future allocations for additional personnel.
In this instance, DEMLR seems to have not considered the costs associated with their proposals,
nor the actions or resources that are required by municipalities to achieve compliance upon
permit issuance.

Technical Basis- In the Draft Factsheet, DEMLR asserts that "...Regional Office staff inspections
have identified problems at facilities in the treatment of industrial, commercial, or municipal
sewage treatment. Particularly, is the event that the sewage treatment lines can, and have been
found to leak...into the stormwater conveyance system"This statement seems to broadly
categorize all Treatment Works facilities into the same group with this alleged violator(s). GUC
asserts that we do not fit into this category. GUC contends that pursuing enforcement actions
against the alleged violator(s) would be more effective than applying such broad and resource-
intensive requirements (quarterly or greater analytical monitoring, reporting of benchmark
exceedances to DEMLR Regional Offices, and possible development of Action Plans) to an entire
industrial sector.
We are also concerned DEMLR has provided no basis for establishing the proposed benchmark
values. DEMLR correctly points out in the Draft Factsheet that in-stream values (water quality
standards) aren't practical for a stormwater benchmark. GUC agrees with this statement and is
trying to ascertain what makes the proposed benchmark value more valid.
GUC would also be required to register for eDMR reporting for the stormwater analytical results.
This also placed an unnecessary burden on facilities who are "compliant" and also provides a risk
of non-compliance with no environmental benefit. DEMLR should delete all the analytical
monitoring text in the Draft GP, including benchmarks and corrective action requirements. This
includes the text on pages 9 (references to benchmarks in draw downs), 13-14 (analytical
monitoring), 15-18 (Tier One, Two, and Three responses), 19 (reports required if more frequent
monitoring has occurred), and 27(Action Plan submittal and approval).
GUC appreciates your consideration of our requests and comments. If you have any questions or
require further information concerning this letter, please feel free to contact, Jason Manning or
JoEllen Gay (email) with any requests for clarification on these comments.