NCG030716_Benchmark Exceedance Notification_20221230

Chandler, Jeffrey A
From:
Riffle, Randall <[e-mail]>
Sent:
Friday, December 30, 2022 9:00 PM
To:
Eplin, Jerry W
Cc:
Chandler, Jeffrey A; Khan, Zahid
Subject:
[External] RE: 2027 Gateway Blvd Exceedance Notification
Attachments:
Action Plan.docx
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Mr. Eplin,
We are aware of the tiered approach and have worked through it. In June of 2021 Christina Walker emailed the
notification of the first consecutive exceedance and that the facility was entering Tier 1. She then emailed in November
of 2021 regarding the second consecutive exceedance and the facility entering the Tier 2. The most recent email was the
notification for the Tier 3. In response to the varying tiers we have previously performed site sampling and rain fall
sampling to try and pin point the area of concern. When it was determined to likely be the dust collectors, we had a
deep cleaning performed by an outside contractor. Which appeared to briefly work for one sample period.
Please see the attached action plan in response to the required Tier Three Response under General Permit NCG03000
Certificate of Coverage NCG030716 for the PNA Construction Technologies facility located at 2027 Gateway Boulevard in
Charlotte, North Carolina.
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Randy Riffle
Plant Manager
Phone: [phone]
Email: [e-mail]
2027 Gateway Blvd.
Charlotte, NC. 28208
www.ona-inc.com
From: Eplin, Jerry W <[e-mail]>
Sent: Thursday, December 15, 2022 9:03 AM
To: Riffle, Randall <[e-mail]>
Cc: Chandler, Jeffrey A <[e-mail]>; Khan, Zahid <[e-mail]>
Subject: 2027 Gateway Blvd Exceedance Notification
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Mr. Riffle:

The NCDEQ Mooresville Regional Office is in receipt of your email below. The referenced General Permit has a tiered
response to analytical monitoring exceedances. Tier one must be implemented after a single benchmark
exceedance. Tier two must be implemented when there are two consecutive exceedances. Tier three must be
implemented when there are four benchmark exceedances within the permit term. Each Tier Level has required
response activities with deadlines, some of which may have already been missed.
Based upon the information submitted below, it would appear that you should be in the Tier Three Response category —
see Section E-7 of the permit. Among other activities, this section requires submittal of a written Action Plan to the
Regional Office within thirty (30) days of receiving the fourth analytical monitoring data point exceeding the
benchmark. We recommend that you review Part E of the referenced permit and respond accordingly.
Jerry W. Eplin, PE
Assistant Regional Engineer
North Carolina Department of Environmental Quality
Division of Energy, Mineral, and Land Resources
Office: [phone] x2147
Email: ierrv.eolinancdenr.aov
Physical and Mailing Address:
610 E. Center Ave. Suite 301
Mooresville, NC 28115
Email correspondence to and from this address is subject to the
North Caro/Ina Public Records Law and may be disclosed to third parties
Mr. Khan, please let this email serve as official notification that the PNA Construction Technologies facility, located at
2027 Gateway Boulevard in Charlotte, under Certification of Coverage NCG030716, has had four stormwater copper
benchmark exceedances under the permit term. These occurred in the Quarter 4- October 28, 2021 sampling event; and
Quarter 1- February 23, 2022 and Quarter 1- March 31, 2022 sampling event 0.0137 mg/L, 0.0133 mg/L, and 0.0283
mg/L, respectively. The next sample event occurred on September 30 of 2022 and was below the benchmark, 0.0086
mg/L. The latest sampling event took place on November 15 and was 0.0146 mg/L.
The DMR for the most recent sampling event in November is in the process of being finalized and submitted as well.
Please let us know if you have any questions or require additional information.

Randy Riffle
Plant Manager
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Phone: [phone]
Email:[e-mail]
2027 Gateway Blvd.
Charlotte, NC. 28208
www.Dna-inc.com