NCG030293_Monitoring Report_20211105

/ SHIELD
ENGINEERING
November 3, 2021
Zahid Khan
Regional Engineer, Land Quality Section
Energy, Mineral, and Land Resources
North Carolina Department of Environmental Quality
Mooresville Regional Office
610 East Center Avenue, Suite 301
Mooresville, North Carolina 28115
[e-mail]
Subject: Tier Three Action Plan, Third Quarter 2021
Circor Pumps North America, LLC — Monroe, NC
Certificate of Coverage NCG030293
Dear Mr. Khan,
On behalf of Circor Pumps North America, LLC (Circor) — Monroe facility, Shield Engineering,
Inc. has prepared and is submitting the attached Tier Three Action for your approval in accordance
with NPDES Industrial Stormwater Permit NCG030000, Part E for Third Quarter, 2021. The
cover page of the report contains the required certification by Circor' s responsible official.
Analytical data received this week from the contract laboratory indicates compliance with the
Copper benchmark for the October sampling event. If you have any questions regarding this Action
Plan, please contact us at [phone] or Richard Mirecki with Circor at
[e-mail].
Sincerely,
SHIELD ENGINEERING, INC.
Melind . Greene
Senior Engineer
Magdaline M. Tzannis
Senior Project Manager
ATTACHMENTS
cc: Richard Mirecki, Circor
James Moore, NCDEQ Mooresville
Robert L. Griffin, P
President/CEO
4301 Taggart Creek Road www.shieldenaineering.com Telephone [phone]
Charlotte, NC 28208 License No. F-0856

/ 1
CIRCOR
l/
Circor Pumps North America, LLC
1710 Airport Road
Monroe, North Carolina
Certificate of Coverage NCG030293
Tier Three Action Plan, Third Quarter 2021
In compliance with General SW Permit NCG030000, Part E-7
Prepared by:
SHIELD
ENGINEERING
4301 Taggart Creek Road
Charlotte, NC 28208
Shield Project No. 1150109-17
November 1. 2021
s
I certify by my signature below, underpenalty 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.
J� 1113
Stephen Mahoney Date

CIRCOR Pumps North America, LLC — Monroe, NC Page 1
Tier Three Response Action Plan November 1, 2021
Facility
CIRCOR Pumps North America, LLC NCG030293
SDO
004
Parameters
Copper
Date Prepared
11/1/2021
INTRODUCTION
This Action Plan has been prepared in accordance with Part E-7(b) of General Permit for
benchmark exceedances which have triggered Tier Three Response. Tier Three status for
Copper at Outfall 004 has carried over from the previous General Permit. CIRCOR has made
progress towards addressing benchmark exceedances at Outfall 004 as evidence by the Zinc
concentrations during the previous permit term. Zinc exited Tier 3 at Outfall 004 during the
previous permit monitoring as there were only 2 exceedances of Zinc during that permit term. This
Action addresses Copper Tier Three Response.
ACTION PLAN ELEMENTS
The General Permit, Part E-7(b), requires specific elements be addressed. Each of these
elements are being addressed as follows:
i. Documentation of the Four Benchmark Exceedances
The table below documents the last 4 benchmark exceedances for Copper at Outfall 004 for
CIRCOR.
Copper benchmark = 0.010 mg/1
Outfall
Month
9/2021
5/2021
3/2021
9/2020
004
0.0118
0.020
0.012
0.012
ii. An Inspection report that covers the industrial activities within the drainage area of the
outfall with the exceedances (including the date of the inspection and the personnel
conducting the inspection)
See attached inspection report. The inspection covered all areas of industrial activity in the
drainage areas that drain Outfall 004 as well as Outfall 005. Roof stacks and vents associated
with potential airborne sources of pollutants (welding, painting, forklift recharging, blast room,
container and waste storage) are all located near the rear walls or east walls, thus associated
with Outfall 004.
The inspection report notes areas of concern observed as having the potential to contribute to
benchmark exceedances. A site map is attached for reference of the drainage area.
ill. An evaluation of standard operating procedures and good housekeeping procedures
CIRCOR has evaluated its standard operating procedures applicable to the potential for pollutants
to reach stormwater as well as its good housekeeping procedures related to industrial activities

