NCS000040_Tier Relief Letter_20200527 (2)

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
BRIAN WRENN
Acting Director
NORTH CAROLINA
Environmental Quality
May 27, 2020
Charlotte Pipe & Foundry Co.
Attention: David Waggoner, Contact Person
1335 South Clarkson Street
Charlotte, North Carolina 28208
Subject: Relief from Monthly Monitoring
Stormwater Permit # NCS000040
Charlotte Pipe & Foundry Co.
Mecklenburg County
Dear Mr. Waggoner:
We are in receipt of your 2019 / 2020 TSS / Metals monitoring study and your April
28, 2020 email requesting next steps at the Charlotte facility. Based on a May 21, 2020
site inspection, the facility is in compliance with the tiered response actions and other
conditions of the NCS000040 Permit. Therefore, the Division is granting regulatory relief
from the Tier responses based on the condition that the TSS Abatement / Best'
Management Plan be continued and that quarterly reports documenting maintenance be
submitted to this office. Upon receipt of this letter, the subject facility may resume the
permit specified semi-annual analytical monitoring at outfalls A, B and C for the remainder
of the current permit term which expires on January 31, 2024. This decision applies to all
the permitted benchmarks. Please update your SWPP plan to reflect outfalls A, B & C as
representative for the site industrial activities.
You must notify this office, in writing, within five business days if you become
aware of any other significant source of TSS / Metals at your facility that have the
potential to be exposed to stormwater. The relief granted in this letter is contingent
upon the current industrial practices at Charlotte Pipe & Foundry Charlotte facility.
Please retain and append this letter to your Stormwater Pollution Prevention Plan
(SPPP) or permit. If you have any questions or comments concerning this letter, please
contact James Moore or me at 704-663-1699.
D E North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
Mooresville Regional Office 1 610 East Center Avenue. Suite 301 1 Mooresville. North Carolina 28115
rooatH cu��u '.
704.663.1699

Letter of Approval with Modifications
Charlotte Pipe & Foundry Company
May 27, 2020
Page 2 of 2
Sincerely,
�L S-. lc�
Zahid S. Khan, CPM, CPESC, CPSWQ
Regional Engineer
Land Quality Section
Enclosure: Inspection Report
cc: Stormwater Laserfiche File NCS000040

Compliance Inspection Report
Permit: NCS000040 Effective: 02/05/19 Expiration: 01/31/24 Owner: Charlotte Pipe & Foundry Co
SOC: Effective: Expiration: Facility: Charlotte Pipe & Foundry Company - Cast Iron
County: Mecklenburg 1335 S Clarkson St
Region: Mooresville
Charlotte NC 28208
Contact Person: David Waggoner Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 05/21/2020
Primary Inspector: James D Moore
Secondary Inspector(s):
Entry Time 11:30AM
Reason for Inspection: Follow-up
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Certification: Phone:
Exit Time: 12:15PM
Phone: [phone]
Inspection Type: Technical Assistance
Page 1 of 3

permit: NCS000040 Owner - Facility: Charlotte Pipe & Foundry Co
Inspection Date: 05/21/2020 Inspection Type : Technical Assistance Reason for Visit: Follow-up
Inspection Summary:
Based on the inspection and a review of 1) outfalls to be representative and 2) TSS abatement plan and record keeping /
reporting it is recommended that outfalls & B and C be representative for the site and that semi-annual monitoring be
initiated on the condition that quarterly reports be submitted regarding TSS abatement and maintenance Please email the
reports to [e-mail].
Page 2 of 3

permit: NCS000040 Owner - Facility: Charlotte Pipe & Foundry Co
Inspection Date: 05/21/2020 Inspection iype : Technical Assistance Reason for Visit: Follow-up
Page 3of3

