NCG030301_Correspondence RE Zn and Cu Evaluation_20210629

Georgoulias, Bethany
From: Georgoulias, Bethany
Sent: Tuesday, August 17, 2021 3:57 PM
To: Georgoulias, Bethany
Subject: FW: [External] Benchmark exceedance re-eval.
Attachments: NCDNR Re-evaluation letter (6-25-21).docx
Correspondence from permittee to WaRO for record.
From: Daniel Hammon <[e-mail]>
Sent: Tuesday, June 29, 2021 12:06 PM
To: Moore, Bill <[e-mail]>
Subject: [External] Benchmark exceedance re-eval.
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Mr. Moore,
Good afternoon. I hope things are going well. You visited our facility in 2018 if I am not mistaken. At that time we were
having difficulties staying below the benchmark for copper and zinc. You were able to get those benchmarks raised.
Since then we have been up and down still with copper and zinc. For the last two samples, (12/20) and (6/21) our copper
levels have been within specs. But we continue to have samples where our Zinc levels are slightly elevated. In the
attachment You will see what measures we have taken to try and make sure that we are doing all we can to get within
specs. I do not know if we can get another eval for Zinc only? Please let me know your thoughts. I am open to
suggestions as to how we can get this under control. Thanks for your input.
Best regards,
Danny Hammon
AP Emissions Technologies, LLC
EH&S Manager
919-580-1940 Office
919-394-4454 Cell
[e-mail]
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mma;
EMISSIONS TECHNOLOGIES'
Bill Moore
Environmental Engineering
Energy Mineral and Land Resources
Subject: Request re-evaluation of the benchmark levels for Zinc
AP Emissions Technologies, LLC Goldsboro NC 27530
General Permit NCG030000, Permit # NCG030301
Wayne County North Carolina
The purpose of this letter is to request re-evaluation of our Benchmark level for Zinc.
In September 2016, the roof on our Manufacturing Building was damaged when Hurricane Matthew
struck North Carolina. Two sections of the roof caved in causing severe damage to the building and
contents. The roof was repaired, and operations resumed.
In Dec. 2016 storm water samples were taken for the second time that year. The lab report indicated
that copper and zinc had exceeded our benchmark levels. Because this was the second sample that
exceeded benchmark levels, we immediately started searching for the cause of these exceedance levels.
We cleaned our parking lot, thew away old equipment that had been sitting in our SE corner of the
parking lot. We entered Tier II. In the spring of 2017, we again took samples for Copper and Zinc. And
again, we exceeded benchmark levels.
We entered the Tier III response level, and we took the following measures:
Inspected and cleaned Storm water catch basins
Covered scrap containers
Moved one scrap container in house
Our manufacturing plant recycles all of its scrap steel as well as all used lubricants, hydraulic fluids, and
dirty mop water. We do not have any stacks emitting anything to the outside.
Since the hurricane, our samples have at times exceeded levels and at other times been below
benchmark levels. We have been able to drop our copper levels. We took samples in Dec. 2020 and June
2021. Both times the copper levels were within specs. But the Zinc was slightly elevated.

The benchmark for Zinc was changed in 2018 to 0.126. Here are the lab results for the last two samples:
Dec. 2020 Outfall #3 Outfall #5
0.139 0.268
June 2021 0.140 0.130
We have taken the following measures for June 2021:
Removed all old equipment from the parking lot.
We are in the process of removing all old baskets, tables, and other things that have been stored
outside.
Filling in potholes
Sending all unused trailers back to the vendors.
Changing to a new style trash compactor that is totally enclosed.
Disposing of all used plastic drums.
We recycle all scrap steel, used oil, dirty mop water, and used oils
I am open to suggestions if the benchmark cannot be raised. I do appreciate your time concerning this
matter.
Best regards,
.Dan W oV aminon
Danny Hammon
EH&S Mgr.
AP Emissions Technologies, LLC
919-580-1940