NC0083658_Response to Notice_20231205

CORR Environmental Resources, Inc.
December 5, 2023
Certified Mail # 7018 0040 0000 8782 3673
Return Receipt Requested
Ms. Morella Sanchez -King
Mr. Bryan Lievre
North Carolina Department Environmental Quality
Water Quality Regional Operations Section
Wilmington Regional Office
127 Cardinal Drive Extension
Wilmington, NC 28405
RECEIVEMCDENR/DWR
Water c)uamy flegional
Operations Section
Wilmington Reqionil Office
Re: Response to Notice of Violation
Tracking Number NOV-2023-MV-0194
September 2023 Discharge Monitoring Report, NPDES Permit #0083668
Daikin Applied Americas, Inc.
Former Heatcraft Remediation Site, New Hanover County
Ms. Sanchez -King and Mr. Lievre:
CORR Environmental Resources Inc. on behalf of Daikin Applied Americas, Inc (Daikin
Applied) is responding to the referenced Notice of Violation, dated November 16, 2023
concerning the September 2023 Discharge Monitoring Report (DMR) for the above
referenced facility. The Notice of Violation letter was received by Daikin Applied and
CORR via email on November 17, 2023.
The NOV references outfall 001 effluent quarterly frequency violation(s); Base Neutral and
Acid (EPA Method 625.1) effluent [76028] and Organics, Total Purgeable(s) VOCs (EPA
Method 624.1) effluent [76029]. These two laboratory tests are required to be collected
and laboratory tested on a quarterly basis.
The required Quarter 3 [August] samples were not collected as an oversight and no
explanation can be offered for the noncompliance, Previous CY-23 quarterly samples
[February and May] had been collected, analyzed, and reported as required. The
November 2023 Quarter 4 samples have also been collected and analyzed, The Quarter
4 data will be reported for the November 2023 DMR submittal.
Corrective Actions
CORR on behalf of Daikin Applied acknowledges the oversight for the Quarter 3 testing
omission and noncompliance with the NPD,ES permit conditions. CORR as the Agent
Responsible for Daikin Applied will revise the September DMR to note these effluent tests
were not performed by entering '0' under the parameter codes 76029 and 76028.
In reference to corrective measures for this noncompliance issue, there are no treatment
system operational and/or maintenance matters which require remedial actions. The
overall effluent standards and permit conditions regarding discharge water quality have
not had an exceedance for volatile or semi volatile organic constituents during the current
permit period. The two previous CY-2023 Base Neutral Acid [EPA 625.1] and Total

CORR Environmental Resources, Inc.
Ms, Morelia Sanchez -King
Mr. Bryan Lievre
December 5, 2023
Page 2
Purgeable [EPA 624.1] laboratory tests in February and May did not indicate any of the
listed constituents above the Method Quantitation Limits [MQLs]. Additionally, the
November 2023 quarterly test results also do not indicate constituent concentrations
above MQL values or permit limitations.
The permit required twice monthly effluent testing for Volatile Organic Constituents
[VOCs], tested using EPA Method 8260D, have also not indicated any listed constituents
above MQLs of 1 pg/L [ppb]; including the specific TCE and TCA effluent parameters.
These data along with quarterly required aquatic toxicity and semiannual Total Volatile
Organics [EPA 601] have effluent data results in compliance with the permit limitations.
These data provide evidence of ongoing compliance with effluent standards for treatment
and permitted discharge of remediated groundwater.
In coordination with the ORC, Stephan Tyler, we had previously posted the requirements
for effluent testing within the weekly log binder along with a copy of the full permit in the
site files. To improve scheduling visibility, we will post a dry -erase style white board within
the treatment building with monthly, quarterly, and semi-annual monitoring frequency
columns to note the time and day of sample collection on a month -to -month basis. These
frequency column blocks will also include shipping dates and tracking numbers for ease
of reference.
Project Oversiaht
Daikin Applied provides as requested budget to CORR to maintain adequate operational
oversight, maintenance, laboratory testing, DMIR preparation and submittals. These
monthly and annual recurring costs provide for as needed and as warranted repairs,
equipment replacement, troubleshooting and for labor costs and contractor charges, At
no time during the remedial actions at the site has Daikin Applied ever denied or withheld
budget requests for all operations and maintenance activities.
Absent routine maintenance tasks, the groundwater remediation treatment system has
operated in compliance with current NPIDES permit requirements and effluent limitations.
The overall responsibility of Daikin Applied is to provide as required and warranted
corrective actions and measures related directly to impacted environmental media such
as groundwater as directed by the NCDEQ Hazardous Waste Section. The primary focus
of site wide corrective measures is to return groundwater to compliance with State water
quality standards. No additional remedial construction, activities specific to the
groundwater treatment system are anticipated. Therefore, at this time, there is no
warranted need to apply for a Special Order of Consent as referenced in the NOV letter
to Daikin Applied,
NOV-2023-MlV-01 94 NC0083658

CORR Environmental Resources, Inc.
Ms. Morella Sanchez -King
Mr. Bryan Lievre
December 5, 2023
Page 3
CORR does not anticipate any issues with the treatment system and we expect to monitor
and report effluent discharge as required.
If there are any questions regarding the response to the NOV or for the site in general,
please contact me at 972-523-0487 or by email at correri(a).frontier .com.
Cordially,
CORR Environmental Resources Inc.
Raymond Roblin, PG
Principal
Cc: Mr. Donald Rooks — DAA
Site File
A&T Services
for
Stephan Tyler LG
Operator Responsible in Charge
NOV-2023-MV-0194 NCO083658