BEST MANAGEMENT PRACTICES
Outfall
Impacted
Location
BMP Descriptio '
Sweeping outside areas of foundry
Appr
Outfall A
Foundry Areas draining to
Continuous
SWO W
Outfall A
Foundry Areas draining to
Implemented policy that as galvanized metal siding is
2013
SWO W
replaced, galvanized aluminum siding will be used
Outfall A
Behind Pipe Storage
Installed sock insert at storm culvert: Behind Pipe Storage
Nov 2018
(swig)
Outfall A
Product Storage
Cover Product Storage Areas
Not Feasible
Outfall 8
Foundry Areas draining to
Sweeping outside areas of foundry
Continuous
Outfall B
Outfall B
Melt
Sweep up dustings around the Cupola baghouse
Continuous
Outfall B
Melt
Operation & Collection of Dust in Cupola Baghouse
Continuous while in
Operation
Outfall B
Hot Dip
#2 & #3 Hot Dip Collection Totes relocated to be within
2008
the building
Outfall B
Hot Dip
Sump from Hot Dip Main Storage Tank piped to WWTP for
2008
treatment
Outfall B
Melt
Sumps from Coke Unloading piped to WWTP for treatment
2009
Outfall B
Melt
Sumps from Additives Handling piped to WWTP for
2010
treatment
Outfall B
Melt
Sumps from Charging System and ground area around
2010
charging area piped to WWTP for treatment
Outfall B
Foundry Areas draining to
Implemented policy that as galvanized metal siding is
2013
Outfall B
replaced, galvanized aluminum siding will be used

BEST MANAGEMENT PRACTICES
BMP Descrptio
Outfall B
E-Coat Process
Started e-coating fittings; more rust -resistant therefore
June 2013
less rust present on stored fittings product
Outfall B
Melt
Dust Supression - Water Spray on charging system to keep
2013
metallics from drifting to areas where run-off will go to
stormwater
Outfall B
Melt
Dust Supression - Water Spray in scrap yard to keep
Jan 2015
metallics contained to that area where run-off will go to
WWTP for treatment
Outfall B
Foundry Areas draining to
Installed filter inserts into storm drains: Corner of Office
Nov 2018
Outfall B
Bldg (SW1), Hot Dip Lean -To (SW2)
Outfall B
Main Gate/E-coat
Installed sock insert into storm culvert: Outside E-coat
Nov 2018
(SW18)
Outfall B
Scrap Yard
Cover Scrap Yard
Not Feasible
Outfall B
Product Storage
Cover Product Storage Areas
Not Feasible
Outfall B
Other Foundry Areas
Treat Stormwater
Not Feasible
draining to Outfall B
Outfall C
Foundry Areas draining to
Sweeping outside areas of foundry
Continuous
Outfall C
Outfall C
Foundry Areas draining to
Operation & Collection of Dust in Baghouses associated
Continuous while in
Outfall C
with HWS, NPF and Rolocast areas
Operation
Outfall C
NPF
Sweep dustings around the HWS, NPF and Rolocast
Continuous
baghouses sand handling collection bins

BEST MANAGEMENT PRACTICES
Outfall
'
Impacted I
Location
Waste Area
a BMP Descriptio '
Installed building to cover Waste Aggregate Area
Approved
2009
Outfall C
Outfall C
NPF
Dust Supression - Covered NPF & Rolocast baghouse dust
2012
collection boxes
Outfall C
NPF
Dust Supression - Covered HWS baghouse dust collection
Feb 2018
boxes
Outfall C
Foundry Areas draining to
Installed filter inserts into storm drains: Oil house (SW6),
Nov 2018
Outfall C
NPF Bagouse (SW7), Sand Lab (SW8), 3 hill @ gas pumps
(SW9, SW10, SW11), HWS Baghouse (SW12), Top of Hill
(SW17)
Outfall C
Core Storage
Cover Core Storage Areas
Not Feasible
Outfall C
Hill
Cover roll -off bins
Not Feasible
Outfall C
Foundry Areas draining to
Treat Stormwater
Not Feasible
Outfall C
Misc Areas
Facility -Wide
Sweeping outside areas of foundry
Continuous
Misc Areas
Facility -Wide
Dust Supression - Covered facility -wide baghouse dust
Continuous
collection boxes
Misc Areas
Facility -Wide
Sweep dustings around all baghouse collection bins
Continuous
Misc Areas
Facility -Wide
Operation & Collection of Facility -Wide Baghouses
Continuous while in
Operation
Misc Areas
Gun Drill
Collect Compressor Condensate in a Tote that is carried to
Continuous
WWTP for treatment

