NCG030650_Email RE Cu Zn Aug 2022 Exceedances_20221027

Georgoulias, Bethany
From: Nicole Johnston <[e-mail]>
Sent: Thursday, October 27, 2022 1:09 PM
To: Georgoulias, Bethany
Cc: Carson, Brittany; Young, Brianna A
Subject: FW: [External] Stormwater exceedances for Copper and Zinc for NCG030650 -
CommScope Claremont (Please note Bucket Sampling results)
Importance: High
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Bethany,
I have revised the eDMR for August 2022 to report the correct outfall sample analysis results.
Anyways, I also revised my earlier email and will now state this:
Per the general permit for CommScope, Inc. (NCG030000) Claremont Facility (under COC NCG030650), sampling was
completed on ROS Outfall 003 for the site on Tuesday, August 30th, 2022 with a rainfall even totaling 0.35" of rain. I
received results from the laboratory (Statesville Analytical) on Monday, September 12th, 2022. For this event, all
parameters were below the benchmark EXCEPT for Copper and Zinc. Please note that following:
1) The benchmark for Copper under General Permit NCG030000 is 0.010mg/L. The result obtained for Copper for
Outfall 003 was 0.082 mg/L, which exceeded the benchmark of 0.010 mg/L.
2) The benchmark for Zinc under General Permit NCG030000 is 0.126mg/L. The result obtained for Copper for
Outfall 003 was 0.1610 mg/L, which exceeded the benchmark of 0.126 mg/L.
3) However, I grabbed a rainwater sample on that same day in a small bucket and had copper, lead, and zinc
analyzed as well. The results from the analyses obtained for the stormwater bucket sample were the following:
Copper: 0.031 mg/L
Lead: <0.0005 mg/L
Zinc: 0.1108 mg/L
4) The rainwater sample was utilized to try and investigate background levels and determine other influences on
benchmark exceedances. These results do provide some background levels to consider for the copper and zinc
benchmark exceedances.
5) It is worth noting at the time of the exceedances, the facility was undergoing construction for some new
storage buildings. These buildings were constructed right beside the outfall site, and due to displaced metal being
moved near the construction site for temporary purposes, this may have led to the metal exceedances.
6) These benchmark exceedances for copper and zinc will be documented in the SWPPP, and corrective action
steps will be implemented to reduce such occurrences. Furthermore, best management practices will be utilized to
assist with reductions for the metal parameters exceeding their respective benchmark values.
Please note that rainfall totals for the Claremont CommScope site are obtained from the National Weather Service.
Please let me know if you need anything further, and hope you both have a very blessed day. Thank you for your
assistance with this matter. Please feel free to call me at 336-366-0870 if you need any further information.
Thanks

Nicole Johnston
From: Nicole Johnston
Sent: Tuesday, September 27, 2022 12:53 PM
To: Georgoulias, Bethany <[e-mail]>
Cc: Carson, Brittany <[e-mail]>; Young, Brianna A <[e-mail]>
Subject: RE: [External] Stormwater exceedances for Copper and Zinc for NCG030650 - CommScope Claremont (Please
note Bucket Sampling results)
Importance: High
Bethany,
I will change the submitted DMR to report the 'actual' data. Jesse McDonnell that just recently left stormwater was the
one that advised about subtracting the number, so not sure about that.
So, as far the sample with the bucket, it was just sat out on a concrete curb in open air right near the outfall area.
As far as the construction, I believe it may have been the soil disturbances causing the issue along with some exposed
equipment utilized for the construction.
I will advise the management team about the clarification you provided as well,....
What else should I do?
Thanks for your help.
Nicole
From: Georgoulias, Bethany <[e-mail]>
Sent: Monday, September 26, 2022 7:43 AM
To: Nicole Johnston <[e-mail]>
Cc: Carson, Brittany <[e-mail]>; Young, Brianna A <[e-mail]>
Subject: RE: [External] Stormwater exceedances for Copper and Zinc for NCG030650 - CommScope Claremont (Please
note Bucket Sampling results)
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the
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Nicole,
How exactly was the bucket set up to collect the rainwater? Did it run off of anything (like a roof or gutter, for example)
before it went into the bucket? Or just sit outside in open air somewhere to collect precipitation?
Values that were collected at the outfall discharge should be reported on the DMR. You should not report results that
are a subtraction calculation of results sampled in a bucket. It is okay to try and use a method like this to investigate
background levels or other influences on benchmark exceedances, but it is the outfall sample analysis results are the
ones that should be officially reported on the monitoring report.
If the construction was happening in the same drainage area as the one that normally drains industrial activities at the
site, remember that these become activities that impact discharges and are subject to conditions/SPPP requirements

