NCS000040 Staff Report May 2009

N�S000040
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
Facility Name:
NI'I)ES Permit Number:
Facility Location:
Type of Activity:
SIC Code:
Receiving Streams:
River Basin:
Stream Classification:
Proposed Permit Requirements:
Monitoring Data:
Response Requested by (Date):
Central Office Staff Contact:
Special Issues:
STAFF REVIEW AND EVALUATION
NPDES Stormwater Permit
Charlotte Pipe & Foundry Co
NC:S000040
1335 South Clarkson Street, Charlotte, NC (Mecklenburg County)
GRAY AND'DUCTILE IRON FOUNDRIES
3321 -
See Figure 1
Catawba River Basin, Sub -basin 03-08-34 rc e
C
See attached draft permit.
See Table 1
Return to: Brian Lowther, [phone]
Issue
Rating Scale: l(easy) to 10(hard)
Compliance history
6
Benchmark exceedance
7
Location (TMDL, T&E
species, etc
7
Other Challenges:
• Missing data
6
Difficulty Rating:
26/40
Special Issues Explanation:
Many analytical monitoring values are over the current benchmarks for Cr, Cu, Pb, Ni, Zn, TKN, COD and
TSS.
Description of Onsite Activities:
• The CP&F facility is located at 1335 South Clarkson Street in Charlotte, NC. The facility is on
approximately 35 acres and has numerous buildings. Total impervious area (parking lots, buildings,
roadways, etc.) is estimated at 95 percent of the total site area. The facility has been operating as a pipe
foundry since 1926 at this location and currently has 475 employees. Plant operations typically occur 24
hours a day, 5 days a week. The facility is engaged in the manufacture of cast iron piping and fittings.
The facility's SIC code is reported as 3321. The facility stores and distributes the following raw materials:
cast iron scrap, coke, coal, limestone, quartz, sand, silicon, bentonite, petroleum -asphalt, gasoline and
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NCS000040
diesel fuel. (Information from inspection report, 05/08/06)
Documents Reviewed:
• NPDES Stormwater Permit Application Materials
• National Heritage Program (NHP) Threatened and Endangered Species Database
•
SPIT File
• Central Files
• EPA Sector -Specific Permit, 2008
• 303(d) List, 2006 final
• 2004 Catawba Basinwide Plan
History:
• August 31, 1994: Date permit first issued. Analytical monitoring parameters included COD, TSS, Total
Kjeldahl Nitrogen, Total Chromium, Total Copper, Total Recoverable Lead, Total Nickel, Total Zinc and
Phenols. Samples were to be taken annually.
• Febivaiy 19, 1999. Petinll teiiewal leinnidei leaet.
• December 3, 1999: Date permit re -issued. Analytical monitoring parameters included COD, TSS, Total
Kjeldahl Nitrogen, Phenols, Total Copper, Total Recoverable Lead, Total Nickel, Total Zinc and Total
Chromium. Samples were to be taken annually for the first three years and quarterly during the 4 1 year.
• May 3, 2004: Permit renewal reminder letter.
• July 7, 2004: Date permittee submitted renewal application.
• April 5..2006,: Site visit by Mr. Donald Ceccarelli of the Mecklenburg County Water Quality Program
:(MCWQP).
e :.May 8, 2006:'Notice of Violation.
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Figure 1: Map of Facility
Page 3 of 9
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NCS000040
Charlotte Pipe & Foundry Co
Latitude: 3511 13' 28" N
Longitude: 80° 51'42" W
County: Nieddenburg
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Recdving Stream: Irwin Creek
d
Stream Class: C
S
Sub -basin: 03-08-34 (Catawba River Basin)
Facility Location
Map Seale 1;24,000
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NCS000040
Central Office Review Summary:
1. Owner's Other Permits:
• AFS — 3711900626
• NCG500117
RCRA NCD980247316
2. General Observations:
• Outfalls: Stormwater runoff from the main manufacturing plant discharges via three stormwater
outfalls (SW001, SW002, SW005) across I-77 and ultimately to Irwin Creek. Tow other outfalls (SWO03,
S W004) have been identified as intermediate outfalls for sampling purposes.
