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Home My WebLink AboutNCS000040_HISTORICAL FILE_20200921STORMWATER DIVISION CODING SHEET NCS PERMITS PERMIT NO. NCsucu)40 DOC TYPE ❑ FINAL PERMIT ❑ MONITORING REPORTS ❑ APPLICATION ❑ COMPLIANCE tK OTHER - HISToCziCA-L- INPOP-mATLO" DOC DATE ❑ 2020p9zi YYYYM M D D ROY COOPER Governor MICHAELS.REGAN Secretary S. DANIEL SMITH Interim Director Mr. David Waggoner Charlotte Pipe and Foundry Company P.O. Box 35430 Charlotte, NC 28235 Dear Mr. Waggoner: NORTH CAROLINA Environmental Quality J February 5, 2019 L� Subject: Final NPDES Stormwater Permit Permit No. NCS000040 Charlotte Pipe and Foundry Company Mecklenburg County In response to your renewal, application for continued coverage under:NPDES stormwater permit No. NCS000040, the Division of Energy, Mineral anala'nd Resources is forwarding. herewith the subject state - NPDES permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215 .1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency dated October 15, 2007 (or as subsequently amended). This final permit includes no major changes from the draft permit sent to you on September 19, 2018. The monitoring strategy remains the same (semi-annual) as the previous term of the permit. Please note that analytical and qualitative monitoring is required in this permit. Failure to complete the monitoring as required is a violation of the permit and any permit noncompliance constitutes a violation of the Clean Water Act. Reference Part III, Section A, Item 2 "Duty to Comply", Item 9 'Penalties for Tampering" and Item 10 "Penalties for Falsification of Reports" of your permit for further information. If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of this letter. This request must be in the form of a written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of Administrative Hearings, Post Office Drawer 27447, Raleigh, North Carolina 27611- 7447. Unless such demand is made, this decision shall be final and binding. Please take notice this permit is not transferable. Part III, B.2. addresses the requirements to be followed in case of change in ownership or control of this discharge. This permit does not affect the legal requirements to obtain other permits which may be required by the Division of Energy, North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources 512 North Salisbury Street 1 1612 Mail Service Center I Raleigh, North Carolina 27699-1612 919.707.9200 Mr. David Waggoner Charlotte Pipe and Foundry Company Subject: Final NPDES Stormwater Permit No. NCS000040 February 5, 2019 Page 2 of 2 Mineral, and Land Resources, or permits required by the Division of Water Resources, Coastal Area Management Act or any other federal or local governmental permit that may be required. If you have any questions or comments concerning this permit, contact Tom S. Poe at (919) 707- 3646, or at email, tom.poe@ncdenr.gov. Sincerely, for S. Daniel Smith, Interim Director Division of Energy, Mineral and Land Resources cc: (sent via ail) IZ:ck,%,J,Far Mer Me(kACt ,iVV Charlotte -Mecklenburg tormwater Services Zahi an, DEMLR Land Quality, Mooresville Regional Office Sam S Ph.D., EPA Region IV, 61 Forsyth Stre t nta, GA 30303 R4NPDESPennits Stormwater Program Files Attachments: NPDES Stormwater Permit No. NCS000040 NPDES Stormwater DMR Forms uxrf-d, NCS000040 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF ENERGY, MINERAL, AND LAND RESOURCES PERMIT TO DISCHARGE STORMWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Charlotte Pipe and Foundry Co is hereby authorized to discharge stormwater from a facility located at Charlotte Pipe and Foundry Company 1335 S Clarkson St Charlotte, NC Mecklenburg County to receiving waters designated as Irwin Creek, a class C stream in the Catawba River Basin, in accordance with the discharge limitations, monitoring requirements, and other conditions set forth in Parts 1, II, III, and IV hereof This permit shall become effective February 2/8 2At,1 L y This permit and the authori tion to discharge shall expire at midnight on January 2QlL3. Signed this day Februa 5 18. for S. Daniel Smith, Interim Director Division of Energy, Mineral and Land Resources By the Authority of the Environmental Management Commission Permit No. NCS000040 TABLE OF CONTENTS PART I INTRODUCTION Section A: Individual Permit Coverage Section B: Permitted Activities Section C: Location Map PART II MONITORING, CONTROLS, AND LIMITATIONS FOR PERMITTED DISCHARGES Section A: Stormwater Pollution Prevention Plan Section B: Analytical Monitoring Requirements Section C: Qualitative Monitoring Requirements Section D: Special Conditions PART III STANDARD CONDITIONS FOR NPDES STORMWATER INDIVIDUAL PERMITS Section A: Compliance and Liability 1. Compliance Schedule 2. Duty to Comply 3. Duty to Mitigate 4. Civil and Criminal Liability S. Oil and.Hazardous Substance Liability 6., Property Rights 7. Severability 8. Duty to Provide Information - 9. Penalties for Tampering 10. Penalties for Falsification of Reports 11. Onshore or Offshore Construction 12. Duty to Reapply i I 1 . Energy. Mineral and Land Resources ENVIRONMENTAL QUALITY DATE: September 17, 2018 TO: [Charlotte Observer] EMAIL: [E-MAIL] ROY COOPER MICHAEL S. REGAN seaem,y WILLIAM E. (TOBY) VINSON, JR. Interinr Oirttcfor FROM: Bradley Bennett, DIVISION OF ENERGY, MINERAL, AND LAND RESOURCES SUBJECT: PUBLIC NOTICE PAGES: 1 Please publish only the information (Public Notice) attached, ONETIME in the legal section of your paper by Friday, September 21, 2018. Please fax a copy of the proof to Bradley Bennett at (919) 807-6368 for final approval prior to publication. Within 10 days after publish date; please send the invoice and two copies of the original affidavit to: Bradley Bennett NCDEQ/DEMLR 512 N. Salisbury St. 1612 Mail Service Center Raleigh, NC 27699-1612 NC DIV. OF ENERGY, MINERAL AND LAND RESOURCES' INTENT TO ISSUE THE FOLLOWING STORMWATER DISCHARGE PERMITS Public comment or objection to the draft permits is invited. Submit written comments to DEMLR at the address below. All comments received through October 21, 2018 will be considered in the final determination regarding permit issuance and permit provisions. Applications: The following facilities have applied for renewal of their NPDES permits to discharge stormwater from their locations in Mecklenburg County. • Charlotte Pipe and Foundry Co, 1335 S. Clarkson St, Charlotte, NC. The facility discharges to Irwin Creek in the Catawba River Basin. Permit NCS000040. • IGM Resins USA, Inc, 3300 Westinghouse Blvd, Charlotte, NC. The facility discharges to Steele Creek in the Catawba River Basin. Permit NCS000049. • Gerdau Ameristeel US, Inc, 6601 Lakeview Rd, Charlotte, NC. The facility discharges to Long Creek in the Catawba River Basin. Permit NCS000304. • Nexeo Solutions, LLC, 3930 Glenwood Rd, Charlotte, NC. The facility discharges to a UT to Stewart Creek in the Catawba River Basin. Permit NCS000315. Stormwater Program Contact: Bradley Bennett (919)807-6392 bradley.bennett@ncdenr.gov A copy of the draft permit is available at: https://bit.ly/2jSfSls. Additional permit documents are available for the reproduction cost at: DEMLR Stormwater Program 512 N. Salisbury Street 1612 Mail Service Center Raleigh, NC 27699-1612 State of North Carolina I Environmental Quality I Energy, Mineral, and Land Resources 1612 Mail Service Center 1512 N. Salisbury St. I Raleigh, NC 27699 919 707 9200 T NC Division of Energy, Mineral and Land Resources NPDES Stormwater Permit Contacts Summary NC DEb1LR has the following contact information in our Permit Database for vour permit as of 8/7/2018 Permit Number: NCS000040 Permit Type: Stonnwater Discharae Individual Facility Name: Chadotte Pipe & Foundry Company — Cast Iron Division ✓ Facility Addressl: 1335 S Clarkson St Facility Address2: City, State & Zip: Charlotte, NC 28208 MUST submit a Change of Name/Ownership form to DEMLR to make any changes to this Owner information. (pick Here for Change of Name/Ownersh — Form) Owner Name: Charlotte Pipe & Foundry Co Owner Type: Non -Government Owner Type Group: Organization *** Legally Responsible for Permit *** (Responsible corporate officer/principle executive officer or ranldng elected official/general partner or proprietor, or any other person with delegated signatory authority from the legally responsible person.) owner wmuapon: wwxam nnw Miae Mall Title: Senior Vice President -Cast Iron Division Addressl: PO-.Bo>Fl-3ag PO Box 35430 Address2: City, State & Zip: ^aon-^-,e ^R,°,,� Charlotte, NC 28235 Work Phone: 704-332-2647 Fax: 704-348-5539 Email Address; Egrice.^^^^^ da..-- m mhall@charottepipe.com _ *** Permit Annual Fee Billing *** Billing Month: August Invoice Number Invoice Date Invoice Due Date Invoice Amount Invoice Status Owner Contact Person(s) Contact Name Ttle Address Phone fax E i Facility Contact Person(s) Contact Name Mig Aggress Phone faX Email David Waggoner PO Box 35430, Charlotte, NC 28235 704-332-2647 704-348-5539 dwaggoner@chadottepipe.com Contact Name Title Address phone Em Email c/ David Waggoner PO Box 35430, Charlotte, NC 28235 704-332-2647 704-348-5539 dwaggoner@chadottepipe.00m Permit Billing Contact Contact Name T1Slfl Aggress Phone fON Email David Waggoner PO Box 35430, Charlotte, NC 28235 704-332-2647 704-348-5539 dwaggoner@chadottepipe.com .% �1pp1Ar 8/7/201e �f Page 1 Subject: Sent from Snipping Tool OUTFALL _..-..LATIT......._._..__...._...__.__.._.._.. UDE LONGITUDE 001 35'13280N -80'51'50"UV P35'13'29"N -80'51'46"VV 35013'37"N -80'51'47"VV ✓004 35' 13'27"N - 80'51'39"W X05 35'13'29"N -80051'41"VV 35013'28"N -80'51'40"W 006 35013'33"N -80'51'44"VV 006A 35'13131N -80'51'45"VV AREA (ACRES) PERCENT IMPERVIOUS AREA I 9A9 50% AREA II 2.90 950/0 AREA III 3.33 85% AREA IV 10.23 95% AREA V 2.28 95% AREA VI 8.14 85% AREA VII 12.50 95% pw by p; pw 54or4' NW liar @A6 4� Oa 4'0T N La Cr; par J7� r FNy Cosy Rn, F9rsr Gu�dr�ll r2�, N 0; 00(0 OUTFALL POTENTIAL POLLUTANTS 001 METALS, CHEMICAL RESIDUES, OIL & GREASE 002 METALS, CHEMICAL RESIDUES, OIL & GREASE 002A METALS, CHEMICAL RESIDUES, OIL & GREASE 004 METALS, CHEMICAL RESIDUES, OIL & GREASE 005 METALS, CHEMICAL RESIDUES, OIL & GREASE 005A METALS, CHEMICAL RESIDUES, OIL & GREASE 006 METALS, CHEMICAL RESIDUES, OIL & GREASE 00&k METALS, CHEMICAL RESIDUES, OIL & GREASE o 4a aok 35. a= g_ v . Oo2 35,?2qV-1 , Eb.gG?�49 DO A 3.5 4q'i Ll go. 9,4305L 00H 35.��y14G�$0,86 3 Dos 35.22g7aa �o.9G 1389 Do5►4 35.aa4tiyu Sa.gGl►i� 60(o 35.a�5833� So•SGas?� oo&4 35, 26,533, gp.R(G?5 r �y r� North Carolina Department of Natural and Cultural Resources Natural Heritage Program Governor Roy Cooper Secretary Susi H. Hamilton July 18, 2018 Bradley Bennett NCDEQ 512 N. Salisbury Street Raleigh, NC 27604 RE: NCS Renewal Report; NCS000040 Dear Bradley Bennett: NCNHDE-6485 The North Carolina Natural Heritage Program (NCNHP) appreciates the opportunity to provide information about natural heritage resources for the project referenced above. Based on the project area mapped with your request, a query of the NCNHP database, indicates that there are no records for rare species, important natural communities, natural areas, and/or conservation/managed areas within the proposed project boundary. Please note that although there may be no documentation of natural heritage elements within the project boundary, it does not imply or confirm their absence; the area may not have been surveyed. The results of this query should not be substituted for field surveys where suitable habitat exists. In the event that rare species are found within the project area, please contact the NCNHP so that we may update our records. The attached 'Potential Occurrences' table summarizes rare species and natural communities that have been documented within a one -mile radius of the property boundary. The proximity of these records suggests that these natural heritage elements may potentially be present in the project area if suitable habitat exists. Tables of natural areas and conservation/managed areas within a one -mile radius of the project area, if any, are also included in this report. If a Federally -listed species is found within the project area or is indicated within a one -mile radius of the project area, the NCNHP recommends contacting the US Fish and Wildlife Service (USFWS) for guidance. Contact information for USFWS offices in North Carolina is found here: ffht(ps 7llwww.fws.aov/offices/D irecto W ListOffices.cfm?statecode=37. Please note that natural heritage element data are maintained for the purposes of conservation planning, project review, and scientific research, and are not intended for use as the primary criteria for regulatory decisions. Information provided by the NCNHP database may not be published without prior written notification to the NCNHP, and the NCNHP must be credited as an information source in these publications. Maps of NCNHP data may not be redistributed without permission. The NC Natural Heritage Program may follow this letter with additional correspondence if a Dedicated Nature Preserve, Registered Heritage Area, Clean Water Management Trust Fund easement, or Federally -listed species are documented near the project area. If you have questions regarding the information provided in this letter or need additional assistance, please contact Rodney A. Butler at rodney.butler ncdcr.eov or 919-707-8603. Sincerely, NC Natural Heritage Program MAILING ADDRESS: 1651 Mall Service Center Raleigh, NC 27699-1651 Telephone: (919)707-8107 xvnv.ncnhp.org LOCATION: 121 West Jones Street Raleigh, NC 27603 Natural Heritage Element Occurrences, Natural Areas, and Managed Areas Within a One -mile Radius of the Project Area NCS Renewal Report Project No. NCS000040 July 18, 2018 NCNHDE-6485 Element Occurrences Documented Within a One -mile Radius of the Project Area axonomic EO ID Scientific Name Common Name Last Element Accuracy Federal State Global State Group Observation Occurrence Status Status Rank Rank Date Rank Bird 32170 Falco peregrinus anatum American Peregrine 2015-06 E 2-High --- Endangered G4T4 S1B,S2 Falcon N Freshwater 7236 Lasmigona decorate Carolina Heelsplitter 1880-Pre X 3-Medium Endangered Endangered G1 S1 Bivalve Mammal 20386 Lasiurus intermedius Florida Yellow Bat 2000 D 1-Very -- Special G4G5T S1 floridanus High Concern 4 Vascular Plant 13743 Delphinium exaltatum Tall Larkspur 1800s Hi? 5-Very --- Endangered G3 S2 Low Vascular Plant 13382 Echinacea laevigata Smooth Coneflower 1900-Pre X 4-Low Endangered Endangered G2G3 S1 S2 Vascular Plant 28127 Echinacea pallida Pale Coneflower 1969-06 H 3-Medium --- Significantly G4 S1 Rare Disjunct No Natural Areas are Documented Within a One -mile Radius of the Project Area Within a One -mile Mecklenburg County Open Space Mecklenburg County Local Government Definitions and an explanation of status designations and codes can be found at btips-Uninnhde.natureserve rq/content/heln. Data query generated on July 18, 2018; source: NCNHP, Q2 April 2018. Please resubmit your information request if more than one year elapses before project initiation as new information is continually added to the NCNHP database. Page 2 of 3 N; S000040 MCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director STAFF REVIEW AND EVALUATION NPDES Stormwater Permit Dee Freeman Secretary Facility Name: Charlotte Pipe & Foundry Cc NPDES Permit Number: NCS000040 Facility Location: 1335 South Clarkson Street, Charlotte, NC (Mecklenburg County) Type of Activity: GRAY AND'DUCTILE IRON FOUNDRIES SIC Code: 3321 Receiving Streams: See Figure 1 River Basin: Catawba River Basin, Sub -basin 03-08-34 Stream Classification: C Proposed Permit Requirements: See attached draft permit. r4licr.—.1 Monitoring Data: See Table IResponse Requested by (Date): Central Office Staff Contact: Return to: Brian Lowther, (919) 807-6368 Special Issues: Issue Rating Scale: 1 eas to 10 hard Corn Hance history 6 Benchmark exceedance 7 Location (TMDL, T&E species, etc 7 Other Challenges: • Missing data 6 Difficult 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 Page 1 of 9 . 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 • SPU 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. • February 19, 1999: Permit renewal reminder letter. • 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`h 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 i�'[vlay 8, 2006:'Notice of Violation. is Page 2 of 9 NCS000040 NCS000040 Map Scale 1:24,000 Figure 1: Map of Facility Charlotte Pipe & Foundry Co Lad aide: 350 13' 28" N Longitude: 800 51' 42" W County: Mecklenburg . Reca mng Stream: Irwin Creek Stream Gass: C Sub -barn: 03-08-34 (Catawba River Basin) Facility Location Page 3 of 9 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 1-77 and ultimately to Irwin Creek. Tow other outfalls (SWO03, SW004) have been identified as intermediate outfalls for sampling purposes. - SW001: 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. - SWO02: This outfall drains approximately 3.1 acres of the 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. - S WO04: This outfall drains approximately 1 1.1 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 S WO04 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", -80' 51'49"), 002A (350 13'23", -800 51'42"), 004 (35° 13'27", -800 51'39"), 005 (35° 13'29", -80° 51'41 "), 006 (350 13'34", -800 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 Creek, 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. Page 4 of 9 Nr S000040 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 Notes: 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`h year. The application only included one sample for each ourfall. The samples had values over our current benchmarks for Cr, Cu, Ph, Ni, Zn, Phenol, COD and TSS. The data was missing information such as total rainfall, event duration, and estimated now. 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 11 Section D of the permit. CP&F personnel indicated that more than 55 gallons of new motor oil were used but no records of quantities have been kept. Oil and Grease was added to the monitoring because it is a potential pollutant onsitc. 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. Page 5 of 9 NCS000040 Table 1: Analytical Monitoring Outfall Sample Date Total Flow (MGD) Precipitation (in) Duration (hours) Cr Cu Pb Ni Zn TKN Phenol COD TSS ELnctvmrk,. I nxjL Benchmark: 0.007 nxjL Bendynaric, 0.03 mYL %nchmrk., 026 rrKYL Benchmark: I 0.067myl- Berchmailc 20 mYL Benchmark: 4,5 n9t Berrhrrork: 120 mqL Bemhnerlc 100mgfL SVV-001 6/2 Y2004 .. . 0.1 190.079.,!!- 0.55- y 0.033 olot-Q.8 4- 1.9 0.29 g 210.-4 %kr21Oj*- SW-002 C/2412004 0.15 W, Q.,I 2 0.81: 0.056 W,1.2 1.6 0.17 M220 t SVV-002A 6125/2004 12 it WO.,45fW-- 0.32'N ",4� 7 1.5 0.09 WWO,' ;AWWM SVV-0D4 6126/2004 0.27 MK0.42; 0.18 4W2-.5, 8.5 `WAW 010700 R*540OWe, SVV-005 6127/2004 0.61 WW0.07 . 'c,0.12, 0.016 <1.0 1.4 "A""400 7,F750DW SVV-ODI '2126/2008 ND 100.01671,, 0.0203 1 ND --,W OA 24, 0.99 0.02 226 30 -SVV-002 2t262008 0.0182 I-0.141 0.0111 AV0.411 1.4 0.063 119 294M SW-002A 21262MB 1.95;,)ft NWY66M, -7v�9.52-' 0.181 17�7'.' 2 1'2 --*41- 1.8 W142KI 1=9610IN SVV-004 2/26/2008 0.0132 WO!620r 0.0199 0.0067 MO.'373'W, 0.92 0.023 36 .SVV- 2(2612008 0.0143 K0.0461k. 0.14 0.0119 vffO.8I5I.:,. 1.9 0.032 "',251 6 SVV t2t2612008 0.0128 0.0265 0.006 WO':21,,,-` 0.92 0.� 50 2M126jW 212&/20018 0.0906 00.0611 i ,0.0891 0.0345 !W0.8�15 1 2.2 0.015 80 -!W'6549K PEEqOver Current Benchmark Data Not Collected Page 6 of 9 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 11 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 stormwater Best Management Practices (BMPs) in a tiered program. 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 1 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 11 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 I 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 11 Section A. 2. Additional requirements for the Stomrwater Management Plan have been specified in Part 11 Section A. More details regarding secondary containment are provided. 3. Additional requirements for the Stormwater Pollution Prevention Plan have been specified in Part 11 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 stormwater management controls as specified in Part 11 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 § I22.26(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. Page 7 of 9 IMIIIIIIIINII Discussions with permittee: David Waggoner, 704-332-2647, 03/19/09 1. General description of industrial activities. Grey metal pipe foundi y. 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 noiv. 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 date inside. The area has French drains that go directly to the server system. Page 8 of 9 . TVCS000040 Recommendations: Based on the documents reviewed, the application information submitted on July 4, 2004 sufficient to issue an Individual Stormwater Permit. Prepared by (Signature) Date Stormwater Permitting Unit Supervisor hG / ��e&Date 3 1G 4 for Bradley Bennett Concurrence by Regional Officv // Date RO Water Quality Supervisor Date Regional Office Staff Comments (attach additional pages as necessary) Page 9 of 9 NCS000040 Site inspection conducted on May 6, 2009 by Michael Parker. Facility contact: David Waggoner. Current NPDGS 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 SW collection system that passes through.the CP&F property via 1/I. 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 in complying with the benchmark levels proposed in the new SW permit based on testing conducted at the SW outfal is 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 outfalis 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. 5ti �iw ��n 'J�!: .- iL_ 1. 0aaPRL0=0==0= PIPE and FOUNDRY COMPANY P.O. Box 35430 • Telephone 704/332-2647 CHARLOTTE, NORTH CAROLINA 28235 Foundry Fax No. 332-4581 August 24, 2016 Bethany Georgoulias NCDENR - Stormwater Permitting Program 1612 Mail Service Center Raleigh,- NC 27699-1612 (91.9) 807-6372 RE: Charlotte Pipe and Foundry Company Permit # NCS000040 NPDES Stormwater Permit Renewal SW006 Outfall Relocation RECEIVED - - - - - - -AUGI2 6 2016- - - DENR•LAND QUALITY STORMWATER PERMITTING Charlotte Pipe and Foundry Company (Charlotte Pipe) is submitting this request to relocate Stormwater Outfall SW006 from a location within our fence line to a location (SW006A) just outside our fence line. This request is being made as raw material storage and drop lot parking were required to be moved due to the sale of property across the railroad tracks (along the southeastern property line) to NCDOT. The aforementioned activities have been moved to drainage Area I along our northern property line. By relocating sampling point SWO06 to SW006A, Charlotte Pipe will capture flow from both the existing SW006 sampling location (it is direct piped to the new location) and from the new material storage area. The existing (SW006) and proposed (SW006A) sample locations are less than 1.00-foot apart and have been highlighted on the attached drawing for reference. If you have any questions or need any additional information, please contact Jenny Pappalardo at (704) 348-5513 or David Waggoner at (704) 348-5408. Sincerely, _.