NCG030486_AO Smith Charlotte - Request for Tier Relief_20230313

Chandler, Jeffrey A
From: Eplin, Jerry W
Sent: Monday, March 13, 2023 11:46 AM
To: Chandler, Jeffrey A
Subject: FW: [External] AO Smith Charlotte (NCG030486) - Request for Tier Relief
From: Eplin, Jerry W
Sent: Monday, March 13, 2023 11:45 AM
To: Seddon, Kimberly <[e-mail]>
Cc: Van Auken, Mark <[e-mail]>; Viers, Laura <[e-mail]>; Woo, Brandon
<[e-mail]>; Rice, Alexandra R <[e-mail]>; Palasini, Maci <mapaIasi [e-mail]>
Subject: RE: [External] AO Smith Charlotte (NCG030486) - Request for Tier Relief
Thank you for providing the additional information.
The spreadsheet that was provided in your email appears to stop at August of 2017. Tabulated data between August
2017 and now would be beneficial in reviewing any Tier relief request.
The data that lead to the conclusion that the sources were not associated with the manufacturing process is not clear to
me. I seethe results indicating that water from the "West Property Line" was high in zinc during February
2017. However, in April 2017, the same sampling location had zinc concentrations well below the outfall values. The
2016/2017 data also indicate that zinc was above benchmark levels in downspouts, but I don't see anything in the file
indicating what the suspected source of that zinc likely was. Many times, zinc in downspouts can result from galvanized
roofing. Does the facility have galvanized roofing? Are there any processes on the roof or that could discharge dust to
the roof? What else is on the roof that could be contributing.
If the facility intends to request Tier relief, the case will have to be made that Tier relief is appropriate. Analytical data
from 5 — 6 years ago would not likely convince us that Tier relief is appropriate. However, your January 9, 2023,
inspection log indicates several potential sources of benchmark exceedances, along with corrective actions that should
be implemented.
My recommendation is to continue with your efforts to identify and reduce the concentrations of parameters leading to
benchmark exceedances. As stated above, if Tier relief is desired, the Permittee will need to make the case that the
benchmark exceedances are not from their process and are beyond their control.
At this time, DEQ cannot grant Tier relief based upon the information that was submitted.
Please feel free to call if you need to discuss.
Jerry W. Eplin,
Assistant Regional Engineer
North Carolina Department of Environmental Quality
Division of Energy, Mineral, and Land Resources
Office: [phone] x2147

Email: ierryg��goy
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
From: Seddon, Kimberly <1<.im. erly S_ d.d.�n.C�2.g.rcad.l_s_:com>
Sent: Thursday, March 9, 2023 3:14 PM
To: Eplin, Jerry W <ierry.eplinC ncdenr. gy>
Cc: Van Auken, Mark <.M.. rk. nA�ak n( rc d%s cqm>; Viers, Laura <Ivi rs( he t t r:cgrn>; Woo, Brandon
<bmwoo( h_otwater.co >; Rice, Alexandra R <arrice( heat t r:cc rrr>; Palasini, Maci <mapp�.l_�sini.( g.pc rn:c rrr>
................... _. .... ...._.............................. .
Subject: [External] AO Smith Charlotte (NCG030486) - Request for Tier Relief
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Resort Sparn.
In response to your email to Ms. Viers on February 241", we wanted to provide some clarification on the January 2023
Stormwater Discharge Outfall Monitoring Report submitted to DEQ on February 141" and our notification to AO Smith
that there were exceedances for benchmark values of copper and zinc that could trigger a Tier 1 response. Because of
site history and recent activities detailed below, it is being requested that the site receive Tier Relief, as was the case
prior to the issuance of the most recent permit.
Provided below is a brief history of stormwater sampling results at the facility before the new General Permit No.
NCG030000 was issued on July 1, 2021 and recent activities being conducted at the facility to comply with the new
permit.
History
In Fall 2016, AO Smith sought relief from Tier 3 status for exceedances for zinc. An initial meeting was held on May 23,
2017 with James Moore of NCDEQ and Chad Broadway of Mecklenburg County to discuss options and a full-scale
sampling program that evaluated the water quality in runoff from various sources including facility roofs, neighboring
properties, and ambient (regional airborne) sources was agreed upon. The results of the analyses (see Sampling Results
Spreadsheet and Next Steps document) concluded that high zinc exceedance levels were from sources not associated
with the facility's manufacturing process and the facility should be allowed to go back to regular non -Tier monitoring.
James Moore of NCDEQ stated for this Tier Relief to occur that filter devices (filter socks or mats) must be installed at
Outfalls 002 and 003.
Recent Activities
Since the stormwater compliance team at AO Smith is almost entirely new and facility management is making a strong
commitment to compliance with the new permit requirements, they asked Arcadis to conduct the annual inspection
tasks in January 2023 to get an early assessment of where they are and where they need to be. During our outfall
inspection we discovered that previous staff had removed the filter mat at Outfall 002 and filter sock at Outfall 003 and

that current staff were unaware of the filter device requirements. At this time, current staff are working to reinstall the
filter mats. Most of the Tier 1 response procedures (inspection of potential causes, identification of measures to resolve
the exceedance, etc.) were actually completed during our annual inspection — before the January sampling event
occurred (see Corrective Action Log with list of prioritized improvements).
We believe the past history of off -site runoff contributions and proposed implementation of prioritized improvements
are sufficient to address the documented exceedances and ask that the AO Smith Charlotte facility be allowed Tier Relief
as was the case before issuance of the current permit. Also, we have been informed that AO Smith does not have a
current account for eDMR submittal of sampling results, so they will continue to submit hard copies until an account can
be obtained.
We appreciate your assistance. Please let us know what steps should be taken to formally document the Tier Relief
requested for the AO Smith facility.
Best,
[C11'6lbeui1y III') Seddoin III'�III';IIIIII
Project Civil Engineer
Arcadis U.S., Inc.
T [phone]
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