NC0083658_Response to Notice_20180620

Environmental Resources, Inc.
June 15, 2018
Certified Mail #70142120000272179342
Return Receipt Requested
Mr. Dean Hunkele
North Carolina Department Environmental Quality
Water Quality Regional Operations Section
Wilmington Regional Office
127 Cardinal Drive Extension
Wilmington, NC 28405
Re:
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Response to Notice of Violation & Intent to Assess Civil Penalty
Tracking Number NOV-2018-LV-0403
April 2018 Discharge Monitoring Report, NPDES Permit #0083658
Daikin Applied Americas, Inc.
Former Heatcraft Remediation Site, New Hanover County
Mr. Hunkele:
CORR Environmental Resources Inc. on behalf of Daikin Applied Americas, Inc (DAA) is
responding to the Notice of Violation and Intent. to Assess Civil Penalty, dated June 5,
2018 concerning the April 2018 Discharge Monitoring Report (DMR) for the above
referenced facility. The Notice of Violation letter was received by CORR on June 11,
2018.
The Violations listed reference Limit Exceedance Violations for outfall 001 effluent for
Trichloroethene (TCE-78391) for both daily maximum and monthly average exceeded.
The correspondence is presented to provide information concerning system operations,
laboratory testing data and ongoing compliance with the effluent limits for TCE.
The April 2018 discharge flow rates and pH values were compliant with the NPDES permit
limits. The first of the two required effluent samples for TCE indicated a concentration of
0.64J ug/L (ppb) while the second sample result indicated anon -complaint concentration
of 14.6 ug/L. Prior effluent samples collected in both calendar years 2017 and 2018 had
not indicated a concentration of TCE above 1.0 ug/L for all samples collected. These
results had not provided any indication of system operational issues in reference to
adequate influent treatment to permit limits or standards. With the issuance of the permit
renewal in March 2017 and the required twice monthly testing, no effluent limit was
exceeded. All quarterly aquatic toxicity testing also indicated Pass results.
The April 23 non-compliant result, upon receipt of the analytical test report, was reported
to the NCDEQ regional office to the attention of Mr. Dean Hunkele via email on May 3,
2018. An effluent sample was collected on May 3 and the laboratory test result indicated
a compliant result of 1 ug/L (ppb). This result was reported to Mr. Hunkele via email on
May 11, 2018.
4609 Candlestick • Garland, Texas 75043 • Phone [phone] . Fax [phone]
Email: [e-mail]

Environmental Resources, lnc,, Mr. Dean Hunkele
June 15, 2018
Page 2
The cause of the non-compliant result is unknown; previous historic analytical testing data
had not indicated TCE at concentrations above 1 ug/L. Subsequent effluent testing also
indicated compliance with the permit limit for TCE in the two May 2018 tests. These data
denote the physical/chemical treatment unit had been operating properly and within
manufacturer specifications absent the single elevated effluent concentration for the
testing on April 23, 2018.
CORR reviewed the analytical testing report in reference to surrogate recoveries and the
percentage brackets for the four tested compounds. The report indicated three of four
chemical concentration recoveries were above 100%. Specific to chlorinated constituents,
one of the four chemicals tested for surrogate recovery was 1,2 Dichloroethane (1,2 DCA).
The surrogate recovery for 1,2 DCA was reported at 124% which was only 1 % below the
upper limit of 125% for the test result to be considered within laboratory standards. In
reference to the April 23rd TCE result, there is likelihood the reported concentration of 14.6
ug/L could be slightly elevated. This observation, based on the high surrogate recovery
value of approximately --25%, would not however reduce the reported TCE concentration
to a value equal to or below the effluent permit limit. CORR considers the reported
analytical testing data to be valid.
Corrective Actions
CORR on behalf of Daikin Applied has endeavored to maintain compliance with the permit
limits for both maximum and average TCE concentrations. These included more frequent
cleaning and operational checks by the licensed Operator Responsible in Charge (ORC)
since the permit renewal and the lower TCE effluent limit. The treatment system lift station
and accumulation tanks were cleaned in mid-March 2018 of sediments and biomass
solids. The lift station tank also had the transfer pump and motor replaced during this
work task. Treatment vessel perforated air stripping trays were also removed and cleaned
at that time. The air stripping trays had their felt gasket inspected and replaced as
warranted along with the front door seals. Subsequent to these work tasks effluent test
results did not indicate TCE above 1 ug/L for the March and the initial April effluent tests.
Operational solutions to a one-time effluent exceedance where laboratory data during the
previous full year period were compliant are inherently difficult to troubleshoot. In
response to the April 23 analytical result, the ORC fully inspected the system as previously
stated and moderately decreased the influent flow rate in an attempt to increase residence
time for groundwater treatment within the system prior to discharge.
In discussion with the ORC, Mr. Steve Tyler, he communicated to CORR there were no
obvious system maintenance issues based on his evaluation of all system components.
Influent and effluent piping runs were/are sealed with no visual leakage. The air blower
systems were/are operating as expected also with no visual or observed leakage. Interior
treatment vessel air pressures were within operational ranges. CORR believes no
operational issues with the daily functions could be identified as the specific cause of the
exceedance. Twice weekly ORC site visits are undertaken to confirm compliance
concerning system operations, effluent sampling/testing and effluent standards.
NOV-2018-LV-0403 NCO083658

Environmental Resources, Inc. Mr. Dean Hunkele
June 15, 2018
Page 3
In reference to the twice monthly sampling and the requirement to collect effluent samples
at least 10 -days apart, the ORC will, going forward, adhere to this required schedule. The
ORC will collect the initial monthly sample no later than the end of the first week of the
month and then collect the second sample as required by the permit no sooner than the
10 -day period.
Daikin Applied provides as requested budget to CORR to maintain adequate operational
oversight, maintenance, laboratory testing, DMR 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 taken at the site , has Daikin Applied ever denied or
withheld budget requests for any and all operations and maintenance activities.
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 and
Federal water quality standards. Therefore, no pollution prevention strategy can be
undertaken to limit the corrective actions currently operating at their former manufacturing
property. 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.
CORR does not anticipate any further issues with the treatment system and expect to
have effluent discharge concentrations for the permitted constituent to remain below the
effluent limit for daily and monthly averages.
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(abfrontier.com.
Cordially,
CORR Environmental Resources Inc.
Raymond Roblin, PG
Principal
Cc: Paul Heim — DAA
Site File
NOV-2018-LV-0403
A&T Services
/Z lal-01M
.p Steve Tyler
°v Operator Responsible in Charge
NCO083658