Loading...
HomeMy WebLinkAboutNCG200342_Teir 3 Response_20220418Industrial Environmental Consultants, LLC 2603 F'essey Park Road • PO Box 40066 i e c Nashville, Tennessee 37204 (615)730-5059 Website: iecuashville.com J. Claiborne Thornton, III, PE Graham P. McRedmond, PE John C. Thornton, Iv, COO Evan M. White, EIT April 13, 2022 Division of Water Resource's Mooresville Regional Office 610 East Center Avenue Suite 301 Mooresville, NC 28115 RE: NPDES Tier 3 - Response Dear Corey Basinger: Environmental Specialists; Zachary A. Watson Tanner Q. Mikell Christina E. Weisbruch Enclosed is the Tier 2 and Tier 3 response for C & C Scrap Iron & Metal Inc, NCG200342. This site has been in Tier 3 before, and will start to do monthly monitoring for qualifying storm events. The facility has reviewed and implemented Control measures and Best Management Practices to reduce stormwater pollution as much as is practicable. The facility is working on control measures as reported with the previous monitoring event. If you have any questions, please do not hesitate to contact me at 615-730-5059. cw/ 14296 Enclosures cc: Tony Cooke - C&C Scrap Sincerely, INDUSTRIAL ENVIRONMENTAL CONSULTANTS, LLC Christina Weisbruch Environmental Scientist www.iecnashviIle. coin NCG20 SWPPP TIER RESPONSE REVIEW FOR BENCHMARK EXCEEDANCE FACILITY: C & C Scrap Iron &Metal is REPORT DATE: 04/13/2022 N���� kNA- PREPARED BY: Christina Weisbruch Tier 1 Response ono ® Valid sampling results are above a benchmark value, or outside of the benchmark range, A any parameter at any outfall. Outfall 001 Benchmark Criteria Sample Date: 02/13/22 Exceedance? Chemical Oxygen Demand 120 m L 19.9 87 Yes No Total Suspended Solids 100 m L Yes _ No Oil & Grease 15 m /L ND YesEj No Copper, Total Recoverable 0.010 m /L 0.0443 Yes ® No Lead, Total Recoverable 0.075 m L 0.0499 1 Yes No Zinc, Total Recoverable 0.126 m /L 0.175 Yes ® No Outfal1002 Benchmark Criteria Sample Date: 02/13/22 Exceedance? Chemical Oxygen Demand 120 m L 33.4 Yes ❑ No Total Sus ended Solids 100 mg& 108 Yes Z No El Oil & Grease 15 m L 0.010 m /L 0.075 mg /L ND Yes El No Cop per, Total Recoverable 0.0431 Yes No ❑ Lead Total Recoverable 0.0420 Yes No Zinc, Total Recoverable _ 0.126 mg/L 0.151 Yes M No El 1. Conduct a stormwater management inspection of the facility within two weeks of receiving sampling results. Date Results Received.- 3/7/2022 Inspection Date: Inspection Personnel. Tony Cooke 2. Identify and evaluate possible causes of the benchmark value exceedance: Parameter Identify Possible Causes COD N/A TSS N/A ❑ Oil & Grease N/A ® Naturally occurring metals (copper) sediment. TSS BMP's need Cu N/A ❑ maintenance. Pb N/A Zn N/A ❑ • iecindustrial environmental consultants NCG20 SIAIPPI) TIE"tt RESPONSE REVIEW EON BENGHMARK EXCEEDANCE 3. Identify potential and select the specific feasible: source controls, open-ational controls, or physical improvements to reduce concentrations of the parameters of concern. Parameter Source Controls Operational Controls Physical Improvements COD N/A ® Remove any scrap stored in the flow path The only solution is to prevent discharge. Cu benchmarks not achievable TSS N/A ❑ Oil & Grease N/A ® Cu N/A ❑ Pb N/A N/A ❑ Zn Additional information about source controls, operational controls, or physical improvements: Evaluate sediment control at the outfalls and oily scrap storage locations within 2 weeks. zI. Implement the selected actions within two months of the inspection. Implementation Schedule: The facility should implement all possible control measures. 5. Record each instance of a Tier One response in the Stormwater Pollution Prevention PMn. Include the date and value of the benchmark exceedance, the inspection date, the personnel conducting the inspection, the selected actions, and the date the selected actions were implemented. Date actions implemented: This Tier 1, 2, and 3 response will be implemented as of this report date i e c industrial environmental consultants NC620 SWPPP TIER RESPONSE REVIEW FOR BENCHMARK EXCEEDANCE Tier 2 Response ® The valid sampling results from two consecutive monitoring periods are above the bencrk values for any specific parameter at a specific discharge outfall. �m Parameter Benchmark Criteria Tier 2 Yes No Effective Date Chemical Oxygen Demand 120 mg/L Total Suspended Solids _ 100 m L Yes ❑ No Oil & Grease 15 m L Yes 0 No Co er, Total Recoverable 0.010 m /L Yes Z No ❑ Tier 3 Lead, Total Recoverable 0.075 m /L Yes No Zinc, Total Recoverable 0.126 m /L Yes Z No ❑ Tier 3 1. Repeat all the required actions outlined above in Tier One. Completed.