NCS000040 Review Document

Last update: 9/19/2018
NC Division of Energy, Mineral and Land Resources
Review for Permit Renewal — NCS000040
Charlotte Pipe & Foundry Co.
Charlotte, NC
Facility Activities and Process - SIC 3321— Grey and ductile iron foundries. Facility has been at this location since 1926.
Manufacture cast iron piping and fittings. Store and distribute cast iron scrap, coke, coal. Limestone, quarz, sand, silicon,
bentonite, petroleum -asphalt, gasoline and diesel fuel.
Monitoring — The facility has been monitoring for TSS, COD, TKN, Phenols, Cu, Pb, Ni, Zn, Cr, 0&G, and pH. Previous
permit did have tier system.
o Data from 2009 — 2017 (in renewal app) shows multiple benchmark exceedances for Cu and Zn at all outfalls. In
addition there are a few TSS and COD exceedances at various outfalls. Outfall SW005 has CU, ZN, Pb, TSS and COD
benchmark exceedances. ** Note that these values were compared to current benchmark numbers which are higher
for most metals parameters than had appeared in the 2009 permit. So according to the permit they may have had
more exceedances. Sample results at 001, 002 and 004 have values that have been deducted from upgradient
outfalls. Need to better determine how this process works.
0 0&G, Cr, TKN, Ni and Phenols do not appear to have had results above the benchmark levels. Propose to remove
these parameters.
o Parameters remaining in the permit — TSS, COD, Cu, Pb, Zn, and pH.
o Tier structure adjusted to have the three levels as in current permits.
o Parameter codes added to permit.
Discussions with Facility — Email to Jenny Pappalardo and David Waggoner on 8/7/2018, wait for response back on
conference call time. Call on 8/10 from Jenny. Touched base 8/22 and she will set up call with her and her boss for wk of
8/27 — she will email — 8/27 @ 1:30.
8/27 - Call with Jenny and David Waggoner — Discussed current outfalls and where they are and aren't? Seems that some
issues on outfalls need to be discussed at the site visit. Areas noted on the plans (I through VII) do not seem to
completely match up with specific outfalls. With the loss of property to DOT south of the railroad tracks some storage
moved to area I. Outfall in this area moved to 006A location instead of 006. Outfall 005/005A needs discussion about
sampling point during site visit. Current location doesn't get much flow. Discussed the notations on DMRs related to
values being "net deductions from upgradient outfalls. This applies to outfalls 001, 002 and 004. Appears that this is
because there are dry weather flows from off site that make it into their system (most likely groundwater) that they
need to account for. They monitor these and have been reducing the concentrations at their outfalls based on the
upgradient monitoring. Question how they net out the upgradient concentration?
No major changes since the renewal application other than aggregate storage that was added in compliance with a
special condition of the 2009 permit. Application mentions change from an asphalt emulsion dip line process to e -
coating. The facility does still have some asphalt based processes but noted that any spills with these would not produce
much impact because the material would not travel far. Facility still has issues with some metals (Zn, Cu, etc.) but the
change in benchmark values (metals values increasing from last permit) may have an impact on the number of
exceedances. Discussed these changes in the permit, they were aware that the benchmark numbers would increase.
Noted in the call that Irwin Creek had impairment for a number of these metals so it was unlikely that monitoring would
go away for them. There are a few other parameters that may be removed based on results.
Jenny will look at the process of providing additional summary data on sampling results. She will also provide updates on
contact information since the data in our report are out of date. Asked facility for an updated site plan that can be
transmitted electronically. Also requested an example of how the net deductions are done in the three outfall results. —
Jenny sent response 9/6/2018 — email and attachments in file and Laserfiche.
Surface Water Information - Facility drains to Irwin Creek in the Catawba River Basin, 11-137-1 , a class C stream. 2016
Integrated Report lists this segment of Irwin Creek as impaired for Cu, Zn, Pb, Fe and Fecal. Fecal has a TMDL but there
don't appear to be any sources of this at this facility. Include general language in permit.
