NCG030591_Email Inspection Follow up_20191008

Georgoulias, Bethany
From: O'Reilly, Kristen <[e-mail]>
Sent: Tuesday, October 8, 2019 11:09 AM
To: Bob Besh
Cc: John Albright; Jon Ward; Moore, James; Hawley, Julianna E
Subject: [External] RE: [EXT] RE: Stormwater Inspection
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
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Hi Bob — I just spoke to James Moore.
1) He confirmed that the representative outfall status for your facility was approved in their system. He said the
conditional language in the letter was unusual, but nonetheless it was approved.
2) 1 explained your flooding situation and lack of Copper and Zinc sources and whether you may be able to apply
for monitoring relief. He said that it has been done before, but it is something that he would need to evaluate
upon inspection of your facility. So there is a possibility.
I have copied James Moore on this in case he would like to correct me or add anything.
Thank you.
Kristen O'Reilly
Water Quality Program Specialist
Charlotte -Mecklenburg Storm Water Services
Cell: [phone]
From: O'Reilly, Kristen
Sent: Monday, October 7, 2019 11:50 AM
To: 'Bob Besh' <[e-mail]>; Hawley, Julianna E <[e-mail]>
Cc: John Albright <[e-mail]>; Jon Ward <[e-mail]>
Subject: RE: [EXT] RE: Stormwater Inspection
Good day Bob,
Please see responses to your email that represent both Juliana and myself in blue below.
Juliana plans to email your inspection report this week.
Feel free to reach back out to me if you have more questions.
Thank you.
Kristen O'Reilly
Water Quality Program Specialist
Charlotte -Mecklenburg Storm Water Services
Cell: [phone]
From: Bob Besh [mailto:[e-mail]]
Sent: Tuesday, October 1, 2019 4:42 PM
To: Hawley, Julianna E <[e-mail]>

Cc: O'Reilly, Kristen <[e-mail]>; John Albright <[e-mail]>; Jon Ward
<[e-mail]>
Subject: [EXT] RE: Stormwater Inspection
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Good afternoon Julianna,
Storm Water Services Group, Jim Frei (Ward's Stormwater consultant) and I researched the letters from the state
addressing changing our testing requirements due to Harris Blvd. The letter from Kahid Khan (Regional Engineer) on
October 25, 2013 stated that It was agreed that (SDO) 002 will be representative of outfalls (SDO) 001 and (SDO) 003 as
long Ward performed two more additional tests on 001 and 003 for Cu and Zn and that the findings were
representative We tested outfall 001 and 003 for two additional samplings which we did and reported appropriately.
Yes. We were glad to find your application and the letter from the state. What we didn't see was communication from
the state confirming that the additional samples were received, determined to be representative, and ultimately that
the representative outfall status was approved. You may be correct and there is no reason for concern, but I recommend
confirming with the state to be sure. Unfortunately we do not have access to the state's records or we would gladly look
it up for you. I called James Moore, NCDEQ, on Friday and this morning and left a voice mail asking on your behalf. I will
let you know when I hear back, but if you would like to ask him yourself, here is his contact information:
[e-mail] or [phone].
We have had no further conversations with the state to change this representative sampling. We have continued to
perform Qualitative Monitoring on all three (SDO) as this same letter reinforces is required. I'm sure the state database
has this letter and any additional comments that were issued when we discussed the flooding and stormwater
contaminants from Harris Boulevard that were washing onto our property and I would assume you have access to that
information. We are of the opinion that we have been consistent with this letter in our testing and reporting and we
have never had any agency communicate anything differently.
We are not sure that monitoring has been consistent with this letter because, as you and your coworker indicated, you
both thought the outfall being sampled was outfall 1 and not outfall 2. Additionally, from my recollection during our
inspection, there seemed to be tiered response monitoring records missing. Unfortunately, photos of all the monitoring
records were not taken so I cannot be sure now. I recommend confirming with Storm Water Services which outfall is
being sampled as outfall 2 and a thorough organization and review of all your records so there is no question during
another inspection.
In November of 2015, Charlie Hansen with Charlotte -Mecklenburg Storm Water Services conducted a site inspection our
facility with zero findings and reported this to Craig Miller, Charlotte Storm Services and Zahid Khan, NCDEQ-DEMLR. At
that time we were performing representative sampling. Yes we saw that inspection report, but we still have questions as
detailed above.
There was a discussion about an area of silt fence that was in disarray that needs to be repaired. You guys felt that this
defective silt fence was creating an additional concentration of stormwater and I agreed to repair the silt fence to
maintain the sheeting action in lieu of a single point of exit through the silt fence. This silt fence is not on the property
line and is not considered an outfall. If there is another outfall or conversation that I am not recollecting correctly,
please let me know.