- S W001: This outfall drains approximately 7.2 acres of the southwestern portion of the facility that
contains the wastewater treatment plant, fitting storage area, scrap iron storage area and the cupola
bag houses. This outfall also drains several off-site properties up gradient of the CP&F facility.
The drainage area is approximately 95% impervious.
- S W002. This outfall dialus appioxiinately 3.1 acres of ilie central portion of the facility, which
contains the main raw material unloading area, machine shop, shell cure building, and cupola
furnace building. The drainage area is approximately 95% impervious.
- SWO03: This outfall is located up gradient of the facility and was historically used to sample off-
site water that flowed onto the property for purposes of comparing influent stormwater samples at
SWO03 to effluent stormwater samples at SW004. However, CP&F determined that SWO03 was
not collecting the major portion of the influent stormwater and this is no longer sampling.
- SWO04: This outfall drains approximately 11.1 acres of the western portion of the facility that
contains the fueling station, fuel storage tanks, maintenance shop, bulk spent material storage area,
pipe production building, pipe coating building, the hot dip coating area, and serves as the permitted
discharge pipe for non -contact cooling water. This outfall also drains many offsite properties up
gradient of the facility. The drainage area is approximately 95% impervious.
-S W005: This outfall drains approximately 2.5 acres of the northwestern portion of the site, which
contains the hot dip collectors and the fittings tar pit building. In addition stormwater from SWO04
flows into SWO05 at Clarkson Street. The drainage area is approximately 95 percent impervious.
After the application was filed the facility purchased more property and there are now a total of seven
outfalls now: 001 (35° 13'27", -80° 51'51"), 002 (35° 13'29", -801 51'49"), 002A (35° 13'23", -800
51'42"), 004 (35° 13'27", -800 51'39"), 005 (35° 13'29", -800 51'41"), 006 (350 13'34", -80° 51'45"), and
007 (350 13'34", -800 51'39").
3. Impairment: Irwin Creek is on the 303(d) list for standard violations for turbidity and fecal coliform, as well
as, having impaired biological integrity. Basinwide Plan recommendations include:
Current Status and 2004 Recommendations
The Irwin Creek site is showing a slight trend of lowered conductivity since the middle 1990s. There is a Fecal
Coliform Bacteria TMDL for Sugar Creek, Irwin Creels, Little Sugar Creek and McAlpine Creek. The TMDL
addresses all identifiable sources of fecal coliform pollution including, but not limited to, wastewater treatment
plants, sanitary sewer overflows, stormwater runoff, failing septic systems, and background wildlife
contributions. The TMDL study indicated that excluding stormwater runoff, the primary contributors of fecal
coliform pollution in this watershed are point sources (WWTP, etc.) and direct input nonpoint sources (failing
septic systems).
4. Threatened and Endangered: Based on the Natural Heritage Virtual Workroom there is one federally
endangered species within 2 miles of the facility: Lasmigone decorata, Carolina Heelsplitter. More information
was provided that showed the element occurrence ranking as X — Extirpated. The most recent survey date was
1987 indicating the Carolina Heelsplitter used to be located in Irwin Creek but no longer exists there.
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NCS000040
5. Location: Drains to a classified C stream. The inspection report indicated the site map needed to be updated.
6. Industrial Changes Since Previous Permit: None provided in renewal application.
Analytical Monitoring: Analytical monitoring parameters included COD, TSS, Total Kjeldahl Nitrogen,
Phenols, Total Copper, Total Recoverable Lead, Total Nickel, Total Zinc and Total Chromium. Samples were
to be taken annually for the first three years and quarterly during the 4t" year. The application only included
one sample for each ou fall. The samples had values over our current benchmarks f'or Cr, Cu, i'b, Ni, Zn,
Phenol, COD and TSS. The data was missing information such as total rainfall, event duration, and estimated
flow.