NC National Heritage review — NHP report shows no aquatic resources within project area. Within one mile there are
listed aquatic species, but these elements are very old and noted as having been destroyed. It does not that there are
species that are an issue with this facility.
Regional Office Information - MRO — Draft to region and to CMSWS on 9/19/2018 by email.

From: Bennett, Bradley <[e-mail]>
Sent: Tuesday, August 28, 2018 11:05 AM
To: Pappalardo, Jenny L. <[e-mail]>
Cc: Waggoner, David G. <[e-mail]>
Subject: RE: [External] RE: Stormwater Permit Renewal - NCS000040
Jenny,
Last update: 9/19/2018
Email with info request after call.
Permitee (Jenny Pappalardo)
responses in red received 9/6/18.
Thanks to you and David for your time talking about the permit renewal yesterday. I think I have a better feel for all the
things going on at your facility. I did want to try and summarize some things from our discussion and also highlight a few
areas where we would like some additional information or where you needed some additional guidance from us.
• We discussed the current outfalls at the facility. We would like to make sure that we have all the right locations and
everyone is on the same page with these. It seems that the best way to accomplish this is through the regional
office site visit that will be coming up after the draft permit is ready. In particular it seems that you have questions
about outfall 0005A since it doesn't get much flow. We understand that once a draft is prepared, we will be
contacted by the regional office to schedule.
• The major facility changes since the renewal application in 2014 seems to be the shift of some activities due to the
loss of property in the southeastern part of your property due to DOT construction. The renewal application also
noted the change to E -coat system and the installation of the aggregate waste storage building (condition of 2009
permit). Please see attached (Site Layout, Revised 9-2018) that indicates new storage locations for aggregate
materials and truck parking within Area 1. The propane tanks in Area VI have also recently been removed and pipe
product is now being stored in that location.
• We discussed the monitoring results and the references to outfalls 001, 002 and 004 being "net deductions from
upgradient outfalls." It would be helpful for me if you could provide a little bit more information on this process
and maybe even give me an example of how this is determined in your monitoring efforts. During a rain event,
samples are taken at our downstream outfall location and also at a location upstream of the foundry. The
concentration from our location is subtracted from the upstream location concentration to get the reportable
quantity. For example for the July 2018 monthly sampling for Zinc from SW004: Net SW004 Zinc Conc, ug/L =
(SW004 Zn Conc, ug/L) — (SW003 Zn Conc, ug/L) _ (124 ug/L) — (56.5 ug/L) = 67.5 ug/L = 67.5 mg/L.
• We discussed the changes in the benchmark values for some of the metal parameters. With some adjustments over
the last few years to Department water quality standards there have also been some changes to our benchmark
values. You will notice in the draft permit that a number of the metals benchmarks will increase. This should make a
difference in your monitoring under the tier system. We look forward to seeing the new concentrations.
• You indicated in our discussion that the contact information that we forwarded for your review is out of data and
needs to be corrected. Please forward me the corrections and I will make the needed changes in our system.
Please see attached file (NCS000040 Contacts Report, Updated 9-2018).
• If you have an electronic version of your site plan that you could provide to me it would be helpful in getting
information to our regional office. We are trying to get more information available electronically, but we don't
have the ability to scan large plans. Please see attached file (Site Layout, Revised 9-2018).
• We also discussed the possibility of getting updated summary information on your facility's qualitative monitoring
results since the renewal application in 2014. You were going to take a look at this at see if you had any
information that you could easily provide. Please see attached file (Outfall Sampling Data, Updated 9-2018).
I hope I hit all the major areas. If you have any questions please let me know. As I mentioned, we will prepare a draft permit
and send it to you for comment in the next few weeks. Our regional office will also schedule a site visit once the draft is
available.
Thanks for your help.
BB