CIRCOR Pumps North America, LLC — Monroe, NC Page 2
Tier Three Response Action Plan November 1, 2021
in the drainage area for SDO 004. Any recommendations for improvements in these activities are
described in the attached inspection report or in (v) below.
iv. Identification of the source(s) of exceedances
CIRCOR has identified sources that may be contributing to the exceedances. The following
causes have a high potential to effect Copper concentrations in stormwater discharged from
Outfall 004 and contribute to benchmark exceedances:
Potential Cause of
Location(s)
Potential
Outfall(s)
Benchmark Exceedance
Pollutant
Affected
Metal Materials
South side on asphalt
Copper
004
Welding Electrodes
Fugitive exhaust from
Copper
004
East side of building
Marine Anti -fouling
Roof vent from paint
Copper
004
Coatings
booth
Cumulative Effect from
Outdoor Asphalt
Copper
004
Vehicle Brake Pad
Pavement
Deposits
v. Specific actions that will be taken to remedy the identified source(s) with a schedule
for completing those actions
Shield believes that implementing a sweeping program and focusing on enhanced housekeeping
will assist CIRCOR in making progress towards meeting the benchmark.
ACTIONS SELECTED FOR IMPLEMENTATION BY SITE
SCHEDULE FOR
COMPLETION'
1. Engage contractor to sweep site.
Initial engagement with
potential contractor has begun
the week of November 1.
2. Implement routine sweeping of site.
The contractor is expected to
initiate sweeping in December
2021. Sweeping will continue
on a biweekly basis.
' The dates provided are target dates and may change due to reasons beyond CIRCOR's control such as contractor personnel
issues or availability.
vi. A monitoring plan to verify that the Action Plan has addressed the source(s).
CIRCOR will attempt to sample SDO 004 at least monthly until three consecutive samples for
Copper are below the benchmark value. In the event a sample cannot be collected during a
month, record documentation as to why a sample could not be collected. CIRCOR will continue
routine facility inspections to ensure the effectiveness of the implemented actions and identify any
new potential causes or contributors to the benchmark exceedances.
ATTACHMENTS:
Stormwater Management Inspection (Copper, Outfall 004)
Site Map

Stormwater Management Inspection Report (Tier Response)
Facility
CIRCOR
Parameter Exceedance
Copper
SDO
004
Date of Sample
9/21 /2021
Date Received from Lab
10/6/2021
Date NC DEQ Notified
10/18/2021
Notification Method
Email & Hardcopy/Priority Mail
Benchmark
0.010 m /I
Lab Result
1 0.0118 m /I
Date/Time of SW Inspection
9/21/2021 1:50pm
Weather during Inspection
Clear, 880
Inspector(s)
M Tzannis Shield
Areas Inspected
Drainage Area for SDO 004 where industrial activity occurs: See attached ma
Areas of Concern
POTENTIAL SOURCE
POTENTIAL IMPROVEMENTS
GENERAL HOUSEKEEPING
There is a potential for airborne sources of
1.
Develop and implement sweeping
pollutants from welding and metal storage to
program for site. Have contract
contribute to the benchmark exceedances
sweepers to collect fine dust and debris
based on a review of electrode SDS and the
from asphalt.
site inspection. Welding pollutants are
2.
Encourage good housekeeping as a
fugitive and exhausted through general
part of a daily and/or weekly routine.
building ventilation and open doors. Metal
stock/raw materials are stored on the south
side of the building.
*Source controls, operational controls or physical improvements

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SHIELD
ENGINEEPUNG
November 3, 2021
Zahid Khan
Regional Engineer, Land Quality Section
Energy, Mineral, and Land Resources
North Carolina Department of Environmental Quality
Mooresville Regional Office
610 East Center Avenue, Suite 301
Mooresville, North Carolina 28115
[e-mail]
Subject: Tier Three Action Plan, Third Quarter 2021
Circor Pumps North America, LLC — Monroe, NC
Certificate of Coverage NCG030293
Dear Mr. Khan,
On behalf of Circor Pumps North America, LLC (Circor) — Monroe facility, Shield Engineering,
Inc. has prepared and is submitting the attached Tier Three Action for your approval in accordance
with NPDES Industrial Stormwater Permit NCG030000, Part E for Third Quarter, 2021. The
cover page of the report contains the required certification by Circor' s responsible official.
Analytical data received this week from the contract laboratory indicates compliance with the
Copper benchmark for the October sampling event. If you have any questions regarding this Action
Plan, please contact us at [phone] or Richard Mirecki with Circor at
[e-mail].
Sincerely,
SHIELD ENGINEERING, INC.
i
Melind . Greene
Senior Engineer
Magdalene M. Tzannis
Senior Project Manager
ATTACHMENTS
cc: Richard Mirecki, Circor
James Moore, NCDEQ Mooresville
4301 Taggart Creek Road www.shieldengineering.com Telephone [phone]
Charlotte, NC 28208 License No. F-0856

CIRCOR
Circor Pumps North America, LLC
1710 Airport Road
Monroe, North Carolina
Certificate of Coverage NCG030293
Tier Three Action Plan, Third Quarter 2021
In compliance with General SW Permit NCG030000, Part E-7
Prepared by:
SHIELD
ENGINEERING
4301 Taggart Creek Road
Charlotte, NC 28208
Shield Project No. 1150109-17
November 1, 2021
s
I certify by my signature below, under penalty of law, that this document and all attachments were
prepared under my direction orsupervision 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.
Stephen Mahoney Date