BEST MANAGEMENT PRACTICES
Outfall
Impacted
BMP Descriptio
p
Misc Areas
Facility -Wide
Implemented policy that as galvanized metal siding is
2013
replaced, galvanized aluminum siding will be used
Misc Areas
WWTP
Required the feldspar delivery truck to place catch pans
Feb 2014
under hopper bottoms to catch potential leaks
Misc Areas
Rolocast
Rolocast Office AC Condensate collected and taken to
Sep 2014
WWTP for treatment
Misc Areas
Rolocast
Dust Supression - Replaced Silo Bin Vent with ductwork to
Feb 2018
vent through baghouse for better capture
Misc Areas
Shell Core/NPF
Installed filter inserts into storm drains: Kitchen Alley side
Jun 2018
(SW13, SW14, SW15), Alley @ Pattern Shop (SW16)
Misc Areas
Rolocast
Installed filter inserts into storm drains: Corner of
Oct 2018
Substation & Rolo Laempe (SW4), Corner of Substation &
Rolo Electr Rm (SW5)
Misc Areas
WWTP
Installed filter inserts into storm drain: Water Treatment
Nov 2018
(SW3)
Misc Areas
Foundry Areas draining to
Treat Stormwater
Not Feasible
Misc Areas

Date of Completion
Continuous
2013
Dec 2018
Not Feasible
Continuous
Continuous
Continuous while in
Operation
2008
2008
2010
2011
2011
2013

Date of Completion
June 2013
2014
Mar 2015
Dec 2018
Dec 2018
Not Feasible
Not Feasible
Not Feasible
Continuous
Continuous while in
Operation
Continuous

Jul 2010
2012
Feb 2018
Nov/Dec2018
Not Feasible
Not Feasible
Not Feasible
Continuous
Continuous
Continuous
Continuous while in
Operation
Continuous

Date of Completion
2013
Mar 2014
Oct 2014
Aug 2018
Jun 2018
Oct 2018
Nov 2018
Not Feasible

Stormwater Insert Schedule
ID# Location Change Schedule Mar-20 Apr-20 May-20 Jun-20 Jul 20 Aug-20 Sep-20 Oct-20
SW1 Corner of Office Building 1/yr x
SW2 Behind Slag Pile 1/grtr x
SW3 Water Treatment 1/6m x
SW4 Corner of Substation & Rolo Laempe 1/6m x
SW5 Corner of Substation & Rolo Electr Rm 1/6m x
SW6 Oil House 1/6m x
SW7 NPF Baghouse 1/grtr x
SW8 Sand Lab 1/grtr x
SW9 Oil House Hill 1/6m x
SW10
Middle Oil House Hill
1/6m x
SW11
Gas Pump
1/6m x
SW12
HWS Baghouse
1/grtr x
SW13
Alley @ HWS & Bath House
1/grtr x
SW14
Alley @ Kitchen
1/grtr x
SW15
Alley @ Cope & Drag
1/mo x x x
SW16
Alley @ Pattern Shop
1/mo x x x
SW17
Top Hill
1/yr
SW18
E-Coat
1/yr x
SW19
Behind Pipe
1/yr

