NCG030486_AO Smith - Tier III Response Letter and Action Plan for NCDEQ Approval_20231206

Eplin, Jerry W
From: Seddon, Kimberly <[e-mail]>
Sent: Wednesday, December 6, 2023 4:39 PM
To: Eplin, Jerry W
Cc: Ball, Jonathon; [e-mail];[e-mail]; Rice,
Alexandra R; Viers, Laura; Ball, Jonathon; Brill, Keri
Subject: [External] NCG030486 AO Smith - Tier III Response Letter and Action Plan for NCDEQ
Approval
Attachments: NCG030486 AO Smith - Tier III Response Letter.pdf, NC030486 AO Smith -
Stormwater Investigation Sampling Plan.pdf
A I V'S
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Jerry,
Thank you for your time last week to review the AO Smith property and potential sources of Zinc and Copper. Attached
is the Tier III Response Letter and the Sampling Investigation Plan that AO Smith will be starting. I believe Tier III requires
NCDEQto sign off on the plan, so please let us know if anything further is needed. We will get started with scheduling
the sampling as soon as we have your agreement.
Best,
Kimberly P. Seddon, PE
Project Civil Engineer/CPM
Arcadis U.S., Inc.
T+1 704 594 4441
PE— NC, SC, FL
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1

A.O.Smith Water Systems
CoSmith hart Raleigh Street
Charlotte,NC 28213
Innovation has a name. [phone]
December 06, 2023,
Mr.Jerry Eplin, PE
Assistant Regional Engineer
North Carolina Department of Environmental Quality
Division of Energy, Mineral, and Land Resources (Mooresville Regional Office)
610 E. Center Ave. Suite 301
Mooresville, NC 28115
Re: Tier Three Action Plan for Zinc and Copper Benchmark Exceedances
A.O.Smith Water Systems(4302 Raleigh Street,Charlotte,NC 28213)
Stormwater Certificate of Coverage NCG030486
Dear Mr. Eplin:
A.O. Smith Water Systems ("A.O. Smith") owns and operates the hot water system manufacturing facility("The
Facility") located at 4302 Raleigh Street, Charlotte, NC 28213.A.O. Smith is authorized to discharge stormwater
associated with industrial activities via their Certificate of Coverage#NCG030486("The Permit"). The Permit is
effective July 01, 2021.
The Facility has two Outfalls that are sampled (Outfalls 002 and 003). Four exceedances above the benchmark
values within a single permit term were noted for Zinc at Outfall 002 and Copper at Outfall 002,triggering the
Tier Three response status per Section E-7 of The Permit. Figure 1, below,shows the outfall placement and
general facility layout.
Figure 1: Layout and Outfall Placement at Facility
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A.O.Smith Water Systems
• Smith 4302 Raleigh Street
Charlotte,NC 28213
Innovation has a name. [phone]
This letter shall serve as The Facility's Action Plan and a summary of the Tier Three Response.
Element 1: Documentation of Benchmark Exceedances
Four benchmark exceedances were found for Zinc at Outfall 002,and Copper at Outfall 002 within the permit
term to date.The exceedances have been documented in The Facility SWPPP in accordance with Section E-5(b)
in The Permit (NCG030000).The exceedances have been summarized in Table 1 below for reference.
Table 1:Summary of Exceedances
Zinc(Outfall 002) Copper(Outfall 002)
Benchmark=0.126 mg/1 Benchmark=0.010 mg/1
Sample Date Sample Value Sample Date Sample Value
February 2022 0.455ug/I September2021 0.0192mg/I
October 2022 0.457 ug/I February 2022 0.0225 mg/I
January 2023 0.571 ug/I October 2022 0.0277 mg/I
August 2023 202 ug/1 August 2023 0.0210 mg/I
Element 2: NCDEQ Notification
Following receipt of the laboratory results indicating benchmark exceedances,The Facility provided the
Stormwater Discharge Outfall Monitoring Report to the regional NCDEQ Office in Mooresville, NC and notifying
the office of the quarter's exceedance dates, pollutants,and values.
Element 3:Stormwater Management Inspection and Identification of Feasible Actions
Prior to the Stormwater sampling event on August 03,2023,The Facility,accompanied by their stormwater
consultants Ms. Kimberly Seddon, PE and Mr. Mark Van Auken, PE at Arcadis, Inc., had conducted their Annual
Inspection on 1/09/2023.The inspection identified a priority list of corrective action items. Subsequent periodic
inspections have occurred and been documented on a monthly basis.
Historically,the facility had filter mats installed at Outfalls 002 and 003 to assist with general pollutant
reduction.Although it was noted during the January inspection that the mats had been removed by previous
staff,filters were replaced in Q2 2023. More samples are needed post-filter in order to determine their overall
effectiveness.
Although several corrective action items were identified early in 2023 for the overall reduction of pollutant
discharge from The Facility, a more robust Action Plan is needed to identify the source of the pollutants
upstream of the inlet filters.A facility inspection occurred on August 25,2023 to assess drainage areas and
potential pollutant sources.The plan Is further detailed below. Please see the Stormwater Investigation Source
Sampling Plan enclosed under separate cover with this letter. Please note that the plan is subject to variability
'depending on in-field conditions or new information received by the project team.The team may opt to revise,
add, or remove sample locations as reasonably required to achieve the plan objective.

