HomeMy WebLinkAboutNCG030293_Tier 3 Action Plan_20220526CIRCOR
Circor Pumps North America, LLC
1710 Airport Road
Monroe, North Carolina
Certificate of Coverage NCG030293
f;ECEIVED
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Revised Tier Three Action Plan, Third Quarter 2021
In compliance with General SW Permit NCG030000, Part E-7
Prepared by:
SHIELD
ENCINEERING
4301 Taggart Creek Road
Charlotte, NC 28208
Shield Project No. 1150109-19
May 4, 2022
Revision Summary: Circor would like to request approval of the revised actions of the Third
Quarter, 2021 Action Plan to replace contractor sweeping of the site with the site's increased
general housekeeping practices-
/
certify by my signature below, under penalty 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.
Stephen Mahoney Date
SHIELD
ENGINEERING
May 4, 2022
Mr. 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
Zahid.Khan@ncdenr.gov
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Subject: Tier Three Action Plan, Third Quarter 2021— Revision
Circor Pumps North America, LLC — Monroe, North Carolina
Certificate of Coverage NCGO30293
Dear Mr. Khan:
On behalf of Circor Pumps North America, LLC (Circor) — Monroe facility, Shield
Engineering, Inc. (Shield) is submitting a revision to the Tier Three Action from Third
Quarter 2021, for the Tier Three exceedance of Copper. This Action Plan is attached, for
your reference.
According to the Third Quarter 2021 Action Plan, Circor's selected actions were to engage
a contractor to sweep the site and to implement routine sweeping of the site. Circor
contacted and engaged a contractor for this purpose and sweeping of the site took place
in 41h Quarter 2021. Since that time Circor has applied increased general housekeeping
practices in the areas of concern and as a result of these efforts, the site has had two
consecutive sampling events at or below the benchmark for Copper, as shown below:
Copper (benchmark = 0.010 mg/1)
Month
Mar-22
Feb-22
Jan-22
Dec-21
Nov-21
Outfall 004
0.0080
0.010
NQE 1
NQE
0.011
1 NQE = No Qualifying Event
4301 Taggart Creek Road www.shieldengineering.com Telephone 704.394.6913
Charlotte, NC 28208 License No. F-0856
Action Plan Revision
Circor Pumps NA — Monroe, North Carolina May 4, 2022
Shield Project No. 1150109-19 Page 2
Attached are Circor's Discharge Monitoring Reports (DMRs) for the months of February
and March 2022, showing that Circor met all the benchmarks for all parameters at both
outfalls.
Circor would like to request approval of the revised actions of the Third Quarter, 2021
Action Plan to replace contractor sweeping of the site with the site's increased general
housekeeping practices.
If you have any questions regarding this Action Plan, please contact us at (704) 394-6913
or Laurie Stewart with Circor at laurie.stewart@circor.com.
Sincerely,
SHIELD ENGINEERING, INC.
Magdaline M. Tzannis
Senior Project Manager
Melin . Greene
Senior Engineer
Robert L. Griffin, PE
President/CEO
ATTACHMENTS: DMRs (2.22 & 3.22) and 3rd Quarter 2021 Action Plan
cc: Laurie Stewart and Stephen Mahoney, Circor
Lily Kay, NCDEQ Mooresville
Shield EngineeringlProjects - 11S0309-17 ORCOR - Compliance Support - 202111'roject Details12021 SlormwoterVIER RESPONSE13rd a 2021
Action Plan Re -Evaluated
0 SHIELD
ENGINEERING
NCDEQ Division of Energy, Mineral and Land Resources
Stormwater Discharge Monitoring Report (DMR) Form for NCG030000
Metal Fabrication
Click here for instructions
Complete, sign, scan and submit the DMR via the Stormwater NPDES Permit Data Monitoring Report (DMRI Upload form within
30 days of receiving sampling results. Mail the original, signed hard copy of the DMR to the appropriate DEMLR Regional Offlce.
Certificate of Coverage No. NCG03 0293
Person Collecting Samples: Magdaline Tzannis /Shield Engineering Inc.
