NCG030099_MACTEC Letter RE Tier One Actions_20080801

AMACTEC
engineering and constructing a better tomorrow
July 24, 2008
Ms. Marcia Allocco
North Carolina Department of
Environment and Natural Resources
Division of Water Quality
610 East Center Avenue, Suite 301
Mooresville, North Carolina 28115
AUG - 1 2008
NL DENR MRO
RE: NPDES Monitoring Requirements Dwo-Surface Water Protedic
Galvan Industries, Inc.
Millbrook Road, Harrisburg, North Carolina
Stormwater Permit NCG030000
MACTEC Project: 6228-08-4605
Dear Ms. Allocco:
MACTEC Engineering and Consulting, Inc. (MACTEC) is currently providing consulting
services to assist Galvan Industries, Inc. (Galvan) in maintaining compliance with the National
Pollutant Discharge Elimination System (NPDES) General Permit NCG030000 and improve their
Stormwater management at the property.
This letter provides results of the Year 1 — Period 1 stormwater sampling and details actions taken
or planned as a result of the results. MACTEC, on behalf of Galvan, collected a stormwater
sample from the approved representative outfall for monitoring period Year 1 — Period 1 on June
21, 2008 during a representative storm event that measured approximately 2.94 inches of rainfall.
As per the permit, the stormwater sample was analyzed by Pace Analytical for lead by EPA
Method 200.7, Oil and Grease by EPA Method 1664A, Total Suspended Solids (TSS) by SM
2540D, and Total Toxic Organics (TTO) (Pesticides and PCBs by EPA Method 608, volatile
organic compounds by EPA Method 624, and semi -volatile organic compounds by EPA Method
625). Additionally, the stormwater sample was analyzed for pH on the site using a calibrated
YSI-63 water quality meter. The analytical results are summarized in the attached Stormwater
Discharge Outfall (SDO) Monitoring Report and the laboratory report is also attached. In
addition to the analytical monitoring, MACTEC conducted qualitative monitoring of each of the
four outfalls on the property during the storm event. The SDO Qualitative Monitoring Reports
are attached.
The analytical results identified lead at a concentration of 1.32 mg/L which exceeds the
benchmark value of 0.033 mg/L and TSS at a concentration of 352 mg/L which exceeds the
benchmark value of 100 mg/L. As a result of the benchmark exceedances, Galvan became a Tier
One facility as outlined by the tiered program of the NPDES permit. The following is a list of
requirements for a Tier One facility and actions performed by Galvan:
Conduct a stormwater management inspection of the facility within two weeks of
receiving sampling results.
Action: Ms. Kerry Reed and Mr. Mark Filardi of MACTEC briefed the Galvan Pollution
Prevention Team (consisting of Mr. Carroll Baynard, the plant manager; Mr. Dean
Burgos, the Human Resources Coordinator; and Mr. Mark Seewok, the facilities
manager) on the Stormwater analytical and qualitative monitoring results on July 8, 2008.
MACTEC Engineering and Consulting, Inc.
2801 Yorkmont Road, Suite 100 • Charlotte, NC 28203 • Phone: [phone] Fax: 704,357.8638 www.mactec.com

NPDES Monitoring Requirements
Galvan Industries, Inc
MACTEC Project. 6228-08-4605
Jule 24, 2008
Following the briefing, Ms. Reed, Mr. Filardi, and Mr. Burgos conducted a facility
inspection to evaluate site operations and waste streams, gather information on exterior
storage activities, and inspect existing stormwater characteristics, outfalls, and control
devices. Observations from the facility inspection are summarized on the attached
Facility Inspection Form.
2. Identify and evaluate possible causes of the benchmark value exceedence(s).
Action: Based on discussions between MACTEC, Galvan, and the NCDENR and
observations from the facility inspection, the following possible causes of the benchmark
value exceedences were identified and require further assessment:
• Dust created from blasting and finishing operations
• Dust and erosion from unpaved surfaces around the site
• Off-site sources from adjacent properties (an underground culvert that discharges
to the outfall originates from an off-site source)
• Septic system
• Silts/solids entering the storm drain near the blasting building
• Silts/solids entering the storm drain north of the maintenance building
• Totes containing zinc sulfate that were not stored under overhead cover
• Concentrations of lead that are naturally occurring in the soils and may have
leached into the sample as a result of preservatives used by the laboratory
• Groundwater infiltration
3. Idents potential, and select the specific: source controls, operational controls, or
physical improvements to reduce concentrations of the parameters of concern, or to
bring concentrations to within the benchmark range.
Action: In July 2008, Galvan will improve the storage structure in which totes
containing zinc sulfate are stored. The roof and walls will be replaced. The dirt floor
will be scraped and impacted soils will be disposed. A berm will be constructed along
the edge of the area to provide secondary containment and ensure totes are stored under
overhead cover. Also, the floor will be graded so that spills will be channeled away from
exterior areas and towards the acid pits. Additionally, Galvan may increase the
frequency of off-site removal of the totes in order to reduce the on-site inventory.
Galvan will assess the ability to abandon the storm drain located near the blasting
building. This storm drain is located under overhead cover near the loading dock for the
blasting building. Operations within the blasting building are a potential source of
pollutants. Currently stormwater is being channeled from surrounding areas to the storm
drain. This allows stormwater to come in contact with pollutants produced by operations
in the blasting building. In lieu of the storm drain, Galvan will assess the ability to grade
the surrounding area to channel stormwater away from the blasting area into the wooded
buffer area in the southwestern portion of the site. In addition to avoiding contact with
potential pollutants from the blasting building, the wooded buffer area contains vegetation
which will reduce particulate matter.
MACTEC is currently conducting a groundwater assessment at the site. SDO #2 has a
continuous non-stonnwater discharge that is most likely attributed to groundwater
infiltration. Additional controls will be evaluated if the results of the groundwater
assessment identify groundwater as a contributor to benchmark exceedences.

NPDES Monitoring Requirements July 24, 2008
Galvan Industries, Inc.
MACTEC Project.- 6228-084605
4. Implement the selected actions within two months of the inspection.
Action: Storage structure improvements will be completed in July 2008. Storm drainage
will be evaluated by August 2008. The groundwater assessment results will be submitted
to the Aquifer Protection Section of the NCDENR in a Site Assessment Report no later
than August 13, 2008.
S. Record each instance of a Tier One response in the Stormwater Pollution Prevention Plan
(SWPPP). Include the date and value of the benchmark exceedence, the inspection date,
the personnel conducting the inspection, the selected actions, and the date the selected
actions were implemented.
Action: A copy of this letter and attachments will be included in the SWPPP. Selected
actions will be reviewed and implemented, as appropriate, before the next stormwater
sampling event.
If the DWQ has additional guidance or would like to discuss items relating to stormwater
management for the subject property, please contact Kerry Reed at 704-357-5626.
Sincerely,
MACTEC Engineering and Consulting, Inc.
Kerry A. Reed, P.E.
Project Engineer
Attachments:
Jesse R. Barker, P.E.
For..............Principal
...............................................
With Pemission

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