- ® Yes ❑ No ❑ N/A 2. Immediately institute monthly monitoring for all parameters at every outfall where a sampling result exceeded the benchmark value for two consecutive samples. Monthly (analytical and qualitative) monitoring shall continue until three consecutive sample results are below the benchmark values or within the benchmark range. Monthly Monitoring Required? ® Yes ❑ No ❑ N/A Comments: Monthly monitoring should be implemented for all representative discharges according to the permit requirements, see #3 below. 3. If no discharge occurs during the sampling period, the permittee is required to submit a monthly monitoring report indicating "No Flow" to comply with reporting requirements. When Monthly monitoring is required, it continues for all parameters at each outfall until 3 consecutive results are below benchmarks for all parameters. Track rainfall during the month using the on -site rain gage. These are the criteria for collecting a valid stormwater sample from a measurable storm event: • Dry weather with no rainfall the preceding 72 hours. • The sample must be collected within the first 30 minutes of discharge. • A discharge must occur • Sample at the outfall only Samples should only be collected if a discharge occurs while the facility is manned under these conditions. For example if there is no flow off the property there should be no sample collected. If rainfall occurs overnight, no sample should be collected due to the first 30-minute condition. Reporting is required even i('there is no samtle collected. 4. Maintain a record of the Tier Two response in the Stormwater Pollution Prevention Plan. Keep this report with the SWPPP. k�i e c industrial environmental consultants MWO SVVPPP TIER HU-SPONSE UNWAI FOR BENCHMARK EXCEFDANCE Tier 3 RMpopsq, 1. During the term of this permit, if the valid sampling results required for the permit monitoring periods exceed the benchmark value for any specific parameter at any specific outfall on four occasions, the permittee shall notify the DEMLR Regional Office Engineer in writing within 30 days of receipt of the fourth analytical results. Vofifie wlioui Owe: Notified Regional DEMMR office of Tier 3 previously 2. Tier 3 Request for DEMLR: Comments: Requested determination of background conditions. No response from DEMLR Continue implementation of pennit/monitoring qualifying storms Monthly. Submit No Discharge DMRs when there is no qualifying event. ❑ require that the permittee revise, increase, or decrease the monitoring frequency for the remainder of the permit, including requiring sampling of additional or substitute parameters ❑ rescind coverage under the General Permit, and require that the permittee apply for an individual stormwater discharge permit; ❑ require the permittee to install structural stormwater controls; ❑ require the permittee to implement other stormwater control measures; ❑ require the l)erinittee to perform upstream and downstream monitoring to characterize impacts of receiving waters; ❑ require that the permittee implement site modifications to qualify for the No Exposure Exclusion; ❑ require the permittee to continue Tier Three obligations through the permit COC renewal process. iecconsultants Industrial environmental EXHIBIT NO.1 C & C SCRAP IRON & METAL, INC. KINGS MOUNTAIN, NORTH CAROLINA NCG200357 OUTFALLS 001 & 002 TABULATION OF ANALYTICAL DATA STORMWATER MONITORING REPORT' FEBRUARY 13, 2022 PARAMETER (mg/L) 001 002 BENCHMARK LIMITS Copper 0.0443 * 0.0431 * 0.010 Lead 0.0499 0.0420 0.075 Zinc 0.175* 0.151 * 0.126 Oil & Grease ND<1.5 ND<1.5 15 COD 19.9 33.4 120 TSS 87 108* 100 * Exceeds benchmark criteria, facility is in Tier 3 monthly monitoring — see benchmark report. ' Samples not collected by IEC, LLC INDUSTRIAL ENVIRONMENTAL CONSULTANTS, LLC Environmental Engineers & Consultants 2603 Fessey Park Road, P. O. Box 40066 Nashville, TN 37204 ph\ 14296 , r �q Ic liSk nvlronmental � i CD p Quality Nsio # 5L�rnnv,Y,nb?r N70hair° , CC))lt�l n, H (SDO) F ; Qualitafive 1iiifitQtolr'hi��Jrt>«rr'u gr=e, 0S R For guidance nnfilling out thisform, please visit litips://deq.nc.gov/about/divisioiisienergy-mineral-land-resourcVst n pd es-stormwater-gps Permit No.: N_/C/ / / / / / ! / or Certificate of Coverage No.: N/C/G/ Facility Name: G C SG/'o P �6� t h�^t° �..