NC0089770_NOD-2019-LV-0091 & NOV-2019 LM-0044 LV0384 AND 0091 Response_20190628

ATLIN"'
Engineers and Scientists
June 28, 2019
North Carolina Department of Environmental Quality
Robbie Bullock
Division of Water Resources
Washington Regional Office
943 Washington Square Mall
Washington, North Carolina 27889
Re: Remedial Action
NPDES Permit No. NCO089770
NOD-2019-LV-0091
NOV-2019-LM-0044
NOV-2019-LV-0384
Dear Mr. Bullock:
Post Office Box 10279
Wilmington, NC 28404-0279
Phone [phone]
Fax [phone]
www.catlinusa.com
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This letter is provided as follow up to the letter submitted to you by CATLIN Engineers
and Scientists (CATLIN) on June 131h. The purpose of this letter is to provide
information pertaining to in-house remedial actions, specifically operational and
procedural policies CATLIN has implemented in response to the recent non -compliant
discharges and reporting deficiencies associated with NPDES Permit number
NCO089770 (Permit). The letter is submitted on behalf of Lisa Kirby and The City of
Greenville in response to the above referenced Notices.
CATLIN has organized a personnel team and developed policies to overcome the
historical deficiencies resulting in Permit Notices. The team includes:
Quality Assurance (QA) Managers: Rick Garrett, PG and Bill Walsh, PE
Project Manager: Ben Ashba
Operator in Responsible Charge (ORC): Ted Triantafillopoulos (Triantis):
Water Pollution Control System Operators Certification Commission PC-
1007106
Senior ORC: Mike D Mason
Field Technician: Steve Kish
A number of team meetings have occurred since receipt of the Notices dated June 6th
The analytical results and treatment system operational notes were reviewed and
communication breakdowns were identified. Policies were implemented to prevent
future communication breakdowns and maintain permit compliance. These policies
were laid out in an internal CATLIN Memo distributed to and discussed with the team.
The Memo is provided as an attachment to this letter.
In addition to the remedial action policies enacted, a detailed review of all data was
performed. This review included trend analyses to identify possible correlation among
various analytical results as well as correlation between analytical results and

Page 2
Mr. Bullock
June 28, 2019
environmental conditions unrelated to activities being performed as part of the ongoing
utility installation project. No correlation was identified between elevated metal (total
zinc, total copper, total lead, total mercury) concentrations and Total Suspended Solids
(TSS) concentrations. That is, elevated levels of metals were observed even when
TSS concentrations were below laboratory detection limits. However, there appears to
be some moderate and strong correlation between levels of metals in discharge
samples and the total local rainfall accumulation in the days preceding the samples
being collected.
The following table summarizes the correlation between laboratory analytical results
from analyses performed on discharge effluent samples and rainfall accumulation
preceding sample collection.
"Y
fCo�relation C.oeffici'ent'Befween
�w
Result and,nx—
Arialytical
rPrevious'.2+Days
Pceviou's' 3 Day s,°'
{ ;Previousr. Days,--,.
3F
3�, N °:
n
Rainfall
Rainfall �,,
Rainfall
Accumulation,;;„._'
Accumulation
, .:Accumulation _,
„,
0.520
0.704
0.621
Total Zinc
(moderate positive
(strong positive
(moderate to strong
correlation)
correlation)
positive correlation)
0.400
0.751
0.777
Total Copper
(weak to moderate
(strong positive
(strong positive
correlation)
correlation)
correlation
0.730
0.683
0.205
Total Lead
(strong positive
(moderate to strong
(no correlation)
correlation)
positive correlation)
0.428
0.356
Total Mercury
0.197
(weak to moderate
(weak positive
(no correlation)
positive correlation)
correlation)
0.324
0.354
Total Suspended Solids
0.044
(weak positive
(weak positive
(no correlation)
correlation
correlation
The rainfall data used was from the Dark Sky Weather app Time Machine via
Meteorological Assimilation Data Ingest System (https:Hmadis.noaa.gov) non-NOAA
providers. Based on these data, there is a strong positive correlation (correlation
coefficient > +0.700) between the rainfall accumulation and the zinc, copper, and lead
results. These correlations suggest these elevated results may have been the result of
metals being introduced into the treatment system by stormwater runoff.
Through additional research CATLIN identified the State of Washington Department of
Ecology Publication Number 08-10-025 "Suggested Practices to Reduce Zinc
Concentrations in Industrial Stormwater Discharges", dated June 2008
(https://fortress.wa.gov/ecy/publications/publications/0810025.pdf). This document
identifies galvanized surfaces (including roofs, ductwork, gutters, downspouts, piping,
and fencing), motor oil, hydraulic fluid, and tire dust as common sources of zinc in
stormwater runoff. CATLIN personnel are researching potential zinc (and other metal)
sources in the area and evaluating the possibility of these entering open excavations
via rain water sheet flow, subsequently entering the treatment system from dewatering
discharge (treatment system influent). Any identified potential sources will be
217112 2019 June Remedial Action CATLIN
Engineers and ScianBab

