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NCG030108_MONITORING INFO_20200122
STORMWATER DIVISION CODING SHEET NCG PERMITS PERMIT NO. DOC TYPE ❑ HISTORICAL FILE ll ( MONITORING REPORTS DOC DATE ❑ na L) a D YYYYM M D D January 16, 2020 Division of Water Quality Attention: DWQ Central Files 1617 Mail Service Center Raleigh, North Carolina 27699-1617 VIA CERTIFIED MAIL RECEIVEC JAN 2 2 2020 CENT i�AL TILES DWR SIECTION REFERENCE: Storm Water Discharge Outfall Monitoring Report —Amended Copy Railroad Friction Products Corporation, Maxton, North Carolina, Certificate of Coverage Number NCG030108 Dear Sir or Madam: In accordance with General Permit Part II Section B, enclosed please find duplicate amended signed copies of Railroad Friction Products (RFPC) Storm water Discharge Outfall Monitoring Report. The amended portion of this report is included in section 2 below (detailing copper exceedances of benchmark values) and basically includes information detailing that RFPC was granted regulatory relief for copper exceedances. The original 2nd half 2019 DMR mailed out December 31, 2019 did not include the information regarding the regulatory relief for copper. This is the only change from this amended DMR compared to the original DMR. This report summarizes analytical monitoring of the site's single outfall and covers the period of July 1, 2019 through December 31, 2019. Below are three issues RFPC wants to make DWQ aware of.' 1. The concentration for zinc remains above listed benchmark value of 0.126 mg/L. During some previous sampling periods zinc sampled values were higher that the listed zinc benchmark range of 0.126 mg/L. The sampling value for first half 2019 was 0.144 mg/L. The sampling value for second half 2018 was 0.249 mg/L. This monitoring period, the zinc sampling value was 0.333 mg/L. This reoccurring zinc over benchmark value has been communicated to DWQ. In a letter issued from NCDEQ to RFPC dated May 25, 2018, RFPC was granted regulatory relief in the form of a collapsed Tier2-Tier 3 response, and RFPC may resume the permitted specified semi-annual analytical monitoring at our facility. RFPC continues to implement actions to mitigate exposure of storm water to materials. For example, RFPC built a building to house the open top reject lined hoppers that holds loose reject material. This building blocks windborne dust from the reject hopper being blown to adjacent facility drainage creek. RFPC has also instituted better housekeeping requirements in order to prevent production material from flowing into the facility drainage creek. In addition, RFPC has installed a StormCeptor unit where storm water drains in back of factory that captures any particles in the storm water to prevent them reaching the drainage creek. Based on the regulatory relief granted in the May 25, 2018 letter, RFPC stopped monthly zinc monitoring. Previous semi-annual DMR at our SDO results are shown below. November 2013: 1.200 mg/L April 2014: 0.390 mg/L SWU-245-033 Page 1 September 2014: 0_130 mg/L October 2014: 0.086 mg/L November 2014: 0.350 mg/L January 2015: 0.050 mg/L November 2015: 0.129 mg/L March 2016: 0.144 mg/L December 2016: 0.181 mg/L May 2017: 0.169 mg/L March 2018: 0.108 mg/L December 2018: 0.249 mg/L February 2019: 0.144 mg/L 2. The concentration for copper is above the listed benchmark value of 0.010 mg/L. The last exceedance was sampling value for first half 2018 - 0.0154 mg/L. Per our permit, this exceedance triggers Tier 1 requirements. In a letter issued from NCDEQ to RFPC dated May 25, 2018, RFPC was granted regulatory relief for copper in the form of a collapsed Tier2-Tier 3 response, which means RFPC can continue the permitted specified semi-annual analytical monitoring at our facility if Tier II status is obtained (which will occur if 1st half 2020 copper sampling value exceeds benchmark value). RFPC is currently at Tier I status, which does not