NCG030075_COMPLETE FILE - HISTORICAL_20150313

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STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
NCGNE n 3O U JI 5
DOC TYPE
HISTORICAL FILE
DOC DATE
❑ p� b� 5 V 3� 3
YYYYMMDD

IN
Pickle, Ken
From: Kucken, Darlene
Sent: Friday, March 13, 2015 3:13 PM
To: Pickle, Ken
Cc: Georgoulias, Bethany; Herbert, Laura Q Bennett, Bradley
Subject: RE: Borg Warner NCG030075
Hi Ken, et.al-
Thanks for this response. I've added a few things below where I wanted to clarify.
Darlene Kucken - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Energy, Mineral, and Land Resources
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
may be disclosed to third parties.
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From: Pickle, Ken
Sent: Friday, March 13, 2015 2:54 PM
To: Kucken, Darlene
Cc: Georgoulias, Bethany; Herbert, Laura C; Bennett, Bradley
Subject: FW: Borg Warner NCG030075
Hi Darlene,
Thanks for sending this to us last Friday and asking for comments. Bethany and I looked at this separately earlier in the
week, and discussed together this morning. See our response below.
Ken
From: Pickle, Ken
Sent: Thursday, March 12, 2015 12:45 PM
To: Georgoulias, Bethany
Subject: FW: Borg Warner NCG030075
1. Our thoughts with respect to the ROS request:
a. We don't have a site plan, but I pulled up the facility on Google Maps: I note that the south parking lot
looks like employee -only parking. Ditto the front door parking on the west. I see the grassed areas. If
1

these are draining to the Outfalls #4, S, 6, and 7 that you cite, we concur that they appear to be from
non -industrial activity areas. The whole site looks pretty clean. One caution: Suggest you make sure
that the permittee understands that these four outfalls are unregulated, which is different from
Representative Outfall Status. He's getting both responses from DEMLR as a result of your CEI, and
clarifying the distinction for him might be helpful in the future. Yes, we talked about this and they
understand.
b. Remaining outfalls #1, 2, 3: We're ok with your recommendation suggesting sampling for #1; and for
#3 as representative of #2 and #3. Again, we don't have a site plan, but you've been there, seen the site
conditions, and looked at the monitoring results. We're ok with the RO call on this. Great.
2. Here are our thoughts with respect to relief from the Tier structure requirement of monthly sampling triggered
by Cu and Zn exceedances:
a. Background: Clayton Creek — Class C to French Broad River — Class B. No TMDL's in the French Broad
River Basin except state-wide Hg. => No special concern wrt receiving water.
b. We note that AMEC is on the payroll for Borg. Darlene, you might consider requiring Borg (presumably
assisted by AMEC) to submit a written engineering argument for the relief from monthly
sampling. Based on the CEI perhaps it's a foregone conclusion that you will grant it. But, still, we think
it's good to have documentation of the basis for our decision and to begin to build a precedent on what
sorts of arguments are meaningful to us, and which ones miss the point. Good idea; they have what they
need to do this.
c. Such an argument by B-W should address what they have already done in response to the
exceedances. I guess the wet mopping, magnet sweep, and sweeping are largely driven by cleanliness
needs of the manufacturing process, not in response to stormwater pollution. Darlene, you report that
they have investigated everything they can. But, what have they done in response? What
action? What have they tried in order to address the exceedances? It would be good to have that in
their argument for relief. You could still grant relief even if they have done nothing and if you think
there's no point in further monthly sampling. But again, here's a chance to reinforce the precedent that
we want folks to try something first, rather than just run to us for administrative relief. Let's first seek
an engineering solution (if one is feasible) before an administrative solution. What they have done is
what I mentioned in my first email — they added the pre -vent filters, started magnet and wet mopping
constantly, are putting in a roof over the waste containers, did a science -based assessment of
stormwater, etc. But I can truly see that this place is spotless. But I agree they can send us this in a
report.
d. Worrisome: the claim that rainwater contains Cu and Zn — it is possible perhaps. But their evidence
appears to be that runoff from the galvanized roof contains these pollutants: I would be careful not to
confuse the evidence by saying that 'rainfall' has these constituents, unless the rainfall was captured
directly out of the sky. Collecting off of a galvanized (i.e. coated with zinc) roof at a facility that may
have combustion processes or painting processes or metal finishing processes ALL WITH ROOF STACKS,
does not establish that the rainfall is polluted at the levels detected: just that the roof runoff
is. Darlene, you might consider if you want to coach them on over -interpreting the data they have. We
are also aware of a few literature reports from highly urbanized areas that attribute some rainfall
impurities to urban air pollution. But at the moment, the generalized extrapolation to a single
manufacturing facility seems an unsupported stretch to us. Amec is actually doing testing of straight
rainwater at several facilities by using an open container with no association with the roof, etc. They
said they'd be glad to share these results and have already been talking with Bill Hunt. They did a water
from the sky test at this facility and gave me the results. He can add this to his report.
e. Summary comment: we're ok with ARO moving ahead to grant relief as proposed by Darlene.
Contact either of us with any follow up. Have a great weekend!
PM