( /� David G. Waggoner Charlotte Pipe and Foundry Company Quality -Environmental Manager VING NUMBER 34-12 J W;r� Hi '-zV� G F 10 u C E 12 d Ar�n Fitting Storage-- Area p ' fruc v -, -Cru�k _ �� ' parking V Z �m J - Z �e �Lu w U �- I- w9w J N CL yC.1 0 0 (n LL OUTFALL SWO02A 72� OUTFALL SW001 SCALE 0' 100' 200' DIRECTION OF STORM WATER FLOW - LOCATION OF STORM WATER OUTFALLS OUTFALL LATITUDE LONGITUDE 001 35°13'27"N -80a51'49"W 002 35°13'29"N -80a51'47"W 002A 38a13'36"N -80a51'47"W 004 35a13'27"N -80051'38"W 005A 35a13'28"N -80a51'40"W 006 35a13'32"N -80°51'44"W 006APROPOSED 35a13'33"N -80°51'45"W AREA (ACRES) PERCENT IMPERVIOUS AREA 1 9.19 50% AREA 11 2.90 95% AREA 111 3.33 85% AREA IV 7.44 95% AREA V 2.28 95% AREA VI 1.78 85% AREA VII 12.50 95% OUTFALL POTENTIAL POLLUTANTS 001 METALS, CHEMICAL RESIDUES, OIL & GREASE 002 METALS, CHEMICAL RESIDUES, OIL & GREASE 002A METALS, CHEMICAL RESIDUES, OIL & GREASE 004 METALS, CHEMICAL RESIDUES, OIL & GREASE 005A METALS, CHEMICAL RESIDUES, OIL & GREASE 006 METALS, CHEMICAL RESIDUES, OIL & GREASE 006A PROPOSED METALS, CHEMICAL RESIDUES, OIL & GREASE I w i rf E L1 J C Ln 1 105/161 Revised as Noted REV I DATE I DESCRIPTION LIMITS UNLESS OTHERWISE SPECIFIED FRACTIONS f 1/64 DEC. FRACTIONS t .01 ANGLES t 30' DECIMALS f .005 SURFACE FINISH 125 R.M.S. CHARLOTTE PIPE AND FOUNDRY CO. 1335 SOUTH CLARKSON STREET CHARLOTTE, NORTH CAROLINA CAST IRON A TITLE Environmental Survey SCALE DR BY DJO DRAWING NUMBER DATE 4-28-2015 CK BY 34-12 Bin Storage IRWIN CREEK OUTFALL SWO06 ti Warehouse OLD S)SWO07 Location _ - - - Asphalt — — Trash s Dunpster Parking � I O Asphalt I Parking BinStorage c,` Asphalt i"` / Dunpsh rash / Dunpsters Bulkulk Mn / Spent Storage Flttln (Covered) Storog Area Storage VAsphalt i HOUSE / USED OIL D Upstream Loc TANK ,vi! r -, 4- � S'd-003 Generator ➢r4n y! uI rn li _ , Sto e i � "� Trash Dunpster �' '® S�J H -- -- / ruuxzzr �g (� y sue srn u;cansu OUTFAL-L Property of Rallroad SWO04 S - OUTFACE SW005 Sp ----------------- SAMPLE LOCATION FORSW002w / m= (SWO02A) Parking a` a.a.n,. n Stag T. �'I H �fi Storage � oar Asphalt I p Gravel n Grass 1,5 OUTFACE — ._ o o SWO02 a DRUM/ 011 CS TOTE i STORAGE. i 1 SHED F� Tvs,vvv-wgW '�I `a' `Y✓'--" -pstream Lur l ��. raxu SW 010 ,ii IIWIaa" 3 Coke !� ®� Storage Asphalt Asphalt / f - x, �: Cardboard / Trash Dunpster Asphalt B - CI -r Dun ster n<u Trnsh /' �pstream Lac sack[ �� storoe: Dun stet SW-Oltl Trucksbom I Bin UM - Parking OUTFALL �/�/Q0l ® .oq IBentonit g Stota e •• Bin ®FeldsP nr SO....,o ma. Storage Silos IF I . Asphalt Gravel Parking Asphalt / ® ® / Truck D nsracmxs vau ✓✓✓ � I I Parking 1, GRASS' upstreon Loc Sw-011 DIRECTION OF STORM WATER FLOW LOCATION OF STORM WATER OUTFALLS LATITUDE LONGITUDE 001 350 13'27" 300 1 °51 LI 002 35°13'29"a 30°51'49" 002A 3 °131:23" 30051' 2" 004 35°13'27" 3 ° 1'39"W 005 350 13'29" 30051 ° 1 " 006 35°13'34" 30051'45" a AREA PERCENT (ACRES -- IMPERMUS -- AREA � — 5.75 9 % -- EA H 2.90 95% AREA III 3.33 35% AREA W 10.23 95% AREA V 2.2 95% AREA V1 8.53 5% AREA M 12.00 95% 001 METALS, CHENCAL RESIDUES, OIL & GREASE 002 MET ALS), CHEMICAL RESIDUES, OIL &GREASE 00 A METALS, CHEMICAL RESIDUES, OIL & GREASE 004 METALS, CHEMICAL RESIDUES, OIL & GREASE 005 METALS, CHEMICAL RESIDUES, OIL & GREASE 006 METALS, CHEMICAL RESIDUES, OIL & GREASE r., ry -i IJ \ V � IN F-1 1 'NC 10,1 RECEIVED JUL 112014 DENR•LAND QUALITY STOP,MWATER PERMITTING ading Dock h3 J sn � As It Prig r' y sn l G- � 4sn f Warehouse OLD Sample Location SWO07 - - Asphalt Trash - Dumpster Parking Bin Storage Asphalt / TOTE STORAGE SHED / Scrop Metal Dumpster Dumpsters -.� Bulk Material Spent Storage / Flttln (Covered) Storag Area /Fitting / Storage Area Storage Asp/It a OIL HDUSE USED OIL � --- TANK Dr m Generator Upstream Loc ® SW-003 OUTFALL LATITUDE I` 001 350 13'2 " 30051'51 " 002 35° 13'29" 0051'49" 002A 35°13' ee 0051'42" 004 35°13'27" 0051'39" 005 35013' 9" 30051 ° 1" 006 35013'34" 300 1'45" Sto —�_ Trash j ... ," O!.T Dumpster - i Bin - y --- d Sn"STY LLG LE Storage / y s�_sra yl — c 'Dr = Asphalt \ a �. ® vnoa Property of Railroad Parking OUTFALL/ 89®; ®, =�@AREA PERCENT I SWO04� tl IMPERVIOUS IRWIN ®AREAI - m ; 5.75 0% CREEK OUTFALL sd AREA 11 2.90 95% SWO06 Asa GRPRL �snw, m yall AREA � � I 3.33 `�/� OUTFALL o^G swoon AREA IV 10.23 95% AREA V 2.28 95% SA �s 'i 2 TOTES OF UIL SAMPLE ° --SHELL CORE UNLOADING AREA AREA V9 3.53 Rom,% I ww GY J/, // v rex� h m LOCATION � �iNpli ®m3 i1 12.0695®�/0 FOR SWO02 / (SWo02A) ,. :, , Parking - --- slag T° Storage OUTFALL SW002 OUTFALL SW001 iPa As halt a-mRr Gravel p ;�L�ADI.G AREAb' / Grass �/ --- DRUM/ z' TOTE 0a ST❑RAGE coxPecssox� SHED Cc , coxoExsnre rl D-GRLLLN� pstrPam Lec , V XnT 9[P TAWW-0SO —. ® ' �' q Coke r ® St... Asphalt St orage m C 3 Siorane Asphalt" e Cardboard dT-1, Trash Dumpster ....� ,.V I ® ❑ 3 - Dumpster Asphalt hal} i Trash ppstream Loc SRxPu: Boa, Dumpster SW-010 as 9 Lcarmx y z -- - ,. SVDI1 - Truck OFFICE Parking Bin 0 ® ® ®Felds00 9 Storage D I onit Fit" Bin f \ par 4 sm�RG.' " - �® m StorageAREA IV -, S"°= Asphalt Gravel Parking �\ Asphalt m Siu gR Tr uck ® Parking GRASS IL yT ® �� am ASS ' Upstream Loc \ R. SW-0Y1 ® �eoeeLi �w in vim '� 00 a I$ 6 "�" A. @ �'" z�JI T i AL.- I d'� E � R`z' 4d t� P� qd ' C �EWC_o��'L � X� s`� a rr^p. e a. � 9-e FZCE ��UEESS9 n,aa o O'IL n .,,m GREASE GREASE 002 METALS, CHEMICAL RESIDUES, OIL & GREASE 002A METALS, CHEMICAL RESIDUES, OIL & GREASE 004 METALS, CHEMICAL RESIDUES, OIL & GREASE 005 METALS, CHEMICAL RESIDUES, OIL & GREASE 006 METALS, CHEMICAL RESIDUES, OIL & GREASE Ve Wu A pr*ah " "Ir. 1 F_FI Y STEEL 160'-0° STEEL Paul Briggs W architect A 22 Talbert Blvd. Lexington, NC 27292 Phone (336) 248-2030 Fax (336) 248-6355 m° Fin " of aa"Y CONSTRUCTION INC. 0 N I a N /1 L) 0 Irq Z 7 r r o: g mx � J lai Z w w z W z w J W` w � N j Z j N u N �aa1 3 M M j.�� N •• 1�1 [�] '`' z z B.9 o C ' 0 ��P Nor o U W o vi y�� d�N R�O� Q Z O F� F p Z Of LL � Z J U W Q L, Q W �p W Z /r G C) � o U a_ SCALE: 1/8" = 1'-O" 0- CONTINUOUS Of U ( ) RELATIVE ELEVATIONS ARE NOTED THUS 100'-0". NUCOR BUILDING SYSTEMS DRAWINGS. (4) DUE TO THE SHORT PIER HEIGHT THE ANCHOR ROD ASSEMBLIES ARE TO BE LINE LINE CAST WITH THE FOOTINGS. THE GENERAL CONTRACTOR IS TO TAKE CARE IN SHEET TITLE PROPERLY LOCATING AND SECURING THE ANCHOR RODS. (5) PRESUMPTIVE ALLOWABLE SOIL BEARING PRESSURES (FIELD VERIFY): Qj a 2000 PSF AT COLUMN FOOTINGS U.N.O. b) 2500 PSF AT CAST -IN -PLACE CONCRETE WALLS U.N.O. FOUNDATION 6 MINIMUM CONCRETE COMPRESSIVE STRENGTH = 3000PSI AT 28 DAYS. PLAN IV\MMM 7 DEFORMED REINFORCING BARS ARE TO CONFORM TO ASTM A615. $ = FINISHED GRADES 8 ANCHOR RODS ARE TO CONFORM TO ASTM F1554 GRADE 36. 9 LOCATE BOTTOM REINFORCING BARS 3" CLEAR FROM BOTTOM OF FOOTING 0 $ T.O.S. =DENOTES TOP OF CONCRETE (10) LOCATE TOP REINFORCING BARS 2° CLEAR FROM TOP OF FOOTING SLAB ELEVATION (11) MINIMUM LAP SPLICE FOR #4 BARS IS 24" SHEET (12) MINIMUM LAP SPLICE FOR #5 BARS IS 27" (13) SUPPORT REINFORCING BARS USING STANDARD BAR SUPPORTS. CJ = DENOTES CONSTRUCTION JOINT OR SAWCUT CONTROL JOINT DATE REVISION DESCRIPTION S1.1 P24-24 = 2'-0"x2'-0"x1'-0" WITH (10) #5 DOWELS AND (3) #3 CLOSED TIES P20-20 = 1'-8"xi'-8"xi'-0" WITH (9) #5 DOWELS AND (3) #3 CLOSED TIES REVISION 1 LINE 39'-5 7/i6" 120'-6 9/i6" LINE 40'-0" 30'-0" 30'-0° 30'-0" 30'-0" STEEL LINE 6 9/16" 29'-6 i/2° DETAIL 52.2 S2.1 52.1 1 FOOTING ' 5 1/2" II S21 I CENTERLINE - F110-110 F120 120 F120-120 F100-100 1/i6")-1'-5 1/16") � r � (-0'-7 5/16") - - , (+2'-9 1/8") I P24-24 I I I P24-24 52.1 I I I P24-24 P24-24 I w z [-0'-11 1/16"] I I [-0'-5 1/16"] I I [+0'-4 11/i6"] I I [+3'-9 1/8"] r _ -' -.� 2 $100'-0" - ---� \ I r-- ---I------� �-----BRACED BAY ----� -- r---------------� F------------------ BENCHMARK �----------- - REFERENCE __ •� I I o I I I I I I I L_ J F60-60 z� c---- ---J L---1---J III L___-1_- L----1--_ J (+3'-11 7/8") o P20-20 � W �_J " p ,- " I f„ T.O.S. ° � .$g9-10 $98-4 $100 0 $102 7 $104'-3" III I [+4'-11 7/8"] (99 0) � $T.O.S. DETAIL r (99�-0") T.O.S.$�� (99 -0) NEW CROSS TIE ^� RETAINING WA FOOTING SCHEDULE MARK SIZE REINFORCING F120-120 12'-0" x 12'-0" x 3'-0" (11) #7 BARS x 11'-6" EACH WAY (TOP do BOTTOM) F110-110 11'-0" x 11'-0" z 3'-0" (10) #7 BARS x 10'-6" EACH WAY (TOP do BOTTOM) F100-100 10'-0" x 10'-0" x 3'-0" (12) #6 BARS x 9'-6" EACH WAY (TOP &BOTTOM) F96-96 9'-6" x 9'-6" x 2'-9" (10) #6 BARS x 9'-0" EACH WAY (TOP k BOTTOM) F70-70 7'-0" x 7'-0" x 2'-6" (7) #6 BARS x 6'-6" EACH WAY (TOP k BOTTOM) F60-60 6'-0" x 6'-0" x 1'-6" (5) #5 BARS x 5'-6" EACH WAY (TOP k BOTTOM) 12 Pnnp- PITr1-I 11 0 Lo N 100,0 - 4- I I �1NnRTH FI FVATInN Y L--_____J EAST ELEVATION 3 �7F. _.�;_o.: ........................ WEST ELEVATION 4 �8 ..1:0 ..............".......................... = - I I L_ _ _ _ _ _ i 12 ROOF PITCH 11 L_L4 I J SOUTH ELE i/s" 2 _ . i "_o;; ..... _ 12 ROOF PITCH STEEL FRAME PIER APPROX. EXIST. GRADE ON TTER 8x6 ILVINm 601i1112.IZI ETAL ALL HEETIN i 0) ro h LASH B K. PATCH EXIST. PA EMENT, SEE STRUCTURAL TYPICAL SECTION DRAWINGS FOR FOOTINGS 1/4 = 1'-O' 0 4' 8' 16' SCALE: 1 /8" = 1'-0" Pcul Briggs architect Loading Dock Bin Storage D Asphalt Asphalt Parking (0h °(0(D 7„ O h rjD Warehouse / QrD °5 r : . WASH AREA FORKLIFTom MAINTENANCE SHOP z m Asphalt m 'arking OUTFAL ANAmnA D Asphalt SHIPPING PLATFORM L Parking Gravel 3 3, Coke 0- h _ Storage m D O 3 m / m< zA O _ `p m O _. Asphalt 1 Bin Storage \ Asphalt m r n m N A D m y D m ti A 3 m ti Vi m O .} S 3 P � Bin Storage 0, � J P � m P Asphalt Truck Parking Gravel Truck Parking F CAL I,_- sue. = A' "S . i � .. I.Y _I� (✓ ,.dl J x g ! Y : ' - � r c� i :J4 JR i kC a t �1f4 ,1 �I • % i_ Jr i 1. r' i l I) IOR M.-A, I ERIAL A,, 7 ITY F. ^r kACF PEA AG ! IQUID OXYGFN STORAGE TANK, 9,000 GA.[- \L''r o .,(3E BI!_ ;C,^,</EREEj AN PRCPA.NE STGRAGE TANK, 6,000 GAL GE Al PR an A AJ FIT�NG CON VEYCR SYSTEM 2,000 GAL r:. P $ F 0 ,N 1 r? P / ,L % sF-A AK 5-FT PIPE CONVEYOR SYSTEM `C '� 4P r 3> �'° -- F :RA REar E AREA AL WASTEIVATER TREAT.dEPJT TANKS G J;l_,rr,:L / ":_I`!E IC GE Tt;i'JK, .QGJ::) GAL AM FQRKLiFT MAINTENANCE SHOP - Irk r. c - r, r`- r ( PIPE : s, _r E F_. TA:.. :H ,,GO GAL ° - c T: r3r {7Z �1 i 1 - AN C F . FIC COATING . a 2 s'. wl S 1 l _ --- I JJ F,IG S-ATi00FJ (G,4S & DFS`_Li AO 5-FT PIPE COATING l Al:` ,,.frf _. w .r4E„ --- --- - J RS J ,A,,kE AIdK. 12,000 GA_ AP FITTING COATING >...............s..._.Au.��zx.. ..r. ..,...,..v..,., .. d...a .r.........,,.... �. �R S TGE - --- — - I< 4aIN )`'` SITOPAG T TANK, '2 COG GALr:. AQ =!-E 4+rlASHING AREA � RRAAE r pIIII NAIF AR FINISHED FITTING STORAGE AREA .r,E. Or U, _;:ORA TANK, 12,C;,v SAL � r KEG I IA: E A: K, C- G%CL AS FIPJISIiED FITTING STORAGE AREA a « KLK 5A .. �.AI,E IK, ,�-' AL E IS Al FINISHED PIPE & FITTING STORAGE AREA, -_ : � m-•�e-�'�`'� EO �Q�HAU FINISHED A : Nti FITTING ( STORAGE RE (!IN .F1 AV FINISHED PIPE STORAGE AREA RA! E AREA:R:AVt 7Ba0LETE EQUiPMEHT STORAG OVEREr' A SAND TURA E 7AIrl T t� rAi_ AJI MENT NEEDING REPAIR, STORA;3E r ,L• c r ivi1 L A Ih� ��J G:1: .. • _ c r E_ f-, _ CE '; rA f ^ i h"AfS �� .. S`��)t ��iLiE Ee5 _. - :.:, :•, B!. V1VL,J rTC/nA E VAA J!� BI:�J% cam.-., EcoienE�, '�� +{ i `• f ClA _l U r D Cr.` 1.,•- 3TiriiJ "�-.a + , _ J i' SFt,RAGE 86 E i` TY AS t,RVl.4 �KA�� _ HALT VII: " I�{l BC EoPT� DR �A STvR �E ,cDLJF ALL _ A$ /ArE.� - BD IAI T,AL i' r'? ANDGRATES srwt' a' ��a QI�'r _ ;R "` 1a, Y BE OUTDOCRAMrJP RiSI`yIr RATES STORAGE 7 f{4{ �J 1 ! ( k yCl-r [.rt BE r M r, l� 6 1 g „' o AA FE AtiLr li krAR H C�u S_PEN Aide "!!_E (REM VED 199?t; �m' AH RF yr Hi MISC. EGUIPIMENT AND DRUMS Y _ M r ; A„ S F BJ J SOLD IE STEE'_ HOLD CORE STORAGE { • ® A �2i W-'oRF.,. 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T ; 1:`l iL. i= DID NOT IJE. �.^�E Tri (=. - _ - - - - - ,. F'1TtcrF .� {- � nsr , r � r, �k 7Y .. '' w vi,.. ,., x"g c.raxcE ,� o Ste,'E F:: L:r,,i .r -C 1, �. F_E(_) P_-.i' Ll,f�I'.�•• ^-r L'T'v1 ,k,. <. ,. E -E s. w : ma-:va _,......,, _ ,. n �cr Al, LlC t / n=eye F.,an .`r aw A 1 _ v - r xs AlTt E hr.ti,, R., _ r - - UUTFALL- uRrE G® a CfLLc f, A Trr ' A\ ' Ir V I DRAT S1TE NAA�, INDEX, NOTE, ANLLEGEND I? — `- 1 u. IF E P F 1 E & FOUNDRY +.J 0! Y 1 i A f i'r t CHAt�LCT ` � !� 0A R 01L NA 9 SCALE S rJOTEC r G� r - Y 'JFA 1 J 9Y - K. S. - - - --- JnTE' 994 FS Ai LL NY REVISE, H®®® ENVIRONMENTM!.� : INC a�a a ON 1 Rb. PROJECT NUMBER NO. nLE - _o _r '�,c 1o51 w.: QS-11 .,5 l -_ �?°, t �'�� - - x �- --:— • - 1 FNISHEL MATERIAL STORAGE-1 P L_ HYuRAULIC ❑IL L li J ,r DRUMS CON PALLETS) AIR LINE BLOWDOWN�T AT SINK TO A ROOF DRAIN b) , r��l • �b v a a .d a _ _ ♦ .— R � ram/ A., t� °L] m F. GUN DRILL SHELL. CURE ,. I �n RCDM AREA T y €� CONDENSATE 7-P'i-, Fr, COC'LING CEPRES�OR LINE ®- TE,/ER DISCHARGE CUPO'_A DISCHARGE-� ^V'r-BELOW I / b y c SISC �,��,lJ 'ISCHARGE HOPPER <' A r w, m „02 i ES SE`COMPRYEREORJTANK T' CONDENSA:E0 DISCHARGEAp!1 ra m 6tU 157.1 .T7k AI.,F AREA �" Y 6ATN L�i l a� G L3 ;I I �` , -Al c �_/ v� ,. iB' PIPE- SLUDGE -+-i�"oDISCHARGE ,RI,a _ �' ❑VERFLOW T r - r � I �CDRAULIC UNiT -t �t7 -L- rna-BUCKET a �,a-�!r .� CHARGING HY _ n Jul HYLRL — , __ � — - T� r .: , �� 0, L Tlm At\-� - COMPRESSOR-3-- SD ®C�YCONDENSATE I _' T- II'I', r, t .- .1-Ti: F, -._ = - r. ca..rss -- -- DICCHARG� .� a - �r �' -- SD vIPLE CATION � ��IICI URCHASIrVGcAD IkNCD�nINi;vRsEGAET- EI� l Di � ��fI I �! �m rffizs ® s� NE E ARKINF SHED_vl r j j Ic D %�4_rn� A / q r1 hEh r_:.. VAIx_C\� 3 F E v reHIrR I C 6 (Y ENS iNEERIN�' y,, EXEC I'�'y �y r _ H,L'E 'CAL _ r ,.E .S�. TF-... a C 7 - ! DEP rIt n , 7" y, m u , — �-4 Ll C A � rl RI v !A—E ATFF ' — C,F, . PK R t �,._ � i ., n w. .L�E c 'Til:'.S DIY ! th y.i;, Ai\'�_�.� A.EA 2 � v / T `.., P - / i l ri =IT DRAG / E � J 3 r, d.�� J �INL:HF' P;-`E EIL MIST i '. NCH',E Ak, SPRAY k t , C i T � _ , . i SCRAP IRON STORAGE AREA r- L .N4 SUMP AT 7�, HIOPERS k DISCHARGE.' UNLOADING ARE�4 7 x� T/ TD , L ` , CASTING STORAGE/ AREA iT' SIC / GiL ANP LUBRICA i❑IL DRUM A TE(AGE NGTF- KFFEk ir) f I::,URE Nn. L F-R _EGE"JT ^1;'T�_; AFlD L 4AliVAG .,h_A'3. i fA-I AN JNLDAUI DRAFT MAY 2 3 1995 SITE SAP CHARLOTTE PIPE & FOUNDRY COMPANY CHARLOTTE, NORTH CAROLINA SCALE AS NOTED APPROVED BY DRAWN BY: J.K.S. ---_---------i ',— DATE NOV 1994 nr=orr,,n av RFvle, n ITPROJECT NUMBER LATE ku v^lo t,ADE APPROVED88— Y 8 Pi��B® ENVIRONMENTAL INC FILE NAME: I881.8s07 105-ii-95i � FIGURE 2-4 h , e 3 m wEon Ar r i PALLETS !,_L� i i �' / j� s) `rr lK 'T.ti '. A_� c ._i. '✓% Yc7� -_ BL!7'S i - v e C'OfIDEIV SATE T 2A�E ._ '_�� r- DISCHARGE N� i_i_P c k O.: 11 �� r7.�a' „��' V ill C h I ! j Ir - I- _e E ". fit• -�,;., � F7'TINi; l,./ F VNI F Ce)UNDRY f c l , x X �1 � I _ T ALL / i T i D UTI � I�i "AEET ER1,A �I L F+• _ — �i�YiD �i PATTERN r SHOP N � i S �A/ 0 0 1—'CURE --- - Q / � , 6. rl / �I ARD I _.�-f`�'`?4fr�� T - � ' P—' ! �� s i� --- / __— F�E �'T, SWO05 t ��*' �- i � J`�L MSIT.IN PAL-.r -xi ;jl hl� REL�DRA1.41 / HY! ET_r1 rjAa CF DRC'7E5 L I Vi_ : DRILL S SHELL CURE .�/ C/ ® ,L �' P�" �,�, RC'rM AREA a ®A E SAND HI nAnTNL I! STREET i I III F PENNMAN i E � — — I_ SAMPLE �UCATION' SW003 �k ax i 1 t III i �jp�� YV DRUM: STORAGE �( AREA GRAVEL OF -- - REFER TO FIGURE '`�Io. s r_`R LLGEk_)S, NOTES AI'%;4 i : �! SHED A W 14 0BSOLETE EQUIPMENT STORAGE i I l ! 1 n !I I! i i I I I ! 1 MAY 2 3 1995 I J SITE ' AP CHARLOTTE PIPE & FOUNDRY COMPANY CHARLOTTE, NORTH CAROLINA tOALE AS NOTED APPROVED BY DRAWN BY: J.K.S. ATE JAN 1995 n e!rnlnn av Rcv!¢rn DATE .__--_ ------ _ '�, PROJECT NUMBER REV]Si2l,tS _- ! MADE 11APPROVED { 38- 1 Z MENArmw TAL INC FILE ANlAEt 18818s01 (0�-71-35) FIGURE 2--3 REFER TO FIGURE '`�Io. s r_`R LLGEk_)S, NOTES AI'%;4 i : �! SHED A W 14 0BSOLETE EQUIPMENT STORAGE i I l ! 1 n !I I! i i I I I ! 1 MAY 2 3 1995 I J SITE ' AP CHARLOTTE PIPE & FOUNDRY COMPANY CHARLOTTE, NORTH CAROLINA tOALE AS NOTED APPROVED BY DRAWN BY: J.K.S. ATE JAN 1995 n e!rnlnn av Rcv!¢rn DATE .__--_ ------ _ '�, PROJECT NUMBER REV]Si2l,tS _- ! MADE 11APPROVED { 38- 1 Z MENArmw TAL INC FILE ANlAEt 18818s01 (0�-71-35) FIGURE 2--3 Gravel Pavement DRUM/ Loading Dock TOTE STORAGE SHED Scrap Metal: Ster Bin Storage age ... DuTmpsters Asp/halt Asphalt Bulk Material Spent Storage Parking Fitting (Covered) Storage Area Fitting Storage Warehouse Area Asphalt Parking Bin Storage L Asphalt Parking OUTFALL Z SWO04 10 'A IRWIN CREEK OUTFALL,:AI I SWO06 rz OUTFALL SWO05 w- OIL HMUSE USED OIL TANK Generator s tDruoro'ge Trash Dumpster SAMPLE LOCATION FOR SWO02 101AMAe A I TeMt T� E-[MT T. Asphalt OUTFALL SWO02 0 k1k, 3 7- . . ; MZ MWETEMora Asphalt Ym Tra h Dumpster P� A MILE OUTFALL I Bin 4, swool Storage Bin & Feldspar Storage SILOS Asphalt st, ROTAINNS W�� GRASS E A W A R rrEl A Pallet t' Storage 31B,, Property of Railroad b 2 TOTES OF OIL SHELL CORE UNLOADING AREA Parking Slag Storage Gravel DRUM/ TOTE STORAGE SHED Coke Storage Cardboard Trash tuirpster Dumpster Asphalt 9'- < Truck',, ' Parking AREA IV Gravel Truck Parking At i CK'-" r'kl 10 N Cj F S T (0) R M 10YAT E R P-A OUTFALL LATIT UDE LONGITUDE 0 �'1327N 3 55, J 4 . 4O � 8 0 `5, 1 4 51 1VNJ 3'5)- 135 42) 9 "N 0-1. A l4 Q IVIV 8 one, ik 3 5 "' 1 3 l 23 "N j J 8 0 5 1 '4 2" 1W 004 3 10' 1 2 7" IN 80 513 9 "VV 005 3 5 " 1 '132 9 "N 8 0 '5 1'4 01 'VV n06 35� 1,564'N 80'51l45"W AREA PERCENT (ACRES) IMPERVIOUS AREA� 7 l- r,- , 11 A R AA 2,90 95% AREA 1111 3, 3 15 85% A R EA I \ ri 10,23 9 5 ��/o A RE A V 2,28 95% AREA V .53 85% R A t-A A" '1206 95% Grass OUTFALL Ii 2 A Asphalt 0`06 Asphalt 5p� Parking POTENTIAL POLLUTANTS �. i L;j J IL E,X IVIE-'JALS, CHEMICAL RESIDUES, OIL & GREASE iVIE.TALS, CHEMICIL'Q- RESIDUES, 011- & GREASE t7 S �,Lb, ('�HE�,,�,ICA�-RESI,DUE1.1,011.-&k�:)REASE. U N1 S C �41ENMCIAL RESIDL11 L 01 & ISE GREA, NAI�TALS, CHEIN"I'Al RESIDUES, Oil- & I.- GRE"ASItz NCNHDE-6485: NCS Renewal Report Bennett, Bradle From: Broadway, Chad <Chad.Broadway@mecklenburgcountync.gov> Sent: Friday, August 17, 2018 8:08 AM To: Bennett, Bradley Cc: Khan, Zahid; Moore, James Subject: [External] RE: [External]Checking in on a few more Mecklenburg County sites Attachments: IGM Resins - 9-22-15 - Final Report.pdf; Gerdau Ameristeel NOV 8-2-12.pdf; Geradu Ameristeel US Inc. - Final - 5-14-13.pdf; Gerdau - Facility Cover Letter and Inspection_ 11.14.17.pdf; Gerdau Monitoring - Cover Letter and Report (Color).pdf; Inspection Report - Charlotte Pipe and Foundry - FINAL.pdf; Final - Nexeo Solutions - Stormwater Facility Inspection.pdf; NexeoSolutions_report_v2.pdf CAUTION: Exter aI email. Do not slick links or open attachments u less verifie .Send all suspicious email as an attachment to .. Hi Bradley, Sorry for the very late response, we've had a number of issues come up over the last month and I'm just now getting caught up. For the facilities you mentioned: • NCS000049 — IGM Resins USA, Inc. —3300 Westinghouse Blvd o Our most recent inspection of the facility was on 9/22/15 (attached), although it was by an inspector who is no longer in our group and is not very thorough/descriptive. o I conducted a complaint -based inspection at the facility in June of this year and found a compromised pipe that conveys process water to their pretreatment system. While I did not view any discharge from the pipe during two visits, the pipe appeared to have a high potential to discharge residual toluene (one of the primary chemicals used on site) and other pollutants from their waste stream. I received notification last week that the pipe has been replaced. o From my visit, there was a fair amount of spilled material and a lot of outdoor ASTs, but most of the exposed area near the plant appears to be collected in a system that discharges to the facility's pretreatment system. • NCS000304 — Gerdau Ameristeel US, Inc. - 6601 Lakeview Road o Our most recent facility inspections were on 10/23/17 and 5/14/13 (attached). o We also conducted stormwater monitoring on 2/9/14. Results are attached — we found slight exceedances of pH, Cu, and Zn. Generally speaking, the facility has a significant amount of exposure and pollution sources, but also reuses a lot of accumulated stormwater and has very large buffers between the plant and the final outfalls. o I responded to a spill of approximately 125 gallons of hydraulic oil on 1/3/18. 