NCG110042_Letter RE Compliance_20240301

RO KB,,,ORD
City of Roxboro
March 1, 2024
Ms. Brittany Cook
Mr. Isiah Reed
Stormwater Program
Division of Energy, Mineral and Land Resources
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
Re: General Permit NCG110000 NPDES Permit to Discharge Stormwater
Dear Ms. Cook and Mr. Reed
The City of Roxboro is not prepared to meet the requirements of Stormwater General Permit NCG110000 set to become
effective March 1,2024. Asa result,we plan to provide funding in our upcoming July 12024—June 30 2025 budget to
have an outside consultant complete a study of our current program. This study will include but not be limited to:
■ Review and updates to existing Stormwater Pollution Prevention Plan, (Should include provisions for onsite
construction issues including stormdrain protections,fuel storage and equipment filling, etc...)
• Update our current General Location Map
• Update our current Site Map
• Update our Narrative Description of Industrial Processes
• Evaluation of Stormwater Outfalls...to include safe access for analytical sampling.
• Update BMP's
• Review and update our existing Spill Prevention and Response Plan
■ Develop a Solvent Management Plan
■ Update our current Preventive Maintenance and Good Housekeeping Program.
■ Provide Employee Training for items included in the permit.
■ Review, determine and make recommendations concerning Representative Outfall Status options.
■ Review existing, identify and provide engineering for secondary containment as required. (Dechlor C and Septic
Unloading facility)
• Determine if there are any devices are exempt from analytical monitoring.
105 S. LAMAR STREET•PO BOX 128•ROXBORO,NORTH CAROLINA 27573 • [phone] • FAX[phone]
www.cityofroxboro.com

Additionally,the Outside Source/Engineer will inspect the Roxboro WWTP site and provide plans and cost estimates
for the following:
• Provide engineering recommendations, plans and cost estimates for the development and installation of safe
access for analytical sampling at all seven outfalls.
• Secondary Containment Plan, including engineering, plans, and cost estimates to install the engineer
recommendations.
• Provide engineering recommendations, modification plans/installation and cost estimates to perimeter fencing
that will allow access to all outfalls.
Beginning,July 1, 2024 we request an implementation schedule that allows:
1. Six months to hire the consultant and complete the study as described above beginning July 1, 2024.
1. Six months for design and to secure funding. (Jan 2025)
2. Develop Plans for bidding(July 2025)
3. Procure funding(July 2026)
4. Six months for construction. (Jan 2027)
5. Six months for implementation in order to achieve compliance status.July 2027
Thank you for your consideration on a reasonable timeline to allow the City of Roxboro to come into compliance with
the new standards set forth in the NCG11000.As noted in our earlier public comments to the proposed changes our
WWTP is an active construction site; we anticipate the completion of Phase One of the WWTP Upgrades to be in
completed August-September 2024. We will work diligently to move to the new standards. Our biggest challenge will be
in designing and constructing SAFE sampling at the required outfalls some of which were constructed in 1965 and were
not originally designed for routine access as required by the new permit standards.Thank you for being partners in
protecting the water quality in our State. We look forward to your response.
Sincerely,
Allen Brooks Lockhart
City Manager/Permittee
City of Roxboro