require monthly monitoring for copper. RFPC immediately conducted an inspection of the facility and found no obvious causes for copper exceedance, but we suspect the copper may be deriving from the various ductwork and other metal structures on our factory roof. Even though it is not required, RFPC has started monthly monitoring for copper in the stormwater outfall and the rainwater flowing from roof downspouts from the factory roof during rainstorms (assuming such rainstorms occur during the month). Previous semi-annual DMR at our SDO results are shown below. February 2013: BDL <0.020 mg/L November 2013: 0.025 mg/L April 2014: BDL <0.020 mg/L September 2014: BDL <0.020 mg/L October 2014: BDL <0.020 mg/L November 2014: BDL <0.020 mg/L January 2015: BDL <0.020 mg/L November 2015: BDL <0.010 mg/L March 2016: BDL <0.010 mg/L December 2016: BDL <0.010 mg/L May 2017: BDL <0.0148 mg/L March 2018: 0.0154 mg/L December 2018: <0.01mg/L S W U-245-031308 Page 2 of 2 February 2019: <0.01mg/L . Sampled PH value was 5.82. This is a problem that we have encountered before, but not since 2014. Then and now, we immediately walked around the entire perimeter of the facility to determine the cause of the low PH reading, but none was found. We then reviewed the manufacturing process to determine if anything occurred that would have caused the low PH reading, but nothing was found with this search either. RFPC will check PH again in stormwater sample in January 2020 and compare to collected rainwater PH and advise results. If there are any questions regarding the enclosed material, please call me at 910.844.9739. Sincerely, RAILROAD FRICTION PRODUCTS CORPORATION Greg Thompson Manager Manufacturing Engineering Enclosure Matt Jarusinski General Manger and Vice President S W U-245-031308 Page 3 of 2 Semi-annual Stormwater Discharge Monitoring Report = for North Carolina Division of Water Quality General Permit No. NCG030000 Date submitted _12/31/19 CERTIFICATE OF COVERAGE NO. NCG030108 FACILITY NAME Railroad Friction Products COUNTY Scotland PERSON COLLECTING SAMPLES _Greg Thompson_ LABORATORY Environmental Chemists Inc Lab Cert. ff _94 Comments on sample collection or analysis: Part A: Stormwater Benchmarks and Monitoring Results SAMPLE COLLECTION YEAR _2019 SAMPLE PERIOD ❑ Jan -June ® July -Dec or ❑ Monthly' (month) DISCHARGING TO CLASS ❑ORW ❑HQW ❑Trout ❑PNA []Zero -flow [:]Watersupply ❑SA ®Other_c;SW PLEASE REMEMBER TO SIGN ON PAGES 2 AND/OR 3 4 No discharge this period?' Outfall No. Date Sample Collected' (mo/dd/yr) 24-hour rainfall amount, Inches' Total Suspended Solids pH Standard units Copper Lead Zinc Non -Polar O&G/ Total Petroleum Hydrocarbons Total Toxic Or anics5 g Benchmarks ===> - - 100 mg/L or 50 mg/0 6.0 — 9.0 0.010 mg/L 0.075 mg/L 0.126 mg/L 15 mg/L 1 mg/L 001 12/18/19 2.25 4.2 mg/L 5.82 <0.014 mg/L <0.01 mg/L 0.333 mg/L <5.0 mg/L NA ' Monthly sampling (instead of semi-annual) must begin with the second consecutive benchmark exceedance for the same parameter at the same outran. 2 For sampling periods with no discharge at any single outfall, you must still submit this discharge monitoring report with a checkmark here. 'The total precipitation must be recorded using data from an on -site rain gauge. Unattended sites may be eligible for a waiver of the rain gauge requirement. "See General Permit, Table 3 identifying the especially sensitive receiving water classifications where the more protective benchmark applies. s Total Toxic Organics sampling is applicable only for those facilities which perform metal finishing operations, manufacture semiconductors, manufacture electronic crystals, or manufacture cathode ray tubes. For purposes of this permit the definition of Total Toxic Organics is that definition contained in the EPA Effluent Guidelines for the facility subject to the requirement to sample (for metal finishing use the definition as found in 40 CFR 433.11; for