1 think this spill was reported to MRO, and then Zahid notified us. The discharge was due to an operator error during facility maintenance, and approximately half of the spilled amount reached the ground with no obvious impacts to the storm drainage system. The affected area was excavated by a remediation contractor within a week and results for remaining soils were below action levels. o We conducted a complaint -based inspection in January 2015 based on reports of discharges from the facility's closed -loop recycle process water (contact) system. During our inspection, no active discharge was occurring, but high-water marks and stained soils around the system's return pond indicated multiple previous discharges from the system. From my understanding, while this may not be relevant to the NPDES permit, this situation also turned into a wrongful termination whistle blower lawsuit. We have been contacted by legal representatives for the former employee on multiple occasions. o We conducted an inspection on 8/2/12 for a spill of 460 gallons of diesel fuel to the ground and a stormwater retention / process water pond. The NOV is attached, and I think James Moore may have recently been contacted about this discharge. NCS000040 — Charlotte Pipe & Foundry Co. - 1335 S. Clarkson Street o Our most recent facility inspection was on 5/14/2015 (attached). From the report, it appears they were in Tier II/III at the time, but there's not information about what parameter(s) were exceeded or how great the exceedances were. o We also responded to an "asphalt -water mixture spill" on 1-13-14. Our file did not have a lot of information about the source and cause of this spill, but I would assume it was due to site improvements as opposed to process -related. • NCS000315 — Nexeo Solutions LLC — 3930 Glenwood Drive I inspected the facility on 11/28/17 and a previous inspection was conducted on 3/31/14. (attached) The facility is a repackaging and distribution center for haz-mats, flammables, caustics, etc., and is generally well -kept. During my inspection, I found they were not conducting qualitative monitoring at all outfalls, as required. Based on the requirement for analytical to only be conducted at one outfall, I could see how this may have been confusing. Chad Broadway, Environmental Specialist Charlotte -Mecklenburg Storm Water Services Mecklenburg County Water Quality Program 2145 Suttle Avenue Charlotte, NC 28208 704-280-1497 (mobile) chad.broadwav@mecknc.eov http:Zlcharlottenc.gov/StormWater Storm Water's WHY statement: We are passionate about making our environment safe and healthy by reducing flood losses and improving water quality for all. chortotfu4j sklenbarg STORK! _ _LL_ WATER _ Services From: Bennett, Bradley <bradley.bennett@ncdenr.gov> Sent: Monday, July 30, 2018 3:55 PM To: Broadway, Chad <Chad.Broadway@mecklenburgcountync.gov> Cc: Khan, Zahid <zahid.khan @ncdenr.gov>; Moore, James <james.moore@ncdenr.gov> Subject: [ExternaljChecking in on a few more Mecklenburg County sites CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you ize the sender and know the content is safe. Hey Chad, Over the next few weeks I'll hopefully be getting to a few more facilities for individual permit renewals. I just wanted to touch base with you and see if you had any information on these that might not be reflected in BIIMS inspections. • NCS000049 — IGM Resins USA, Inc. — 3300 Westinghouse Blvd • NCS000304 — Gerdau Ameristeel US, Inc. - 6601 Lakeview Road • NCS000040 — Charlotte Pipe & Foundry Co. - 1335 S. Clarkson Street • NCS000315 — Nexeo Solutions LLC — 3930 Glenwood Drive I haven't started the review just yet so I don't have any drafts ready. Just wanted to see if you have anything to pass along on these that we should consider as we work through it. I'll check through BIMS and see if there were any issues from the most recent DEMLR or CMSWS inspections. Zahid, James— heads of for you guys also. Let me know if you are aware of any issues. CI Bradley Bennett Stormwater Program Note New Phone Number NC Division of Energy, Mineral & Land Resources Phone: (919) 707-3646 512 N. Salisbury Street Fax: (919) 807-6494 1612 Mail Service Center Email: brad ley. bennett(cDncdenr.gov Raleigh, NC 27699-1612 Email correspondence to and from this address may be subject to public records laws Charfooee-Mecklenbburrg 700 North Tryon Street 0 t! .STORM Charlotte, NC 28202 WATER Facility Inspection Fax 704.336.4391 — . Services Facility Name: Charlotte Pipe & Foundry Company Inspection ID: 16536 Contact: Jenny Pappalardo, Environmental Engineer Permit #: NCS000040 Inspector: Ron Eubanks Receiving Stream: IRWIN Inspection Date: 05104/2015 Entry Time: 9:30 am Exit Time: 12:00 pm SIC #: Facility Description: The Charlotte Pipe and Foundry facility is located at 1335 South Clarkson Street on approximately 45 acres of property. The facility manufactures cast iron piping and cast iron piping joints & fittings. File Review/History: Stormwater inspections have been previously conducted by Charlotte -Mecklenburg Storm Water Services at Charlotte Pipe and Foundry Company on April 19, 2002, April 5, 2006, and May 3, 2010. Inspection Summary: During the recent inspection, Charlotte Pipe and Foundry Company was observed to be in compliance with the Charlotte Storm Water Pollution Control Ordinance. Please refer to the report for comments and recommendations regarding the inspection. Site Inspection Deficiency Comment Stormwater system (catch basins, No Stormwater runoff from the property drains by sheet flow into inlets, outfalis, etc.) a series of catch basins and discharges from the property via five (5) outfalls. The stormwater drainage systems appeared to be in good condition; no significant pollution issues were observed. Erosion issues No No stormwater erosion issues were observed on the property during the inspection. Structural stormwater BMPs Recommendation The structural stormwater best management practices (BMPs) at the site include inlet protection in some of the catch basins on the property. The waste aggregates have also been recently relocated indoors on the property to prevent contact with stormwater runoff. Routine parking lot sweeping and catch basin inlet cleaning activities are recommended to reduce the amount of sediment in stormwater runoff from the property. Illicit discharges/connections No No illicit discharge or connections were observed on the property during the inspection. Aboveground storage tank(s) - list No The aboveground storage tanks (ASTs) on the property tank sizes & contents include: one (1) 10,000-gallon gasoline AST, one (1) 10,000-gallon diesel fuel AST, one (1) 15,000-gallon hot asphalt AST, and one (1) 500-gallon used oil AST. Each of the ASTs are located within secondary containment with a locked drain valve. Underground storage tank(s) - fill N/A port area; list tank sizes & contents Outdoor material storage area(s) No Some raw materials and finished product are stored outdoors on paved and gravel areas of the property. No significant stormwater pollution issues were observed in the outdoor material storage areas. Outdoor processing area(s) N/A • To report pollution or drainage problems call: 311 http:// s t o r m w a t e r. c h a r m e c k. o r g . cauu.trrrr•.. 5/21/2015 4:52:31PM Page 1 of 3 Site Inspection Deficiency Comment Loading/unloading area(s) No There are several loading/unloading areas on the property. No significant stormwater pollution issues were observed in the loading/unloading areas. Vehicle/equipment area(s) - fueling, Recommendation Facility vehicles and equipment are fueled onsite from the fuel washing, storage, etc. dispenser pumps located adjacent to the gasoline and diesel fuel ASTs. Facility vehicles and equipment are also washed on the property in a wash bay. The wash bay drains into an oil/ water separator which is connected to the sanitary sewer system. Since there are storm water inlets located down gradient from the fueling area, stormwater inlet protection BMPs are recommended. Oil/Water separator and/or No There is an oil/water separator located on the property for the pretreatment vehicle wash bay. Charlotte Pipe and Foundry Company also has a Pretreatment Permit (#0665) with Charlotte Water (formerly Charlotte -Mecklenburg Utilities). Waste storage/disposal area - Recommendation There are municipal waste, scrap metal recycling, and wood dumpsters, scrap metal bins, etc. pallet recycling dumpsters located on the property. Each of the observed dumpsters appeared to be in good condition; however, the scrap metal recycling dumpster were uncovered. It is recommended that the dumpsters be covered to prevent stormwater accumulation. Food service area(s) No There is a grease trap located on the property; the grease trap is cleaned annually. Indoor material storage area(s) No Various chemicals and paint are stored indoors on the property. Indoor processing area(s) No Floor drains No The floor drains on the property are connected to the pretreatment system which discharges to the sanitary sewer. Spill response equipment No Spill kits are located at the garage, oil house, and loading/unloading areas on the property. Stormwater Pollution Plan Observed Comment Does the facility have a stormwater Yes pollution prevention plan? General location (USGS) map Yes Narrative description of practices Yes Detailed site map Yes List of significant spills (past 3 years) Yes A spill from the hot dip asphalt area was properly reported on January 13, 2014, Non-stormwater discharge Yes evaluation of outfall(s) Feasibility study Yes All necessary secondary Yes containment provided Collected water evaluated and Yes documented prior to release BMP Summary Yes Spill prevention and response plan Yes Preventative maintenance and good Yes housekeeping plan Facility provides and documents Yes Employee training was conducted in December 2014. employee training List of responsible parties Yes Reviewed and updated annually Yes Stormwater facility inspection Yes program conducted semi-annually Qualitative/Analytical Monitoring Observed Comment • KrnTo report pollution or drainage problems call: 311 http://stormwater.charmeck.arg ClLtlll,l l"ITt;. 5/21/2015 4:52:31PM Page 2of3 Qualitative/Analytical Monitoring Observed Comment Qualitative monitoring conducted Yes The most recent qualitative monitoring was conducted on semi-annually December 16, 2014 and April 14, 2015. Analytical monitoring conducted Yes The most recent analytical monitoring was conducted on semi-annually December 16, 2014 and April 14, 2015. Due to recent benchmark exceedences, monthly monitoring is being conducted at stormwater outall #4. Analytical monitoring from vehicle Yes maintenance Permit and Outfalls Observed Comment Copy of permit and certificate of Yes Charlotte Pipe and Foundry Company has an Individual coverage onsite NPDES Stormwater Permit (NCS000040). All ouffalls observed Yes No stormwater pollution issues were observed at the outfalls. Number of Outfalls Observed 5 Representative ouffall status N/A documented by NCDWQ Annual no -exposure self N/A re -certification documented Additional Findings Observed Comment Observation(s) Observation(s) Observation(s) Phase II Permit Requirements Observed Comment Wastes removed from the MS4 N/A properly disposed Public transportation (roadway) N/A projects constructed within the last year Curb miles and parking lots swept N/A documented Catch basin and storm drain pipe N/A cleaning documented Records of pesticide/herbicide N/A applicator licenses maintained for staff and contractors If pesticide treatment areas N/A exceeded, was permit application submitted? Pesticide limitations in Goose Creek N/A Watershed followed • To report pollution or drainage problems call: 311 h IIp:// s t o r m w a t e r. c h a r m e c k. o r g I:ILtRl.l1'1'1'1_ cLL 5/21/2015 4:52:31 PM Page 3 of 3 CHARL( TTE PIPE and FOUNDRY COMPANY P.O. Box 35430 • Telephone 704/332-2647 CHARLOTTE, NORTH CAROLINA 28235 Foundry Fax No. 332-4581 July 1.0, 2014 NCDENR -DEMLR Attn: Zahid Khan 61.0 East Center Ave., Suite 301 Mooresville, NC 28115 704.663.1.699 r RF�jIz1j p J0 i1'i14 STORYWAER ": ?ARTY NG RE: Charlotte Pipe & Foundry Co. - Mecklenburg County, NC NPDES Stormwater Permit NCS000040 SWO04 Zinc Benchmark Exceedance Dear Mr. Khan: In follow-up to a phone conversation with Ken Pickle, NCDEMLR Stormwater - Raleigh on Thursday, July 10, 2014, I am submitting this written notification that we have exceeded the benchmark value for Zinc from SWO04 on four occasions since our delay of tiers has expired. We have implemented several significant BMPs over the past several years to reduce concentrations of regulated parameters in our stormwater. These include, but are not limited to: • Installation of a Waste Storage Building to cover our waste piles; • Installation of sump pumps in our scrap storage area and charging system pits which pump rain water to our on -site water treatment plant for recycling; • Placement of covers on outside baghouse collection bins to prevent run-off to the storm drains; • Routine sweeping of facility grounds; • Vacuuming of multiple storm drains; • Weekly 5S departmental cleaning of outside areas; • Monthly inspections of material storage areas; and • Quarterly visual and housekeeping inspections of the site. Mr. Khan Page 2 We would like to work with you to establish a path forward. Please contact me at 704.348.5513 to schedule a site visit or if you need any additional information. Thank you for your assistance. Sincerely, Jenny Pappalardo Charlotte Pipe and Foundry Co. Environmental Engineer cc: Ken Pickle ] 612 Mail Service Center Raleigh, NC 27699-1612 (919)807-6376 Pickle, Ken From: Eubanks, Ron <Perry.Eubanks@mecklen rgcountync.gov> Sent: LTuesday, July 14, 2015 10:54 AM To: Jay Cc: bert; Pappalardo, Jenn .; dwaggoner@charlottepipe.com; Pickle, Ken Subject: rmwater Ins ection - harlotte Pipe and Foundry Attachments: e Pi a and Found Cover Letter.pdf; Inspection Report - Charlotte Pipe and Foundry - FINAL.pdf Good morning Jay, I spoke with Ms. Jenny Pappalardo (Charlotte Pipe & Foundry) earlier this morning regarding the planned construction activities to be performed at the site. From our conversation, it is my understanding that the construction activities are being performed to accommodate the CATS Light Rail expansion project near the Charlotte Pipe & Foundry property. As you may be aware, Charlotte -Mecklenburg Storm Water Services (CMSWS) performs inspections at various industrial facilities within the City of Charlotte under the City's Phase I Stormwater Permit. The recent inspection conducted by CMSWS on May 4, 2015 has been attached for reference. I explained to Ms. Pappalardo that the construction activities at the site would have to comply with the City of Charlotte Soil Erosion and Sediment Control Ordinance. I explained that an Erosion Control Plan would also be required if the disturbed area was greater than one (1) acre. As for their NPDES Individual Stormwater Permit, it is currently up for renewal at the State and they plan to update their Stormwater Pollution Prevention Plan (i.e., Site Map, Outfall locations, etc.) when the construction activities have been completed. Please contact Ms. Pappalardo at (704) 348-5513 to discuss the City of Charlotte erosion control requirements for this project. Please send me an e-mail or contact me at (980) 721-4191, if you have any questions or need additional information regarding this matter. Thanks as always for your help. Have a great day! Ron Eubanks, Environmental Specialist Charlotte -Mecklenburg Storm Water Services Mecklenburg County Water Quality Program 700 North Tryon Street Charlotte, North Carolina 28202 Phone: (704) 336-5446 (office), (980) 721-4191 (cell) E-mail: Perry.Eubanks@MecklenburgCountyNC.gov /✓4fllefP!,A ISS. o I-e-V;.re �oenH��7�/ Coul1--S qo/�/rt2Tien /a 4eo;.VOr( Consider the environment before printing this email or the attachment. 71/4/Ae/S K,BP advisPo/✓enn y /a�oPa�a��o o� From: Eubanks, Ron Sent: Thursday, May 21, 2015 5:12 PM To: 'Pappalardo, Jenny L.' Cc: 'dwaggoner@charlottepipe.com' Subject: RE: Stormwater Inspection - Charlotte Pipe and Foundry C'P:1rF thif.- L • �r'opotPa/P/a�rcT s�tw/off �e reiclee-f-d /A ��aat°d 5Aae W.-w oalva//s nray 6e o// D/!PS a ban do ono,(. Hi Jenny, Please find attached copies of the cover letter and report from the recent stormwater inspection conducted by Charlotte -Mecklenburg Storm Water Services at Charlotte Pipe and Foundry. From the report, there are a few recommendations; however, no written response is necessary. Please send me an e-mail or call with any questions. Thank you and David for your cooperation with the inspection. Have a great "Memorial Day" weekend. Ron Eubanks, Environmental Specialist Charlotte -Mecklenburg Storm Water Services Mecklenburg County Water Quality Program 700 North Tryon Street Charlotte, North Carolina 28202 Phone: (704) 336-5446 (office), (980) 721-4191 (cell) E-mail: Perry.Eubanks@MecklenburgCountyNC.gov NA Consider the environment before printing this email or the attachment From: Pappalardo, Jenny L.[mailto:ipappalardo@charlottepipe.com] Sent: Friday, April 24, 2015 2:26 PM To: Eubanks, Ron Subject: Re: Stormwater Inspection - Charlotte Pipe and Foundry Yes, check in at guard shack at main gate and have them page me. Look forward to seeing you. Sent from my iPhone On Apr 24, 2015, at 1:11 PM, Eubanks, Ron <Perry. Eubanksmecklenburgcountync.gov> wrote: Hi Jenny, Let's plan to meet at 9:30 a.m. on May 41h. Do you want me to meet you at the visitor entrance at guard house? Have a good afternoon. Ron Eubanks, Environmental Specialist Charlotte -Mecklenburg Storm Water Services Mecklenburg County Water Quality Program 700 North Tryon Street Charlotte, North Carolina 28202 Phone: (704) 336-5446 (office), (980) 721-4191 (cell) E-mail: Perry.Eubanks@MecklenburgCountyNC.gov Consider the environment before printing this email or the attachment From: Pappalardo, Jenny L. [mailto:ipappalardoPcharlottepipe.coml Sent: Friday, April 24, 2015 11:38 AM To: Eubanks, Ron Subject: Re: Stormwater Inspection - Charlotte Pipe and Foundry Thank you Ron. I would prefer AM, but can work around anything convenient for you. Sent from my iPhone On Apr 24, 2015, at 10:05 AM, Eubanks, Ron <Perry.Eubanks&mecklenbur cg ountynagov> wrote: Good morning Jenny, Please find attached an explanation letter for the requested stormwater inspection and a copy of the report from the previous inspection conducted by Charlotte -Mecklenburg Storm Water Services at Charlotte Pipe and Foundry on May 3, 2010. From your e-mail, I am also available on May 4`h. Do you prefer to schedule the inspection in the morning (9:30 a.m. —11:30 a.m.) or afternoon (1:30 p.m. — 3:30 p.m.)? Please send me an e-mail or contact me at (980) 721- 4191 to confirm. Thanks again to you and David Waggoner for your cooperation. Have a great weekend. Ron Eubanks, Environmental Specialist Charlotte -Mecklenburg Storm Water Services Mecklenburg County Water Quality Program 700 North Tryon Street Charlotte, North Carolina 28202 Phone: (704) 336-5446 (office), (980) 721-4191 (cell) E-mail: Perry.Eubanks@MecklenburgCountyNC.gOv NA Consider the environment before printing this email or the attachment From: Pappalardo, Jenny L. [mailto:ipappalardo@charlottepipe.com] Sent: Thursday, April 23, 2015 3:15 PM To: Eubanks, Ron Subject: Stormwater Inspection Ron, In follow-up to our phone conversation, I am available May 4, 7-8, 12-15 for you to visit the site. Please let me know what works for you. Have a nice day. Thanks, Jenny Jenny L. Pappalardo CHARLOTTE PIPE and FOUNDRY CO. 1335 South Clarkson Street Charlotte, NC 28208 Office: 704-348-5513 <Explanation Letter - Charlotte Pipe and Foundry Company.pdf> <Inspection Report -Charlotte Pipe and Foundry-FINAL.pdf> ChadattaMwklenbure STORM WATER Services - May 18, 2015 Jenny Pappalardo, Environmental Engineer Charlotte Pipe and Foundry Company 1335 South Clarkson Street Charlotte, NC 28208 Subject: Industrial Facility Inspection Charlotte Pipe and Foundry Company Dear Ms. Pappalardo: 700 North Tryon Street Charlotte, NC 28202 Fax 704.336.4391 On May 4, 2015, Ron Eubanks of Charlotte -Mecklenburg Storm Water Services (CMSWS) conducted an inspection of the above referenced facility as a requirement of the City of Charlotte's NPDES Permit, NCS000240, Part 11 Section H. Inspection authority is granted by Charlotte City Code Chapter 18, Article III, Section 18-82. At the time of inspection, the facility was observed to be in compliance with the City of Charlotte Storm Water Pollution Control Ordinance; however, the following recommendations are provided: Structural stormwater BMPs — The structural stormwater best management practices (BMPs) at the site include inlet protection in some of the catch basins on the property. Routine parking lot sweeping and catch basin inlet cleaning activities are recommended to reduce the amount of sediment in stormwater runofffrom the property. Vehicle/equipment area(s) — Facility vehicles and equipment are fueled onsite from the fuel dispenser pumps located adjacent to the gasoline and diesel fuel aboveground storage tanks (ASTs). Since there are stormwater inlets located down gradient from the fueling area, stormwater inlet protection BMPs are recommended. Waste storage/disposal area(s) - There are municipal waste dumpster, scrap metal recycling, and wood pallet recycling dumpsters located on the property. Each of the observed dumpsters appeared to be in good condition; however, the scrap metal recycling dumpsters were uncovered. It is recommended that the scrap metal dumpsters be covered to prevent stormwater accumulation. • O To report pollution or drainage problems, call: 311 e http://stormwater.charmeck.org C.11,(IILOTfIt Ms. Jenny Pappalardo Page 2 May 18, 2015 The attached report provides details about inspection observations and should be self- explanatory. Please contact me at (980) 721-4191, if you have any questions or need additional information. Thank you for your time and cooperation with the inspection. Sincerely, P. Ronald Eubanks Environmental Specialist Charlotte -Mecklenburg Storm Water Services cc: Craig Miller, Charlotte Storm Water Services Erich Schweiber, NCDENR — DEMLR David Waggoner, Charlotte Pipe and Foundry Company Cbar►fgob1aMeeklwbef�jg 700 North Tryon Street S1L®�9rM Charlotte, NC 28202 WATERFacility Inspection Fax: 704.336.4391 Facility Name: Charlotte Pipe & Foundry Company Inspection ID: 18536 Contact: Jenny Pappalardo, Environmental Engineer Permit #: NCS000040 Inspector: Ron Eubanks Receiving Stream: IRWIN Inspection Date: 05/04/2015 Entry Time: 9:30 am Exit Time: 12:00 pm SIC #: Facility Description: The Charlotte Pipe and Foundry facility is located at 1335 South Clarkson Street on approximately 45 acres of property. The facility manufactures cast iron piping and cast iron piping joints & fittings. File Review/History: Stormwater inspections have been previously conducted by Charlotte -Mecklenburg Storm Water Services at Charlotte Pipe and Foundry Company on April 19, 2002, April 5, 2006, and May 3, 2010, Inspection Summary: During the recent inspection, Charlotte Pipe and Foundry Company was observed to be in compliance with the Charlotte Storm Water Pollution Control Ordinance. Please refer to the report for comments and recommendations regarding the inspection. INSPECTION DETAILS Site Inspection Deficiency Comment Stormwater system (catch basins, No Stormwater runoff from the property drains by sheet flow into inlets, outfalls, etc.) a series of catch basins and discharges from the property via five (5) outfalls. The stormwater drainage systems appeared to be in good condition; no significant pollution issues were observed. Erosion issues No No stormwater erosion issues were observed on the property during the inspection. Structural stormwater BMPs Recommendation The structural stormwater best management practices (BMPs) at the site include inlet protection in some of the catch basins on the property. The waste aggregates have also been recently relocated indoors on the property to prevent contact with stormwater runoff. Routine parking lot sweeping and catch basin inlet cleaning activities are recommended to reduce the amount of sediment in stormwater runoff from the property. Illicit discharges/connections No No illicit discharge or connections were observed on the property during the inspection. Aboveground storage tank(s) - list No The aboveground storage tanks (ASTs) on the property tank sizes & contents include: one (1) 10,000-gallon gasoline AST, one (1) 10,000-gallon diesel fuel AST, one (1) 15,000-gallon hot asphalt AST, and one (1) 500-gallon used oil AST. Each of the ASTs are located within secondary containment with a locked drain valve. Underground storage tank(s) - fill N/A port area; list tank sizes & contents Outdoor material storage area(s) No Some raw materials and finished product are stored outdoors on paved and gravel areas of the property. No significant stormwater pollution issues were observed in the outdoor material storage areas. Outdoor processing area(s) N/A ifT1,• O To report pollution or drainage problems call: 311 http:// s t o r in w a t e r. c h a r m e c k. o rg (]4UIIAYI'IE 5/21/2015 4:52:31PM Page 1 of 3 Site Inspection Deficiency Comment Loading/unloading area(s) No There are several loading/unloading areas on the property. No significant stormwater pollution issues were observed in the loading/unloading areas. Vehicle/equipment area(s) - fueling, Recommendation Facility vehicles and equipment are fueled onsite from the fuel washing, storage, etc. dispenser pumps located adjacent to the gasoline and diesel fuel ASTs. Facility vehicles and equipment are also washed on the property in a wash bay. The wash bay drains into an oil/ water separator which is connected to the sanitary sewer system. Since there are storm water inlets located down gradient from the fueling area, stormwater inlet protection BMPs are recommended. Oil/water separator and/or No There is an oiUwater separator located on the property for the pretreatment vehicle wash bay. Charlotte Pipe and Foundry Company also has a Pretreatment Permit (#0665) with Charlotte Water (former) Charlotte -Mecklenburg Utilities). Waste storage/disposal area - Recommendation There are municipal waste, scrap metal recycling, and wood dumpsters, scrap metal bins, etc. pallet recycling dumpsters located on the property. Each of the observed dumpsters appeared to be in good condition; however, the scrap metal recycling dumpster were uncovered. It is recommended that the dumpsters be covered to prevent stormwater accumulation. Food service areas) No There is a grease trap located on the property; the grease tra is cleaned annual) . Indoor material storage area(s) No Various chemicals and paint are stored indoors on the property. Indoor processing area(s) No Floor drains No The Floor drains on the property are connected to the pretreatment system which discharges to the sanitary sewer. Spill response equipment No Spill kits are located at the garage, oil house, and loading/unloadingloading/unloading areas on the property. Stormwater Pollution Plan Observed Comment Does the facility have a stormwater Yes pollution prevention plan? General location (USGS) map Yes Narrative description of practices Yes Detailed site map Yes List of significant spills (past 3 years) Yes A spill from the hot dip asphalt area was properly reported on January 13, 2014. Non-stormwater discharge Yes evaluation of outfall(s) Feasibility study Yes All necessary secondary Yes containment provided Collected water evaluated and Yes documented prior to release BMP Summary Yes Spill prevention and response plan Yes Preventative maintenance and good Yes housekeeping plan Facility provides and documents Yes Employee training was conducted in December 2014. employee training List of responsible parties Yes Reviewed and updated annually Yes Stormwater facility inspection Yes program conducted semi-annually I Qualitative/Analytical Monitoring Observed Comment • To report pollution or drainage problems call: 311 http:// s t o r m w a t e r. c h a r m e c k. o rg (:11,11t1A17TE. 5/21/2015 45231PM Page 2 of 3 QualitativelAnalytical Monitoring Observed Comment Qualitative monitoring conducted Yes The most recent qualitative monitoring was conducted on semi-annually December 16, 2014 and April 14, 2015. Analytical monitoring conducted Yes The most recent analytical monitoring was conducted on semi-annually December 16, 2014 and April 14, 2015. Due to recent benchmark exceedences, monthly monitoring is being conducted at stormwater outfall #4. Analytical monitoring from vehicle Yes maintenance Permit and Outfalls Observed Comment Copy of permit and certificate of Yes Charlotte Pipe and Foundry Company has an Individual coverage onsite NPDES Stormwater Permit (NCS000040). All outfalls observed Yes No stormwater pollution issues were observed at the outfalls. Number of Outfalls Observed 5 Representative outfall status N/A documented by NCDWQ Annual no -exposure self N/A re -certification documented Additional Findings Observed Comment Observation(s) Observation(s) Observation(s) Phase II Permit Requirements Observed Comment Wastes removed from the MS4 N/A properly disposed Public transportation (roadway) N/A projects constructed within the last year Curb miles and parking lots swept N/A documented Catch basin and storm drain pipe N/A cleaning documented Records of pesticide/herbicide N/A applicator licenses maintained for staff and contractors If pesticide treatment areas N/A exceeded, was permit application submitted? Pesticide limitations in Goose Creek N/A Watershed followed To report pollution or drainage problems call: 311 http:// s t o r m w a t e r. c h a r m e c k. o rg 5/21/2016 4:52:31PM Page 3 of 3 NC®ENR North Carolina Department of Environment and Natural Resources Pat McCrory Governor Charlotte Pipe & Foundry Co. Attention Ms. Jenny Pappalardo P.O. Box 35430 Charlotte, North Carolina 28235 Dear Ms. Pappalardo: John E. Skvarla, III Secretary August 8, 2014. Subject: Compliance Evaluation Inspection Stormwater Permit # NCS000040 Mecklenburg County, North Carolina Enclosed is a copy of the Compliance Evaluation Inspection (CEI) report for the inspection conducted on August 6, 2014 by Mr. Erich Schweiber and Mr. Samar Bou- Ghazale of this Office. The report should be self-explanatory; however, should you have any questions concerning the report, please do not hesitate to contact Mr. Bou-Ghazale at (704) 663- 1699 Ext.2199. Sincerely, Zahid S. Khan, CPM, CPESC, CPSWQ Regional Engineer Land Quality Section Attachment Division of Energy, Mineral, and Land Resources Land Quality Section - Mooresville Regional Office 610 East Center Avenue, Suite 301. Mooresville, North Carolina 28115 Telephone: 704-663-16991 FAX: 704-663-6040 • Internet: http://portal.nodenr.org/web/Ir/land-quality An Equal opportunity / Affirmative Action Employer — 50% Recycled / 10% Post Consumer Paper Compliance Inspection Report Permit: NCS000040 Effective: 11/06/09 Expiration: 07/31/14 Owner: Charlotte Pipe & Foundry Cc SOC: Effective: Expiration: Facility: Charlotte Pipe & Foundry Company County: Mecklenburg 1335 S Clarkson St Region: Mooresville Charlotte NC 28208 Contact Person: David Waggoner Title: Phone: 704-332-2647 Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 08/06/2014 Entry Time: 09:15AM Primary Inspector: Samar E Bou Ghazale Secondary Inspector(s): Reason for Inspection: Routine Permit Inspection Type: Stormwater Discharge, Individual . Facility Status: ® Compliant ❑ Not Compliant Question Areas: ® Storm Water (See attachment summary) Certification: Phone: Exit Time: 1145AM Phone: 704-663-1699 Ext.2199 Inspection Type: Compliance Evaluation Page: 1 Permit: NCS000040 Owner -Facility: Charlotte Pipe & Foundry Cc Inspection Date: 08/06/2014 Inspection Type : Compliance Evaluation Reason for Visit: Routine Inspection Summary: Site is in compliance. However, there are several areas that need to be investigated prior to applying for reduced monitoring. There are 3 garbage bins that are rusted and discharge stormwater to outfall# 4. Also, several oil patches were noted on the concrete and lots of tires marks. Several areas contain rusted metals that discharge to outfall # 4. Please continue the investigations around the site in order to identify the source of the zinc. Page: 2 permit: NCS000040 Owner- Facility: Charlotte Pipe 8 Foundry Co Inspection Date: 08/06/2014 Inspection Type : Compliance Evaluation Reason for Visit: Routine Stormwater Pollution Prevention Plan Yes No NA NE Does the site have a Stormwater Pollution Prevention Plan? ® ❑ ❑ ❑ # Does the Plan include a General Location (USGS) map? ®❑ ❑ ❑ # Does the Plan include a "Narrative Description of Practices'? ®❑ ❑ ❑ # Does the Plan include a detailed site map including outfall locations and drainage areas? ®❑ ❑ ❑ # Does the Plan include a list of significant spills occurring during the past 3 years? ®❑ ❑ ❑ # Has the facility evaluated feasible alternatives to current practices? ❑ ®❑ ❑ # Does the facility provide all necessary secondary containment? ®❑ ❑ ❑ # Does the Plan include a BMP summary? ® ❑ ❑ ❑ # Does the Plan include a Spill Prevention and Response Plan (SPRP)? ® ❑ ❑ ❑ # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? is ❑ ❑ ❑ # Does the facility provide and document Employee Training? W ❑ ❑ ❑ # Does the Plan include a list of Responsible Party(s)? ® ❑ ❑ ❑ # Is the Plan reviewed and updated annually? ® ❑ ❑ ❑ # Does the Plan include a Stormwater Facility Inspection Program? ® ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? ® ❑ ❑ ❑ Comment: Please provide feasible alternatives to current practices. Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ® ❑ ❑ ❑ Comment Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? ® ❑ ❑ ❑ # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ® ❑ ❑ ❑ Comment: Permit and Outfalls ' Yea Na NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? ®❑ ❑ ❑ # Were all outfalls observed during the inspection? ®❑ ❑ ❑ # If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ® ❑ # Has the facility evaluated all illicit (non stornwater) discharges? ® ❑ ❑ ❑ Comment: No need to collect samples from Outfall # 5 since it is not a representative sample. Please collect the sample from inside the facility above outfall # 5 near the gate. Page: 3 RECEIVED DIVISION OF t�fATER QUALITY JAN 21 W4 PIPE and FOUNDRY COMPANY MOORESVILLEREGiONALOFFICE P.O. Box 35430 • Telephone 704/332-2647 CHARLOTTE, NORTH CAROLINA 28235 Foundry Fax No. 332-4581 January 15, 2014 NCDENR-DEMLR Attn: Mike Parker 610 East Center Ave., Suite 301 Mooresville, NC 28115 704.663.1699 RE: Charlotte Pipe & Foundry Co. - Mecklenburg County, NC NPDES Stormwater Permit NCS000040 Spill Report Dear Mr. Parker: In follow-up to a phone conversation with Wes Bell on Monday, January 13, 2014, I am submitting this written discharge report in reference to a hot dip asphalt -water mixture spill that occurred at our facility. The incident occurred on Monday, January 13, 2014 and was discovered about 6:30AM. Ron Eubanks with Charlotte -Mecklenburg Storm Water Services came to the site that afternoon to discuss the incident and to observe the spill area and clean-up efforts. A complete summary of the incident is enclosed. Please contact me at 704.348.5513 if you need any additional information. Thank you for your assistance. Sincerely, Jenny L. Pappalardo Charlotte Pipe and Foundry Co. Environmental Engineer cc: Ron Eubanks, CMSWS 700 N. Tryon Street Charlotte, NC 28202 704.336.5446 CHARLOTTE PIPE DISCHARGE REPORT Facility Name: Charlotte Pipe & Foundry Facility Phone Number: 704-332-2647 Facility Location: 1335 South Clarkson St., Charlotte, NC Specific Plant: Cast Iran Foundry Maximum Oil Storage Capacity: NIA gallons Normal Daily Oil Throughput: NIA gallons (max) Facility Description: Iron Foundry Reportable Incident Type Evacuation Required? No Discharge to eater that exceeds 1,000 gallons Two discharges to water that exceed 42 gallons each within 12-month period Discharge to water that violates applicable water quality standards X Discharge to water that causes sheen upon or discoloration of water surface Discharge to water that causes a sludge or emulsion to form beneath water surface Discharge of 75 gallons or more of diesel fuel within 24-hour period X Discharge of 25 gallons or more of petroleum product other than diesel within 24-hour period Incident Source and Location: #4 and #5 Fnrrre Collector Incident Date: Mondail,lanuary 13, 2014 Weather Conditions: Morning, Sunny Approximate Time Incident Began:—06:00arr Discovered:—06:30arr Ended: Water turned ojfinnnediatehLpon discovery; containment and clear -up lasted throughout the dal Material Discharged: Hot Dip Asphalt -Water Mixture Concentration of Discharge: Unknown Total Quantity Discharged: 100-200 gals Qty. Discharged to Navigable Waters: Yes, but Unknown gals Affected Media: Asyholted Area Stormwater Drains, Irwin Creek Transportation Characteristics of Media into Which Material Discharged: All water lines had been drained in the facility the previous week to prevent freezing/busting with the cold weather. During startup on Monday AM, while drrning on water valves to startup equipment, a plant employee accidently turned on tine water valve for the emergency flood system (emergency use in case of fire) for the #4 and #5 frone collectors. The fume collectors started filling with water. Since the valve to the effluent tote was not closed, the asphalt -water from the fume collectors started flowing to the tote until it overflowed. The asplmlt-water mixture flowed along the asphalted area to three stornrwater drains in the area. 77rc asplmlt-water rnixtttre traveled through the stornrwater drains and entered Irwin Creek. Person Possessing or Controlling Material at Time of Discharge It is unknown as to who opened the flood systern valve. Person Having Actual Knowledge of Facts Surrounding Discharge: Robert Hooks, Bobby Morton, Glen Allen Person to Contact for Additional Information Concerning Discharge: David Waggoner, 704.348.5408 Jenny Pappolardo, 704,348,5513 Robert Hooks CHARLOTTE PIPE DISCHARGE REPORT, Page 2 Cause of Discharge, Including Failure Analysis: A plant employee turned on the water valve for the emergency flood system for the #4 and #5 fioue collectors. Tire f une collectors started filling with water, which ran into the effluent tote. While the flood system valve is currently labeled, Charlotte Pipe has replaced the existing sign with a more obvious sign. In addition, a plastic zip tie, carter pin, and safety pin have been added to the valve. Th us, f dure use will require the zip tie to be cut and the carter pin to be renwved so tine safety pin can be accessed and removed (like a fire extinguisher) to open the valve. Efforts Taken to Control or Mitigate Discharge: Oil -day was inunediately put down iu tine area of the spill. Stonnwater drain covers were removed and oil -dry was applied and dug -out of the catch basins to collect as much of tine spilled naterial as possible. Boons were put down in Irvin Creek at tine out/all area to bean and collect oil entering the creek. Harmful Effects of Discharge, if Known: An unknown quantity of oily asphalt flowed through the stornrwater drains to Irwin Creek, which drains into Catawba River. Damages or Injuries Caused by Discharge: No injuries. Corrective Actions and Countermeasures Taken, Including Equipment Repairs and Replacements: Plant ennployees have been instructed that tine tote valves need to be closed when system is not in use. Measures Taken or Planned to Reduce Possibility of Recurrence: The emergency flood system valve was ennrrently labeled, but Charlotte Pipe has replaced the existing sign with a more obvious sign. In addition, a plastic zip tie, carter pin, and safety pin have been added to the valve. Thus, future use will require the zip tie to be cut and the carter pin to be removed so the safety pin can be accessed and removed (like a fire extinguisher) to open the valve. Present or Proposed Remedial Action at Site of Discharge: Oil -dry was hnniediately put down i❑ the area of the spill. Stormwater drain covers were renwved and oil -dry was applied and dug -out of the catch basins to collect as rmuch of the spilled material as possible. Boonns were put down in Irwin Creek at the outfall area to bean and collect oil entering the creek. FCC was contracted to clean and vacuron out the stornrwater drains associated with the spill area. In addition, bomrnS were added in tine deep stornudrains to absorb any residual oil. This was done the afternoon of the spill as it was scheduled to rain the nest day. FCC also used absorbent pads to clean oil contained in the bernred area of the creek. This was consistent with Ron Eubanks (CMSWS) reconuaendation as lie cane to the site to discuss tine incident and to observe tite spill area and dean -up efforts. Tine original absorbent pads were picked up the evening of the spill and new ores were put down to catch additional oil Within the drains that may get flushed out dining the rainfall on Tuesday. Wednesday, FCC returned to pick tip the absorbent pads on Wednesday and put down new ones. These pads and booms will be left in fire creek for a few extra days in the event that there is any additional residual oil. All materials have beenlzvill be disposed of in compliance with regulatory requirennents. Individuals and/or Organizations Contacted: Charlotte -Mecklenburg Storm Water Services (CMSWS) - Ron Eubanks, 704.336.5446 EPA National Response Center (NRC), 800,424,8802 Division of Energy Minerals and Land Resources (Mooresville Regional Office) — Wes Bell, 704.663.1699 Prepared by: lenity L. Pappmlardo Title: Environnantal Engineer Signature: J Date: lammrn 16, 2014 1 r� NCDENR North Carolina Department of Environment and Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director June 9, 2011 David Waggoner, Environmental Manager Charlotte Pipe and Foundry Company 1335 South Clarkson Street Charlotte, NC 28208 Natural Resources Subject: Stormwater Monitoring Results Charlotte Pipe and Foundry Company at 1335 South Clarkson Street NPDES Stormwater Permit - NCS000040 Mecklenburg County Dear Mr. Waggoner: �r. Dee Freeman Enclosed are the monitoring results from the stormwater sampling upstream and downstream of the subject facility on April 5, 2011. The grab samples were collected during the sampling investigation performed by Ron Eubanks of Charlotte -Mecklenburg Storm Water Services and included analyses required by your permit and additional analyses of interest in stormwater discharges. The stormwater samples were collected as a follow-up to the sampling conducted on November, 16, 2010. This sampling highlighted elevated concentrations of chemical oxygen demand (COD), total suspended solids (TSS), copper, lead, and zinc in stormwater runoff at the site with the benchmark values contained in Stormwater Permit NCS00004. You were forwarded these results on January 19, 2011. The April 5, 2011, sampling investigation was conducted as part of a cooperative working agreement between Mecklenburg County and the Division of Water Quality. In addition, the investigation was conducted on behalf of the City of Charlotte in compliance with the City's NPDES Permit, NCS000240, Part II Section H. The enclosed monitoring results indicate that the stormwater samples collected downstream of Charlotte Pipe and Foundry Company facility contained elevated concentrations of copper and zinc compared with the benchmark values contained in Stormwater Permit NCS000040. However, the copper concentration was also elevated at the upstream sampling location. This indicates that zinc is the only monitored parameter that may be attributed to industrial activities at the Charlotte Pipe and Foundry Company facility. All other measured parameters were below the permit benchmarks downstream of the site. Through previous correspondence this Office is aware that you have installed best management practices (BMPs) to reduce your impact on stormwater discharges. The BMPs appear to be working properly as the water quality of the stormwater downstream of the facility was very good. This Office commends your efforts to reduce the concentrations of the above noted parameters in your stormwater runoff. It is recommended that you continue to evaluate the effectiveness of the chosen BMPs and continue-upstream-stormwater-monitoring-to-assess-off-site-impacts-on-the-stormwater-disch arges-from - your site. Please keep this Office informed of your efforts to meet the permit benchmark concentrations. Mooresville Regional Office Location: 610 East Center Ave.. Suite 301 Mooresville, NC 28115 One Phone: (704) 663-16991 Fax (704) 663-60401 CustornerService: 1-877-623-6748 NoTthCar011Ila Internet: hltpalpoRal.ncdencorglwebhvq ��li GLII {Lry�� An Equal Opportunity', Afrmauve Action Employer-50% Rccycledl109% Post Conscmer paper bi David Waggoner,.CFiarlotte Pipe and Foundry Company Stormwater Sampling, Page 2 June 9, 2011 The enclosed results should be self-explanatory, however should you have any questions concerning the sampling results or have any questions regarding your permit, please do not hesitate to contact Ron Eubanks with CMSWS or Ms. Marcia Allocco of the Division of Water Quality at (704) 235-2204. Sincerely, for Robert B. Krebs, Regional Supervisor Surface Water Protection Section Mooresville Regional Office Enclosure: Sampling Results from 4/5/11 cc: Rusty Rozzelle, MCWQP Craig Miller, City of Charlotte Water Quality Central Files Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NO 28115 Phone: (704) 663-16991 Fax: (704) 663-60401 Customer Service: 1-877-623-6748 Internet: hHp:llpogal.ncdenr.org/web/wq An Equat Opportunity t Affirmative Actium Employer- 30% Recycled110% Past Consumer paper One NorthCarolina Naturally David Waggoner, Charlotte Pipe and Foundry Company Stormwater Sampling, Page 3 June 9, 2011 ADDENDUM The National Pollutant Discharge Elimination System (NPDES) program was established under the federal Clean Water Act and then delegated to the Division of Water Quality for implementation in North Carolina. The NPDES permitting program for stormwater discharges was established in 1990. Phase I focuses on site and operations planning to reduce pollutant sources. Through the NPDES permitting program industrial facilities that fall into one of the subject ten categories are required to obtain permit coverage under a general permit or an individual permit, depending upon the facilities SIC code and the industrial activity occurring at the facility. There are currently 19 active general stormwater permits in North Carolina. One condition that is applicable to both the general permits and individual stormwater permits is the requirement to develop and implement site -specific comprehensive Stormwater Pollution Prevention plans (SPPP). These plans are required to include a comprehensive evaluation of the site and operations to reduce pollutant sources and prevent pollutant discharge. Copies of the general permits and accompanying documents can be accessed from the following webpage: http://portal.ncdenr.org/web/wq/ws/su/npdesswl#General_Permits_NPDES. Permit text, technical bulletins, discharge monitoring forms, and a Notice of Intent [which is the application for coverage under a NPDES General Stormwater Permit] can be found on this website. The following items are a subset of permit requirements and are listed to assist you and help bring your attention to certain permitting issues, process and condition requirements of your permit. Please see the above mentioned website to obtain a copy of the permit so you may fully comply with all the conditions therein. Failure to properly comply with conditions of the permit, like those bulleted below, is a violation(s) of the permit and subject to civil penalty assessment(s) of up to $25,000.00 per day. • Industrial facilities that fall into one of the subject ten categories are required to obtain permit coverage under a general NPDES stormwater permit or an individual NPDES stormwater permit • All persons desiring to have facilities covered by a General Permit must register with the Division of Water Quality (DWQ) by filing of a Notice of Intent (NOI) and Applicable Fees. • This Notice of Intent (NOI) must be submitted and a Certificate of Coverage issued prior to any discharge of stormwater associated with the industrial activity, process wastewater, and/or mine dewatering. • Once the Notice of Intent is received, DWQ will review and determine whether a Certificate of Coverage (COC) may be issued. If this Certificate of Coverage is issued the facility is covered by the General Permit. That is, the permittee is authorized to discharge stormwater, process wastewater, and/or mine dewatering pursuant to the type of General Permit until the permit expires or is modified or revoked. • Any other point -source discharge to surface waters of the state is prohibited unless it is an allowable non-stormwater discharge or is covered by another permit, authorization, or approval. • . There are currently 19 active general permits. Permit conditions vary accordingly; however, most of the permits have the following condition requirements (you must read your entire permit to ensure full compliance): o Development and compliance with the Stormwater Pollution Prevention Plan o Collection, reporting, and recording of Analytical Monitoring o Collection, reporting, and recording of Qualitative Monitoring !Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 Phone: (704) 663-16991 Fax: (704) 663a401 Customer Service: 1-877-623-6748 Internethttp:llponal,ncdenr.c lwebiwq Ono NorthCarolina i/vaturallil An Equal opportunity V.Afrrmaiive Action Employer - 30% Recvclec,109b Post Consumer paper David Waggoner, Charlotte Pipe and Foundry Company Stormwater Sampling, Page 4 June 9, 2011 o Collection, reporting, and recording of Vehicle Maintenance Monitoring (if applicable) Records — Visual monitoring shall be documented and records maintained at the facility along with the Stormwater Pollution Prevention Plan. Copies of the analytical monitoring results shall also be maintained on site. The Permittee shall retain records of all monitoring information, including all calibration and maintenance records and all original strip -chart recordings for continuous monitoring instrumentation, and copies of all reports required by this general permit for a period of at least 5 years from the date of the sample measurement, report, or application. Expiration — The permittee is not authorized to discharge after the expiration date of the general permit. In order to receive automatic authorization to discharge beyond the expiration date, the permittee shall submit forms and fees as are required by the agency authorized to issue permits no later than 180-days prior to the expiration date. Any permittee that has not requested renewal at least 180 days prior to expiration, or any permittee that does not have a permit after the expiration and has not requested renewal at least 180 days prior to expiration, will be subject to enforcement. Failure to renew your permit is a violation. Transfer — The Certificate of Coverage (COC) issued pursuant to this general permit is not transferable to any person expect after notice to and approval by the Director. The Director may require modification or revocation and reissuance of the Certificate of Coverage to change the name and incorporate such other requirements as may be necessary under the Clean Water Act. The Permit is NOT transferable. Name Change, Closure, or Facility Ownership change — Permittee is required to notify the Division in writing in the event the permitted facility is sold or closed. The Division of Water Quality views changes of name or ownership as a modification that requires the Director's approval and reissuance of the permit. Name and ownership changes require you to complete a Name/Ownership Change Form from the Division and mail it back to the Division of Water Quality along with all appropriate information. o Proper Operation and Maintenance is a requirement of the permit. Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NO 28115 Phone. (704) 663-16991 Fax: (704) 663 60401 Customer Service: 1-877-623-6748 Internet: m1pa/ponal.ncdenr.orglweblwq An Equal Opporiunily t Affirmative Acton Employer - 30% Recycled!!0% Post Consumer paper One NorthCarolina Naturally ANALYTICAL RESULTS SHEET Name of Facility: Charlotte Pipe and Foundry Company Grab: ® Composite: ❑ Sample Date(s): 04/05/2011 NPDES Permit No.: NCS000040 Sample Location: Upstream County: Mecklenburg Temperature (°C) 15.2 Fecal coliform (CFU/100 mL) <100 Dissolved Oxygen (mg/L) 9.92 E. Coli (MPN/100 mL) <100 Conductivity (Ns/cm) 186 Enterococcus (MPN/100 mL) <100 pH 7.76 Ammonia -nitrogen (NH3-N) (mg/L) 0.23 Turbidity (NTU) 27 Total Kjeldahl Nitrogen (TKN) (mg/L) 0.46 Biological Oxygen Demand, 5-day (BOD5).(mg/L) <2.0 Nitrate/Nitrite-nitrogen (NO2 and NO3) (mg/L) 1.0 Chemical Oxygen Demand (COD) (mg/L) <10 Total Phosphorus (P) (mg/L) 0.075 Total Suspended Solids JSS) (mg/L) 6.6 Chromium (Cr) (pg/L) <5.0 Total Sediment Concentration (mg/L) 5.5 Copper (Cu) (pg/L) 9.3* Oil & Grease (mg/L) <5.0 Lead (Pb) (Ng/L) <5.0 Zinc (Zn) (Ng/L) 18 " - denotes an exceedance of the permit benchmark concentration ANALYTICAL RESULTS SHEET Name of Facility: Charlotte Pipe and Foundry Company Grab: M Composite: ❑ Sample Date(s): 4/5/2011 NPDES Permit No.: NCS000040 Sample Location: Downstream County: Mecklenburg Temperature (°C) 14.6 Fecal coliform (CFU/100 mL) 230 Dissolved Oxygen (mg/L) 10.33 E. Coli (MPN/100 mL) 100 Conductivity (ps/cm) 193 Enterococcus (MPN/100 mL) 410 pH 7.95 Ammonia -nitrogen (NH3-N) (mg/L) 0.23 Turbidity (NTU) 37 Total Kjeldahl Nitrogen (TKN) (mg/L) 0.68 Biological Oxygen Demand, 5-day (BODO (mg/L) 2.7 Nitrate/Nitrite-nitrogen (NO2 and NO3) (mg/L) 0.93 Chemical Oxygen Demand (COD) (mg/L) 18 Total Phosphorus (P) (mg/L) 0.078 Total Suspended Solids (TSS) (mg/L) 17 Chromium (Cr) (pg/L) <5.0 Total Sediment Concentration (mg/L) 13 Copper (Cu) (pg/L) 12` Oil & Grease (mg/L) <5.0 Lead (Pb) (pg/L) 9.9 Zinc (Zn) (pg/L) 100' denotes an exceedance of the permit benchmark concentration U"AR"LOTTE RECEIVED • • 1 FO UNDRY• 1 P.O. Box 35430 • Telephone 704/332-2647 MAR 15 2011 CHARLOTTE, NORTH CAROLINA 28235 Foundry Fax No. 332 4581 MOORESVILLE REGIONAL OFFICE March 11, 2011 To: Mr. Robert Krebs From: David Waggoner RE: Charlotte Pipe Storm Water Sampling Mr. Robert Krebs, On November 16, 2010, Ron Eubanks with the Land Use and Environmental Services Agency performed some storm water sampling at two of our outfalls. Some of the monitoring parameters were above our permitted benchmarks. Charlotte Pipe was also poised to sample this day at outfalls both above and below our property. Our consultants ended up not testing this day due to the rain event total only reaching .07 inches. Our industrial activity has been way off the normal production levels as we have followed the economy down. We only operated about three days/week during 2010 and had nothing going on out of the ordinary that would have impacted storm water runoff from our property. The reason that we now test above and below our property is to show NCDENR-DWQ the contamination levels of the storm water before it enters under our plant as several major arteries run from uptown, under our plant and out to Irwin Creek. Also we are surrounded on one side of our property by an old Norfolk Southern Railroad. In 2009 we offered to build a massive BMP to help reduce our impact on our storm water. It was completed last summer. We also installed a sprinkler system on our scrap handling yard to keep the dust knocked down. DENR's Raleigh storm water division helped us work through our new permit. They also agreed to give us a two year extension on compliance with the benchmarks so that we would have time to work on BMPs while also gathering more analytical data above and below our site so that we can see what our net average impact truly is. I hope this helps. You may reach me at 704-348-5408 if you have any questions. Thank you, David Waggoner Allocco, Marcia From: Hall, Erin R. [Erin.Hall@mecklenburgcountyne.gov] Sent: Friday, February 04, 2011 11:27 AM To: Allocco, Marcia Cc: Eubanks, Ron Subject: FW: Charlotte Pipe and Foundry Company - Stormwater Monitoring Report Attachments: USGS Raingage CRN-15 - Grapl•.pdf; USGS Raingage CRN-19 - Graph.pdf Marcia, Below is an email from Ron regarding the rainfall totals for Charlotte Pipe and Foundry. Attached are the USGS rainfall totals from CRN-15 and CRN-19. Ron is planning to collect additional stormwater samples for Charlotte Pipe and Foundry. He will contact David Waggoner regarding this... David may want to collect samples at the same time to compare analytical results, as Ron has stated below. Let Ron and myself know if we need to take a different approach with this. Thanks, Erin From: Eubanks, Ron Sent: Friday, February 04, 2011 11:19 AM To: Hall, Erin R. Subject: RE: Charlotte Pipe and Foundry Company - Stormwater Monitoring Report . Hi Erin, From our conversation earlier today, please find attached the USGS rain. -age data for CRN-15 and CRN-19. These are the closest USGS raingages to the Charlotte Pipe and Foundry Company. The USGS recorded rainfall at CRN-15 was 0.02 inches and the rainfall recorded at CRN-19 was 0.08 inches. I'm not certain of the exact rainfall that occurred at the Charlotte Pipe and Foundry Company during the storm event on November 16. 2010: however, there was enough rainfall to runoff the site and the stornwater samples were collected within the first hour of the storm event. Since the storm event does not appear to have exceeded the 0.10 inches of rainfall for a representative event, I will plan to collect additional storm water samples at the site. I will coordinate the stormwater monitoring with UIr. David Waggoner (Charlotte Pipe and Foundry Company), in case they want to compare analytical results. Please send me an e-mail or drop by, if you have any questions or need additional information regarding this matter. Thank you. Have a good weekend. Ron Eubanks Environmental Specialist Mecklenburg County Water Quality Program 700 North Tryon Street Charlotte, North Carolina 28202 Phone: (704) 336-5446 Fax: (704) 336-4391 E-mail: Perry.Eubanks(aDMecklenburgCountyNC.gov LI From: Hall, Erin R. Sent: Monday, January 31, 2011 To: Miller, Craig M. Cc: Eubanks, Ron Subject: RE: Charlotte Pipe and Craig, 11:30 AM Foundry Company - Stormwater Monitoring Report Below is part of Marcia's email that should clarify "additional results." I don't have the DMR that she is referring to. We can look up DN1Rs in BIMS, but I think it's only for wastewater permits. "I have attached the final documents that will go out today. Changed around the letter a bit because I had a copy of the permittee's DNIR from July and I also liked the wording I had done for the Norfolk Southern letter regarding the additional analyses (need to update your template). I thought this was a better way to highlight the elevated concentrations rather than comparison with water quality standards. This is also based on a conversation with Gilbert Turner (Norfolk southern) where he was not understanding the language in that part of his letter." From: Miller, Craig M. [mailto:cmmiller@ci.charlotte.nc.us] Sent: Monday, January 31, 2011 11:21 AM To: Hall, Erin R. Cc: Eubanks, Ron Subject: RE: Charlotte Pipe and Foundry Company - Stormwater Monitoring Report Hi Erin, Ron and I haven't discussed Pipe & Foundry's results yet. DENR's letter mentions "additional results" and it sounds like concentrations for several parameters improved. Do either of you have those results? Ron, please give me a shout when you get a chance. Thank you, Craig Miller, QEP Senior Water Quality Specialist Charlotte Mecklenburg Stormwater Services 600 East 4th St. Charlotte, NC 28202 Phone: (704) 336-7605 Fax: (704) 353-0473 Email: cmmiller@ci.charlotte.nc.us Please comment on my work/assistance by completing this very short, anonymous customer service survey. http://www.surveviTioiikev.com/s.aspx?siii=vld 20A5th3sJ l fI Fo 2bAU7O 3d 3d It is able to be filled out and submitted electronically. Results are sent to and tabulated by a 3rd party. A customer is anyone who I communicate with about work, whether external or internal. Thank you! From: Hall, Erin R. [mailto:Erin.Hall@mecklenburgcountync.gov] Sent: Monday, January 31, 2011 10:15 AM To: Miller, Craig M. Subject: FW: Charlotte Pipe and Foundry Company - Stormwater Monitoring Report Craig, Has Ron already discussed lab results with you for Charlotte Pipe and Foundry? He's either not in today or in the field. Wasn't sure what was decided on for this facility. Marcia was inquiring about the TP result. The monitoring report/tables are attached. Thanks, Erin From: Allocco, Marcia [mailto:marcia.allocco@ncdenr.gov] Sent: Monday, January 31, 2011 9:44 AM To: Hall, Erin R. Subject: RE: Charlotte Pipe and Foundry Company - Stormwater Monitoring Report Is that an enforceable water quality standard? From: Hall, Erin R. [mailto: Erin. Hall@mecklenburgcountync.gov] Sent: Monday, January 31, 2011 9:38 AM To: Allocco, Marcia Subject: RE: Charlotte Pipe and Foundry Company - Stormwater Monitoring Report Hey Marcia, Regarding the TP... we have our own local water quality standard for TP (watch and action levels). The local action level for TP is 0.4 mg/L. I believe that was the confusion... local versus state water quality standards. I'll try to remember to use Norfolk Southern report as a template for any other reports that I review until we get the updated template. Thanks, Erin From: Allocco, Marcia [mailto:marcia.allocco@ncdenr.gov] Sent: Friday, January 28, 2011 10:44 AM To: Hall, Erin R. Subject: RE: Charlotte Pipe and Foundry Company - Stormwater Monitoring Report Hi Erin, I have attached the final documents that will go out today. Changed around the letter a bit because I had a copy of the permittee's DMR from July and I also liked the wording I had done for the Norfolk Southern letter regarding the additional analyses (need to update your template). I thought this was a better way to highlight the elevated concentrations rather than comparison with water quality standards. This is also based on a conversation with Gilbert Turner (Norfolk southern) where he was not understanding the language in that part of his letter. I saw where Ron was unsure if there was a phosphorus water quality standard. At this time there is not one. The Division is still proposing to the EPA to use chlorophyll A concentrations as a surrogate for N and P. There is a TMDL developed for phosphorus in the Catawba which resulted in phosphorus loading limits in the 3 of the CMUD permits and the Twelve mile WWTP in Union county. Perhaps this is where Ron was getting the 0.4 mg/L from but I have not seen that number before associated with phosphorous. Marcia From: Hall, Erin R. [ma ilto: Erin. Hall@mecklenburgcountync.gov] Sent: Wednesday, January 19, 2011 4:22 PM To: Allocco, Marcia Subject: FW: Charlotte Pipe and Foundry Company - Stormwater Monitoring Report Charlotte Pipe and Foundry report and result tables are attached. From: Eubanks, Ron Sent: Wednesday, January 19, 2011 3:47 PM To: Hall, Erin R. Subject: Charlotte Pipe and Foundry Company - Stormwater Monitoring Report Hi Erin, Please review the revised stormwater monitoring report for the Charlotte Pipe and Foundry Company to send to Ms. Marcia Allocco. Per your comments, I included turbidity and total phosphorus in the stream standards section of the letter. What is the stream standard for total phosphorus? It is my understanding that it is 0.4 mg/I. If so, only Outfall #001 would exceed the stream standard for total phosphorus. Please send me an e- mail or drop by, if you have any questions or need additional information regarding this matter. Thank you. Have a great day! Ron Eubanks Environmental Specialist Mecklenburg County Water Quality Program 700 North Tryon Street Charlotte, North Carolina 28202 Phone: (704) 336-5446 Fax: (704) 336-4391 E-mail: Perry. Eubanks(()MecklenburoCountyNC.gov T?4 NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director July 9, 2010 David Waggoner, Environmental Manager Charlotte Pipe and Foundry Company 1335 South Clarkson Street Charlotte, NC 28208 Subject: Compliance Evaluation Inspection Charlotte Pipe and Foundry Company 1335 South Clarkson Street Charlotte, INC 28208 NPDES Stormwater Permit NCS000040 Mecklenburg County Dear Mr. Waggoner: Dee Freeman Secretary On May 3, 2010, Ron Eubanks from Charlotte -Mecklenburg Stormwater Services (CMSWS), conducted a site inspection of the Charlotte Pipe and Foundry Company facility located at 1335 South Clarkson Street in Charlotte, Mecklenburg County, North Carolina. The site drains to an unnamed tributary of Irwin Creek, Class C waters located in the Catawba River Basin. The site visit and file review revealed that the subject facility is covered by NPDES Individual Stormwater Permit — NCS000040. This inspection was conducted as part of a cooperative working agreement between Mecklenburg County and the Division of Water Quality. In addition, the inspection was conducted on behalf of the City of Charlotte in compliance with the City's NPDES Permit, NCS000240, Part II Section H. The following observations were noted during the Charlotte -Mecklenburg Stormwater Services inspection (please see the attached addendum for information about your permit): 1) Stormwater Pollution Prevention Plan (SPPP) A Stormwater Pollution Prevention Plan (SPPP) has been developed, recorded, and properly implemented. Yes ® No ❑ 2) Qualitative Monitoring Qualitative monitoring has been conducted and recorded in accordance with permit requirements. Yes ® No ❑ 3) Analytical Monitoring Analytical monitoring has been conducted and recorded in accordance with permit requirements. Yes Z No ❑ NA ❑ Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NO 28115 Phone: (704) 663-16991 Fax: (704) 663-60401 Customer Service: 1-877-623-6748 Internet: hftpJ/portal.ncdenr.org/webiwq NorthCarolina Natimallt/ Mr. David Waggoner, Charlotte Pipe and Foundry Company Compliance Evaluation Inspection, Page 2 July 9, 2010 4) Permit and Outfalls It was noted during the site inspection that storm water samples are no longer collected from stormwater outfall SWO 07. This is in line with the guidance provided by M. Parker of the Division of Water Quality during the May 2009 DWQ inspection. 