CIRCOR Pumps North America, LLC - Monroe, NC Page 1
Tier Three Response Action Plan November 1, 2021
CIRCOR Pumps North America, LLC NGG030293
-Facility
SDO
004
Parameters
Copper
Date Prepared
11/1/2021
This Action Plan has been prepared in accordance with Part E-7(b) of General Permit for
benchmark exceedances which have triggered Tier Three Response. Tier Three status for
Copper at Outfall 004 has carried over from the previous General Permit. CIRCOR has made
progress towards addressing benchmark exceedances at Outfall 004 as evidence by the Zinc
concentrations during the previous permit term. Zinc exited Tier 3 at Outfall 004 during the
previous permit monitoring as there were only 2 exceedances of Zinc during that permit term. This
Action addresses Copper Tier Three Response.
ACTION PLAN ELEMENTS
The General Permit, Part E-7(b), requires specific elements be addressed. Each of these
elements are being addressed as follows:
i. Documentation of the Four Benchmark Exceedances
The table below documents the last 4 benchmark exceedances for Copper at Outfall 004 for
CIRCOR.
Copper benchmark = 0.010 mg/I
outfall
Month
9/2021
5/2021
3/2021e9/2O2O004
0.0118
0.020
0.012
ii. An Inspection report that covers the industrial activities within the drainage area of the
outfall with the exceedances (including the date of the inspection and the personnel
conducting the inspection)
See attached inspection report. The inspection covered all areas of industrial activity in the
drainage areas that drain Outfall 004 as well as Outfall 005. Roof stacks and vents associated
with potential airborne sources of pollutants (welding, painting, forklift recharging, blast room,
container and waste storage) are all located near the rear walls or east walls, thus associated
with Outfall 004.
The inspection report notes areas of concern observed as having the potential to contribute to
benchmark exceedances. A site map is attached for reference of the drainage area.
ill. An evaluation of standard operating procedures and good housekeeping procedures
CIRCOR has evaluated its standard operating procedures applicable to the potential for pollutants
to reach stormwater as well as its good housekeeping procedures related to industrial activities

CIRCOR Pumps North America, LLC — Monroe, NC Page 2
Tier Three Response Action Plan November 1.2021
in the drainage area for SDO 004. Any recommendations for improvements in these activities are
described in the attached inspection report or in (v) below.
iv. Identification of the source(s) of exceedances
CIRCOR has identified sources that may be contributing to the exceedances. The following
causes have a high potential to effect Copper concentrations in stormwater discharged from
Outfall 004 and contribute to benchmark exceedances:
Potential Cause of
Location(s)
Potential
Outfall(s)
Benchmark Exceedance
Pollutant
Affected
Metal Materials
South side on asphalt
Copper
004
Welding Electrodes
Fugitive exhaust from
Copper
004
East side of building
Marine Anti -fouling
Roof vent from paint
Copper
004
Coatings
booth
Cumulative Effect from
Outdoor Asphalt
Copper
004
Vehicle Brake Pad
Pavement
Deposits
v. Specific actions that will be taken to remedy the identified source(s) with a schedule
for completing those actions
Shield believes that implementing a sweeping program and focusing on enhanced housekeeping
will assist CIRCOR in making progress towards meeting the benchmark.
ACTIONS SELECTED FOR IMPLEMENTATION BY SITE
SCHEDULE FOR
COMPLETION'
1. Engage contractor to sweep site.
Initial engagement with
potential contractor has begun
the week of November 1.
2. Implement routine sweeping of site.
The contractor is expected to
initiate sweeping in December
2021. Sweeping will continue
on a biweekly basis.
' The dates provided are target dates and may change due to reasons beyond CIRCOR's control such as contractor personnel
issues or availability.
vi. A monitoring plan to verify that the Action Plan has addressed the source(s).
CIRCOR will attempt to sample SDO 004 at least monthly until three consecutive samples for
Copper are below the benchmark value. In the event a sample cannot be collected during a
month, record documentation as to why a sample could not be collected. CIRCOR will continue
routine facility inspections to ensure the effectiveness of the implemented actions and identify any
new potential causes or contributors to the benchmark exceedances.
ATTACHMENTS:
Stormwater Management Inspection (Copper, Outfall 004)
Site Map

Stormwater Management Inspection Report (Tier Response)
Facility
CIRCOR
Parameter Exceedance
Copper
SDO
004
Date of Sample
9/21 /2021
Date Received from Lab
10/6/2021
Date NC DEQ Notified
10/18/2021
Notification Method
Email & Hardco / dority Mail
Benchmark
0.010 m /l
Lab Result
0.0118 m /l
Date/Time of SW Inspection
9/21/2021 1:50 m
Weather during Ins ection
Clear, 88°
Inspector(s)
M Tzannis Shield
Areas Inspected
Drainage Area for SDO 004 where industrial activity occurs: See attached ma
Areas of Concern
POTENTIAL SOURCE
POTENTIAL IMPROVEMENTS
GENERAL HOUSEKEEPING
There is a potential for airborne sources of
1.
Develop and implement sweeping
pollutants from welding and metal storage to
program for site. Have contract
contribute to the benchmark exceedances
sweepers to collect fine dust and debris
based on a review of electrode SDS and the
from asphalt.
site inspection. Welding pollutants are
2.
Encourage good housekeeping as a
fugitive and exhausted through general
part of a daily and/or weekly routine.
building ventilation and open doors. Metal
stock/raw materials are stored on the south
side of the building.
*Source controls, operational controls or physical improvements

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