NCG030727_Tier 3 Action Plan_20240506

Peterson, Kathryn S
From: Peterson, Kathryn S
Sent: Monday, May 6, 2024 2:26 PM
To: Denise Prescott; Eplin, Jerry W
Cc: John Bailey; Mandy Tzannis
Subject: Re: [External] Action Plan - Kelly Pipe, LLC—COC NCG030727
Mandy:
DEQ approves the proposed Tier 3 action plan for Kelly Pipe, LLC. Please keep us updated with any
changes.
Denise:
DEQ has received your notification of benchmark exceedance for TSS at Outfall 002. Continue to follow
procedures listed in Table 3:Tier One Response for a Benchmark Exceedance of General Permit No.
NCG03000 COC NCG030727. Let us know if you need any technical assistance.
Best,
Kathryn
Kathryn Peterson
Assistant Regional Engineer
North Carolina Department of Environmental Quality
Division of Energy, Mineral and Land Resources
Office: [phone]
Mobile: [phone]
Email: [e-mail]
Mooresville Regional Office
610 East Center Avenue, Suite 301
Mooresville, NC 28115
j
' TH AROL
M HPVjlortmertl al�lr, y
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From: Denise Prescott<[e-mail]>
Sent:Thursday, April 25, 2024 2:43 PM
To: Peterson, Kathryn S<[e-mail]>; Eplin,Jerry W<[e-mail]>
1

Cc:John Bailey<[e-mail]>; Mandy Tzannis<[e-mail]>
Subject: RE: [External]Action Plan - Kelly Pipe, LLC—COC NCG030727
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
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Dear Ms. Peterson, and Mr. Eplin,
Kelly Pipe (COC NCG030727) is providing email notification as required by NCG030000 as per benchmark
exceedances.
Kelly Pipe has become aware of benchmark exceedances for TSS at Outfall 002 for the samples collected on
March 27t". (results received April 13tn)
This will put our facility in a Tier One Stormwater Permit Status for TSS at Outfall 002.
The lab report dated 3/27/24 indicated a TSS concentration of 118 mg/I (benchmark is 100 mg/I) for Outfall 002.
We have previously submitted an action plan for the Tier Three status for Zinc on Outfall 003 and are currently
waiting on states approval to implement the plan.
Thank You,
Dev.%se Prescott
Kelly Pipe—Admin/Acct Assistant
11024 Nations Ford Rd.
Pineville, NC 28134
Office 704-504-3302 Ext 3516
2

CDG
4301 Taggart Creek Road March 25, 2024
Charlotte,NC 28208
Tel[phone] Zahid Khan
NC License No.C-4973 Regional Engineer,Land Quality Section
SC COA No.7171 Energy, Mineral,and Land Resources
North Carolina Department of Environmental Quality
cdge.com Mooresville Regional Office
610 East Center Avenue,Suite 301
Mooresville,North Carolina 28115
[e-mail]
Re: Tier Three Action Plan, First Quarter 2024
Kelly Pipe,LLC—Pineville,NC
Certificate of Coverage NCG030727
Dear Mr. Khan,
On behalf of Kelly Pipe, LLC (Kelly Pipe) — Pineville facility, CDG, Inc. has
prepared and is submitting the attached Tier Three Action for your approval in
accordance with NPDES Industrial Stormwater Permit NCG030000, Part E-7
for First Quarter, 2024. The cover page of the report contains the required
certification by Kelly Pipe's responsible official. If you have any questions
regarding this Action Plan, please contact us at [phone] or Ms. Denise
Prescott with Kelly Pipe at [e-mail].
Sincerely,
CDG, Inc.
<r'
agdalEine 'zannis 4Mfellinn' a M. Greene
Team Leader Project Manager
cc: Denise Prescott-Kelly Pipe,LLC Pineville, NC
Jerry W. Eplin,PE-NCDEQ Mooresville,NC

k elly;-" pipe
7�`L ULTIMATE SOURCE
Kelly Pipe Company, LLC
11024 Nations Ford Road
Pineville, North Carolina
Certificate of Coverage NCG030727
Tier Three Action Plan, First Quarter 2024
In compliance with General SW Permit NCG030000, Part E-7
Prepared by:
CDG
4301 Taggart Creek Road
Charlotte, NC 28208
CDG Project No. R990156448
March 25, 2024
I certify by my signature below, under penalty of law, that this document and all attachments were
prepared under my direction or supervision in accordance with a system designed to assure that
qualified personnel properly gather and evaluate the information submitted. Based on my inquiry
of the person or persons who manage the system, or those persons directly responsible for
gathering the information, the information submitted is, to the best of my knowledge and belief,
true, accurate, and complete. I am aware that there are significant penalties for submitting false
information, including the possibility of fines and imprisonment for knowing violations.
3/28/24
John Bai(ey Date
Facility Kelly Pipe, LLC NCG030727
SDO 002
Parameters Zinc
Date Prepared 3/25/2024