A.O.Smith Water Systems
CoSmulth Charlotte,
Raleigh Street
Charlotte,NC 28213
Innovation has a name. [phone]
The staff at A.O. Smith has made a strong commitment to compliance and are eager to bring The Facility into
conformance with The Permit requirements.
If you have any questions related to this notification, please contact me at [phone] x202 or
([e-mail].
d Regards,
c
aura Viers
JAA*nO Smith, Charlotte Water Systems
Plant Manager

Memo 04ARCADIS
SUBJECT TO NC Engineering License#C-1869
Source Sampling Plan Mr. Jamie Hayes NC Surveying License#C-1869
DATE PROJECT NUMBER
September 25, 2023 30160413
COPIES TO NAME
Ms. Laura Viers Jonathon Ball, CPM
Mr. Brandon Woo 864-987-322
Arcadis G&M of North Carolina, Inc. (Arcadis) has prepared this Source Sampling Plan on behalf of A.O. Smith,
Water Systems (AO Smith)to investigate potential sources of stormwater impacts at the AO Smith facility located
at 4302 Raleigh Street in Charlotte, Mecklenburg County, North Carolina as shown on Figure 1. The primary
constituents under review in this Source Sampling Plan are copper and zinc, which have been observed at
Outfalls 002 and 003 at elevated concentrations and sometimes above the benchmark standards (in the 2014-
2023 dataset). Additionally, elevated concentrations of total suspended solids (TSS) have been observed
sporadically at Outfalls 002 and 003, and are also included. Although pH, lead, chemical oxygen demand, and
non-polar oil and grease are additional constituents that require monitoring and sampling in stormwater
discharges, none of these constituents have historically been observed above benchmark standards consistently
and are thus not included in this source investigation.
Arcadis personnel visited the site on August 25, 2023 to assess drainage areas and potential sources contributing
to Outfalls 002 and 003. Drainage area limits as observed during the site visit have been adjusted slightly from
historical depictions and are included on Figure 2. During the site visit, Arcadis also reviewed each drainage area
and identified various potential contributing sources to elevated concentrations at Outfalls 002 and 003, including
outside tank storage, roof drains or runoff, maintenance spraydown activities, and sediments or soils. Sample
locations and techniques were selected to investigate each potential contributing source. Proposed techniques
include wipe sampling, soil/sediment sampling, and water runoff sampling of select constituents.
Background Rainfall Investigation
To identify background rainfall conditions at the site and account for potential variability across the site, three
rainfall samples will be collected by placing three plastic buckets away from existing infrastructure in various
areas across the site. Each of the rainfall samples will be collected and submitted for analysis of zinc and copper
by USEPA Method 200.7 and TSS by Standard Method 2540D. Sample details and sample locations are
provided in Table 1 and Figure 3, respectively.
Outfall 002 Source Investigation
During the August 2023 site visit, potential contributing sources at Outfall 002 were identified, as follows:
• Outside tank storage (red primer tank and galvanized tanks) adjacent to Buildings B and C;
• Roof runoff from the southern end of eastern side of Building A, northern side of Building B, and southern
end of eastern side of Building C;
• Maintenance spraydown activities at the southeastern corner of Building A; and
• Exhaust Vent at Building C.
Arcadis G&M of North Carolina,Inc.,3540 Toringdon Way,Suite 220,Charlotte,North Carolina,704 752 4258,www.arcadis.com
1/4