semiconductor manufacture use the definition as found in 40 CFR 469.12; for electronic crystal manufacture use the definition as found in 40 CFR 469.22; and for cathode ray tube manufacture use the definition found in 40 CFR 469.31). Permit Date: 11/1/2012-10/31/2017 SWU-245, last revised 10/25/2012 Page 1 of 3 Facilities that incorporate a solvent management plan into the Stormwater Pollution Prevention Plan may so certify, and the requirement for TTO monitoring may be waived. The solvent management plan shall include list of the total toxic organic compounds used -and the other -elements fiste ' d in the General Permit. For those facilities electing to employ the TTO monitoring waiver, the discharger shall sign the following certification statement: "Based upon my inquiry of the person or persons directly responsible for managing compliance with the permit monitoring requirement for total toxic organics (TTO), I certify that to the best of my knowledge and belief, no dumping of concentrated toxic organics into the stormwater or areas which are exposed to rainfall or stormwater runoff has occurred since filing the last discharge monitoring report. I further certify that this facility is implementing the all the provisions of the solvent management plan included in the Stormwater Pollution Prevention Plan." Matt Jarusinski Name (Print name) GM and VP Title (Print title) 2,Q (Signature (Date) Note: Results must be reported in numerical format. Do not report Below Detection Limit, BDL, <PQL, Non -detect, ND, or other similar non -numerical format. When results are below the applicable limits, they must be reported in the format, "<XX mR/L", where XX is the numerical value of the detection limit, reporting limit, etc. in mg/L. Note: if you report a sample value in excess of the benchmark, you must implement Tier 1, Tier 2, or Tier 3 responses. See General Permit text. Part B: Vehicle Maintenance Area Monitoring Results: only for facilities averaging > 55 gal of new oil per month. n No discharge this period?z Outfall No. Date Sample Collected' (mo/dd/yr) 24-hour rainfall amount, Inches' Non -polar O&G/TPH by EPA 1664 (SGT-HEM) Total Suspended Solids pH Benchmarks =_=> - - 15 mg/L 100 mg/L or 50 mg/L' 6.0 — 9.0 SU NA NA NA NA NA NA Footnotes from Part A also apply to this Part B ' See General Permit text, Table 5, identifying the especially sensitive receiving water classifications where the more protective benchmark applies. Permit Date: 11/1/2012-10/31/2017 SWU-245, last revised 10/25/2012 Page 2 of 3 Note: If you report a sample value in excess of the benchmark, you must implement Tier 1, Tier 2, or Tier 3 responses. See General Permit text. FOR PART A AND PART B MONITORING RESULTS: • A BENCHMARK EXCEEDANCE TRIGGERS TIER 1 REQUIREMENTS. SEE PERMIT PART II SECTION B. • 2 EXCEEDANCES IN A ROW FOR THE SAME PARAMETER AT THE SAME OUTFALL TRIGGER TIER 2 REQUIREMENTS. SEE PERMIT PART II SECTION B. • TIER 3: HAS YOUR FACILITY HAD 4 OR MORE BENCHMARK EXCEEDENCES FOR THE SAME PARAMETER AT ANY ONE OUTFALL? YES ® NO ❑ IF YES, HAVE YOU CONTACTED THE DWQ REGIONAL OFFICE? YES ® NO ❑ REGIONAL OFFICE CONTACT NAME: _Mike Lawyer Mail an original and one copy of this DMR including all "No Discharge" reports within 30 days of receipt of the lab results (or at end of monitoring period in the case of "No Discharge" reports) to: Division of Water Quality Attn: DWQ Central Files 1617 Mail Service Center Raleigh, North Carolina 27699-1617 YOU MUST SIGN THIS CERTIFICATION FOR ANY INFORMATION REPORTED: "I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations." (Signature of Permit Date: 11/1/2012-10/31/2017 // 21y (Date) SWU-245, last revised 10/25/2012 Page 3 of 3 Shipping: 2401 W. 51b St. Lumberton NC 28358 TBL RAILROAD FRICTION 13601 AIRPORT ROAD MAXTON, NC 28364 ,ATTN: GREG THOMPSON SAMPLE NUMBER - 13439 DATE SAMPLED - 12-18-19 DATE RECEIVED-12-18-19 TIME RECEIVED - 0910 PAGE 1 