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Home My WebLink AboutNC0004308_Review of Moniitoring Reports_20220812 (3) Badin Business Park LLC c/o Alcoa Corporation 201 Isabella Street Suite 500 Pittsburgh, PA 15212-5858 USA Tel: 1 412 315 2900 August 12, 2022 Roberto Sheller Senior Environmental Specialist Division of Water Resources, Water Quality Regional Operations Section North Carolina Department of Environmental Quality 610 East Center Avenue, Suite 301 Mooresville, NC 28115 VIA ELECTRONIC MAIL Re: Internal Review of Monitoring and Reporting Procedures Badin Business Park (f/k/a Alcoa - Badin Works) Badin, North Carolina NPDES Permit No. NC0004308 Dear Mr. Sheller: Through the development of the Badin Business Park website and in anticipation of Randall Kiser’s retirement and replacement, Badin Business Park LLC (BBP) contracted a third-party review of recent Electronic Discharge Monitoring Report (eDMRs) for the above referenced facility along with a review of sampling procedures at the site. The purpose of the third-party review was to identify potential discrepancies and improve our National Pollutant Discharge Elimination System (NPDES) monitoring and reporting procedures. This review identified multiple errors in reporting of results from various eDMR s. BBP has summarized the administrative reporting issues in the attached tables. As these reporting errors do not change the historical compliance with the facility’s NPDES permit, BBP is requesting guidance on whether the DMRs should be resubmitted with the corrections or if this letter is acceptable. Should you have any questions or comments, please contact me at your convenience. Sincerely, Robyn L. Gross Director, Asset Management Americas Tables Roberto Sheller Electronic Discharge Monitoring Reports August 12, 2022 Electronic Discharge Monitoring Report Proposed Data Amendments Badin Business Park Badin, North Carolina NPDES Permit No. NC0004308 eDMR Month Location eDMR Sample Date Parameter Administrative Error Reported Value Revised Value Permit Limit 19-Aug Outfall 013 8/6/2019 Al The parameter was estimated, or J-flagged, at a concentration below the RL. Estimated concentrations are not considered quantifiable. 0.35 mg/L < 0.20 mg/L Not Applicable 19-Aug Mixing Zone MZ2A 8/14/2019 F Analytical results reported in the eDMR were higher than actual results. < 10 mg/L < 0.10 mg/L Not Applicable 19-Sep Mixing Zone MZ3B Not Applicable F The parameter was not detected in the sample. 0.10 mg/L < 0.10 mg/L Not Applicable 19-Oct Outfall 002 10/16/2019 Al The parameter was not detected in the sample. 0.20 mg/L < 0.20 mg/L Not Applicable 19-Oct Outfall 012 10/16/2019 CN The parameter was estimated, or J-flagged, at a concentration below the RL. Estimated concentrations are not considered quantifiable. 3.2 µg/L < 5.0 µg/L 285 µg/L 19-Oct Mixing Zone MZ1B Not Applicable TCE The parameter was not detected in the sample 1.0 µg/L < 1.0 µg/L Not Applicable 19-Dec Outfall 005 12/16/2019 CN Parameter results are included in the eDMR comments but not in the eDMR form per instructions from NCDEQ. One parameter result listed in the comments is incorrect. < 10 µg/L 13 µg/L 46.6 µg/L 20-Apr Outfall 019 Not Applicable Discharge The discharge status will be amended from "No Discharge" to "Yes". Not Applicable Not Applicable Not Applicable 20-May Outfall 005 5/28/2020 CN The parameter was previously reported as non-detect with an incorrect RL. < 10 µg/L < 6 µg/L 46.6 µg/L 20-Jul Outfall 011 5/17/2020 Al Analytical results reported in the eDMR were higher than actual results. < 200 mg/L < 0.20 mg/L Not Applicable 20-Oct Outfall 011 10/11/2020 CN Analytical results reported in the eDMR were lower than actual results. Effluent limitations were not exceeded. < 6 µg/L 17 µg/L 46.6 µg/L Roberto Sheller Electronic Discharge Monitoring Reports August 12, 2022 eDMR Month Location eDMR Sample Date Parameter Administrative Error Reported Value Revised Value Permit Limit 21-Jan Outfall 012 1/5/2021 CN Analytical results reported in the eDMR were lower than actual results. Effluent limitations were not exceeded. 7.8 µg/L 78 µg/L 285 µg/L 21-Mar Outfall 012 3/16/2021 F, TSS, Al The parameters are listed twice in the comments. The eDMR will be amended to remove the duplicate listing. Not Applicable Not Applicable Not Applicable 21-Mar Outfall 012 3/16/2021 COD The comments list the incorrect units for the parameter. 100 mg/ 100 mg/L Not Applicable 21-Mar Outfall 013 3/16/2021 TSS The parameter is listed twice in the comments. Not Applicable Not Applicable Not Applicable 21-Mar Outfall 017 3/16/2021 Al Analytical results reported in the eDMR were higher than actual results. 350 mg/L 0.35 mg/L Not Applicable 21-Mar Outfall 018 3/16/2021 Al Analytical results reported in the eDMR were higher than actual results. 2300 mg/L 2.3 mg/L Not Applicable 21-Mar Outfall 022 3/16/2021 Al Analytical results reported in the eDMR were higher than actual results. 1400 mg/L 1.4 mg/L Not Applicable 21-Oct Outfall 017 10/4/2021 Al Analytical results reported in the eDMR were higher than actual results. 210 mg/L 0.21 mg/L Not Applicable 21-Oct Outfall 020 10/4/2021 Al Analytical results reported in the eDMR were higher than actual results. < 200 mg/L < 0.20 mg/L Not Applicable 21-Nov Outfall 013 11/3/2021 Acute Toxicity Sample was incorrectly collected as a grab sample, in lieu of the permit-required composite sample. Not Applicable Not Applicable Not Applicable Notes: eDMR – Electronic Discharge Monitoring Report. Permit Limit – The Daily Maximum Effluent Limitation for the respective Outfall as designated in the August 1, 2019 NPDES Permit. Al – Aluminum. F – Fluoride. CN – Cyanide. TCE – Trichloroethylene. TSS – Total Suspended Solids. COD – Chemical Oxygen Demand. mg/L – Milligrams per Liter. RL – Reporting Limit.