NCG060098_Action Plan_20230814

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Certified Mail 7015 1520 0000 9324 8966
11 Aug .( t2nosartment of
Environmental
Quality
Regional Supervisor AUG 14 2023
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NC Division of Energy, Mineral and Land Resources Winston-Salem
450 Hanes Mill Road, Suite 300 Regional Office
Winston-Salem, NC 27105
RE: Aurorium Greensboro (formally Vertellus Greensboro)
Stormwater Permit # NCG060000
Certificate of Coverage #NCG060098
Fourth Benchmark Exceedance Action Plan
Dear Regional Supervisor:
Aurorium Greensboro is required to conduct periodic stormwater sampling as a part of
it's stormwater permit. Outfall 06 had a fourth (4th) Benchmark Exceedance of Total
Suspended Solids (TSS) during the June stormwater sampling event. As a result, the
facility is required to complete the following tasks:
• Conduct a stormwater management inspection.
• Identify and evaluate possible causes.
• Prepare an Action Plan for approval.
• Implement the approved Action Plan.
• Notify the Division of the completion of the Action Plan.
Consequently, the facility is submitting this Action Plan for review and approval. Once
the facility has received approval, we will implement the Action Plan and notify the
Division once all steps are completed.
Should you have any questions or require additional information, please do not hesitate
to contact me.
Respectfully,
J ice Timpson
Manager, Environmental Health &Safety
[e-mail]
C + 1.336.542.7920
2110 West Gate City Boulevard, Greensboro, NC 27403 USA • +1.336.292.1781
aurorium.com

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Action Plan
Facility Overview
Aurorium owns and operates a manufacturing facility located at 2110 West
Gate City Blvd., Greensboro, NC 27403. The facility operates under General
Permit number No. NCG060000 and Certificate of Coverage No. NCG060098.
As a requirement of the General Permit, Aurorium is required to conduct
analytical monitoring and compare the results to benchmarks for several
parameters, including Total Suspended Solids (TSS).
Site Description
The overall housekeeping at the facility is good. All onsite storm drains are easily
identified because they are painted green.
There are six (6) total stormwater outfalls at the facility. Outfalls 01 , 05, and 06 are
considered representative outfalls for the site and are currently being sampled
as required by the Stormwater Permit.
Outfalls 02 and 03 contain a significant percentage of water from the adjoining
City of Greensboro streets. Outfall 04 mainly contains runoff from the facility's
non-industrial employee parking lot area.
Potential Causes
Based on the stormwater management inspection, Aurorium believes the most
likely cause of the elevated TSS readings at Outfall 06 is runoff of dirt and dust
from the adjoining gravel area. Therefore, the potential cause of the elevated
TSS may be a combination of the following:
• The proximity of the gravel area to the storm drains that feed into outfall
06.
• Forklift traffic and employee foot traffic, which may increase the amount
of disturbed dirt and dust.
Potential Solutions
To reduce the amount of runoff Aurorium proposes to do the following:
• Clean the storm drains that feed into Outfall 06.
• Determine a required frequency to clean the storm drains.
• Create a preventative maintenance (PM) schedule to track the required
frequency.
• Research the application option of Gorilla Snot Dust Control. Gorilla-Snot
is an eco-safe, biodegradable, liquid copolymer used to provide erosion
control and dust suppression. It is non-hazardous, and it is safe for the
2110 West Gate City Boulevard, Greensboro, NC 27403 USA +1.336.292.1781
aurorium.com

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environment. Gorilla-Snot will not migrate away from the treated areas,
and it will not seep into the groundwater. It will not wash away in the rain
and does not re-emulsify with water.
The facility does need to complete additional research on the Gorilla-
Snot product to include the following areas:
o Cost
o Effectiveness
o Concerns
Visual Overview of Area of Concern
Stormwater Permit
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TSS Exceedance. .
Area Overview Green Stormwater Drain x Outfall 06
Al Green storm dra in
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Gravel Area
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Gravel flows into the storm drain during rain events.The sample collection point is Outfall 06.
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2110 West Gate City Boulevard, Greensboro, NC 27403 USA +1.336,292.1781
aurorium.com