� TM G County: e -0.1 Phone No. ' 673 Inspector: A � _ Date of Inspection: ,��� Time of Inspection: Total Event Precipitation (inches): ®. All permits require qualitative monitoring to be performed during a "measurable storm event." A"measurable storm event" is a storm event that results in an actual discharge from the permitted site outfall. The previous measurable storm event must have been at least 72 hours prior. The 72-hour storm interval does not apply if the permittee is able to document that a shorter interval is representative for local storm events during the sampling period, and the permittee obtains approval from the local DEMLR Regional Office. By this signature, I certify that this report is accurate and complete to the best of my knowledge: (Signature of Perrnitiec� or Designee) 11111 IN 11111111 liiiiiii IIIIIIIIIIIII111102 �3 industrial EnvuomnnMAt Consullnnls, LLC M56 58 Proiect# 14296 1. Outfall Description: Outfall No. I_ Structure (pipe, ditch, etc.):�'?'N� Receiving Stream: Describe the industrial activities that occur within the outfall drainage area: Page I of 2 MU-242, LasI modified 06101/2018 ~ 2. Color: Describe the color of the discharge usin_ color,�(red, brown, blue, etc.) and tint (light, medium, dark) as descriptors: _ l.11or IC 3. Odor: Describe any distiu ,t odors that the discharge may have (i.e., smells strongly of oil, weak chlorine odor, etc.): _N P% 4. Clarity: Choose the number which best describes the clarity of the: discharge, where I is clear and 5 is very cloudy: I 2 Q 4 5 5. Floating Solids: Choose the number which best describes the amount of floating solids in the stormwater discharge, where t is no solids and 5 is the surface covered with floating solids: 1 2 l> 4 5 6. Suspended Solids: Choose the number which best describes the amount of suspended solids in the stormwater discharge, where 1 is no solids and 5 is extremely muddy: 2 4 5 7. Is there any f onrtu in the stormwater discharge? O Yes • No. 8. Is there an oil sheen in the stormwater discharge? OYes (WNo. 9. Is there evidence of erosion Or deposition at the outfall'? O Yes 4g No. 10. other<° ObvioLm lrudieaitor5 of Polltution: List and describe 11111Jill1124 0 � ilLuu-. It.(, P(Oltrl a 14296 09 56 58 Note: Low clnrity, high solids, and/or the presence of foam, oil sheen, or ei,osion/depositlon >imvi/ iav indicative of pollWaank v,%pogtme. These conditions a^raV V211t further invegtigation, Nagc 2 of 2 S W U-242, Last modi I)ed 06/0 U201 S r. Environmental o Quafrty y °d0 For guidance on filling out this form, please visit htlps:t'ldeq.ne.gov/about/divisions/energy-miner mid -resources/ npdes-stormwater-gps "m Permit No.: N/C/ / / / / / / / or Certificate of Coverage No.: N/C/G/ / / / / / / Facility Name: G �,cra.p TWW At OY1,ek-Z .r,44 . County: -..a(ift 19 OL,I Phone No. ! ! O i 541— 9V-+9' Inspector: t C} �•_ Date of Inspection: Time of Inspection:._q • �,�n,. Total Event Precipitation (inches): ), 9 -- All permits require qualitative monitoring to be performed during a "measurable storm event." A "measurable storm event" is a storm event that results in an actual discharge from the permitted site outfall. The previous measurable storm event must have been at least 72 hours prior. The 72-hour storm interval does not apply if the permittee is able to document that a shorter interval is representative for local storm events during the sampling period, and the permittee obtains approval from the local DEMLR Regional Office. By this signature, I certify that this report is accurate and complete to the best of my knowledge: II1I11�IIIIIII��II11NI1'�I�NI1II11I1I1I1f 3Dana (Signature of Permittee or Designee) 7 02412-24 Influslnal v-flVJr0Mt1P"1A1 CpUSU1hulls_ LLC 2'24'20:2 Pfoferf 0 f <12% 09:56 58 1. Outfall Description: Outfall No. -Z' Structure (pipe, ditch, etc.): Receiving Stream: Describe the industrial activities that occur within the outfall drainage area: _ Page 1 of 2 SWU-242. Last modified 06/01/2018 2. Color: Describe the color of the discharge tlsil basic colors (red, brown, blue, etc.) and tint (light, medium, dark) as descriptors: L{ �1. -r 3. Odor: Describe any distinct odors that t iy, discharge may have (i.e., smells strongly of oil, weak chlorine odor, etc.): —_—� _ --- 1 4. Clarity: Choose the number which best describes the clarity of the discharge, where I is clear and 5 is very cloudy: I 2 D 4 5 5. Floating Solids: Choose the number which best describes the amount of floating solids in the stormwater discharge, where 1 is no solids and 5 is the surface covered with floating solids: 1 2 LID 4 5 6. Suspended Solids: Choose the number which best describes the amount of suspended solids in the stormwater discharge, where 1 is no solids and 5 is extremely muddy: 1 2 & 4 5 7. Is there any foam in the stormwater discharge? O Yes 10 No. 8. Is there an oil sheen in the stormwater discharge? OYes 4PNo. 9. Is there evidence of erosion or deposition at the outfall? ® Yes 0 No. 10. Other Obvious Indicators of Stormwater Pollution: tntrrntal GunsulArnts,LC L o2-24- -as-zozz Proiect # 14296 09•56 r8 Note: Low clarity, high solids, and/or the presence of foam, oil sheen, or erosion/deposition may be indicative of pollutant exposure. These conditions warrant further investigation. Page 2 of 2 SWU-242, Last modified 06/01/2018