Kelly Pipe, LLC—Pineville, NC Page 2
Tier Three Response Action Plan March 25 2024
INTRODUCTION
This Action Plan has been prepared in accordance with Part E-7(b) of General Permit for
benchmark exceedances which have triggered Tier Three Response. This Action Plan addresses
Zinc Tier Three Response.
ACTION PLAN ELEMENTS
The General Permit, Part E-7(b), requires that specific elements be addressed. Each of these
elements are being addressed as follows:
L Documentation of the Four Benchmark Exceedances
The table below documents the last 4 benchmark exceedances for Zinc at SDO 002:
Zinc benchmark=0.126 mg/L
Month 5/27/2023 8/3/2023 1/9/2024 2/12/2024
SDO 0.250 0.140 0.550 0.240
#002
ii. An Inspection report that covers the industrial activities within the drainage area of the
SDO with the exceedances (including the date of the inspection and the personnel
conducting the inspection)
See attached inspection report. The inspection covered all areas of industrial activity in the
drainage areas that drain SDO 002 as well as SDO 001 and 004. The drainage area for SDO
002 consists of a single stormwater inlet which collects stormwater from the manufacturing
building roof and directs the flow through a 12-inch pipe towards the northwest side of the property
to SDO 002. Part of the grassy area located NW of the manufacturing building and the roof for
approximately half the manufacturing building are associated with SDO 002.
A site map is attached for reference of the drainage area.
iii. An evaluation of standard operating procedures and good housekeeping procedures
Kelly Pipe has evaluated its standard operating procedures applicable to the potential for
pollutants to reach stormwater as well as its good housekeeping procedures related to industrial
activities in the drainage area for SDO 002. Any recommendations for improvements in these
activities are described in the attached inspection report or in (v) below.

Kelly Pipe, LLC—Pineville, NC Page 3
Tier Three Response Action Plan March 25 2024
iv. Identification of the source(s) of exceedances
Kelly Pipe has identified sources that may be contributing to the exceedances. The following
causes have a high potential to effect Zinc concentrations in stormwater discharged from SDO
002 and contribute to benchmark exceedances:
Potential Cause of Benchmark Location(s) Potential SDO(s)
Exceedance Pollutant Affected
Galvanized Pipes exposed to Along grassy swale, NW of Zinc 002
stormwater manufacturing building
Sediment Build Up 12 inch 2i e - sampling oint Zinc 002
Metal Roof NW half of roof Zinc 002
v. Specific actions that will be taken to remedy the identified source(s)with a schedule
for completing those actions
CDG believes that relocating the galvanized pipes will assist Kelly Pipe in making progress
towards meeting the benchmark.
ACTIONS SELECTED FOR IMPLEMENTATION BY SITE SCHEDULE FOR
COMPLETION
1. Move any galvanized pipes away from the grassy April 5, 2024
area NW of the manufacturing building, either
indoors if space is available or in the drainage area
of SDO 004 (retention pond)
2. Reach out to contractor to assess the sediment Initial engagement with
build up in 12-inch pipe (and potential clean-out) contractor by April 5, 2024
vi. A monitoring plan to verify that the Action Plan has addressed the source(s).
Kelly Pipe will attempt to sample SDO 002 at least monthly until three consecutive samples for
Zinc are below the benchmark value. In the event a sample cannot be collected during a month,
Kelly Pipe will document the reasons as to why a sample could not be collected. Kelly Pipe will
continue routine facility inspections to ensure the effectiveness of the implemented actions and
identify any new potential causes or contributors to the benchmark exceedances.
ATTACHMENTS:
Stormwater Management Inspection (Zinc, SDO 002)
Site Map