This industry (SIC 3321) is covered in the EPA Multi -Sector General Permit under Subsector F2, Iron and
Steel Foundries. The parameters recommended for monitoring include Total Aluminum, TSS, Total Copper,
Total Iron, and Total Zinc.
The inspection report indicated the facility uses more than 55 gallons of new motor oil and therefore should
have done analytical monitoring under Part II Section D of the pen -nit. CP&F personnel indicated that more
than 55 gallons of now motor oil woro usod but no records of quantities havo boon kept
Oil and Grease was added to the monitoring because it is a potential pollutant onsite.
Another set of values was sent from at storm event on February 26, 2008. Many values are over the current
benchmarks for Cr, Cu, Pb, Ni, Zn, TKN, COD and TSS.
8. Qualitative Monitoring Notes: No visual monitoring was provided. An inspection report was given instead.
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.I NCS000040
Revised Permit Recommendations: Analytical Monitoring:
1. Maintain monitoring for COD, TSS, Total Kjeldahl Nitrogen, Phenols, Total Copper, Total Recoverable
Lead, Total Nickel, Total Zinc and Total Chromium. Oil & Grease has been added to the monitoring.
2. pH has been added to the analytical monitoring requirements.
3. All analytical monitoring has been set to semi-annually during a representative storm event as defined in Part II
Section B. The permittee must also document the total precipitation for each event. If no discharge occurs
during the sampling period, the permittee must submit a monitoring report indicating "No Flow" within 30 days
of the end of the six-month sampling period. Additionally, samples must be taken a minimum of 60 days apart,
as specified in Table 2.
4. Benchmarks for analytical monitoring have been added to this draft permit. Exceedances of benchmark values
require the permittee to increase monitoring, increase management actions, increase record keeping, and/or
install stoiznwater Best Management Practices (BMPs) in a tiered prograin. If the sampling results are above a
benchmark value, or outside of the benchmark range, for any parameter at any outfall then the facility shall
follow the Tier t guidelines which require a facility inspection within two weeks and implementation of a
mitigation plan within two months. If during the term of this permit, the sampling results are above the
benchmark values, or outside of the benchmark range, for any specific parameter at a specific discharge outfall
two times in a row (consecutive), then the facility shall follow the Tier 2 guidelines which require a repetition
of the steps listed for Tier 1 and also immediately institute monthly monitoring for all parameters at every
outfall where a sampling result exceeded the benchmark value for two consecutive samples.
5. The permittee is required to collect all of the analytical and qualitative monitoring samples during
representative storm events as defined in Part lI Section B. Qualitative monitoring is required regardless of
representative outfall status.
6. The permittee is responsible for all monitoring until the renewal permit is issued. See Footnote 1 of Tables 1,
4, and 5.
7. The flow reporting requirement has been removed per DWQ revised strategy. (The total rainfall parameter is in
this permit, however.)
8. Vehicle maintenance monitoring has been revised to semi-annually in order to coincide with analytical and
qualitative monitoring.
Other Proposed Changes to the Previous Permit:
1. Additional guidance is provided about the Site Plan requirements. The site map must now identify if the
receiving stream is impaired and if it has a TMDL established. It must also describe potential pollutants in each
outfall. The map requirements are stated more explicitly. And, the site plan must contain a list of significant
spills that have occurred in the past three years and also must certify that the outfalls have been inspected to
ensure that they do not contain non-stormwater discharges. Additional information is provided in Part I1
Section A.
2. Additional requirements for the Stormwater Management Plan have been specified in Part II Section A. More
details regarding secondary containment are provided.
3. Additional requirements for the Stormwater Pollution Prevention Plan have been specified in Part 1I Section A.
The plan must also be updated annually to include a list of significant spills and to certify that the outfalls do
not contain non-stormwater discharges.
4. The facility must now implement a semi-annual Facility Inspection Program of the site's stonnwater
management controls as specified in Part II Section A.