Mr. Jamie Hayes
A.O. Smith Water Systems
September 25, 2023
To account for all sediment and debris within the Outfall 002 drainage area, a soil sample will be collected of the
fines and debris collected within the drain filter and submitted to Pace for analysis of zinc and copper by USEPA
Method 6010. Sample details and sample locations are provided in Table 1 and Figure 3, respectively.
Outside Tank Storage
For investigation of the outside tank storage areas as a potential contributing source of zinc, copper, and TSS,
wipe samples and runoff samples will be collected from one red primer tank adjacent to Building C and two
galvanized tanks adjacent to Buildings B and C (one each). Wipe samples will be collected and submitted to Pace
Analytical Services (Pace) in Huntersville, North Carolina for analysis of zinc and copper by United States
Environmental Protection Agency (USEPA) Method 6010.
A secondary containment will be constructed of poly sheeting and lumber to collect stormwater below the pallet of
each tank selected for wipe sampling. Stormwater will then be collected from the containment using a peristaltic
pump and submitted to Pace for analysis of zinc and copper by USEPA Method 200.7 and for analysis of TSS by
Standard Method 2540D. Additionally, if enough volume is present within the secondary containment, an in-line
0.45-micron filter will be placed at the peristaltic pump discharge, and samples will be collected for analysis of
dissolved zinc and dissolved copper by USEPA Method 200.7.
Roof Runoff
For investigation of the roof runoff from the southern end of the eastern side of Building A, northern side of
Building B, and southern end of the eastern side of Building C as a potential contributing source of zinc, copper,
and TSS, roof runoff samples will be collected from one point of Building A and two points on each of Building B
and Building C. A plastic bucket will be placed below one of the roof channels at each sampling location to collect
stormwater runoff from the roof. A stormwater sample from each roof runoff sampling location will be submitted to
Pace for analysis of zinc and copper by USEPA Method 200.7 and TSS by Standard Method 2540D. Additionally,
should enough volume be present following the storm event, a peristaltic pump with an in-line 0.45-micron filter
will be used to collect an additional sample for submittal to Pace for analysis of dissolved zinc and dissolved
copper by USEPA Method 200.7.
To analyze the potential release of constituents from historical stormwater runoff from the roof at Building C, a soil
sample will be collected adjacent to each stormwater runoff sampling location at Building C and a ditch adjacent
to the galvanized tanks and slightly east of Building C where stormwater runoff from the roof would accumulate in
a shallow ditch prior to sheet flow across the parking lot to Outfall 002. Each of these three soil samples will be
collected from 0 to 3 inches below ground surface (in bgs)and submitted to Pace for analysis of zinc and copper
by USEPA Method 6010. No surface soils are present adjacent to Building A or Building B that would be sufficient
for sampling to analyze historical stormwater runoff from the roof.
Maintenance Spraydown
For investigation of the maintenance spraydown activities at the southeastern corner of Building A as a potential
contributing source of zinc, copper, and TSS, wipe samples, soil samples, and runoff samples will be collected
within or directly downgradient of the maintenance spraydown area. A wipe sample will be collected from the
discolored exterior wall of Building A adjacent to the maintenance spraydown area. The wipe sample will be
submitted to Pace for analysis of zinc and copper by USEPA Method 6010. Additionally, sediment and debris
appear to have collected in the corner of a forklift travel path crossing directly downgradient of the maintenance
spraydown area. A soil sample of this sediment will be collected from 0 to 3 in bgs and submitted to Pace for
analysis of zinc and copper by USEPA Method 6010. Next, an apparatus will be constructed to attempt to
www.arcadis.com 2/4