Page 3
Mr. Bullock
June 28, 2019
evaluated to determine if any best management practices (as recommended in the
State of Washington publication) should be implemented.. This may be further
investigated (and discussed if deemed appropriate) following receipt of the first, post
0.5 micron bag filter sampling analytical results.
Thanks for your consideration regarding this on going project and our attempts to
satisfy the Permit requirements. We will keep you up to date with the latest conditions.
If you have any questions or require any additional information, please do not hesitate
to contact us at [phone].
Sincerely,
Benjamin J. Ashba, P.G. Theodore J. Triantafillopoulos.
Project Manager Operator In Responsible Charge
Cc: Robert Tankard, NCDEQ Washington Regional Office
Lisa Kirby, PE, City of Greenville
217112 2019 June Remedial Action Z CATLIN
Engineers and Scientlsb

wt�E =Ial
�1."' CATLIN
Engineers and Scientists
CATLIN Engineers and Scientists
220 Old Dairy Road
Wilmington, NC 28405
Phone [phone]
To: Ted Triantis, Kish, Mike D. Mason, Bill Walsh, Rick Garrett
From: Ben Ashba
CC: Jason Catlin
Date: June 26, 2019
Re: Greenville Town Creek Culvert NPDES Permit Procedural and Operational Policies
EFFECTIVE IMMEDIATELY
Procedural Policies
Any/All laboratories performing analytical work associated with NPDES Permit Number
NCO089770 compliance monitoring requirements have been (or will be) instructed to
provide all analytical data to the Project Manager (Ben Ashba), the Operator in
Responsible Charge (ORC) (Ted Triantis), the Senior ORC providing oversight (Mike D.
Mason), and the assigned senior Quality Assurance (QA) Manager (Rick Garrett/Bill
Walsh).
The Project Manager will review the complete analytical reports within 24 hours of
receipt. If unable to do so, the Senior ORC (or designee) will review the reports (and
provide notifications described below).
o Notify The City and DEQ WaRO (Robbie Bullock or Richard Tankard) via telephone
and email (cc'd to all) of any non-compliance findings and planned remedies.
DEQ NEEDS TO BE MADE AWARE OF THESE ISSUES IMMEDIATELY, DO NOT
WAIT FOR NORMAL MONTHLY eDMR REPORTING TO BRING THIS TO THEIR
ATTENTION!
(I will also be notifying The City of Greenville and DEQ WaRO of compliant findings
over the next few weeks/months.)
• Every Friday morning following the weekly staff planning meeting, the Project Manager,
ORC, Senior ORC and the QA Manager will meet to discuss permit compliance. In
addition to compliance status, this meeting should also forecast upcoming compliance
schedule items as well as observed trends in analytical and operational data that may
indicate pending problems.
• The ORC will continue collecting weekly samples and notify the Project Manger and
Senior ORC when samples are collected. The ORC will also continue to be onsite the
majority of each week overseeing treatment system operations with the Field Technician
(Steve Kish). The Field Technician's primary responsibility will continue to be excavation
oversight and soil disposal coordination.
The Senior ORC will begin making weekly site visits until there have been three
consecutive months of permit compliance. These visits are intended to be twofold.
1. Inspect treatment system components and review operational logs and,
2. Provide further training and oversight for the ORC.
Page 1 of 2 Greenville Town Creek Culvert NPDES Permit Procedural and Operational Policies