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Worksheet 5
Stormwater Industrial Routine Facility Inspection Checklist
General Information
Facility Name: Kelly Pipe Co.,LLC
NPDES General Permit COC Number: NCG030727
Date of Inspection fq a y Start Time c ��
Inspector's Name(s) I.St
Inspector's Affiliation 7 F
Weather Information
eElEl ❑ther at time of this inspection?
ear ❑Cloudy Rain Sleet Fog ❑Snow ❑High Winds
Other: Temperature:
Are there any discharges occurring at the time of inspection?❑Yes 4ro
If yes,describe:
Control Measures
The structural storm water control measures are identified in your SWPPP on your site map and all structural and
non-structural control measures are described in your SWPPP. Corry a copy of the site map with you during your
inspections. This list will ensure that you are inspecting all required control measures at your facility.
Control Measure Control FRRepairor
o,In Need of Corrective Action Needed and Notes
Measure is intenance, (identify needed maintenance and repairs,or
Operating any failed control measures that need
Effe vely? Replacement? replacement)
A Grassy swale NW of Mfes ❑No ❑Maintenance
manufacturing ❑Repair
building. ❑Replacement
B Detention 4Kes ❑No ❑Maintenance
Pond/Sand Filter ❑Repair
❑Replacement
C Stormwater inlet in es ❑No aintenance G/C�y�L[ pA_4 �ft
SDO 001. ❑Repairtnd
❑Replacement
D Stormwater inlet in es ❑No ❑ Maintenance
SDO 004. ❑Repair
❑Replacement
E Vegetative strip es ❑No ❑Maintenance
along NW site of ❑Repair
facility property. ❑Replacement
F General es ❑No ❑'Wlaintenance -070 4. -,d awn
Housekeeping ❑Repair f-CX-6-nU.PIfU,r4 �A//�
❑Replacement
G Spill Response Kit 2fes ❑No N/A
❑Yes ❑No ❑Replacement
Last Update:11.1.2023

Areas of Industrial Materials or Activities exposed to stormwater
The areas of industrial materials or activities as identified on your site map and listed in your SWPPP. Carry a copy
of the site map with you during your inspections. This list will ensure that you are inspecting all required control
measures at your facility.
Area/Activity Inspected? Controls Corrective Action Needed and Notes
Adequate
(effective&
operating)?
1 Loading/Unloading Yes No ❑ N/A Illes ❑No
Dock.
2 Diesel Fuel tank(500-g, Wes ❑No ❑ N/A es []No
double walled).
3 Pipe laydown areas iZes ❑No ❑ N/A es ❑No
(SDO 001,002,and
gravel).
4 Outdoor containers, es ❑No ❑ N/A es ❑No
bins,roll-offs(trash,
recycling,scrap)
5 ❑Yes ❑No ❑ N/A ❑Yes ❑No
6 ❑Yes ❑No ❑ N/A ❑Yes ❑No
7 ❑Yes ❑No ❑ N/A ❑Yes ❑No
8 ❑Yes ❑No ❑ N/A ❑Yes ❑No
9 ❑Yes ❑No ❑ N/A ❑Yes ❑No
10 ❑Yes ❑No ❑ N/A ❑Yes ❑No
Add notes below as necessary to describe any additional observations not described above.
INSPECTOR'S SIGNATURE p��(�, n I a,,,.,
Print name an itle: V� S( 6 ,1�M1� S� �&M �f�J'►
Signature: Date: pl /
Last Update: 11.1.2023

NOTE: OUTFALL DRAINAGE FLOWS TO g
LEGEND UNNAMED TRIBUTARY(APPROXIMATELY
450 FT) AND THEN TO SUGAR CREEK 8
DIESEL TANK (APPROXIMATELY 1 MILE DOWNSTREAM)
❑T TRASH/RECYCLE
❑s SCRAP METAL
7 PIPE STORAGE ooa (R
© LOADING/UNLOADING
R SPILL KIT
® STORMWATER INLET
O STORMWATER MANHOLE
® STORMWATER OUTFALL •�
ooz
STORMWATER PIPE(CMP)
3
--� DIRECTION OF STORMWATER 001 '
_ FLOWARROW
UNNAMED DITCH
PROPERTY LINE DT P
ASPHALT BERM/CONC.DITCH
= SDO 001 _
EDO 002 58E` °tea
rn P �♦ I `tl x a o6
4 ~
25 L I P P
g K fly Pipe Co.,LLC
Drainage Estimated% SDO Coordinates LP — L
Outfall Area
Impervious (deg,min,sec)
g (Acres) - T
fi
SDO ODl 1.02 100.0% N 35°CG 50.r; _ { _ L
W 80'S0'S2.6"
N 35°06'50.91; o o c '`o
' SDO 002 0.35 100.0% Wes,�,52 d, _ SHEETTT-E:
SDO 004 2.20 64.0% N 35°06'53ff; pirveviuE rvc
�? WW 54'51.0"
0 30 60 120
SITE MAP
D
e NOTE: FIELD INSPECTION CONDUCTED ON SHEET:
3 (IN FEENOVEMBER 1,2023. =
1"=60. FIG 2
60'