5. Information regarding the No Exposure Exclusion has been added to this draft permit. If industrial materials
and activities are not exposed to precipitation or runoff as described in 40 CFR § 122.26(g), the facility may
qualify for a No Exposure Exclusion from NPDES stormwater discharge permit requirements. Additional
information is provided in Part I Section A.
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Discussions with permittee: David Waggoner, 704-332-2647, 03/19/09
1. General description of industrial activities. Grey metal pipe foundry. Use recycled material. Melt iron and
then cast pipes and fittings.
2. Have there been any changes in industrial activities since the application was submitted? Yes. Will be
submitted in an email.
3. What is Outfall 002A? Outfall close to 002. There are seven outfalls now.
4. The inspection report for a 2006 visit indicated that the site map and SPPP needed to be updated. Has this been
done? Can you send us the map? They have been updated. Will send a copy of the site map.
5. Do you have onsite vehicle maintenance? Yes. All maintenance is done inside. The area has French drains that go
directly to the sewer system.
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r. NES000040
Recommendations: Based on the documents reviewed, the application inforination submitted on July 4, 2004
sufficient to issue an Individual Stormwater Permit.
Prepared by (Signature) �-- Date
.,/
Slormwalei Permitting UnA Supervisor Z: �� Date 3 AG
for Bradley Bennett
Concurrence by Regional Officeiw Date 5 U i
RO Water Quality Supervisor 174 - 3 4---- Date
Regional Office Staff Comments (attach additional pages as necessary)
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NCS000040
Site inspection conducted on May 6, 2009 by Michael Parker. Facility contact: David Waggoner.
Current NPDES SW permit expired in 2004. Area had received significant rainfall the evening prior to
the site visit. Charlotte Pipe and Foundry (CP&F) is presently operating on a reduced schedule (3 — 4
days per week) due to depressed economic conditions. The site is located in a heavily commercial and
industrialized area of downtown Charlotte.
The SW drainage system at this site was installed back in the 1920's when the company located to this
site. The existing SW drainage system not only serves CP&F, but also receives SW from other
businesses and commercial property adjacent and upgradient to the CP&F site. Some of these off-site
properties have been found to have significant soil and GW contamination, and on-going remediation
activities are being conducted. Such being the case, the possibility exists that some of these
contaminants may be entering the S W collection system that passes through the CP&F property via 1/1.
CP&F personnel have not verified (through analytical testing) that upstream contaminants are entering
their SW system, however, it was suggested during the site visit that additional testing be conducted of
the upstream SW drainage system to ascertain the impacts (if any) these upgradient properties may be
having on contaminant levels found in the SW sampling data collected by CP&F.
Analytical testing reviewed during the site visit indicated that CP&F will have difficulty iii complying
with the benchmark levels proposed in the new SW permit based on testing conducted at the SW
outfalls located at this site. If the current benchmark values.noted in the draft permit are incorporated
into the final permit, CP&F will likely be subject to Tier II and Tier. III monitoring requirements during
the first rainfall event. Such being the case, consideration should be given to either modifying the
current benchmark values or consider the inclusion of a compliance schedule to allow CP&F to
implement BMPs that may help reduce the off-site migration of pollutants. It should also be noted that
CP&F plans a major site construction project in 2009, which will result in a substantial portion of the
property covered under a metal roof. The area to be covered is suspected to be a significant source for
pollutants found in CP&F SW sampling data. If a compliance schedule is incorporated into the
renewed permit, the completion schedule of this project should be taken into consideration.
Since the original renewal application was received in 2004, there has been additional property added
to the CP&F site on both the north side and the east side. This additional property also includes SW
outfalls that may have not been reflected in the original renewal application. It is suggested that an
updated renewal application be provided including a revised site map that indicates the current
property boundaries and existing SW outfalls. It is also recommended that use of SW outfall 004 be
discontinued since it eventually flows through outfall 005, which is currently monitored and outfall
007 be eliminated as it does not receive SW from the industrial process/storage areas.