C ATLIN
Engineers and Scientists
• The Senior ORC will review and complete final submittal of eDMR data within 30 days of
the monthly sampling event. In the event the Senior ORC is unable to review and
physically finalize submittal, he will notify the Project Manager, ORC, and the QA
Manager. The ORC will then finalize and submit the eDMR under the QA Manager's or
Project Manager's supervision.
Operational Policies
To date, discharge samples have contained non -compliant levels of the following:
Dissolved Oxygen (DO), Turbidity, Total Copper, Total Mercury, Total Zinc, Total Lead,
and Total Suspended Solids.
o Non -compliant DO was the result of a faulty meter (likely due to calibration) and a
replacement meter not being available onsite. In accordance with CATLIN's
Standard Methods and the manufacturer's instructions, the DO meter should be
calibrated every day before use. If calibration fails or non -compliant DO levels are
measured, notify the Project Manager and/or Senior ORC and they will coordinate
delivery of a replacement DO meter to the site. A FUNCTIONING DO METER MUST
BE ON SITE AND UTILIZED DURING COMPLIANCE SAMPLING.
o Non -compliant Turbidity may have also been the result of a faulty meter but bag filter
failure is also suspected. The Turbidity meter should also be calibrated and used in
accordance with CATLIN's Standard Methods and the manufacturer's manual.
Should a faulty meter be suspected, the Project Manager and/or Senior ORC will
coordinate delivery of a replacement Turbidity meter to the site.
■ New 10 micron bag filter vessels were recently installed and the former 10
micron bag filter vessels that suffered failures (bag filter canister became
dislodged from its seated position due to .corrosion of the lip/rim of the seated
position) and a number of unsuccessful "fix' attempts have been moved to the
end of treatment train with 0.5 micron bag filters installed. Additionally, gaskets
(not typically required with this style of bag filter) were added to the 0.5 micron
bag filter canisters to prevent the canisters from becoming dislodged from their
seated position within the vessel. Preliminary tests indicated (based on
differential pressures between the influent and effluent) that the gaskets are
providing a seal and the canisters maintained their seated position.
• If non -compliant Turbidity is measured and a bag filter failure is suspected or
confirmed, notify the Project Manager, Senior ORC, and/or QA Manger. The bag
filter vessel supplier (CarbonAir/ProAct/Evoqua) will be notified and a new bag
filter vessel will be requested. SHUT DOWN THE SYSTEM -NO FURTHER
DISCHARGE SHALL OCCUR IF TURBITY IS NON -COMPLIANT. The Senior
ORC or Project Manger will notify the Trader Construction Supervisor that
dewatering activities discharging to the treatment system need to be halted until
the new bag filter vessel is in place. If necessary to facilitate continued
construction dewatering activities, "pump and haul" or frac tank storage capacity
will be coordinated by the Project Manager, Senior ORC, or QA Manager.
o Total Copper, Total Mercury, and Total Zinc non -compliant concentrations are
suspected to be the result of insufficient bag filtration. The 0.5 micron bag filters
were added to address this. We are waiting to receive the first, post 0.5 micron bag
filter sample results. If non -compliant concentrations are revealed, additional metals
treatment, "pump and haul", or other remedies will be implemented.
o Total Suspended Solids non-compliance was the result of the bag filter failures. If a
bag filter failure is suspected or confirmed, notify the Project Manager, Senior ORC,
and/or QA Manger. The failure will be evaluated with CarbonAir/ProAct/Evoqua and
a new bag filter vessel will be requested or a supplier representative/technician will
complete the appropriate repair.
Continue daily checks and documentation in accordance with the CarbonAir/ProAct/
Evoqua equipment operations manuals.
Notify the Project Manager or Senior ORC immediately if any atypical operations occur.
Page 2 of 2 Greenville Town Creek Culvert NPDES Permit Procedural and Operational Policies