OF 1 Mailin : PO Box 589 Lumberton, NC 28359 FINAL REPORT OF ANALYSES Phone: 910-738-6190 Fax:910-671-8837 Email: pam.hester- tbl(aDhotmail.com PROJECT NAME:TBL- 29429 REPORT DATE:121-8-19 SAMPLE ID - STORMWATER SAMPLER - JAY HUCKS DELIVERED BY - CLIENT ANALYSIS METHOD BIOCHEMICAL OXYGEN DEMANDSM5210-B TOTAL SUSPENDED SOLIDS SM2540D ,AMMONIA NITROGEN SM450ONH3D FECAL COLIFORM SM9222D CONDUCTIVITY SM25108 CHEMICAL OXYGEN DEMAND SM5220D PH SM4500 H+B VOLATILE SUSPENDED SOLIDS SM2540E N/R = ANALYSIS NOT REQUESTED DATE RESULT N/R 12/18/2019 4.2 N/R N/R N/R N/R N/R N/R LABORATORY DIRECTOR SAMPLE MATRIX - WW TIME SAMPLED - 0800 RECEIVED BY - THI QUAL DET. UNITS CODE LIMIT MG/L 2.0 MG/L 2.6 MG/L 0.1 MPN/100ML 1 UMHOS/CM 10 MG/L 30.0 STD UNITS 0.1 MG/L 500 NCDENR DWQ 6 37, NCDENR DW p 37781 TBL Environmental Laboratory , Inc. 2401 W. 5th St Lumberton, NC 28358 (910) 73 619Q \\ Billing Information: AnelysislContalnerrPreservativa TBL VERIFIED 0/B SAMPLE VOLUME TO BE , ?1`F` MLS AS COMPARED' TO CALIBRATED BOH LE' , { N' Kj 1^ { 11 h ♦ TI I _ C1 l I J` i I ' Rap rxito; Project I- Description: S -1zn" ["`1I AJe✓ 'uy Phone: FAX: 9/0 -81W- qr Acp Client Project b: M �nq 3G r ESC Key: Collected by: 'C' Ll ky SitelFaclllty, ID$- P.O.a: CoCode (lab use only) TemplatelPrelogin Shipped Via: Collected by (signature): mmediatcl arkeJ nn 1' N Semple ID Rush? ( Lab MUST Be Notified) — Same Day.. • • _ ..200% Nert Day........ 100% Twu Day .........50% ComplGrab Mauir• Depth Ifnitcs [s cededr of Cnlre - Email? No Yes FAX? _N0—yes Date Time RemaAUConmmmant Sample k(lab only) S s�, I I I I l I T (' c— -►Lt f f f I I j R93 i! i f l j Diic T� 'II i I I I -Malri,c SS-SoiVSelld GW-Groundvvater VUW•WasteWater DW-Orinking Water OT-Other Pt rcmp Remarks: Fkm Ogxr lgna re) ture XRelinquishad Datz: Date: Time: T /a Tine: Rzce • Sign ure) Received by: gnelure) Samples roturned via: ❑ UPS ❑ FedE% ❑Courier ❑ Condition: (lab use only) CcC Seals lniect: Y N NA Temp: Bottles Received; Date: Time: Received for tab by: (Signature) Date: Time: pH Checked: NCF: re) Environmental Chemists, Inc. i 1 6602 Windmill Way, Wilmington, NC 28405 • 910.392.0223 Lab • 910.392.4424 Fax sM 710 Bowsertuwn Road, Manteo, NC 27954 • 252.473.5702 Lab/Fax ' 255-A INilmin ton Hi hwav Jacksonville NC 28540 • 910 347 SR43 I L F ANALYTICAL & CONSULTING CHEMISTS in1ii(4cm ironmentalchemists.com 7BL Date of Report: Dec 30, 2019 P.O. Box 589 Customer PO #: Lumberton NC 28358 Customer ID: 11040019 Attention: Pam Hester Report #: 2019-21307 Project ID: Railroad Friction Products Lab ID Sample ID: Collect Daterrime Matrix Sampled by 19-53966 Site: Storm Water 12/18/2019 8:00 AM Water Jay Hucks 'Test Method Results Date Analyzed �, Oil �B Grease (O&G) EPA 1664 <5 mg1L 12/20/2019 Copper EPA 200.7 0.014 mg/L 12/20/2019 Lead EPA 200.7 <0.01 mg/L 12/20/2019 Zinc EPA 200 7 0.333 mg/L 12/20/2019 Comment: Reviewed by: �LU11� 1 1 4 — —) /-,A TBLEnvironmental Laboratory, Inc. 2401 W. 5th St Lumberton, NC 28358 (910) 73-61 Billing Information: ��&,Gonlq r/Preservative zjN r11 Q: TBL VERIFIED 0/6 SAMPLE VOLUME TO BE IALS AS COMPARED TO CALIBRATED Barra sport ta: Ind[] In: Project Description: kF-i2 54VnXtJC,4e-,- iiy SAC Phone: FAX: 910 1��J& Client Project IPQ 1499 ESC Key: Collected by: Sile]Faclllty 10P P.O.M CoCade (lab use only) Ternplaleff'relogin Shipped Via: Collected by (signature): Im -�d--fn, "k-edonice N CY) (Lab MUST Be Notified) Same Day ....... 200% Next Day........ 100% Two Day ......... 50% Tk �. rl.