5) City of Charlotte Stormwater Ordinance Review: The facility appeared to be in compliance with the City of Charlotte Stormwater Ordinance. Thank you for the assistance and cooperation during the inspection. Overall, the facility's Stormwater program was well developed and implemented and this Office commends the permittee's efforts to ensure compliance with your NPDES permit. If you have any questions, comments, or need assistance understanding any aspect of your permit, please do not hesitate to contact Ron Eubanks with CMSWS or Ms. Marcia Allocco of the Division of Water Quality at (704) 235-2204. Sincerely, � for Robert B. Krebs Regional Supervisor Surface Water Protection Section Mooresville Regional Office cc: Rusty Rozzelle, MCWQP Craig Miller, City of Charlotte Water Quality Central Files Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 Phone: (704) 663-16991 Fax: (704) 663-60401 Customer Service: 1-877-623-6748 Internet: www.ncvvaterquafny.org One NorthCarolina An Equal Opportunity 1 Affirmative Action Employer - 30 h Recycled110% Post Consumer paper Mr. David Waggoner, Charlotte Pipe and Foundry Company Compliance Evaluation Inspection, Page 3 July 9, 2010 ADDENDUM The National Pollutant Discharge Elimination System (NPDES) program was established under the federal Clean Water Act and then delegated to the Division of Water Quality for implementation in North Carolina. The NPDES permitting program for stormwater discharges was established in 1990. Phase I focuses on site and operations planning to reduce pollutant sources. Through the NPDES permitting program industrial facilities that fall into one of the subject ten categories are required to obtain permit coverage under a general permit or an individual permit, depending upon the facilities SIC code and the industrial activity occurring at the facility. There are currently 19 active general stormwater permits in North Carolina. One condition that is applicable to both the general permits and individual stormwater permits is the requirement to develop and implement site -specific comprehensive Stormwater Pollution Prevention plans (SPPP). These plans are required to include a comprehensive evaluation of the site and operations to reduce pollutant sources and prevent pollutant discharge. Copies of the general permits and accompanying documents can be accessed from the following webpage. http://portal.ncdenr.org/web/wq/ws/su/npdessw#General_Permits_NPDES. Permit text, technical bulletins, discharge monitoring forms, and a Notice of Intent [which is the application for coverage under a NPDES General Stormwater Permit] can be found on this website. The following items are a subset of permit requirements and are listed to assist you and help bring your attention to certain permitting issues, process and condition requirements of your permit. Please see the above mentioned website to obtain a copy of the permit so you may fully comply with all the conditions therein. Failure to properly comply with conditions of the permit, like those bulleted below, is a violation(s) of the permit and subject to civil penalty assessment(s) of up to $25,000.00 per day. • Industrial facilities that fall into one of the subject ten categories are required to obtain permit coverage under a general NPDES stormwater permit or an individual NPDES stormwater permit • All persons desiring to have facilities covered by a General Permit must register with the Division of Water Quality (DWQ) by filing of a Notice of Intent (NO[) and Applicable Fees. • This Notice of Intent (NOI) must be submitted and a Certificate of Coverage issued prior to any discharge of stormwater associated with the industrial activity, process wastewater, and/or mine dewatering. • Once the Notice of Intent is received, DWQ will review and determine whether a Certificate of Coverage (COC) may be issued. If this Certificate of Coverage is issued the facility is covered by the General Permit. That is, the permittee is authorized to discharge stormwater, process wastewater, and/or mine dewatering pursuant to the type of General Permit until the permit expires or is modified or revoked. • Any other point -source discharge to surface waters of the state is prohibited unless it is an allowable non-stormwater discharge or is covered by another permit, authorization, or approval. • There are currently 19 active general permits. Permit conditions vary accordingly; however, most of the permits have the following condition requirements (you must read your entire permit to ensure full compliance): o Development and compliance with the Stormwater Pollution Prevention Plan o Collection, reporting, and recording of Analytical Monitoring Mooresville Regional Office Location, 610 East Center Ave., Suite 301 Mooresville, NC 28115 Phone: (704) 663.16991 Fax: (704) 663-60401 Customer Service: 1-877 623-6748 Internet: wN.nmaferquality.org One. NorthCarolina Naturally An Equal Gpponunily t Affirmative Acton Employer - 30% Recycledi10% Post Consumer paper Mr. David Waggoner, Charlotte Pipe and Foundry Company Compliance Evaluation Inspection, Page 4 July 9, 2010 o Collection, reporting, and recording of Qualitative Monitoring o Collection, reporting, and recording of Vehicle Maintenance Monitoring (if applicable) Records —Visual monitoring shall be documented and records maintained at the facility along with the Stormwater Pollution Prevention Plan. Copies of the analytical monitoring results shall also be maintained on site. The Permlttee shall retain records of all monitoring information, including all calibration and maintenance records and all original strip -chart recordings for continuous monitoring instrumentation, and copies of all reports required by this general permit for a period of at least 5 years from the date of the sample measurement, report, or application. Expiration — The permittee is not authorized to discharge after the expiration date of the general permit. In order to receive automatic authorization to discharge beyond the expiration date, the permittee shall submit forms and fees as are required by the agency authorized to issue permits no later than 180-days prior to the expiration date. Any permittee that has not requested renewal at least 180 days prior to expiration, or any permittee that does not have a permit after the expiration and has not requested renewal at least 180 days prior to expiration, will be subject to enforcement. Failure to renew your permit is a violation. Transfer —The Certificate of Coverage (COC) issued pursuant to this general permit is not transferable to any person expect after notice to and approval by the Director. The Director may require modification or revocation and reissuance of the Certificate of Coverage to change the name and incorporate such other requirements as may be necessary under the Clean Water Act. The Permit is.NOT transferable. Name Change, Closure, or Facility Ownership change — Permittee is required to notify the Division in writing in the event the permitted facility is sold or closed. The Division of Water Quality views changes of name or ownership as a modification that requires the Director's approval and relssuance of the permit. Name and ownership changes require you to complete a Name/Ownership Change Form from the Division and mail it back to the Division of Water Quality along with all appropriate information. o Proper Operation and Maintenance is a requirement of the permit. Mooresville Regional Office Location. 610 East Center Ave.. Suite 301 Mooresville, NC 28115 Phone: (704) 663-1699 \ Fax'. (704) 663-6040 \ Customer Service: 1-877-623-6748 Internet: www.ncvvaterquallty.org An Equal Oppodunity 1 Affirmative Action Employer - 30% Recycled110% Post Consumer paper One NorthCarolina Naturally Permit: NCS000040 SOC: County: Mecklenburg Region: Mooresville Compliance Inspection Report Effective: 11/06/09 Expiration: 07/31/14 Owner: Charlotte Pipe & Foundry Cc Effective: Expiration: Facility: Charlotte Pipe & Foundry Company 1335 S Clarison St Contact Person: David Waggoner Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Charlotte NC 28208 Title: Phone: 704-332-2647 Certification: Phone: Inspection Date: 05/03/2010 Entry Time: 10:15 AM Exit Time: 12:15 PM Primary Inspector: Water Quality Program Meckenburg County Phone: 704-336-5449 Secondary Inspector(s): Reason for Inspection: Routine Permit Inspection Type: Stormwater Discharge, Individual Facility Status: M Compliant Q Not Compliant Question Areas: Storm Water (See attachment summary) Inspection Type: Compliance Evaluation Page 1 Permit: NCS000040 Owner - Facility: Chadotte Pipe & Foundry Co Inspection Date: 05/03/2010 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: Facility Description. The Charlotte Pipe and Foundry Company facility is comprised of approximately 45 acres and includes seven drainage areas. The facility typically operates 24 hours a day, five days a week. The facility manufactures cast iron piping and cast iron piping joints and fittings. The manufacturing process at Charlotte Pipe and Foundry begins with receipt of the raw materials (i.e., scrap cast iron, pig iron, coke, coal, limestone, quartz, sand, silicon, bentonite, petroleum asphalt, gasoline, and diesel fuel) from suppliers. The raw materials are used throughout the facility to manufacture cast iron piping and cast iron fittings. Finished piping and fittings are packaged, stored, and then shipped to customers. Raw materials and finished products are stored outdoors on paved and gravel areas at the site. Dry materials small enough to be stored on pallets are maintained inside the foundry buildings. To support production activities, the facility maintains a wastewater processing system, which discharges into the local sanitary sewer system. Compliance History: The Mecklenburg County Water Quality Program (MCWQP) conducted prior Industrial Facility Inspections at Charlotte Pipe & Foundry Company on April 19, 2002 and April 5, 2006. A Notice of Violation (NOV) was issued to Charlotte Pipe & Foundry Company from the April 5, 2006 inspection for violations described under the facility site review, self monitoring program, and stormwater/pollution prevention sections of the NPDES Stormwater Permit. A NOV was also issued to Charlotte Pipe & Foundry Company on February 23, 2004 for the discharge of hydraulic oil to Irwin Creek via the municipal storm water collection system. The Division of water quality conducted a compliant stormwater inspection at the facility in May 2009. Industrial Operations/City of Charlotte Stormwater Ordinance Review: No housekeeping problems were noted during the inspection, and the facility appeared to be in compliance with the City of Charlotte Stormwater Ordinance. Page: 2 J Permit: NCS000040 Owner - Facility: Charlotte Pipe & Foundry Co Inspection Date: 05/03/2010 Inspection Type: Compliance Evaluation Reason for Visit: Routine Stormwater Pollution Prevention Plan Yes No NA NE Does the site have a Stormwater Pollution Prevention Plan? 13 n n # Does the Plan include a General Location (USGS) map? M ❑ ❑ ❑ # Does the Plan include a "Narrative Description of Practices"? ® n n In # Does the Plan include a detailed site map including outfall locations and drainage areas? ®n n n # Does the Plan include a list of significant spills occurring during the past 3 years? n # Has the facility evaluated feasible alternatives to current practices? ® n n n # Does the facility provide all necessary secondary containment? ® n n n # Does the Plan include a BMP summary? ® n n n # Does the Plan include a Spill Prevention and Response Plan (SPRP)? ® n n n' # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ® n n n # Does the facility provide and document Employee Training? ® n n n- # Does the Plan include a list of Responsible Party(s)? ® ❑ n n # Is the Plan reviewed and updated annually? ® n n n # Does the Plan include a Stormwater Facility Inspection Program? 1B n n Has the Stormwater Pollution Prevention Plan been implemented? m n n n Comment. The Storm Water Pollution Prevention Plan (SWPPP) was reviewed and updated in December 2009. Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? MOOD Comment Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? ® n n n # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? m n n n Comment: The drains in the garage area discharge into the Charlotte -Mecklenburg Utilities (CMU) sanitary sewer system via an oil/water separator. Permit and Outfalls Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? M n n n # Were all outfalls observed during the inspection? M n n n # If the facility has representative outfall status, is it properly documented by the Division? n n _ ® n # Has the facility evaluated all illicit (non stormwater) discharges? ® n n n - Page:3 Permit: NCS000040 Owner - Facility: Charlotte Pipe & Foundry Co Inspection Date: 05/0312010 Inspection Type: Compliance Evaluation Reason for Visit: Routine Comment. A non-stormwater discharge was observed in the storm sewer system draining onto the Charlotte Pipe and Foundry property. A sample was collected on May 5, 2010, and delivered to the Charlotte -Mecklenburg Utilities Laboratory to be analyzed for fecal coliform and fluoride. Based on the fluoride concentration of the laboratory results, the non-stormwater discharge may be a City water leak. The fecal coliform concentration of the non-stormwater discharge sample was below the laboratory reporting limit. During the site inspection, it was noted that storm water samples are no longer collected from stormwater outfall SWO 07. This is in line with the guidance provided by M. Parker of the Division of Water Quality during the May 2009 DWQ inspection. Page:4 Laboratory Analysis Report Report Date: 5/19/2010 10:07:08 AM wauyrm eww+uowe:¢ LABORATORY SERVICES DIVISION LOCATION: Charlotte Pipe LOC ID: W-SPEC SAMPLE DATE -TIME 5/5/2010 14:50 SAMPLE DESCRIPTION: Grab CHAIN OF CUSTODY #: 100505035 Parameter Result Units RL Method Start Date I Time Analyst AD49761 FECAL COLIFORM <10 CFU/100 ml 10 SM 9222D 5/5/2010 16:01 EKR AD49761 FLUORIDE 0.86 mg]L 0.10 Ski 4500FC 5/7/2010 9:43 TCV Comment: Laboratory Supervisor: 4L /2/124 CMU-Environmental Laboratory Servi s N.C. Certification No.192 N.C. DHHS Certification No. 37417 4222 Westmont Drive, Charlotte, North Carolina 28217 Page 1 of 1 North Carolina Beverly Eaves Perdue c4iLA. NC®ENR Department of Environment and Division of Water Quality Coleen H. Sullins Governor Director May 11, 2009 Mr. David Waggoner, Project Engineer Charlotte Pipe & Foundry Company Post Office Box 35430 Charlotte, North Carolina 29235 Dear Mr. Waggoner: Natural Resources Dee Freeman Secretary Subject: Compliance Evaluation Inspection Charlotte Pipe & Foundry Permit No. NCS000040 Mecklenburg County, NC Enclosed is a copy of the Compliance Evaluation Inspection (CEI) report for the inspection conducted at the subject facility on May 6, 2009, by Mr. Michael L. Parker with this Office. Thank you for your assistance and cooperation during the inspection. The enclosed report should be self-explanatory. Overall, your facility's Stormwater Pollution Prevention Plan (SPPP) was well developed and implemented, however, you will find that an organizational structure that closely follows the template established in the SPPP will be helpful when locating various components of the Plan during future inspections. Renewal changes planned for the subject permit were discussed during the site visit and are also summarized in the attached inspection report. As a reminder, please notes that your SPPP should be updated on an annual basis as required by Part II, Section A, No. 7. of your permit. If you have any questions, comments, or need assistance with understanding any aspect of your permit, please do not hesitate to contact Mr. Parker at (704) 663-1699. incerely, for Robert B. Krebs Regional Supervisor Surface Water Protection Section Enclosure cc: Shelton Sullivan — NPS/ACO Unit Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 One Phone: (704) 663-1699 \ Fax: (704) 663-6040 \ Customer Service: 1-877-623-6748 North!�narOltna Internet: www.ncwaterquality.org Naturally An Equal Opportunity \Affirmative Action Employer— 50% Recycled/10% Post Consumer paper Compliance Inspection Report Permit: NCS000040 Effective: 12/06/99 Expiration: 12/31/04 Owner: Charlotte Pipe & Foundry Cc SOC: Effective: Expiration: Facility: Charlotte Pipe & Foundry Company County: Mecklenburg 1335 S Clarkson St Region: Mooresville Cr„rlc+re N(. 2n2na Contact Person: David Waggoner Title: Phone: 704-332-2647 Directions to Facility: System Classifications: Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): 24 hour contact name David Waggoner Phone: 704-332-2647 On -site representative David Waggoner Phone: 704-332-2647 Related Permits: Inspection Date: 05/06/2009 Entry Time: 10:00 AM Exit Time: 11:50 AM Primary Inspector: Michael L Parker' Y Phone: Ext.21 3-1699 xt.2194 Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Stormwater Discharge, Individual Facility Status: 0 Compliant Q Not Compliant Question Areas: ® Storm Water (See attachment summary) Page: 1 Permit: NCS000040 Owner - Facility: Charlotte Pipe & Foundry Cc Inspection Date: 05/0612009 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: The SPPP maintained by Charlotte Pipe & Foundry (CP&F) contained all the components of the SPPP as required by the SW permit, however, there was room for improvement as to the organization of the various facets of the Plan. The SW drainage system at this site was installed back in the 1920's when the company originaiiy iocated to tnis 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 SW collection system that passes through the CP&F property via 1/I. 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 in 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 representative rainfall event. If the proposed benchmark values remain in the permit, CP&F should consider requesting 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 large 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. 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. CP&F should update the 2004 renewal application and includ a revised site map that indicates the current property boundaries and existing SW outfalls. CP&F should also request that that use of SW outfall 004 be discontinued as it eventually Flows through outfall 005, which is currently monitored and (new) outfall 007 be eliminated as it does not receive SW from any of the industrial process/storage areas. Page:2 Permit: NCS000040 Owner - Facility: Charlotte Pipe & Foundry Co Inspection Date: 05/06/2009 Inspection Type: Compliance Evaluation Reason for Visit: Routine Stormwater Pollution Prevention Plan Yes No NA NE Does the site have a Stormwater Pollution Prevention Plan? ■ n n n ■000 if Does the Pian inciude a Genarai LuCaliun (,;CGC) map" # Does the Plan include a "Narrative Description of Practices"? ■ n n n # Does the Plan include a detailed site map including outfall locations and drainage areas? ■ n n n # Does the Plan include a list of significant spills occurring during the past 3 years? ■ n n n # Has the facility evaluated feasible alternatives to current practices? ® Q Q 0 # Does the facility provide all necessary secondary containment? ■ n n n ■ n n n # Does the Plan include a BMP summary? #.Does the Plan include a Spill Prevention and Response Plan (SPRP)? ■ ❑ Q ❑ #-Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ■ ❑ ❑ ❑ # Does the facility provide and document Employee Training? ■ f_1 n 0 # Does the Plan include a list of Responsible Party(s)? ■ 0 # Is the Plan reviewed and updated annually? ■ 0 ❑ 0 # Does the Plan include a Stormwater Facility Inspection Program? ■ n n n Has the Stormwater Pollution Prevention Plan been implemented? ■ n n n Comment: Permittee provides secondary containment, however, all SW collected in the containment structures are routed to the municipal sewer system and do not discharge to SW. Yes No NA NE Qualitative Monitoring Has the facility conducted its Qualitative Monitoring semi-annually? ■ Comment. Yes No NA NE Analytical Monitoring Has the facility conducted its Analytical monitoring? ■ n n n # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ■ n n n Comment: Current analytical testing results were found to be at or above the proposed benchmark values contained in this facilities draft permit. Yes No NA NE Permit and Outfalls # Is a copy of the Permit and the Certificate of Coverage available at the site? ■ n n Cl # Were all outfalls observed during the inspection? ■ n n n # It the facility has representative outfall status, is it properly documented by the Division? ■0U0 # Has the facility evaluated all illicit (non stormwater) discharges? ■ n n n Page: 3 Permit: NCS000040 Owner- Facility: Charlotte Pipe & Foundry Cc Inspection Date: 05106/2009 Inspection Type: Compliance Evaluation Reason for Visit: Routine Comment: Outfall 004 appears to join with outfall 005 prior to discharging, therefore, elimination of outfall 004 from SW testing is recommended. Outfall 007 does not drain any industrial process/storage areas. The permittee should COiSiu'or rcyucbiiF1g uiat' S —u —" t3c monitoring. Page4 - ,j NCDENR North Carolina Department of Environment and Natural RescuroH Division of'Nater Quality Eeveny Eaves °erdue Coleen H. Sullins Gee Freeman Gevernor Director Secretar January 28, 201 i David Waggoner, Environmental Manager Charlctte Pipe and Foundry Company 1335 South Clarkson Street Charlotte, NC 28208 Subject: Stormwater Monitoring Results Charlotte Pipe and Foundry Company 1335 South Clarkson Street NPDES Stormwater Permit — NCS000040 Mecklenburg County Dear Mr. Waggoner: Enclosed are the monitoring results from the sampling of the stormwater discharges from Outfalls #001 and #002 at the subject facility on November 16, 2010. The grab samples were collected during the sampling investigation performed by Ron Eubanks of Charlotte -Mecklenburg Storm Water Services (CMSWS) and included analyses required by the permit and additional analyses of interest in stormwater discharges. This sampling investigation was conducted as part of a cooperative working agreement between Mecklenburg County and the Division of Water Quality. In addition, the investigation was conducted on behalf of the City of Charlotte in compliance with the City's NPDES Permit, NCS000240, Part II Section H. The enclosed monitoring results indicate that the stormwater discharged on November 16,.2010, from Outfall #001 contained elevated concentrations of chemical oxygen demand (COD), total suspended solids (TSS), copper, lead, and zinc compared with the benchmark values contained in your individual stormwater permit. The Stormwater discharged from Outfall #002 on the same day contained elevated concentrations of chemical oxygen demand (COD), copper, lead, and zinc compared with the benchmark values. Of the additional analyses performed on the stormwater discharges, elevated concentrations of turbidity, biological oxygen demand (BOD), fecal coliform, and enterococcus were detected in Outfall #001 and elevated turbidity was detected in Outfall #002 as compared with the Divison's benchmark concentrations developed for these parameters in individual stormwater permits [turbidity - 50 NTU; BOD - 30 mg/L, fecal coliform — 1,000 CFU/100 nil, and enterococcus - 500 enterococci/100 mill. A comparison was made between the results noted in the enclosed analytical results sheets and the data reported on your Discharge Monitoring Report for the stormwater sampling you conducted on July 19, 2010. The sampling conducted by CMSWS personnel resulted in elevated concentrations of pollutants compared with your sampling. Please assess your industrial activities during the last six months of 2010 to determine if any activities may have contributed to the elevated concentrations of the analytes noted above. Through the development and implementation of stormwater management programs it is the Division of Water Quality's expectation that stormwater discharges at industrial sites covered by NPDES stormwater permits do not impact receiving waters. Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 Phone: (704) 663-16991 "Fax: (704) 663-60401 Customer Service: 1.877-623-6748 Internet hUp:/ipo.qal,nalenr.org/web/wq one NOrthCarohna yw David Waggoner, Charlotte Pipe and Foundry Company Stormwater Sampling, Page 2 January 28, 2011 The enclosed results should be self-explanatory, however should you have any questions concerning the sampling results or have any questions regarding your permit, please do not hesitate to contact Ron Eubanks with CMSWS or Ms. Marcia Allocco of the Division of Water Quality at (704) 235-2204. Sincerely, i for Robert B.