Mr. Jamie Hayes
A.O. Smith Water Systems
September 25, 2023
channelize stormwater runoff from the maintenance spraydown area to allow it to be sampled. Should enough
flow be accumulated, a sample will be collected and submitted to Pace for analysis of zinc and copper by USEPA
Method 200.7 and TSS by Standard Method 2540D. Additionally, a sample will attempt to be collected and
passed through a 0.45-micron filter for analysis of dissolved zinc and dissolved copper from this runoff.
Exhaust Vent
Lastly, an exhaust vent was observed adjacent to Building C with exposed fabric material and direct discharge to
the Outfall 002 drainage area. Although Building C is currently used for only warehouse activities, due to
uncertainties of historical usages and potential accumulation of metals within the exposed fabric material now
subject to rainfall and stormwater runoff, a sample of the exposed fabric material will be submitted to Pace for
analysis of zinc and copper by USEPA Method 6010. A soil sample directly below the exhaust vent will be
collected from 0 to 3 in bgs and submitted to Pace for analysis of zinc and copper by USEPA Method 6010.
Outfall 003 Source Investigation
During the August 2023 site visit, potential contributing sources at Outfall 003 were identified to include the
following:
• Roof runoff from Building A and associated loading dock and
• Sediment present at various areas across the Outfall 003 drainage area.
To account for sediment and debris within the Outfall 003 drainage area, a soil sample will be collected of the
fines and debris collected within the drain filter and submitted to Pace for analysis of zinc and copper by USEPA
Method 6010. Sample details and sample locations are provided in Table 1 and Figure 3, respectively.
Roof Runoff
For investigation of the roof runoff from Building A as a potential contributing source of zinc, copper, and TSS,
roof runoff samples and wipe samples will be collected from select roof drains. Roof runoff samples will be
collected from each of the two roof drains within the fenced portion of the site north of the loading dock at Building
A, at the north roof drain at the loading dock of Building A, and at the southern roof drain of Building A prior to the
setback at the maintenance spraydown area described above. A grab sample of stormwater from each roof drain
sampling location will be submitted to Pace for analysis of zinc and copper by USEPA Method 200.7 and TSS by
Standard Method 2540D. Additionally, water from each roof drain will be collected in a clean container and a
peristaltic pump with an in-line 0.45-micron filter will be used to collect an additional sample from each roof drain
for submittal to Pace for analysis of dissolved zinc and dissolved copper by USEPA Method 200.7. Additionally, a
wipe sample will be collected from each sampled roof drain and submitted to Pace for analysis of zinc and copper
by USEPA Method 6010.
Drainage Area Sediment
For investigation of the sediment accumulated at various locations as a potential contributing source of zinc,
copper, and TSS, soil samples will be collected. A soil sample of the sediment present will be collected from 0 to
3 in bgs within the parking lot area, loading dock area, and concrete trough adjacent to the rolloff area and
submitted to Pace for analysis of zinc and copper by USEPA Method 6010.
Conclusions
This Source Sampling Plan has been prepared to identify background rainfall conditions and to investigate
potential contributing sources of zinc, copper, and TSS to Outfalls 002 and 003. Identified potential contributing
www.arcadis.com 3/4