Facility Name: Circor Pumping Technologies
Laboratory Name: Pace Analytical
Facility County: Union
Laboratory Cert. No.: 329
Discharge during this period:Qyes
0No
(if no, skip to signature and date)
Has your facility implemented mandatory Tier response actions this sample period for any benchmark exceedances? Yes No
If so, which Tier (I, II, or III)? III
A copy of this DMR has been uploaded electronically via https://edocs.deg.nc.gov/Forms/SW-DMR Ej Yes Lj No
Date Uploaded:
Analvtical Monitoring Requirements for Outfalls with Industrial Activities —Benchmarks in (Red)
Parameter
Parameter
Outfall 004
Outfall 005
Outfall
Outfall
Outfall
Code
N/A
Receiving Stream Class
C
C
N/A
Date Sample Collected MM/DD/YYYY
2/4/2022
2/4/2022
46529
24-Hour Rainfall in inches
0.55
0.55
C0530
TSS in mg/L(100 or 50')
14
13
PH in standard units (6.0-9.0 FW,
7.0
7.0
00400
6.8.8.5 SW)
Copper, total recoverable in mg/L
01119
0.010 FW, 0.0058 SW)
0.010
0.010
Lead, total recoverable in mg/ L
01051
<0.010
<0.010
(0.07S FW, 0.22 SW)
Zinc, total recoverable in mg/ L (0.126
01094
FW, 0.095 SW)
0.048
0.041
Chemical Oxygen Demand (COD) in
00340
mg/L 120)
25
<20
00552
Non -Polar oil & Grease in mg/L (15)
<5.0
<5.0
' Outfalls to Outstanding Resource Waters (ORIN), High Quality Waters (HQW), Trout Waters (Tr) and Primary Nursery Areas jFNA)
have a benchmark TSS limit of 50 mg/L. All other water classifications have a benchmark of 100 mg/L
FW (Freshwater) SW (Saltwater)
Notes (optional): SOO #004 & SOO #005 meet all benchmark values for this sampling event.
"I certify by my signature below, under penalty 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."
Signature of Permittee or Delegated Authorized Individual Date
Email Address
Phone Number
NCDEQ Division of Energy, Mineral and Land Resources
Stormwater Discharge Monitoring Report (DMR) Form for NCG030000
Metal Fabrication
Click here for instructions
Complete, sign, scan and submit the DMR via the Stormwater NPDES Permit Data Monitoring Report (DMR1 Upload form within
30 days of receiving sampling results. Mail the original, signed hard copy of the DMR to the appropriate DEMLR Regional Office.
Certificate of Coverage No. NCG03 0293
Person Collecting Samples: Magdalene Tzannis /Shield Engineering Inc.
Facility Name: Circor Pumping Technologies
Laboratory Name: Pace Analytical
Facility County: Union
Laboratory Cert. No.: 329
Discharge during this period:
v
Yes
❑ No (if no, skip to signature and date)
Has your facility implemented mandatory Tier response actions this sample period for any benchmark exceedances? Yes No
If so, which Tier (I, II, or III)? III
A copy of this DMR has been uploaded electronically via httos://edocs.deg.nc.gov/Forms/"5w-DMR Q Yes I INo
Date Uploaded:
Analvtical Monitoring Requirements for Outfalls with Industrial Activities — Benchmarks in (Red)
Parameter
Parameter
Outfall004
Outfall005
Outfall
Outfall
Outfall
Code
N/A
Receiving Stream Class
C
C
N/A
Date Sample Collected MM/DD/YYYY
3/16/2022
46529
24-Hour Rainfall in inches
0.34
C0530
TSS in mg/L (100 or SO*)
12.4
PH in standard units (6.0-9.0 FW,
6.1
00400
6.8.8.5 SW)
Copper, total recoverable in mg/L
01119
W, 0.0058 SW)
0.0080
al recoverable in mg/ L
01051
W, 0.22 SW)
<0.010
al recoverable in mg/ L (0.126
01094
5 SW)
ffNon-Po1arOiy11c&vG�rebaMs(e
0.036
l Oxygen Demand (COD) in
00340
0)
<20
00552
ar Oil &Grease in mg/L (15)
<5.1
• Outfalls to Outstanding Resource Waters (ORW), High Quality Waters (HQW), Trout Waters lir) and Primary nursery Areas jPNAl
have a benchmark TSS limit of SO mg/L. All other water classifications have a benchmark of 200 mg/L
FW (Freshwater) SW (Saltwater)
Notes (optional): SDO #004 has met all benchmark values for this sampling event. SOO #005 is on quarterly sampling and was sampled In 2/22.
"I certify by my signature below, under penalty 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."
Signature of Permittee or Delegated Authorized Individual Date
Email Address Phone Number
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
Zahid.Khan@ncdenr.gov
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 (704) 394-6913 or Richard Mirecki with Circor at
richard.mirecki@circor.com.
Sincerely,
SHIELD ENGINEERING, INC.
Melind6Greene
Senior Engineer
Magdahne 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.shieldengineering.com Telephone 704.394.6913
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
I certify by my signature below, under penalty 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.
_� 9Vwt,
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:
f. 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
O.oZO
0.012
0.012
H. 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.
it!. 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
Stormwater Management Inspection Report (Tier Response)
Facility
- CIRCOR
Parameter Exceedance
Copper
SDO
004
Date of Sample
9121 /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, 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