NCG030650_Email RE Benchmark Exceedances (to MRO)_20230128

Georgoulias, Bethany
From: Nicole Johnston <[e-mail]>
Sent: Saturday, January 28, 2023 1:11 PM
To: Chandler, Jeffrey A
Cc: Georgoulias, Bethany; Carson, Brittany
Subject: [External] Copper Exceedances for CommScope, Claremont for November and
December 2022
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Per the general permit for CommScope, Inc. (NCG030000) Claremont Facility (under COC NCG030650), sampling was
completed on ROS Outfall 003 for the site on Friday, November 11th, 2022 with a rainfall even totaling 0.51" of rain. I
received results from the laboratory (Statesville Analytical) on Wednesday, November 30th, 2022. For this event, all
parameters were below the benchmark EXCEPT for Copper.
Please forgive me for missing reporting this to the local regional office in a timely manner ..... I didn't see that I had not
done this until I was working on files today, and am also emailing with this notification an exceedance for Copper for
December as well (and within the two -week required notification).
Please note the following for the November results:
1) The benchmark for Copper under General Permit NCG030000 is 0.010mg/L. The result obtained for Copper for
Outfall 003 was 0.020 mg/L, which exceeded the benchmark of 0.010 mg/L.
2) As completed recently in the past, I grabbed a rainwater sample on that same day in a small bucket and had
copper, lead, and zinc analyzed as well. The results from the analyses obtained for the stormwater bucket sample were
the following:
Copper: 0.011 mg/L — This also exceeds the benchmark of 0.010 mg/L.
Lead: 0.0021 mg/L
Zinc: <0.01 mg/L
4) The rainwater sample was utilized to try and investigate background levels and determine other influences on
benchmark exceedances. These results (as for last month) do provide some background levels to consider for the
copper benchmark exceedance.
5) It is worth noting at the time of this exceedance, the facility was still undergoing some construction for some
new storage buildings (as stated for September). These buildings were constructed right beside the outfall site, and due
to displaced metal being stored in an open dumpster utilized by the contractor, this may have led to the copper
exceedance.
6) This benchmark exceedance for copper will be documented in the SWPPP, and corrective action steps will be
implemented to reduce such occurrences. Furthermore, best management practices will be utilized to assist with
reducing the copper with exceeding its respective benchmark value.
Per the general permit for CommScope, Inc. (NCG030000) Claremont Facility (under COC NCG030650), sampling was
completed on ROS Outfall 003 for the site on Thursday, December 15th, 2022 with a rainfall even totaling 0.46" of rain.
received results from the laboratory (Statesville Analytical) on Friday, January 20th, 2023. For this event, all parameters
were below the benchmark EXCEPT for Copper.
Please note the following for the December results:
1) The benchmark for Copper under General Permit NCG030000 is 0.010mg/L. The result obtained for Copper for
Outfall 003 was 0.011 mg/L, which exceeded the benchmark of 0.010 mg/L.

2) As completed recently in the past, I grabbed a rainwater sample on that same day in a small bucket and had
copper, lead, and zinc analyzed as well. The results from the analyses obtained for the stormwater bucket sample were
the following:
Copper: <0.002 mg/L— Non -Detect
Lead: <0.0005 mg/L
Zinc: 0.018 mg/L
4) The rainwater sample was utilized to try and investigate background levels and determine other influences on
benchmark exceedances. These results do not really provide any background levels to consider for the copper
benchmark exceedance.
5) It is worth noting at the time of this exceedance, the facility was still undergoing some construction for some
new storage buildings (as stated above for November). These buildings were constructed right beside the outfall site,
and due to displaced metal being stored in an open dumpster utilized by the contractor, this may have led to the copper
exceedance. As of the time that the January results were obtained (which was Wednesday, January 25t", this dumpster
has been removed from the facility by the contractor. We are hopeful that this would have corrected the issue with the
copper. We will know further in the next couple of weeks when the data results comes back from the lab.
6) This benchmark exceedance for copper will be documented in the SWPPP, and corrective action steps will be
implemented to reduce such occurrences. Furthermore, best management practices will be utilized to assist with
reducing the copper with exceeding its respective benchmark value.
Please note that rainfall totals for the Claremont CommScope site are obtained from the National Weather Service.
Please contact me on my cell at [phone] if you need any further information. Thank you.
Nicole
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