Mr. Jamie Hayes
A.O. Smith Water Systems
September 25, 2023
sources include outside tank storage, roof runoff, maintenance spraydown activities, historical site operations, and
general soils and sediments. Sampling techniques to be utilized during this investigation include water sampling,
wipe sampling, and sediment or soil sampling. Water samples are intended to be collected during the first flush of
a qualifying storm event from each of the prescribed sampling locations; however, wipe and sediment or soil
sampling activities are intended to be collected during dry conditions. Sample details and sample locations are
provided in Table 1 and Figure 3, respectively.
Enclosures
Tables
1 Sample Summary
Figures
1 Site Location Figure
2 Site Drainage
3 Sampling Locations
www.arcadis.com 4/4

Tables

Table 1 i& ARCAD I S
Sample Summary
A. O. Smith Charlotte Facility
4302 Raleigh Street
Charlotte, North Carolina 28213
Method'Sample Name Sample Description Potential Source I sample media Constituents Analysis
ackground Rainfall Investigation
WT-BG-01 Background Rain Sample South Background Rainfall WT ZOI(Cu/
EPA 200.7/SM 2540D-2015
WT-BG-02 Background Rain Sample East Background Rainfall WT EPA 200.7/SM 2540D-2015
WT-BG-03 Background Rain Sample North Background Rainfall WT EPA 200.7/SM 2540D-2015
02 Source
WP-RT-01 Wipe sample from Red Tank adjacent to BuildingC Outside Tank Storage WP EPA 6010
WP-GT-01 Wipe sample from galvanized tank adjacent to Building C Outside Tank Storage WP Zn/Cu EPA 6010
WP-GT-02 Wipe sample from galvanized tank adjacent to building B Outside Tank Storage WP Zn/Cu EPA 6010
WT-RT-01 Runoff from Red Tank adjacent to Building C Outside Tank Storage WT Zn/Cu/TSS3 EPA 200.7/SM 2540D-2015
WT-GT-01 Runoff from galvanized tank adjacent to Building C Outside Tank Storage WT Zn/Cu/TSS3 EPA 200.7/SM 2540D-2015
WT-GT-02 Runoff from galvanized tank adjacent to Building B Outside Tank Storage WT Zn/Cu/TSS3 EPA 200.7/SM 2540D-2015
WT-BA-01 Water from channelized roof at Building A Roof Runoff WT Zn/Cu/TSS3 EPA 200.7/SM 2540D-2015
WT-BB-01 Water from channelized roof east portion of Building B Roof Runoff WT Zn/Cu/TSS3 EPA 200.7/SM 2540D-2015
WT-BB-02 Water from channelized roof west portion of Building B Roof Runoff WT Zn/Cu/TSS3 EPA 200.7/SM 2540D-2015
WT-BC-01 Water from channelized roof north portion of Building C Roof Runoff WT Zn/Cu/TSS3 EPA 200.7/SM 2540D-2015
WT-BC-02 Water from channelized roof south portion of Building C Roof Runoff WT Zn/Cu/TSS3 EPA 200.7/SM 2540D-2015
SL-BC-01 Soil sample adjacent to roof discharge at Building C Roof Runoff SL Zn/Cu EPA 6010
SL-BC-02 Soil sample adjacent to roof discharge at Building C Roof Runoff SL Zn/Cu EPA 6010
SL-BC-D-01 Soil sample adjacent to Building C in drainage area Roof Runoff SL Zn/Cu EPA 6010
SL-MA-A-01 Fines/debris adjacent to forklift path east of maintenance Maintenance SL Zn/Cu EPA 6010
s ra down area at Building A S ra down Area
WP-MA-A-02 Wipe sample black buildup on wall adjacent to maintenance Maintenance WP Zn/Cu EPA 6010
s ra down area at Building A S ra down Area
WT-MA-A-03 Runoff from Spraydown Area at Building A Maintenance WT Zn/Cu/TSS3 EPA 200.7/SM 254OD-2015
S raydown Area
EV-BC-01 Exhaust Vent on side of Building C Historical Site SL Zn/Cu EPA 6010
Operations
SL-EV-BC-01 Soil below Exhaust Vent on side of Building C Historical Site SL Zn/Cu EPA 6010
,Operations
SD-002 I Fines collected in inlet filter Outfall 002 JOutfall Sediment ISL IZn/Cu I EPA 6010
1/2

