NCG030717_Tier 3 Action Plan_20220520

' SHIELD
May 19, 2022
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, April 2022
Jim Myers & Sons, Inc. — Charlotte, North Carolina
Certificate of Coverage NCG030717
Dear Mr. Khan,
On behalf of Jim Myers & Sons, Inc. (JMS) — Charlotte 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 the month of April 2022. The cover
page of the report contains the required certification by JMS's responsible official. If you have any
questions regarding this Action Plan, please contact us at [phone] or Derek Fleetwood with
JMS at [e-mail].
Sincerely,
SHIE D ENGINEERING, INC.
Magdaline M. Tzannis
Senior Project Manager
ATTACHMENTS
cc: Lily Kay, NCDEQ Mooresville
Thomas Witner, PG
Principal
4301 Taggart Creek Road www.shieldengineering.com Telephone [phone]
Charlotte, NC 28208 License No. F-0856

Jim Myers & Sons, Inc.
5120 Westinghouse Blvd.
Charlotte, North Carolina
Certificate of Coverage NCG030717
Tier Three ,Action Plan
In compliance with General SW Permit NCG030000, Part E-7
Prepared by:
! SHIELD
/ ENGINEERING
4301 Taggart Creek Road
Charlotte, NC 28208
Shield Project No. 1200008-05
May 10, 2022
1 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, h4uding the possibility of fines and imprisonment for knowing violations.
Dave Myers
JMS - Charlot
Date

JMS Page 2
Tier Three Response Action Plan Mav 10. 2022
Facility
Jim Myers & Sons, Inc. — Charlotte NCG030717
SDO
001
Parameter(s)
Copper
Date Prepared
5/10/2022
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. This Action Plan was
developed to address Copper Tier 3 Response at Outfall 001.
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 tables below document the last four benchmark exceedances for Copper at Outfall 001 for
JMS.
Copper benchmark = 0.010 mg/I
Month 4/2022 3/2022 1 2/2022 9/2021
Outfall 001 1.0.01.7 0.024 1 0.025 0.064
This data indicates that efforts previously undertaken by JMS have contributed to decreased
concentration of Copper in the stormwater discharge.
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 001. Typical industrial activities that occur in this drainage area
include material storage, scrap metal storage, finished product storage, passivation,
loading/unloading.
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.
iii. An evaluation of standard operating procedures and good housekeeping procedures
JMS 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 in
the drainage area for SDO 001. 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
The data above show a clear decreasing trend in Copper concentrations due to the following
actions taken by JMS:

JMS Page 3
Tier Three Response Action Plan _ _ May 10, 2022
1. Clean-up and removal of the debris around the stormwater inlet in the truck lane (high risk
drain);
2. Fill of truck tire rutting in Drainage Area 001 near passivation shed to limit run-off coming
into contact with passivation process;
3. Regrading around stormwater basin in Drainage Area 001 to capture more flow into basin;
4. Relocation of scrap and shavings/turning bins;
5. Spreading of gravel pile evenly into the yard area;
6. Clean-up of loose metallics in the yard area;
7. Training of employees on the requirements of the SWPPP.
As an ongoing effort to achieve the benchmark for Copper, JMS has identified sources it believes
may be impacting the current exceedances. The following causes have a high potential to effect
Copper concentrations in stormwater discharged from Outfall 001 and contribute to benchmark
exceedances:
Potential Cause of
Benchmark Exceedance
Location(s)
Potential
Pollutant
Outfall(s)
Affected
Cumulative Effect from
Outdoor Asphalt
_ _
Copper
001
Vehicle Brake Pad
Pavement
Deposits
Wood is often treated with
Treated Wood
Copper
001
a copper compound. JMS
appears to be using copper
treated wood in the
equipment laydown area to
elevate finished equipment
from the round.
In addition to the benchmark exceedances of the General Permit, JMS is currently in the design
phase for compliance with the City of Charlotte Post -Construction Stormwater Ordinance and
zoning requirements. This design will include a stormwater management structure that will impact
Drainage Area 001 and allow for the capture and treatment of additional stormwater flow.
Therefore, this requirement has been included below in Item v, ACTIONS SELECTED FOR
IMPLEMENTATION BY SITE.

JMS Page 4
Tier Three Response Action Plan May 10, 2022
v. Specific actions that will be taken to remedy the identified source(s) with a schedule
for completing those actions
ACTIONS SELECTED FOR IMPLEMENTATION BY SITE
SCHEDULE FOR
COMPLETION
Enhance sweep shipping/receiving areas located in the
Action will be implemented
drainage area of outfall 001, on a routine basis.
internally, by May 30.
Determine if the treated wood contains copper compounds
JMS has identified (4/25/22) that
that could leach and evaluate feasibility of reducing use or
the treated timber used in the
replacing copper -treated wood with other options.
yard is MCA-C (Micronized
Copper Azole).JMS has begun
replacing the treated timbers
with untreated timbers.
Evaluate the chemicals used by landscaping.
JMS will complete this
evaluation by May 30.
Design evaluation for filtration and attenuation of
Action is ongoing and will
stormwater per latest City of Charlotte Post Construction
depend on approval from the
Stormwater Ordinance.
City of Charlotte
vi. A monitoring plan to verify that the Action Plan has addressed the source(s).
JMS will attempt to sample SDO 001 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, JMS
will maintain documentation as to why a sample could not be collected. JMS 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 001)
Site Map

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