Repair of the silt fence will likely result in the same problem. Silt fence commonly directs and concentrates sheet flow
causing the fence to fail at the most downstream point during large rain events. From my observations, this is what
appears to have happened.
I recommended looking at the issue more holistically - how can you contain the blasting materials and maintain
representative flow from this drainage area towards a single outfall? You may be able to accomplish that if you adjust
the silt fence, or use other practices, to contain materials in a way that directs flow towards outfall 2 and maintains
sheet flow otherwise. Conversely, you may be able to direct flow from outfall 2 towards the new point of concentration
and propose moving outfall 2 to the new location? The solution is not something that we can recommend directly. It
will likely require some experimentation to determine what works with site conditions during rain events.
As we discussed extensively during your visit, I still need help in addressing the massive amount of stormwater and
stormwater contaminants that come from Harris Blvd due to undersized/under designed stormwater drains on Harris
Blvd. As you and Kristen confirmed during your audit, I have reached out to Kevin Herring with the city for years to
address this issue only to be sent to the state who has only agreed to clean out the drains. This issue continues to
plague us and we would appreciate any help. I am hoping that as you research the actual current requirements as
required by the state for outflow testing that you may be able to assist with a reasonable plan to deal with the
contaminants and excessive that are being washed onto our property from this state highway.
We truly sympathize with this problem but as I mentioned the stormwater flow from Harris Blvd is an NCDOT road and
therefore something that is within their jurisdiction to mitigate. Kevin Herring, City Storm Water Services,
communicated this to you in the past and I reiterated it during our inspection once I heard back from him. Kevin Herring
provided the following contact for NCDOT as a starting point for you: Jon Hinson [phone]. [e-mail]
As far as monitoring relief, I encourage you to discuss this with James Moore.
Bob Besh
VP of Production, Ward Vessel & Exchanger
6670 East WT Harris Blvd. Charlotte, NC 28215
T: 704 972-4357 1 F: 704 536-3259
• " if [Newsletter
From: Hawley, Julianna E <[e-mail]>
Sent: Tuesday, October 1, 2019 9:16 AM
To: Bob Besh <[e-mail]>
Cc: O'Reilly, Kristen <[e-mail]>
Subject: Stormwater Inspection
Bob,
I was just following up with you about the letter from the State about approval to only sample one
outfall. When we met, it was noted that you received a letter from the State noting that you could sample a
representative outfall but needed to continue to sample the remaining two outfalls for copper and zinc until you
received approval from the State.
It was also recommended that you notify the state of the fourth outfall.
I will need to submit my report to the State in a week, so please let me know if you have any other information
before then.
Thank you,
Julianna Hawley

Environmental Specialist
Charlotte -Mecklenburg Storm Water Services
Mecklenburg County Water Quality Program
2145 Suttle Avenue
Charlotte, NC 28208-5237
704-654-1394
[e-mail]
http://charlottenc.gov/StormWater
Storm Water's WHY statement: We are passionate about making our environment safe and healthy by reducing
flood losses and improving water quality for all.
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