NCG110143_Notice of Deficiency_20190405

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Interim Director
NORTH CAROLINA
Environmental Quality
April 5, 2019
CERTIFIED MAIL: 7013 1710 0002 1922 0329
RETURN RECEIPT REQUESTED
City of Reidsville
Attn: Preston Mitchell
230 West Morehead Street
Reidsville, NC 27320
Subject: NOTICE OF DEFICIENCY (NOD-2019-PC-0086)
Permit No. NCG 110143
Reidsville Waste Water Treatment Plant
Rockingham County
Dear Permit Holder:
On April 3, 2019, Brandon Wise, inspector with the North Carolina Department of
Environmental Quality (NCDEQ) — Division of Energy, Minerals, and Land Resources met with
site contacts at the facility located at 407 Broad Street in Reidsville, to conduct a compliance
inspection as part of the NCDEQ's mission to inspect all permitted site once a permit cycle. The
inspection consisted of review of the Stormwater Pollution Prevention Plan (SWPPP) and each
of its components, review of the facility outfalls, as well as the review of the overall site
conditions.
The compliance inspection was conducted to ensure all site practices and facilities are in
working order. The inspection was also conducted as assistance to the City of Reidsville should
there be any questions about permit NCG110143.
Permit:
This facility has General Stormwater Permit NCG110143 to discharge stormwater from
industrial activity associated with Wastewater Treatment Device or System with a design -
flow of 1.0 million gallons per day (MGD) or more under the National Pollutant Discharge
Elimination System (NPDES). The permit was originally issued on February 13, 2009 and this
version of the permit was issued on May 31, 2018 and will expire on May 31, 2023.
Records/Reports:
This facility is required to develop and maintain a SWPPP in accordance with Part II,
Section A of the permit. All qualitative and analytical monitoring records are required to be
maintained with the SWPPP for a minimum of five (5) years. Under this permit, analytical
monitoring is not required under current operating procedures. The facility records are lacking
North Carolina Department of Environmental Quality I Division of Energy. Mineral and Land Resources
Winston-Salem Regional Office 1 450 Hanes Mill Road. Suite 3001 Winston-Salem. North Carolina 27103
336.776.9800

any records from May of 2015 to present. The existing SWPPP was last updated in 2015 and
after speaking with the site contact it appears some changes need to be made to the SWPPP to
ensure it accurately depicts operations at the facility. The facility has three outfalls, after
discussing on site one of the outfalls will be relocated to a catch basin that is on site, rather than a
pipe outlet off site, to make it safer for employees to perform monitoring. The facility is
required to maintain employee training records in accordance with Part II, Section A, Item 6 of
the permit. A training program appears to have been in place but has not been kept up with, any
employees that perform tasks that have to do with the permit need to have training annually and
this should be kept with the SWPPP.
Facility Site Review:
This facility operates as the waste water treatment plant for the city of Reidsville. The
facility is tiered in a way that each tier is primarily flat with most stormwater running to the
south or east sides of the facility. There are multiple catch basins that direct stormwater on site
to three different outfalls. Two outfalls drain to the south of the facility to an unnamed tributary.
One outfall drains to the east of the facility directly to Little Troublesome Creek. All outfalls
catch stormwater from different parts of the treatment process before discharging. The overall
housekeeping of the site is very good. There was no trash or potential pollutants seen on site and
the facility appeared to be on a regular cleaning schedule.
Effluent Receiving Waters:
Effluent from this facility drains into Little Troublesome Creek, class "WS-V; NSW"
waters of the Cape Fear River Basin.
Self -Monitoring Program:
This facility is required to provide Qualitative Monitoring twice annually. The outfalls
discharging from the facility are expected to be properly maintained and sampled. It appears as
though no monitoring has been completed since 2015. Monitoring should begin as soon as the
next representative rainfall event occurs. NCDEQ's template for qualitative monitoring is
attached to this report along with being available online.
Violations Noted:
- SWPPP has not been updated since 2015.
- SWPPP on site does not accurately depict operations and structures at the facility.
- Qualitative Monitoring is required twice annually and has not been done since 2015.
- Employee training is to be completed annually and has not been completed since
2015.
North Carolina Department of Environmental Quality I Division of Energy. Mineral and Land Resources
Winston-Salem Regional Office 1 450 Hanes Mill Road, Suite 3001 Winston-Salem, North Carolina 27103
336.776.9800

Thank you for your attention to this matter. This office requires that a response outlining
a plan to fix the violations mentioned in this report is given to NCDEQ within 30 days of receipt
of this Notice. Should these violations not be properly resolved a Notice of Violation could be
issued along with potential for a civil penalty assessment of up to $25,000 per day per violation.
Your efforts to undertake activities to bring the subject site into compliance are not an admission,
rather they are actions that must be taken in order to being to resolve ongoing environmental
issues. Should you have any questions regarding these matters, please contact Brandon Wise
(336-776-9660 or [e-mail]) or Matt Gantt (336-776-9654 or
[e-mail]).
�7
Bran n Wise
Stormwater Specialist
Land Quality Section
Winston-Salem Regional Office
Enclosures: Inspection Report
Qualitative Monitoring Form
cc: NCDEQ — DEMLR (WSRO) w/o enclosure
Sincerely,
Matt Gantt
Regional Engineer
Land Quality Section
Winston-Salem Regional Office
North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
Winston-Salem Regional Office 1 450 Hanes Mill Road, Suite 3001 Winston-Salem, North Carolina 27I03
336.776.9800