-Krebs Regional Supervisor Surface Water Protection Section Mooresville Regional Office Enclosures: Analytical Results Sheet — SDO #001 Analytical Results Sheet — SDO #002 cc: Rusty Rozzelle, MCWQP Craig Miller, City of Charlotte Water Quality Central Files Stormwater permitting, Brian Lowther Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NO 28115 Phone: (704) 663-16991 Fax: (704) 663-60401 Customer Service: 1-877-623-6748 Internet: http:lportal.ncdenr.orglweblwq One NorthCarolina Ai Equal Opportunity t Affirmative Action Employer- 30% Recycled/10% Post Consumer paper David'P/acgener, Charlotte ^rice and Fcundry Company Stormwater Sampling, Pace 3 Januar✓ 28, 2011 ADDENDUM The National Pollutant Discharge Elimination System (NPDES) Program was established under the federal Clean Water Act and then delegated to the Division of Water Cuality for implementation in Ncrh Carolina. The NPDES permitting program for stonmv✓ater discharges was established in 1990. Phase I focuses on site and operations planning to reduce pollutant sources. Through the NPDES permitting program industrial facilities that fall into one of the subject ten categories are required to obtain permit coverage under a general permit or an individual permit: depending upon the facilities SIC code and the industrial activity occurring at the facility. There are currently 19 active general stormwater permits in North Carolina. One condition that is applicable to both the general permits and individual stormwater permits is the requirement to develop and implement site -specific comprehensive Stormwater Pollution Prevention plans (SPPP). These plans are required to include a comprehensive evaluation of the site and operations to reduce pollutant sources and prevent pollutant discharge. Copies of the general permits and accompanying documents can be accessed from the following webpage: http://portal.ncdenr.org/web/wq/ws/su/npdessw#General_Permits_NPDES. Permit text, technical bulletins, discharge monitoring forms, and a Notice of Intent [r high is the application for coverage under a NPDES General Stormwater Permit] can be found on this website. The following items are a subset of permit requirements and are listed to assist you and help bring your attention to certain permitting issues, process and condition requirements of your permit. Please see the above mentioned website to obtain a copy of the permit so you may fully comply with all the conditions therein. Failure to properly comply with conditions of the permit, like those bulleted below, is a violations) of the permit and subject to civil penalty assessments) of up to $25,000.00 per day. • Industrial facilities that fall into one of the subject ten categories are required to obtain permit coverage under a general NPDES stormwater permit or an individual NPDES stormwater permit • All persons desiring to have facilities covered by a General Permit must register with the Division of Water Quality (DWQ) by filing of a Notice of Intent (NOI) and Applicable Fees. • This Notice of Intent (NOI) must be submitted and a Certificate of Coverage issued prior to any discharge of stormwater associated with the industrial activity, process wastewater, and/or mine dewatering. • Once the Notice of Intent is received, DWQ will review and determine whether a Certificate of Coverage (COC) may be issued. If this Certificate of Coverage is issued the facility is covered by the General Permit. That is, the permittee is authorized to discharge stormwater, process wastewater, and/or mine dewatering pursuant to the type of General Permit until the permit expires or is modified or revoked. • Any other point -source discharge to surface waters of the state is prohibited unless it is an allowable non-stormwater discharge or is covered by another permit, authorization, or approval. • There are currently 19 active general permits. Permit conditions vary accordingly, however, most of the permits have the following condition requirements (you must read your entire permit to ensure full compliance): o Development and compliance with the Stormwater Pollution Prevention Plan o Collection, reporting, and recording of Analytical Monitoring o Collection, reporting, and recording of Qualitative Monitoring Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 l Phone: (704) 663-16991 Fax:1704) 663-60401 Customer Service: 1-877-623-6748 NorthCaioh t7T Internet: htip:ffpogal.ncdenr.org/webiwq Naturally ra /l, , An Equal Oppotlunity, 1 Affirmative Action Employer -30% Recycled110% Post Consumor paper (/VLL lL ((J .1 Cavid Waggoner. Charlotte Pipe and Foundr/ Company S;ormwater Sampling, Page 4 January28, 2091 c Collection, reporting, and recording of Vehicle Maintenance Monitoring (if applicable) Records —Visual monitoring shall be documented and records maintained at the facility along with the Stormwater Pollution Prevention Plan. Copies of the analytical monitoring results shall also be maintained on site. The Permittee shail retain records of all monitoring information, including all calibration and maintenance records and all original strip -chart recordings for continuous monitoring instrumentation, and copies of all reports required by this general permit for a period of at least 5 years from the date of the sample measurement, report, or application. Expiration — The permittee is not authorized to discharge after the expiration date of the general permit. In order to receive automatic authorization to discharge beyond the expiration date, the permittee shall submit forms and fees as are required by the agency authorized to issue permits no later than 180-days prior to the expiration date. Any permittee that has not requested renewal at least 180 days prior to expiration, or any permittee that does not have a permit after the expiration and has not requested renewal at least 180 days prior to expiration, will be subject to enforcement. Failure to renew your permit is a violation. c Transfer — The Certificate of Coverage (COC) issued pursuant to this general permit is not transferable to any person expect after notice to and approval by the Director. The Director may require modification or revocation and reissuance of the Certificate of Coverage to change the name and incorporate such other requirements as may be necessary under the Clean Water Act, The Permit is NOT transferable. o Name Change, Closure, or Facility Ownership change — Permittee is required to notify the Division in writing in the event the permitted facility is sold or closed. The Division of Water Quality views changes of name or ownership as a modification that requires the Director's approval and reissuance of the permit. Name and ownership changes require you to complete a Name/Ownership Change Form from the Division and mail it back to the Division of Water Quality along with all appropriate information. o Proper Operation and Maintenance is a requirement of the permit. Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 Phone: (704) 663-16991 Fax: (704) 663-60401 Customer Service: 1.877-623-6748 Internet: htpilpoaal.ncdenr.orglweo1wq An Equal Opportunity 1 Af rfrative Action Employer - 30% Recycledll0% Post Cen6nmGf paper Otte NorthCarolina Natimallry ANALYTICAL RESULTS SHEET Name of Facility: Charlotte Pipe and Foundry Company Grab: Composite: ❑ Sample Date(s): 11/16/2010 NPDES Permit No.: NCS000040 Sample Location: SDO # 002 County: Mecklenburg Temperature (°C) 17.5 Fecal coliform (CFU/100 mL) <100 Dissolved Oxygen (mg/L) 9.52 E. Coli (MPN/100 mL) <100 Conductivity (ps/cm) 267 Enterococcus (MPN/100 mL) 480 pH 8.68 Ammonia -nitrogen (NH3-N) (mg/L) 0.55 Turbidity (NTU) 160 Total Kjeldahl Nitrogen (TKN) (mg/L) 1.5 Biological Oxygen Demand, 5-day (BOD5) (mg/L) 19 Nitrate/Nitrite-nitrogen (NO2 and NO3) (mg/L) 1.6 Chemical Oxygen Demand (COD) (mg/L) 150* Total Phosphorus (P) (mg/L) 0.16 Total Suspended Solids (TSS) (mg/L) 100 Chromium (Cr) (pg/L) 9.2 Total Sediment Concentration (mg/L) 120 Copper (Cu) (pg/L) 29* Oil & Grease (mg/L) <5.0 Lead (Pb) (pg/L) 60* Zinc (Zn) (pg/L) 570* denotes an exceedance of the permit benchmark concentrations ANALYTICAL RESULTS SHEET Name of Facility: Charlotte Pipe and Foundry Company Grab: M Composite: ❑ Sample Date(s): 11/16/2010 NPDES Permit No.: NCS000040 Sample Location: SDC # 001 County: Mecklenburg Temperature (°C) 17.7 Fecal coliform (CFU/100 mL) 1,700 Dissolved Oxygen (mg/L) 9.36 E. Coli (MPN/100 mL) 310 Conductivity (Ns/cm) 238 Enterococcus (MPN/100 mL) 5,000 pH 8.59 Ammonia -nitrogen (NH3-N) (mg/L) 1.9 Turbidity (NTU) 550 Total Kjeldahl Nitrogen (TKN) (mg/L) 3.9 Biological Oxygen Demand, 5-day (BOD5) (mg/L) 71 Nitrate/Nitrite-nitrogen (.NO2 and NO3) (mg/L) 2.2 Chemical Oxygen Demand (COD) (mg/L) 480* Total Phosphorus (P) (mg/L) 0.47 Total Suspended Solids (TSS) (mg/L) 200* Chromium (Cr) (pg/L) 17 Total Sediment Concentration (mg/L) 190 Copper (Cu) (Ng/L) 49* Oil & Grease (mg/L) 19 Lead (Pb) (Ng/L) 170* Zinc (Zn) (Ng/L) 970* denotes an exceedance of the permit benchmark concentrations Waggoner, David From: Lowther, Brian [brian.lowther@ncdenr.gov] Sent: Tuesday, December 15, 2009 1:11 PM To: Waggoner, David Subject: RE: Aggregate storage building drawings I usually get mail through mail services which is 1617 Mail Service Center Raleigh, NC 27699-1617 But our physical address is Division of Water Quality Stormwater Permitting Unit 512 North Salisbury St. Raleigh, NC 27604 Brian From: Waggoner, David [mailto:dwaggoner@charlottepipe.com] Sent: Tuesday, December 15, 2009 1:06 PM To: Lowther, Brian Subject: RE: Aggregate storage building drawings Brian, �/�''An/ w�r-k$ That's not a problem. Can you give me your direct mailing address? Thanks, David From: Lowther, Brian [mailto:brian.lowther@ncdenr.gov] Sent: Tuesday, December 15, 2009 1:03 PM To: Waggoner, David Subject: RE: Aggregate storage building drawings David, -rr`e,4k-5, I quickly reviewed the drawings and they look to be good but I was wondering if you could send me hardcopies to review. We don't have a way to easily plot the drawings. Thanks, Brian From: Waggoner, David [mailto:dwaggoner@charlottepipe.com] Sent: Monday, December 14, 2009 9:21 AM To: 'Brian Lowther' Lowther, Brian From: Pickle, Ken Sent: Monday, October 19, 2009 12:25 PM To: Lowther, Brian Cc: Bennett, Bradley Subject: CP&F Attachments: NCS000040_Charlotte Pipe and Foundry Co_Modification Cover Letter2.docx Brian, Looks good. See my couple of small suggestions. It looks like you dealt with the question of, Do they have the right to appeal?, by including just the mods in their right to appeal. Seems like a reasonable resolution to me. Let's see if it causes any problems — I don't think it will. Our rationale here for not going forward with full procedural duplication is as follows: a) We consider this an allowable minor modification, not requiring repetition of all the previous procedural steps b) We issued a final permit, already, once. CP&F did not review/comment during the public comment period. c) Upon issuance they wanted to petition for changes via OAH; we talked them out of that time-consuming and costly approach, and instead persuaded them to ask for a permit modification. Subsequently we agreed to delay the Tiers kick -in, in exchange for a permit requirement to install a rather costly BMP without waiting for further analysis or investigation. d) 15A NCAC 2H .0114(b)(1) allows reduced procedural steps for modifications to the monitoring program, which we consider the kick -in of the Tiered program to be, by virtue of it's direct connection to monitoring results, and by virtue of its appearance in the permit text in Part II Section B Analytical Monitoring Requirements. (Note that we have not changed any text under Part III A 1. Compliance Schedule, which appears to be limited by the same rule part (b)(3) to a maximum of four months delay.) Ken E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law, and may be disclosed to third parties. 1PRE.TXT WET POND 0 0 0 0 1 3 7 --------------- 12 12 -------------------------------------------------- Total (cfs) 0 0 0 0 1 3 7 12 12 ----------------------------------------------------------- subarea 12.5 12.6 12.7 12.8 13.0 13.2 13.4 13.6 -- 13.8 Description hr hr hr hr hr hr hr hr hr ------------------------------------------------------------------------------- WET POND 10 8 6 5 3 2 2 2 2 -- --- - - --- -- - -- --- -- Total (cfs) - -------- 10 -- ------- 8 - - 6 ---- --- 5 -- --- ----- 3 --- -- 2 ---------- 2 2 2 --------------------------------------------------------------------------- subarea 14.0 14.3 14.6 15.0 15.5 16.0 16.5 17.0 17.5 Description hr hr hr hr _ ___ hr hr -_____------------- hr hr hr - _ ____ WET POND 2 _ ___ 1 1 1 1 1 __-______-____----------_- i i ___________________________________________ Total (cfs) 2 1 1 1 1 1 1 1 1 -- --- -- ---- ----------- subarea 18.0 -- ------- 19.0 - --- 20.0 -- -- 22.0 ------- 26.0 -- - -- --- -- -- --- ---- ----- Description hr hr hr hr hr ----------------------------------------------------------------------- WET POND 1 1 1 0 0 '-------------_- --------------------------------------------------------------- Total (cfs) 1 1 1 0 0 0 Quick TR-55 version: 5.46 5. TR-55 Executed: 0 watershed file: --> c Hydrograph file: --> c Time (hrs) 11.0 11.1 11.2 11.3 11.4 11.5 11.6 11.7 11.8 11.9 12.0 12.1 12.2 12.3 12.4 12.5 12.6 12.7 12.8 12.9 13.0 13.1 13.2 13.3 13.4 13.5 13.6 13.7 13.8 13.9 14.0 14.1 14.2 HVDROGRAPH METHOD Distribution ration storm) 1 YEAR 24 PRE-DEVEL FI OW (cfs) 1-2009 11:19:52 rojects\209\talc rojects\209\tale H UR STORM OPE RUNOFF 14.8 14.9 15.0 15.1 15.2 15.3 15.4 15.5 15.6 15.7 15.8 15.9 16.0 16.1 16.2 16.3 16.4 16.5 16.6 16.7 16.8 16.9 17.0 17.1 17.2 17.3 17.4 17.5 17.6 17.7 17.8 17.9 18.0 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 Page 4 WSD HVD Page 2 CHARLOTTE PIPE and FOUNDRY COMPANY P.O. Box 35430 • Telephone 704/332-2647 CHARLOTTE, NORTH CAROLINA 28235 Foundry Fax No. 332-4581 September 24, 2009 North Carolina Department of Environment & Natural Resources Division of Water Quality Stormwater Permit Unit Mr. Ken Pickle Mr. Brian Lowther 1617 Mail Service Center Raleigh, NC 27699-4714 SUBJECT: Charlotte Pipe NPDES Stormwater Permit #NCS000040 Charlotte Pipe is requesting a minor modification to NPDES Permit #NCS000040. As per our conversations with your office, we are requesting a two-year delay to the kick in of the tiered monitoring approach as specified in Section B of the permit. Due to offsite contributions and stormwater exposure on site, we anticipate stormwater sampling results to exceed the benchmark values set in Section B of the existing permit. To minimize these exceedences, we propose the installation of a BMP to reduce the stormwater pollutants at the facility. We propose to construct a cover over the aggregate storage area located at the northeast portion of our property. The cover will be a 150'L x 120'W x 35'H pre-engineered steel building. The containment area will include an eight inch concrete floor and concrete retaining walls on three sides. The storage building will be designed with an internal water spray system for dust control. The water spray system will apply water in amounts as to minimally wet the pile, not create a stormwater runoff. The anticipated construction date of the cover is December 2009. Please contact me at (704) 348-5408 if you have any questions or need any additional information.. Sincerely, f David W ggoner [N SEP 2 9 2009 I �f�hi �' I` 1, ty;�'1 !. I ':. J„ .... I 3 a' Pickle, Ken. From: Sent: To: Subject: Lowther, Brian Monday, August Pickle, Ken RE: Charlotte PA res��.n 6e,- A/i r4T4Qv-als e x a7C7'/r, e%/Z4G / /his � 6e :08 PM /07 374 0 61470?ls ei. care Ot me Bradley correctly. Your note on the file said Bradley said it was "ok to be flexible on time, parameters." I don't really re Brian Laura, Thanks for following up on this and talking with us on the phone this F307 make sure. �it ✓e alone . ��' ,.f wtio�d mat � aaA 6e After our last phone conversation Ken and I were asked to talk with Br dley Bennett to discuss th e and the possibility of delaying the permit. We have talked with Bradley and i formed him of the permitt e _oncerns and of the issues with the site and the permit. Bradley understood it was a diff ult site given the location and recommended contacting Charlotte/Me jsleEb rrg CountyWfor more information �He� somewhat flexible wit`h jpme and parameter3howeve teowe could not raise the benchmarks. He sai that we would not delay the permiit�ut 1 WG could do a minor mg of the monitorin schedul f d� a/ yosfl't�N 1llf ari7�o�/)��oin ret+9,� /t��a Po//��Tc�Yiy6u7`%��n. !� We understand thi I �' the site location ntAHowever, we want to protect the water quality as much as possible and strive to reac b� ance these with our erm� We understand our L current permit is not favoraOto the permittee because they will probably be ov Af ee Oer°hmarks. We *AAA Tb t/Jo�� tter4" with the permitteAu -'-^r- ih. 6 ,__ We do encourage collecting samples to identify the Aei! /47 Vo o? Q-@4k- �-�off site r butions. We feel ., cuLrent permit gives time for this sampling to occur before more sampling is required�,Pere is some trust req i c from the permittee that the state will work with the permittee in order to address the exceedances of the benchmarks. We feel the permit sets up viable options in this case which include but are not limited to: require that the permittee increase or decrease the monitoring frequency for the remainder of the permit; require the permittee to install structural stormwater controls; require the permittee to implement other stormwater control measures; or Again though, we feel that the state will do its best to work with the permittee tc to work with the physical constraints of the site. Q)✓Q 44// &/MM J,4 0? aMY VOR a re -I ,44-ft, area:i�.caT�im/jj�ear►dilero oi- aaF7dA4 r Please'(et me know if you have any questions or comments. Brian Lowther d a+.sd �i/p/efalio�cmRgop;y daa C�1ee/oa, )alance protecting water quality and eW Itw- / 4O*-W oolo A Pcc� S 1�i° T� From: Laura Moody [mailto: Laura. Moody@erm.com] Sent: Monday, August 03, 2009 10:38 AM too peril 14,V✓e QQ L M/ To: Pickle, Ken lk iei' A in aigdoq /enj /r12� T mode Subject: Charlotte Pipe ! J e /�P1�1°q /%) O/7c�1' /Q da/o'/'I�SS c�/)CiI.ON/'� eI�LPP�PAGBS' f0 KeniB exr,,SS 0le %.Z 01,0414 Alep q 0.7 7%0 //r»I/Jq m� .J . .SoLa1p/i�xj er/eg7�: Case 08=017898-ATS• Doc 297 Filed 04101/09 Entered.04/01/09 15'45:10' Page'46'of - 83 , , writing by the Sellers and { fie Purchasers iri•whole or m part to the•extent permitted by applicable (a) there shall not be in effect any statute, rule,Y regulation, executive order enacted, issued, entered or promulgated by a Governmental Body of competent jurisdiction restraining, ., enjoining or otherwise , ,prohibiting; the, Consummation of the transactions contemplated hereby; and (b) \the' Bankru'ptcy'Court shall have entered the Sale Order (as provided in ' v Article VI), and such•order $hall be,,a..Final.,Order and •in, form and substance reasonably satisfactory' to'the Sellers and the Purcliasers„which order shall not have been reversed, modified, amended or stayed. s i 8.2 Conditions Precedent to the Obligations of the Sellers. The obligations of the Sellers to consummate the transactions contemplated by this Agreement are subject to the fulfillment, on or prior to the Closing Date, of each of the following conditions (any or all of which may be waived in writing by the Sellers in whole or in part to the extent permitted by applicable Law): (a) the representations and warranties of the Purchasers set forth in Article V hereof shall be true and correct in all material respects, in each case as of the Execution Date and as of the Closiiig,•Date as though made ; on and as of the Closing Date (except for such representations and,warranties made as of'a specific date, which shall be true and correct in all material respects'as-of such date) and.the Sellers shall have received a certificate signed by an , ,.; ;,,. , ,:,,•,�, authorized officer &-each Purchaser, dated the Closing Date, to the foregoing effect; (b) - the Purchasers, shall have -,performed and complied in all material respects with all obligations and agreements required,bydhi$ Agreeient to, be -performed •ort complied,_ with by the Purchasers on or prior to' the :Closing Dafe;!me dding,- without`limltation, ,the Purchasers prpviding adequate assurance `of future perforriance as required under the t,e Bankruptcy C8de'46 effect the assumption and assignment of the Assigned Contracts and r ; Assumed Liabilities, and the Sellers shall have received a certificate signed by. an authorized officer of each Purchaser, dated the Closing Date, to the foregoing effect; (c) the Purchasers shall have delivered, or caused to be delivered, to the Sellers all of the items set forth in Section 3.3; and (d) the Purchasers shall have delivered the Purchase Price in accordance with Article IL 8.3 Conditions Precedent to the Obligations of the Purchasers. The obligations'of the'+' r• ° . Purchasers to consummate the transactions contemplated by this Agreement are subject to the fulfillment, on or prior to the Closing Date, of each of the following conditions (any or all of which may be waived in writing by the Purchasers in whole or in part to the extent permitted by applicable Law): (a) the Sellers shall have delivered to the Purchasers, a certified copy, of the Sale Order (which shall contain the teens described in'Section 6.'2); ` LEGAL _US_E # 82611875.8 ''' 23 • f • ,,, .. .•. „ 4�'). Case 08-01789-8-ATS Doc 297 Filed 04/01/09 Entered 04/01/09 15:45:10 Page 47 of 83 (b) the representations and warranties of the Sellers set forth in Article IV hereof shall be true and correct as of the Execution Date and as of the Closing Date as though made on and as of the Closing Date (except for such representations and warranties made as of a specific date, which shall be true and correct as of such date) except where the failure of such representations or warranties to be true and correct (without giving effect to any limitation or qualification as to "materiality" or "Material Adverse Effect" set forth in such representations and warranties) has not had and would not reasonably be expected to have, individually or in the aggregate, a Material Adverse Effect, and the Purchasers shall have received a certificate signed by an authorized officer of each Seller, dated the Closing Date, to the foregoing effect; (c) the Sellers shall have performed and complied in all material respects with all obligations and agreements required in this Agreement to be performed or complied with by them on or prior to the Closing Date, and the Purchasers shall have received a certificate signed by an authorized officer of each Seller, dated the Closing Date, to the forgoing effect; (d) except as provided in Section 7.3, and provided the Purchasers have provided adequate assurance of future performance as required under the Bankruptcy Code to effect the assumption and assignment of the Assigned Contracts, all of the Assigned Contracts set forth on Schedules 1.1(a)(vii) and 1.1(b)(viii) shall (i) be in full force and effect on the Closing Date, subject to the Bankruptcy Exception, (ii) be assignable to the Purchasers without the consent of the counterparty to such Assigned Contract for such assignment (or such consent shall have been received prior to the Closing Date) and (iii) have had the amount of all of the Sellers' breaches and defaults thereunder finalized to the best of the Sellers' ability, such that the Cure Costs may be paid by (or creation of reserves therefor) in accordance with the Sale Order; (e) the Sellers shall have delivered, or caused to be delivered, to the Purchasers all of the items set forth in Section 3.1 and (f) the Purchasers shall have received all authorizations, in form and substance reasonably satisfactory to the Purchasers, from FERC, under the FPA, to acquire, own and operate the Purchased Assets. 