Nov-20 Dec-20

Summary of Analytical Monitoring Results
Bench-jini.L.
2018
Ol/2019
06/2019
10/2019
03/2020
Filter
Post Filter
Post Filter
Post Filter
Post Filter
Markques�m
MR,q ,"E
ASRryuesled
AS Requesed
AS Requesed
Cu
0.01009
0.005
0.030
0.006
0,012
Pb
0.075054
ND
0.009
ND
0.010
Zn
0.126138
0.076
0,048
0.110
0.147
TSS
1001.0
51.6
22.2
20.8
55
PH
6-9.8
5,2
5.3
52
8.6
COD
1208.9
NO
ND
41.2
60
Total Rainfall1.8
1.2.4
1.0
1.8
0.5
Bench-
10/2018
01/2019
06/2019
10/2019
03/2020
.,. No Filter
No Filter
Pre -Filter
Pre -Filter
Pre -Filter
Requested
ASRequested
ASRequested
as flequuted
ASRequested
Cu
0.01
mg/L
: 0.024
0.007
0.OG6
0.006
OA15
Pb
0.075
mg/L
0,033
0.0091
0.010
0.007
0.028
Zn
0.126
mg/L
0.553
0.120
0.099
0.095
0.203
TSS
100
mg/L
108
34.5
43.6
36.9
66
pH
6-9
7.2
6.7
6.2
5.8
8.7
COD
120
mg/L
103
32.5
ND
29.3
55
Total Rainfall
in
1.8
1.24
1.0
1.8
0.5
Bench-
10/2018
01/2019
06/2019
10/2019
03/2020
""' , " """"
No Filter
No Filter
Post Filter
Post Filter
Post Filter
AS Reque4etl
ASRequested
ASRequested
ASRequested
ASRequested
Cu
0.01
mg/L
0.009
0.012
0.006
0.932
0.016
Pb
0.075
mg/L
0.01
0.014
0.010
0.124
0.027
j Zn
0.126
mg/L
0.223
0. 210
0.096
1.27
0.216
TSS
100
mg/L
31
125
24.6
1640
111
PH
6-9
7.6
5.4
5.4
6.2
8.8
COD
120
mg/L
44-2
531
NO
19311
87.7
Total Rainfall
in
1.8
1 1.24
1.0
1.8
0.5
Bench-
10/2018
O1/2019
0612019
10/2019
03/2020
'•-"'^"t^'�"•-"'•''^s^'_"'
"^
Pre -Filter
Pre -Filter
Pre -Filter
Post -Filter
Pre -Filter
Post -Filter
Pre -Filter
Post -Filter
_
AZ Requested
AS Requesletl
AS Requesed
ASRequested
ASRequested
ASRequested
MR,SrI
ASRepu Md
ND
ND
ND
ND
ND
ND
ND
ND
Oil & Grease
15
mg/L
Cu
0.01
mg/L
0.023
0.016
ND
0,006
0.035
0,014
0.039
0.132
Pb
0.075
mg/L
0.023
0.014
ND
0.005
0.040
0.010
0.035
0.134
Zn
0.126
mg/L
0.651
0,372
0.404
0307
0.356
0.577
0.652
0.657
TSS
100
mg/L
178
88.3
15.9
27.0
238
14.0
317
836
PH
6-9
7.2
6.4
5.5
5.8
6.0
5.2
9.0
8.7
COD
120
mg/L
156
80.9
ND
1 202
117
60.1
232
678
Total
Rainfall
in
1.8
1.24
1.0
1.8
0.5
10/2018
01/2019
0612019
10/2019
03/2020
Requested
AS Requened
AS Rrqufszed
ASRequested
ASRequested
Oil & Grease
15
mg/L
ND
Cr
-
mg/L
ND
Cu
0.01
mg/L
NO
Pb
0.075
mg/L
ND
Ni
-
mg/L
ND
Zn
0.126
mg/L
0.013
TSS
100
mg/L
ND
PH
6-9
5.6
4.3
5.6
TKN
-
mg/L
ND
Phenols
-
mg/L
0.014
COD
120
mg/L
ND
Total
Rainfall
in
1 A
LR
0 c