NCG030647_Rep Outfall Status Request_20190501

© REI Engineering Inc. P:\6000-6099\6016-Greenheck\North Carolina\Stormwater\Shelby Storm Water\DEQ Correspondence\Req for Rep Outfall Status\6016NCROS.docx
May 1, 2019

NC DENR Division of Water Quality
Surface Water Protection Section
610 East Center Ave.
Mooresville, NC 28115

Subject:

Representative Outfall Status (ROS) Request
Greenheck Fan Corporation COC: NCG030647

To Whom It May Concern:

On behalf of Greenheck Fan Corporation, please find the enclosed “Representative Outfall Status
(ROS) Request Form,” two (2) copies of the facility site map, and a summary of monitoring results
table to request ROS analytical sampling at Outfall #1 at the property. This request is being
submitted after on-site review and discussions with Holliday Keen, an Environmental Senior
Specialist at DEMLR. Holliday would be familiar with site operations and history of the site.

The facility is regulated under General Permit No. NCG030000 “Metal Fabrication.” The facility is
additionally regulated by Permit No. SW003 under the City of Shelby’s Phase II Stormwater
Ordinance. Three (3) drainage areas with corresponding outfalls are present at the property (see
enclosed site maps). To comply with City of Shelby’s Phase II Stormwater Ordinance, Drainage
Area #1 was designed as high-density and runoff is controlled and treated by a wet detention basin.
Drainage areas #2 and #3 were designed as low-density. No TMDLs or impairments are noted for
the associated receiving waterbody beyond a statewide TMDL for mercury contaminated fish tissue.

All potential industrial stormwater exposures are contained outside the southern portion of the
facility and within Drainage Area #1 as indicated on the enclosed site maps. Potential exposures
within Drainage Area #1 include:

1) Scrap metal dumpsters,
2) Wood pallets,
3) Laser dust dumpster,
4) Lumber,
5) Empty drums,
6) Metal parts,
7) Loading docks, and
8) Garbage dumpsters.

Drainage Areas #2 and #3 serve only as employee parking and are ancillary to associated industrial
activity. The parking area is paved and surrounded by manicured grass. We are requesting ROS
for Outfall #1 (Drainage Area #1) only since the vast majority of industrial activity occurs within this
drainage area and would be representative of the true industrial stormwater exposures at the site.

© REI Engineering Inc. - 2 - P:\6000-6099\6016-Greenheck\North Carolina\Stormwater\Shelby Storm Water\DEQ
Correspondence\Req for Rep Outfall Status\6016NCROS.docx
A summary of monitoring results table is enclosed. Historical sampling at Outfalls #1 and #2 have
been within permitted benchmark values. One (1) exceedance of the benchmark for zinc occurred
at Outfall #3 on February 28th, 2018 during the first annual sampling event. It is unknown why zinc
was present at levels above the benchmark at this outfall since this drainage area is not associated
with storage of industrial materials and no material handling operations occur in the area. A
potential explanation may be the third-party laboratory may have collected the sample at the wrong
location. As seen in the attached site map, if the sample was collected downstream of the outlet pipe
it would not be representative of the stormwater leaving the facility parking area. Collecting a
sample beyond the outlet pipe would include runoff from off-site properties and roadways located
north of the facility.

In summary, we are formally requesting analytical sampling requirements for Outfall #1 only.
Outfall #1 represents stormwater runoff from all industrial activities at the site. We request that
analytical sampling is waived for Outfalls #2 and #3 since these areas of the property are ancillary
to industrial activity and serve as employee parking. All other permit requirements would apply to
Outfalls #2 and #3.

Please feel free to contact me with any questions at [phone]. A copy of this request has also
been emailed to Suzanne McCoy at [e-mail] as directed by your website.

Sincerely,
REI Engineering, Inc.

Jason Christopherson, M.S.
Environmental & Safety Consultant

Enclosures

Division of Water Quality / Surface Water Protection

National Pollutant Discharge Elimination System

REPRESENTATIVE OUTFALL STATUS (ROS)
REQUEST FORM
FOR AGENCY USE ONLY
Date Received
Year Month Day

Page 1 of 3
SWU-ROS-2009 Last revised 12/30/2009
If a facility is required to sample multiple discharge locations with very similar stormwater discharges, the
permittee may petition the Director for Representative Outfall Status (ROS). DWQ may grant Representative
Outfall Status if stormwater discharges from a single outfall are representative of discharges from multiple
outfalls. Approved ROS will reduce the number of outfalls where analytical sampling requirements apply.
If Representative Outfall Status is granted, ALL outfalls are still subject to the qualitative monitoring
requirements of the facility’s permit—unless otherwise allowed by the permit (such as NCG020000) and DWQ
approval. The approval letter from DWQ must be kept on site with the facility’s Stormwater Pollution
Prevention Plan. The facility must notify DWQ in writing if any changes affect representative status.