� 95�1. D,t 3413-Niecded: No. f Email? No_Ycs FAX? No Yes Sample fD Comp/Grab Matrix' Depth Date TTZ— Grim RamarkslConfarninant Semple (lab only) G Ds'Oonlip'-3 P;q 173 C ;it oil 6 w--r L U w 'Matrix SS-Soil/Solld GW-Groundwater VM-WasleWaler Dyy- Drinking Water OT-Other ill-[ _ Temp Remarks, Flom, Other igna re) RelneTollahWily (Sig alural, Date: ais-6 Time: 0 1 Rece Sig une) AReed by: Sig Samples ralumed via: El UPS ElFedEx ClCourfer 0 Condition: (lab use only) c3aW Time: Temp: Bottles Received: 41-1 t a- coc seals Intact:_ Y — N — NA Relinquished Igna re) Date: Time, Flaceived for lab by: (Signature) I Ea Time pH Checked, NCF: -- MA NCDENR Stormwater Discharge Outfall (SDO) Qualitative Monitoring Report Forguidance on filling out thisjorm, please visit. gip//nnrt?Lnadenr.arsh eb/Ir/nth es-storm_t+ater/ Permit No.: N/C/_/_/ FacilityName: (z4• County: Sr.yt 1 a� Inspector: G1-e Date of Inspection. _ Time of Inspection: _ -/ / of Certificate of Coverage No.: N/[/G/v/3q'1 /D/49/ Total Event Precipitation (inches): Was this a "Representative Storm Eve (See information below.) EE] Yes ❑ No or "Measureable Storm Event" as defined by the permit? Please verify whether Qualitative Monitoring must be performed during a "representative storm event" or "measureable storm event" (requirements vary, depending on the permit). Qualitative monitoring requirements vary. Most permits require qualitative monitoring to be !� performed during a "representative storm event" or during a "measureable storm event." However, some permits do not have this requirement. Please refer to these definitions, if applicable. A "representative storm event" is a storm event that measures greater than 0.1 inches of rainfall and that is preceded by at least 72 hours (3 days) in which no storm event measuring greater than 0.1 inches has occurred. A single storm event may contain up to 10 consecutive hours of no precipitation. A "measurable storm event" is a storm event that results in an actual discharge from the permitted site outfall. The previous measurable storm event must have been at least 72 hours prior. The 72-hour storm interval does not apply if the permittee is able to document that a shorter interval is representative for local storm events during the sampling period, and the permittee obtains approval from the local DWQ Regional Office. By this signature, I certify that this report is accurate and complete to the best of my knowledge: i_ _ r 1 -YvOa.r-L-� (SignaturWof Permittee gr Designee) Pagel of 2 SWU-242. Last modified 7/31/2013 1. Outfall Description: f 0utfaII No. <? U ( Structure (pi e ditch, etc.) _.,—O . 4 e V, Receiving Stream: (. D e Describe the industrial activitie5 Chat occur within the outfall drainage a ea: g 4 rPj p t �� U 2. Color: Describe the color of the discharge using basic colors (red, brown, u , etc.) and tint (light, medium, dark) as descriptors: JL-P �'f� • �' _-_.�._.._.._ 3. Odor: Describe any distinct odors that the discharge may have (i.e., smells strongly of oil, weals chlorine odor, etc.): tr1�G 4. Clarity: Choose the number tthich best describes the clarity of the discharge, where I iS clear and S is very cloudy: 1 3 4 S S. Floating Solids: Choose the niunber which best describes the amount of Floating solids,in the stormwater discharge, where 1 is po solids and 5 is the surface covered with Floating solids: 'I 1 O 3 4 5 6. Suspended Solids: Choose the number which best describes the amount of suspended solids in the stormwater discharge, where 1 is no solids and 5 is extremely muddy: 1 © 3 4 5 7. Is there any foam in the stormwater discharge? Yes U 8. Is there an oil sheen in the stormwater discharge? Yes !off v 9. Is there evidence of erosion or deposition at the outfall? Yes l 1/ 10. Other Obvious Indicators of Stormwater Pollution: List and describe t L �^ f7 �1 7 l tv0 C rf,° 41,E A._� jC — Note: Low clarity, high solids, and/or the presence of foam, oil sheen, or erosion/deposition may be indicative of pollutant exposure. These conditions warrant further investigation. Page 2 of 2 SWI1412, last modified 7/31 /'1113 s • y � , v .�W t p J r •. f � Y ' i • PH Tf acre ioc1 �i y r.. t ,': q w ^Y e ;F..e'• r ar "� u .e.• � f2 , on rnode read., ;. *~ Doff e :•'L i .v r .m ✓• iJ' � yr '�,^lp � � n i � Y�g,�t ;J'�^. s f t � .. - � _. .. � l A �. w�. 7 �' ��'y.. it • t",�, 4�'tiia