laid out by your NPDES stormwater permit. The construction itself may have its own coverage under an NCG01 permit
for construction (if it's an acre or more), but if the disturbance is impacting the outfall's industrial stormwater
discharges, it is a factor to be addressed under the industrial NPDES permit as well. In this case, it could be soil
disturbances that are the influence, and there might not be much to do about that, or it could be other equipment that
is exposed (or some other reason). Consider a case where dirt is being disturbed in an area where prior chemical or
equipment storage left something behind on site that is suddenly exposed to run off. It may be hard to nail down, but I
just wanted to clarify that the construction disturbances in areas of industrial activity are equally part of the NPDES
stormwater permit and monitoring considerations.
Bethany Georgoulias (she/her)
Environmental Engineer
Stormwater Program, Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental Quality
919 707 3641 office
[e-mail]
512 N. Salisbury Street, Raleigh, NC 27604 (location)
1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing)
Website: http//deq.nc.gov/about/divisions/energy-mineral-land-resources/stormwatgr
DE
NORTH CAROLINA -
Department o1 Environmental Quality
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From: Nicole Johnston <[e-mail] >
Sent: Sunday, September 25, 2022 11:38 PM
To: Georgoulias, Bethany<[e-mail]>; Morman, Alaina <[e-mail]>; Carson,
Brittany <[e-mail]>
Subject: [External] Stormwater exceedances for Copper and Zinc for NCG030650 - CommScope Claremont (Please note
Bucket Sampling results)
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Bethany and Alaina and Brittany,
Per the general permit for CommScope, Inc. (NCG030000) Claremont Facility (under COC NCG030650), sampling was
completed on ROS Outfall 003 for the site on Tuesday, August 30th, 2022 with a rainfall even totaling 0.35" of rain. I
received results from the laboratory (Statesville Analytical) on Monday, September 12th, 2022. For this event, all
parameters were below the benchmark EXCEPT for Copper and Zinc. Please note that following:
1) The benchmark for Copper under General Permit NCG030000 is 0.010mg/L. The result obtained for Copper for
Outfall 003 was 0.082 mg/L, which exceeded the benchmark of 0.010 mg/L.
2) The benchmark for Zinc under General Permit NCG030000 is 0.126mg/L. The result obtained for Copper for
Outfall 003 was 0.1610 mg/L, which exceeded the benchmark of 0.126 mg/L.

3) However, I grabbed a rainwater sample on that same day in a small bucket and had copper, lead, and zinc
analyzed as well. The results from the analyses obtained for the stormwater bucket sample were the following:
Copper — 0.031 mg/L
Lead — <0.0005 mg/L
Zinc — 0.1108 mg/L
4) By subtracting the copper and zinc results for the stormwater bucket from the Outfall 003 results, the
reportable values become as follows:
Copper: 0.082 mg/L— 0.031 mg/L = 0.051 mg/L (Still an exceedance)
Zinc: 0.1610 mg/L— 0.1108 mg/L = 0.0502 mg/L (Now below benchmark level)
5) After these subtractions, the Copper result is still a reportable exceedance since it exceeds the benchmark of
0.010 mg/L; however, the Zinc result is below the benchmark level of 0.126 mg/L and is no longer an exceedance.
6) It is worth noting at the time of the exceedance, the facility was undergoing construction for some new storage
buildings. These buildings were constructed right beside the outfall site, and due to displaced metal being moved near
the construction site for temporary purposes, this may have led to the metal exceedances.
7) This copper exceedance will be documented in the SWPPP, and corrective action steps will be implemented to
reduce such occurrences. Furthermore, best management practices will be utilized to assist with reductions for the
metal parameters exceeding their respective benchmark values.
Please let me know if you need anything further, and hope you both have a very blessed day. Thank you for your
assistance with this matter. Please feel free to call me at 336-366-0870 if you need any further information.
Thanks
Nicole Johnston
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