Ken
From: Georgoulias, Bethany
Sent: Friday, March 06, 2015 8:58 AM
To: Pickle, Ken
Subject: FW: Borg Warner NCG030075
FYI, re: Darlene's question on Cu/Zn
Bethany Georgoulics, Environmental Engineer
NCDENR / Division of Energy, Mineral, and Land Resources
Stormwater Permitting Program
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury Street, Raleigh, NC 27604
919 / 807-6372 (phone); 9191807-6494 (fax)
Website: http://portal.ncdenr.or_a./web/1r/sormwater
E-mail correspondence to and from this address may he subject to Phe Earth Carolina Public Records lair and may he disclosed to third parries,
From: Kucken, Darlene
Sent: Thursday, March 05, 2015 3:30 PM
To: Georgoulias, Bethany
Subject: RE: Borg Warner NCG030075
No problem! The BorgWarner folks know we are understaffed and that they will get a response soon. I will be in the
field next Mon -Wed, returning Thur. If I had a response by next Friday I'd be delighted. O
Darlene Kucken - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Energy, Mineral, and Land Resources
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
may be disclosed to third parties.
`,A Go Green! Print this email only when necessary. Thank you for helping NCDENR be environmentally responsible.
From: Georgoulias, Bethany
Sent: Thursday, March 05, 2015 2:12 PM
To: Kucken, Darlene; Herbert, Laura C
Subject: RE: Borg Warner NCG030075
Hi —just a quick note. Apologies on the delay, but Mike, Ken, and I are working against a deadline to have three draft
permits for power plants ready by tomorrow, when the Department sends them to notice. Ken and I will be in touch
with you on this when we get through those.
Thanks!
Bg

Bethany Georgoulias, Environmental Engineer
NCDENR 1 Division of Energy, Mineral, and Land Resources
Stormwater Permitting Program
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury Street, Raleigh, NC 27604
919 1807-6372 (phone); 919 1807-6494 (fax)
Website: http://Portal.ncdenr.org/web/iristormwater
E-mail correspondence to and from this address mats be subject to the North Carolina Public Records lair and nrav be disclosed to third parlies.
From: Kucken, Darlene
Sent: Tuesday, March 03, 2015 10:47 AM
To: Georgoulias, Bethany; Pickle, Ken
Cc: Herbert, Laura C; King, Melissa
Subject: Borg Warner NCG030075
All,
Melissa King and I conducted an inspection at the Borgwarner facility on 2/25 in response to a request for:
1. Representative Outfall Status, and 2. Relief from Tiered sampling for Zinc and Copper.
I found their SWPPP in very good condition, the plant itself is spotless, and there is nothing inside or outside of the plant
that I noted that seems to be impacting the Zinc and Copper levels. Matthew Wallace of amec is their engineer and he
has done some very thorough investigation both inside and outside the facility. They magnet and wet mop their floors
constantly every day, have filters on in -plant vents that get changed frequently, clean sweep the loading dock area, and
are currently building a galvanized covered roof for the open top dumpsters which collect chips and turnings. Note that
they also have a Thermal Oxidizer for on -site destruction of.process coolant and mop water. In addition, Matthew is
conducting an assessment of Zn and Cu levels in rainwater and he is finding that natural rainwater has elevated levels ofi
With the above in mind, I'd like to recommend the following:
1. Document in the SWPPP outlets #4, 5, 6 and 7 but not require analytical monitoring. These outlets are totally
from grassed areas and parking lots and are not connected to any processing.
2. Agree that Outfails #2 & 3 are representative of each other and given that outfall #3 has higher values, only
require analytical sampling on #3. There is a small corner of the building that has a new galvanized roof that
does not have any coating material on it. They believe the new roof is the culprit and from what I gathered from
the site, I would agree this is likely. Both outfall #2 & 3 drain this roof and the loading dock area.
3. Since the levels of Zn and Cu continue to be elevated and they have investigated everything they can, I suggest
we either: .
a. tell them to continue tiered sampling of just outfalls #1 & #3 for some period of time to see what happens to
the levels as the new roof ages and the loading dock roof is installed, OR
b. give them relief from tiered sampling and just have them continue normal sampling at outfalls #1 & #3 only
(dropping requirements for outfalls 4,5,6 and 7 as noted above and to allow outfall #3 to be representative of
both #2 and 3). My recommendation is option b.
Please ,let me know if you have any questions and I will prepare an inspection report and letter based on your input.
Thanks so much!
Darlene Kucken - [e-mail]
North Carolina Dept. of Environment and Natural Resources

. II
Asheville Regional Office
Division of Energy, Mineral, and Land Resources
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
may be disclosed to third parties.
`�j Go Green! Print this email only when necessary. Thank you for helping NCDENR be environmentally responsible.