For questions, please contact the DWQ Regional Office for your area (see page 3).
(Please print or type)
1) Enter the permit number to which this ROS request applies:
Individual Permit (or) Certificate of Coverage

2) Facility Information:
Owner/Facility Name Greenheck Fan Corporation
Facility Contact Jason Powell
Street Address 2000 Partnership Drive
City Shelby __________________________ State NC _____ZIP Code 28150
County Cleveland _______________________ E-mail Address [e-mail]
Telephone No. [phone] Fax: ________ _________________________
3) List the representative outfall(s) information (attach additional sheets if necessary):

Outfall(s) 1 is representative of Outfall(s) 2
Outfalls’ drainage areas have the same or similar activities? □ Yes X No
Outfalls’ drainage areas contain the same or similar materials? □ Yes X No
Outfalls have similar monitoring results? X Yes □ No □ No data*
Outfall(s) 1 is representative of Outfall(s) 3
Outfalls’ drainage areas have the same or similar activities? □ Yes X No
Outfalls’ drainage areas contain the same or similar materials? □ Yes X No
Outfalls have similar monitoring results? X Yes □ No □ No data*
Outfall(s) is representative of Outfall(s)
Outfalls’ drainage areas have the same or similar activities? □ Yes □ No
Outfalls’ drainage areas contain the same or similar materials? □ Yes □ No
Outfalls have similar monitoring results? □ Yes □ No □ No data*

*Non-compliance with analytical monitoring prior to this request may prevent ROS approval. Specific
N C S N C G 0 3 0 6 4 7
Representative Outfall Status Request

Page 3 of 3
SWU-ROS-2009 Last revised 12/30/2009
Notes
The submission of this document does not guarantee Representative Outfall Status (ROS) will be granted as
requested. Analytical monitoring as per your current permit must be continued, at all outfalls, until written
approval of this request is granted by DWQ. Non-compliance with analytical monitoring prior to this request
may prevent ROS approval. Specific circumstances will be considered by the Regional Office responsible for
review.

For questions, please contact the DWQ Regional Office for your area.

Asheville Regional Office
2090 U.S. Highway 70
Swannanoa, NC 28778
Phone [phone]
FAX [phone]
Fayetteville Regional Office
Systel Building,
225 Green St., Suite 714
Fayetteville, NC 28301-5094
Phone [phone]
FAX [phone]
Mooresville Regional Office
610 East Center Ave.
Mooresville, NC 28115
Phone [phone]
FAX [phone]
Raleigh Regional Office
1628 Mail Service Center
Raleigh, NC 27699-1628
Phone [phone]
FAX [phone]

Washington Regional Office
943 Washington Square Mall
Washington, NC 27889
Phone [phone]
FAX [phone]
Wilmington Regional Office
127 Cardinal Drive Extension
Wilmington, NC 28405
Phone [phone]
FAX [phone]
Winston-Salem Regional Office
585 Waughtown Street
Winston-Salem, NC 27107
Phone [phone]
Water Quality Main FAX [phone]
Central Office
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone [phone]
FAX [phone]

0SCALE50100ORIGINAL MAPPING PROVIDD BY MANSOUR EDLIN CONSULTING, DATED 10/25/2013.
0SCALE50100ORIGINAL MAPPING PROVIDD BY MANSOUR EDLIN CONSULTING, DATED 10/25/2013.
Total
Rainfall
(in)
Total
Suspended
Solids
(mg/L)
pH,
Standard
Units
Total
Copper
(mg/L)
Total Lead
(mg/L)
Total Zinc
(mg/L)
Non-Polar
O&G
(mg/L)
Total Toxic
Organics
(mg/L)
N/A 100 6.0-9.0 0.010 0.075 0.126 15 1
2/28/2018 0.22 22 6.47 <0.0050*<0.0010*0.032 <4.5*N/A
10/11/2018 1.28 6.1 6.2 <0.0050*<0.0010*<0.010*<4.3*N/A
2/28/2018 0.22 58 6.39 0.0056 0.0016 0.027 <4.3*N/A
10/11/2018 1.28 7.5 6.4 <0.0050*<0.0010*<0.010*<5.1*N/A
2/28/2018 0.22 26 6.86 0.0093 0.0016 0.160 <4.3*N/A
10/11/2018 1.28 80 6.4 <0.0050*<0.0010*0.016 <4.5*N/A
* Below the Limit of Quantitation (LOQ)
Outfall #1
Outfall #2
Outfall #3
Benchmarks for Permit No. NCG030000
Date
Sample
Collected
Outfall
Summary of Monitoring Results
Greenheck Fan Corporation
2000 Partnership Drive
Shelby, NC 28150
Certificate of Coverage: NCG030647