NCG030075_Email to ARO RE Tier Status_20210830

Georgoulias, Bethany
From:
Reed, Isaiah L
Sent:
Monday, August 30, 2021 3:48 PM
To:
[e-mail]
Cc:
[e-mail]; [e-mail]; Wallace, Matthew E; Hutchins,
Gregory; [e-mail]; [e-mail]; Georgoulias, Bethany;
Aiken, Stan E; Smith, Mike M; McCoy, Suzanne
Subject:
RE: [External] August Stormwater
Mr. Martindale,
I am no longer with the Division of Energy Mineral and Land Resources. I have copied the Asheville and Central Office
staff that would be best to contact with further questions.
I apologize for the confusion.
Isaiah Reed, Ell, CPSWQ, MS4CEC1
Asheville Regional Office — Environmental Engineer
Division of Water Resources — Public Water Supply
North Carolina Department of Environmental Quality
828-296-4581 office
828-545-3024 mobile
[e-mail]
2090 U.S. Highway 70
Swannanoa, NC 28778
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From: [e-mail] <[e-mail]>
Sent: Friday, August 27, 2021 5:26 PM
To: Reed, Isaiah L <[e-mail]>
Cc: [e-mail]; [e-mail]; Wallace, Matthew E <[e-mail]>;
Hutchins, Gregory <[e-mail]>; [e-mail]; [e-mail]
Subject: [External] August Stormwater
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Isaiah,
On August 18, we received the results of the August stormwater sampling event. DMRs were uploaded and copy sent to
your Regional office. Zinc, copper, and chemical oxygen demand (COD) exceeded the benchmark values at OF-1 and OF-
3.

Notification
The new permit states the previous permit's Tier Two and/or Three response status roll over into the new permit. Per
the new Tier (One and Three) two -week notification requirements, below is a status of the current tiered conditions:
• Tier One response for COD at outfalls OF-1 and OF-3
• Tier One response for zinc at outfall OF-1
• Tier One response for copper at outfall OF-1
• Continued Tier Three response for zinc and copper at OF-3
Stormwater Management Inspection and Program Review 8-26-2021 and 8-27-2021
• Minor oil and grease on pavement from back dock and shipping dock operations
• Some scrap metal (mainly ferrous) under back dock roof extending into the elements
• Scrap hopper of fans from plastics molding operation free of chemicals and oils
• Scrap Hopper with Turbos — outside (no oils or chemicals)
• Outside storage of new pallets and plastic dunnage free of chemicals and oils
• No outside storage of chemicals, most chemicals are under roof and outside coolant is under cover and drains to
separate system
• Only chemicals stored outside are gasses (e.g., propane, 02, N2, Ar)
• We have been sampling and mitigating for years for Cu and Zn at both outfalls with limited success
o Roof coating on -going, roof at back dock needs paint coating of remaining 20%
• Drainage ditch inlet erosion — already being quoted
Possible causes
• Roofs
o Upstream sampling necessitated evaluation of gutters and roof run-off since their Zn/Cu values were
higher than surface run-off
■ Zn and Cu — older metal roof on back dock 80% painted — check feasibility of painting remaining
20% of unpainted section
■ HVAC condensate? however, does not drain to back dock roof
■ Drain downspouts to
o No COD sources identified
• Surface run-off
o Chemicals outside are drained away from stormwater and under roof — sampling may identify sources
o Downspouts have higher Zn ad Cu as opposed to direct run-off
o Remove emptied paint buckets and hopper with scrap turbos from outside Tech Center
o Drain fuel pad containment — goes to wastewater— not an isssue
• Ground
o Old galvanized stormwater pipe
■ Outfall #4 pipe replaced in 2021 for corrosion
■ Highest concentrations of Zn and Cu come from roof (upstream of the storm drain) so not the
likely source
Tier One Response (OF-1 COD/Zn/ Cu; OF-3 COD)
i. Document exceedance - Attached
ii. This e-mail notification to Division's Regional Office
iii. Inspection Complete
iv. Possible causes — (see above)
a. There are very few industrial activities associated or near OF-1
b. Roof painting at Tech Center accomplished in 2018 with positive effects
c. Unknown COD
sources
Fil

Tier Three Response (OF-3 Zn/Cu)
i. Document exceedance - Attached
ii. Monthly monitoring - complete
iii. Notification to Regional Office in writing - USPS certified written copy pending (please advise if there is a
NCDEQ form to complete now or in future)
iv. Stormwater Inspection - Complete
V. Possible causes of benchmark exceedances (see above)
a. Back dock activity is mostly under roof to manage scrap Aluminum, Cast Iron, Titanium and their
coolants
i. Zn and Cu are not used in production
ii. Some brass fittings and copper wire in Assembly, but no machining or scrap generated in
quantity
b. Upstream sampling indicated roof as source for Zn and Cu rather than surface runoff
c. Back dock roof painted in 2021— some small portions pending
vi. Looks like we will continue to identify sources and submit a plan to you for your approval within the next
two weeks. We can review any additional details on -site or at your convenience.
Side Note:
Representative Outfall Status (ROS) Renewal Certification Form
We noticed a new requirement for re -applying our representative outfall status which we were granted in 2015 (OF-3
represents OF-2). The ROS Recertification Form was completed and the original letter allowing ROS in 2015 uploaded to
the Laserfiche address (Suzanne McCoy) and attached.
Regards,
Jack Martindale, CSP CHMM
EHS Manager
Emissions, Thermal & Turbo Systems
BorgWarner
1849 Brevard Road
Arden, NC 28704
Tel: [phone]
Cell: [phone]
jmartindale(cDborgwarner.com

Table 3: Tier One Response fora Benchmark Exceedance
Timeline From
Receipt of
Tier One Required Response/Action
Sampling Results
Continuously
i. Document the exceedance and each required response/action in the
SWPPP in accordance with E-5(b) above.
Within two weeks
ii. Notify the Division's Regional Office of the exceedance date and value
via email or, when it is developed, an electronic form created by the
Division for reporting exceedances.
iii. Conduct a stormwater management inspection.
iv. Identify and evaluate possible causes of the benchmark exceedance.
Within one month
v. Select specific, feasible courses of action to reduce concentrations of
the parameter(s) of concern including, but not limited to, source
controls, operational controls, or physical improvements.
Within two months
vi. Implement the selected feasible actions.
Table S: Tier Three Response for Four Benchmark Exceedances Within the Permit Term
Timeline From
Receipt of Fourth
Tier Three Required Response/Action
Sampling Result
Continuously
i. Document the exceedances and each required responselaction in the
SWPPP in accordance with E-7(c) above.
ii. Implement or continue monthly monitoring for all parameters at the
subject outfall and continue until three samples in a row are below the
benchmark valu e.
Within two weeks
iii. Notify the division's Regional Office in writing of the affected outfall,
four exceedance dates and values.
iv. Conduct a stormwater management inspection.
v. Identify and evaluate possible causes of the benchmark exceedance.
Within one month
vi. Preparean Action Plan that should include specific, Feasible courses of
action to reduce concentrations of the parameters) ofconcern
including, but not limited to, source controls, operational controls, or
physical improvements and submit to the Division's Regional Office
for review and approval.
Upon DEQ Approval
Al. Implement the approved Action Plan.
Upon Completion of
Approves! Action
viii. Notify the Division's Regional Office of Action Plan completion.
Plan