Table 1 a ARCAD I S
Sample Summary
A. O. Smith Charlotte Facility
4302 Raleigh Street
Charlotte, North Carolina 28213
Method'Sample Name Sample Description Potential Source sample media Constituents Analysis
utfall 003 Source�vestigati
WT-RD-01 1st Northern Roof Drain Building A Roof Runoff WT Zn/Cu/TSS3 EPA 200.7/SM 2540D-2015
WT-RD-02 2nd Northern Roof Drain Building A Roof Runoff WT Zn/Cu/TSS3 EPA 200.7/SM 2540D-2015
WT-RD-03 Loading Dock Roof Drain Building A Roof Runoff WT Zn/Cu/TSS3 EPA 200.7/SM 2540D-2015
WT-RD-04 Southern Roof Drain Building A Roof Runoff WT Zn/Cu/TSS3 EPA 200.7/SM 2540D-2015
WP-RD-01 1st Northern Roof Drain Building A Roof Runoff WP Zn/Cu EPA 6010
WP-RD-02 2nd Northern Roof Drain Building A Roof Runoff WP Zn/Cu EPA 6010
WP-RD-03 Loading Dock Roof Drain Building A Roof Runoff WP Zn/Cu EPA 6010
WP-RD-04 Southern Roof Drain Building A Roof Runoff WP Zn/Cu EPA 6010
SL-PL-01 Composite sample of sediment/debris in parking lot Soils/Sediment SL Zn/Cu EPA 6010
SL-LD-01 Composite ample of sediment/debris in Loading Dock Soils/Sediment SL Zn/Cu EPA 6010
SL-CT-01 Fines/debris from concrete trough west of compactors adjacent Soils/Sediment SL Zn/Cu EPA 6010
to 003
SD-003 Fines collected in inlet filter Outfall 003 Outfall Sediment SL Zn/Cu EPA 6010
Notes:
1.Water samples will be analyzed for zinc(Zn)and copper(Cu)by United States Environmental Protection Agency(EPA)Method 200.7 and for total suspended solids(TSS)by Standard Method(SM)2540D-
2015.
2.Wipe and solid samples will be analyzed for zinc(Zn)and copper(Cu)by United States Environmental Protection Agency(EPA)Method 6010.
3.If sufficient volume is present following initial sample collection,additional sample volume will be passed through 0.45-micron in-line filter to allow for analysis of dissolved Zn and Cu by EPA Method 200.7.
Acronyms and Abbreviations:
Sample Media:
WT=Water
WP=Wipe
SL=Soil or sediment
Constituents:
Zn=Zinc
Cu=Copper
TSS=Total Suspended Solids
EPA=United States Environmental Protection Agency
SM=Standard Method
2/2

Figures

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LEGEND A.O.SMITH WATER SYSTEMS
PROPERTY BOUNDARY 4302 RALEIGH STREET
CHARLOTTE,NORTH CAROLINA 28213
PIPED STORMWATER INFRASTRUCTURE
--—————-- SITE OUTFALL BASIN BOUNDARY SITE DRAINAGE
STORMWATER STRUCTURE
�# SITE OUTFALL AARCADIS I F�2RE
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CHARLOTTE,NC 28213
id- k10 THREE ON SITE OUTFACES
dMk%*1:_
LEGEND
PROPERTY BOUNDARY Background Rainfall Investigation Sample Location A.O.SMITH WATER SYSTEMS
4302 RALEIGH STREET
PIPED STORMWATER INFRASTRUCTURE • CHARLOTTE,NORTH CAROLINA 28213 Outfall 002 Investigation Sample Location
---------- SITE OUTFALL BASIN BOUNDARY
•STORMWATER STRUCTURE Outfall003 Investigation Sample Location SAMPLING LOCATIONS
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�# SITE OUTFALL c;i,ier
ARCADIS s