8.4 Frustration of Closing Conditions. Neither the Sellers nor the Purchasers may rely on the failure of any condition set forth in Sections 8.1, 8_2 or 8_3, as the case may be, if such failure was caused directly by such party's failure to comply with any provision of this Agreement. p ARTICLE IX. ADDITIONAL DEFINITIONS 9.1 Certain Definitions. As used herein: (a) "Accounts Receivable" means (i) any and all accounts receivable, trade accounts and other amounts receivables (including overdue accounts receivable) owed to a Seller relating to the Business and other rights to payment owed to a Seller and the full benefit of all security for such accounts or rights to payment relating to the sale of goods or provision of services by a Seller, including all trade accounts receivable representing amounts receivable in LEGAL -USE # 82611875.8 24 Hope you had a great weekend and you have recovered from having the grandkids there! Have you had an opportunity to talk with Bradley in regards to the stormwater permit options for Charlotte Pipe? Thanks, Laura Laura Rohe Mood)' ERM NC, PC 8000 Corporate Center Drive Suite 200 Charlotte, NC 28226 Phone:7O4-541.-8345 Pax:7O4-541-8416 This electronic mail message may contain information which is (a) LEGALLY PRIVILEGED, PROPRIETARY IN NATURE, OR OTHERWISE PROTECTED BY LAW FROM DISCLOSURE, and (b) intended only for the use of the Addressee (a) names herein. If you are not the Addressee (a), or the person responsible for delivering this to the Addressee (a), you are hereby notified that reading, copying, or distributing this message is prohibited. If you have received this electronic mail message in error, please contact us immediately at (704) 541-8345 and take the steps necessary to delete the message completely from your computer system. Thank you, ERM NC, PC. This electronic mail message may contain information which is (a) LEGALLY PRIVILEGED, PROPRIETARY IN NATURE, OR OTHERWISE PROTECTED BY LAW FROM DISCLOSURE, and (b) intended only for the use of the Addressee (a) names herein. If you are not the Addressee (a), or the person responsible for delivering this to the Addressee (t), you are hereby notified that reading, copying, or distributing this message is prohibited. If you have received this electronic mail message in error, please contact us immediately at our Atlanta office (770) 590-8383 and take the steps necessary to delete the message completely from your computer system. Thank you, Environmental Resources Management. Sew. H Ak a6� A--NZ`7`L yo� 1)C14e Ne/l�E 4Je �d� MI � c� 5 yO tti 2 Permit No. NCS000040 SEC P FN ' P To -s� r Faa' rl` `35+ � �. The Permittee shall ' / selected BMP nc Include.consu:uct••ionnd-mam errartce-records in the facility's SPPP: / L / �e P (a.) Tl e MP ust be selected based on the assessment of t i�tal for sources to contribute signifi t qua tities of pollutants to tormwater discharges, d based on data collected through historical m oFitg o€sto�rnwcrt is s-Fhzseleeted- - may-beitlaexsicuctural taf nrttE�t BMPs o source reducti #selee st be selected and submitted to the Diviswvrrnot ter than December 1, 2009. pon receipt of timely approval of the selected BMP, the permittee shall develop construction plans for the selected and approv BM Construction plans, including a narrative description, a i construction schedule, and support g dee gn calculations, must be submitted for each BMP not later than January 1, 2010. (c.) Upon receipt ofi imelapproval of the construction and associated documentation, the Permittee shall construct and/or implement the selected and approved BMPs. The selected BMPs shall be installed, operating, or implemented not later than July 31, 2010. The Permittee shall provide monthly progress reports to the Division between January 1, 2010 and July 31, 2016, or until final installation, operation, or implementation of the selected and approved BMPs is achieved. Any subsequent revisions to the selected-BMP required.in.this_Section E shall not require a revision to the Stormwater Permit. Any revision to the construction and maintenance records after the he initial review and approval of DWQ shall be accomplished by mutual agreemep� between DWO and the Permittee. _ 11Jp /�O u,-) A fi� uS. Gffr B. 'Q �are�s�B��dyo.�ladrw• o-�e. 5��-�, LLY e \j E �6 mP , I S,np cc Ce t + /'o b Part II Page 12 of 11 ?7 w rev. 4z APPLICATION FOR A MINING PERMIT E. DETERMINATION OF AFFECTED ACREAGE AND BOND The following bond calculation worksheet is to be used to establish an appropriate bond (based upon a range of $500 to $5,000 per affected acre) for each permitted mine site based upon the acreage approved by the Department to be affected during the life of the mining permit. Please insert the approximate acreage for each aspect o the mining operation that you intend to affect during the life ofthis mining permit (in addition, please insert the appropriate reclamation cost/acre for each category from the Schedule of Reclamation Costs provided with this application form) OR you can defer to the Department to calculate your bond for you based upon your Wraps and standard reclamation costs: AFFECTED RECLAMATION RECLAMATION CATEGORY ACREAGE COST/ACRE* COST Tailings/Sediment Ponds: 0.00 Ac. X $ 0 /Ac. _ $ 0 Stockpiles: 0.00 Ac. X $ 0 /Ac. _ $ 0 Wastepiles: 0.00 Ac. X $ 0 /Ac. _ $ 0 Processing Area/Haul Roads: 2.54 Ac. X $ 1800.00 /Ac. _ $ 4,272.00 Mine Excavation: 38.14 Ac. X $ 500.00 /Ac. _ $ 19,070.00 Other: 0.00 Ac. X $ /Ac. _ $ TOTAL AFFECTED AC.: 40.68 Ac. (TOTAL PERMITTED AC.: 40.68 Ac.) Divide the TOTAL AFFECTED AC. above into the following two categories: a) affected acres that drain into proposed/existing excavation and/or b) affected acres that will be graded for positive drainage where measures will be needed to prevent offsite sedimentation and sedimentation to onsite watercourses and wetlands. a) Internal Drainage 40.68 Ac. b) Positive Drainage 0 Ac. X $1,500.00 = $ 0 SUBTOTAL COST: $ 23,342.00 Inflation Factor: 0.02 X SUBTOTAL COST: $ 466.84 X Permit Life (1 to 10 years): 10 INFLATION COST: $ 4,668.40 TOTAL COST = SUBTOTAL COST + INFLATION COST = $ 28,010.40 Total Reclamation Bond Cost: $ 28,000.00 (round down to the nearest $100.00) -14- t., Lowther, Brian From: Lowther, Brian Sent: Tuesday. August 04, 2009 1 10 PM To: 'Laura.Moody@erm.com' Cc: Pickle, Ken; David, Waggoner,: 'maxiustice@parkerpoe.com' Subject: RE: Charlotte Pipe ftannitn for fohow,ia,; u[) on this and hdkiui; with tin on too phone ymyrddir. " cut On phyn non-vanon 0 n re asked to talk who Brodhv i-i- - i the son and the pobytidn ,!,naymg the jo min, Ae have 1,, . 4raclb, ind informed hvii that on 41 , concerned about corrunuxf� 4- chnnark er nAk ns,4, and tN pc ,-o a , that ,*nlh'watef I)OHLIt,ors dI,, 1' nq be completely below v-0mail vdnpn jml of in_ %, k -% . " 1 o we dak the permit sack v urn i was a &Hmuq one glen the ov mon and rausn"i, hoed that we , r old( i, C.harkyte/h/locklenbuig County q4, at ny wAt-f for more Noinfaterd 'Pla.1h we dov, done. Tacky noted that we can he somewhat flexible with tinn, a 1 no ametes; however he noted on, could not rain the benchmarks. He >a d that we would not delay the permit imeq r w crauki do a minor modification of' thmonitol njj n( heduln without to )v through the public notice and pur.tlic comm r,t PPHOCI c,,c undeisiaht' thrs is a diftic Lilt sae -a: :I'e Site Deaf ern land vomnkvr• 'd D i,. r e upstream pollutant (,1,Irmutjow, Howosu, vju war, w - I the walarr quahtf, a, much " r)k �, ! Ive to reach a balance between then vith our permit d,- w : :and c ., current porina s rwi 7 V We permittee because they will puldhN be own surn, of the & n i h he vv at to rotor, -Au tiait a',;i o -er uonf e is not a permit violation. An exioiqhiwe is iWpHdc 1 two trigger odditional quirruwanr nn inqt it icnon by the permittee. We hope to work oitin th,> riprmitto, r < nif r,iative mode in order to odd"�o out hu _ �irn im exceederwes to the extent eojnsocailyfex,iblp We do ersooraa, your current plan to collect additional arrN yes ioidentify the magnitude of if xe contributions. We feel that the current permit gives time for this wmphng 1', -nu!r before more SJITIPling It, inquired, poifo=0; " ovAns of 12 � Uh, depending roi the tmiii,t or ri, There is some tiu'n , rdiared from i 1),• ;erfnrth e th,o th., in, will tak., into account the fea onkuy of j � :&A sumn-twator managenny,t dr hons as the not itittwo androw edentc, of the bern hinnaks. V , kn, KTQo Not offsite contributions, her, tj� J ovaii,&� 'd )at! ill ... ; nts it, !y vent well hi -A , hat _� , ) . :)Y nornhoater management owrans We hia tho rermit airwany r nm that DAKI "send, to work wita n* won wi that it sets LOP viable cpums where bpqchHmrk exwyqw. minue; ire options .0toadf, KIN IA- , ri permit include, but are not Iminked to: • mcLm , No the roi = e . ,w or do roam the moritonriq WAVwl: y I lVI remainder of the permit; • i equir, in� pc"nabev to an, 5 1 Ar.Juril stormwater ciamouly or • requite Wo pin mitfue to "jn. npqa other stormwater control na,a,ja- Ago", though, we fownilow 11h, n'. to . v Is boa to Nwk wrth wi, perp. ', ' , i protecting water quality and Q A/Awk widurs the #hR I Co.vdnw, thn Ote. DVK) will provotV j at n 1 A wiN agreements, modificatton, conditions, or, it, th r , NuAN; from mogauatn"I VP , tt 1�1hy considerations, and ,AE�rjjietatronrol on , )inh 'Iaio r�i r PC iy� lot me Know A, aw hav,, any c -airs or cornrinctst. brion Lowther Parkway just west of the pro tee box on golf hole 1. This section of stream needs 2 to 4 inches of sediment removal. Trail Parkway west of golf hole 1. This section of stream needs 2 to 4 inches of sediment removal. Photo Point Six: Greenbrier Creek below Wilderness Trail Parkway west of golf hole 1. This section of stream needs 2 to 4 inches of sediment removal. Photo Point Eight: Greenbrier Creek below Wilderness Trail Parkway west of golf hole 1. This section of stream needs 2 to 4 inches of sediment removal. From: Laura Moody [mailto:Laura. Moody@erm.com] Sent: Monday, August 03, 2009 10:38 AM To: Pickle, Ken Subject: Charlotte Pipe Ken - Hope you had a great weekend and you have recovered from having the grandkids there! Have you had an opportunity to talk with Bradley in regards to the stormwater permit options for Charlotte Pipe? Thanks, Laura Laura Rohe Mooc1Y ERM NC, PC 8000 Corporate Center Drive Suite 200 Charlotte, NC 28220 Phone:704-541-8345 Fax:704-541-8416 This electronic mail message may contain information which is (a) LEGALLY PRIVILEGED, PROPRIETARY IN NATURE, OR OTHERWISE PROTECTED BY LAW FROM DISCLOSURE, and (b) intended only for the use of the Addressee (s) names herein. If you are not the Addressee is), or the person responsible for delivering this to the Addressee (s), you are hereby notified that reading, copying, or distributing this message is prohibited. If you have received this electronic mail message in error, please contact us immediately at (704) 541-8345 and take the steps necessary to delete the message completely from your computer system. Thank you. FIRM NC.. PC. This electronic mail message may contain information which is (a) LEGALLY PRIVILEGED, PROPRIETARY IN NATURE, OR OTHERWISE PROTECTED BY LAW FROM DISCLOSURE, and (b) intended only for the use of the Addressee (s) names herein. If you are not the Addressee (s), or the person responsible for delivering this to the Addressee (s). you are hereby notified that reading. copying, or distributing this message is prohibited. If you have received this electronic mad message in error. please contact us immediately at our Atlanta office (770) 590-8383 and take the steps necessary to delete the message completely from your computer system Thank you. Environmental Resources Management hole 1 which needs 2 to 4 inches of sediment removal. tributary to Greenbrier Creek. This portion of stream is between holes 1 and 17 and needs 1 to 2 inches of sediment removal. hole 1. This pool section needs to have 4-6 inches of sediment removal. tributary to Greenbrier Creek. This portion of stream needs 2 to 4 inches of sediment removal. �(,o:* -B O N N d _. p CD rn= q 0CD CD � N CD N o -I C> Cn O O N IV N CD O Ca 3 North Carolina Beverly Eaves, Perdue Governor ®r HCEN Department of Environment and Natural Resources Division of Water Quality Coleen H. Sullins Mr. David Waggoner Charlotte Pipe & Foundry Company PO Box 35430 Charlotte, NC 28208 Dear Mr. Waggoner: Dee Freeman Director Secretary May 20, 2009 Subject: Draft NPDES Stormwater Permit Permit No. NCS000040 Charlotte Pipe & Foundry Company Mecklenburg County Enclosed with this letter is a copy of the draft stormwater permit for your facility. Please review the draft very carefully to ensure thorough understandhig of the conditions and requirements it contains. The draft permit contains the following significant changes from this facility's current permit: Analytical monitoring changes: 7. Analytical monitoring parameters, COD, TSS, Total Kjeldahl Nitrogen,.Phenols, Total Copper, Total Recoverable Lead, Total Nickel, Total Zinc and Total Chromium, have been maintained in the permit. Oil & Grease and pH has been added to the permit based on the parameter being potential pollutants at the site. 2. 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 precipitatiomfor 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. Additioriaily, samples must be taken a minimum of 60 days apart, as specified in fable 2. 3. .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 stormwater Best Management Practices (BMPs) in a tiered program. 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 1 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. 4. You are required to collect all of the analytical and qualitative monitoring samples during representative storm events as defined in Part II Section B. Qualitative monitoring is required regardless of representative outfall status. 5. You are responsible for all monitoring until the renewal permit is issued. See Footnote 1 of Tables 1, 4, and 5. Wetlands and Stormwater Branch - - - One 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 1,!'+ NOTCHCaTO11Tla Location: 512 N. Salisbury St. Ralegh, North Carolina 27604 Phone: 919-807-6300 1 FAX: 919-807-64941 Customer Service:1-877-623-6748 - �y /{.l,p�t //// �Q'`urQL[J/ Internet: vmv.nmaterquality.org i/ An Equal Oppodunity \ Affirmative Action Employer Mr. David Waggoner Charlotte Pipe & Foundry Company Permit No. NCS000040 6. The flow reporting requirement has been removed per DWQ revised strategy. (The total rainfall parameter is in this permit, however.) 7. Vehicle maintenance monitoring has been revised to semi-annually in order to coincide with analytical and qualitative monitoring. This requirement appears in all Individual Stormwater permits, however it only applies to facilities that do vehicle' maintenance. If the facility begins vehicle maintenance during the permitted timeframe then the requirements shall apply. Other permit changes: 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 II 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 II 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 stormwater management controls as specified in Part 1I 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 CPR §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. 6, Per the requirements of the Catawba Riparian Buffer Riffle, all stormwater drainage from portions of this site that have been constructed after June 30, 2001 must be discharged through'a correctly designed level spreader or another device that meets diffuse flow requirements per 15A NCAC 213 .0243. Diffuse flow requirements are described in Chapter 8 of the North Carolina Stormwater BMP Manual, available at:littp://h2o.enr.state.nc.us/su/brnp_forms.hhn Please submit any comments to me no later than thirty (30) days following your receipt of the draft. Comments should be sent to the address listed at the bottom of this page. If no adverse comments are received from the public or from you, this permit will likely be issued in about two months. If you have any questions or comments concerning this draft permit, contact me at (919) 807-6368 or bi-ian.lowther@ncdenr.gov cc: Mooresville Regional Office Stormwater Permitting Unit Attachments: Draft Permit Sincerely, 2 Brian Lowther Environmental Engineer Stormwater Permitting Unit 2 �� NCDENR North Carolina Department of Environment and Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director DATE: May 20, 2009 TO: Charlotte Observer EMAIL: publicnotices@charlotteobserver.com FROM: SARAH YOUNG, DIVISION OF WATER QUALITY SUBJECT: PUBLIC NOTICE PAGES: 1 Natural Resources Dee Freeman Secretary Please publish only the information (Public Notice) below, ONE TIME in the legal section of your paper by Tuesday, May 26, 2009. Please fax a copy of the proof to me at (919) 807-6494 for final approval prior to publication. Within 10 days after publish date, please send the invoice and two copies of the original affidavit to: Sarah Young NCDENR/DWQ Stormwater Permitting Unit 1617 Mail Service Center Raleigh, NC 27699-1617 NC DIVISION OF WATER QUALITY INTENT TO ISSUE A STORMWATER DISCHARGE PERMIT Public comment or objection to the draft permit is invited. Submit written comments to DWQ at the address below. All comments received prior to June 25, 2009 will be considered in the final determination regarding permit issuance and permit provisions. Application: Charlotte Pipe & Foundry Company, PO Box 35430. Charlotte, NC 28208 has applied for an NPDES permit to discharge slormwater from an industrial facility at: Charlotte Pipe & Foundry Company, 1335 South . Clarkson Street, Charlotte, NC, Mecklenburg County. The facility discharges to the Irwin Creek. Copies of the draft permit, No. NCS000040, are available at: http://h2o.enr.state.nc.us/su/publicnotice.htm . Additional permit documents are available for the reproduction cost at: DWQ Stormwater Permitting Unit 512 N. Salisbury Street (location, zip 27604) 1617 Mail Service Center (mail) Raleigh, NC 27699-1617 DWQ Contact: Brian Lowther (919)-807-6368 brian.lowther@ncdenr.gov Wetlands and Stormwater Branch 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 Phone: 919-807.63001 FAX: 9194f07-6494\ Customer Service: 1-877-623-6748 Internet: www.ncwaterquality.org An Equal opportunity 1 Affirmative Acton Employer Noi thiCarotina Naturally The Charlotte Observer Publishing Co. CharLotte, NC North Carolina ) ss Affidavit of Publication Mecklenburg County} THE CHARLOTTE OBSERVER STORMWATER PERMITTING UNIT NCSDENR/DWO 1617 MAIL SERVICE CENTER RALEIGH NC 27699-1677 REFERENCE: 30064055 6347714 stormwater discharge Before the undersigned, a Notary Public of said County and State, duly authorized to administer oaths affirmations, etc., personally appeared, being duly sworn or affirmed according to Law, doth depose and say that he/she is a representative of The CharLotte Observer Publishing Company, a corporation organized and doing business under the Laws of the State of De Laware, and publishing a newspaper known as The Charlotte Observer in the city of Charlotte, County of Mecklenburg, and State of North Carolina and that as such he/she is famiLiar with the books, records, files, and business of said Corporation and by reference to the files of said publication, the attached advertisement was inserted. The following is correctly copied from the books and files of the aforesaid Corporation and PubLication. PUBLISHED ON: 05/26 AD SPACE: 52 LINE FILED ON: 05/29/09 NAME: (1neLU/'A,1U\ ,U97` Ti TITLE: 11,i `--i(\. DATE: . MIRY 217009 In Testimony Whereof I have hereunto set my hand and affixed my seat, the day and tear aforesaid. a. Nota /—'LMy Commission Expires: My Commission Expires May 27, 2011 NC DIVISION OF WATER QUALITY INTENT TO Issue A STORMWATER DISCHARGE PERMIT Public comment or imitation to the draft permit is invited. Submit written comments to WO at the address below. All Comments mceived prior to Juno 25, 2009 will be considered in the final deterina6bn regard'ag peril issuance and permil provisions. Application: Charlotte Pipe A Foundry Company, PO Box 3SJ30. Charlotte. NO 282W has applied for an NPDES permit to did. Chargestormwxter tram r industrial fecilty at. Charlotte Pipe 8 Founary Company, 1335 South Clarkson Street, Charlotte. NO, Mecklenburg County The facility discharges to the Irwin Crook. Copies of the draft permit, No. NCS0900a0, are available ab M1no'llh n a no e_/_ ulottelancred hire Additional permit ocum tlarmsn ere available - far the reproduction cost at DWO Stormwater Permitting Unit 512 N Salisbury Street (location, zip 27") 1617 Mail Samoa Center hasip Raleigh, NO 27699-1617 OWO Contact: Stan L3wmer (919)-807-6368 - brian.lowmerpncdenr gov LP63a7)la NCQ,000040 0 ®®ggam�++ 9�� DENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary STAFF REVIEW AND EVALUATION NPDES Stormwater Permit Facility Name: Charlotte Pipe & Foundry Co NPDES Permit Number: NCS000040 Facility Location: 1335 South Clarkson Street, Charlotte, NC (Mecklenburg County) Type of Activity: GRAY AND' DUCTILE IRON FOUNDRIES SIC Code:, 3321 Receiving Streams: See Figure 1 River Basin: Catawba River Basin, Sub -basin 03-08-34 Stream Classification: C Proposed Permit Requirements: See attached draft permit. Monitoring Data: See Table 1 Response Requested by (Date): Central Office Staff Contact: Return to: Brian Lowther, (919) 807-6368 Special Issues: 5 ", Issue ,Ratio .Scale' ;1(eas to 10 hard ` Com Hance histor 6 Benchmark exceedance 7 Location (TMDL, T&E s ecies, etc 7 Other Challenges: • Missin data 6 Difficult 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 Page 1 of 9 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 • SPU File • Central Files • EPA Sector -Specific Permit, 2008 0 303(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. • February 19, 1999: Permit renewal reminder letter. • 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'h year. • May 3, 2004: Pen -nit 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 (MC WQP). • May 8, 2006: Notice of Violation. Page 2 of 9 NCS000040 NCS000040 M40 Scale 1:24, 000 Figure I: Map of Facility Charlotte Pipe & Foundry Co Lad tude: 350 13' 28" N Longitude: 800 51' 42" W County:Vleddenburg Receving Stream: Irwin Creek Stream Class: C Sub -basin: 03-08-34 (Catawba River Basin) O`LORION!r �S • � �drrTr k.++ Facility Location Page 3 of 9 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, SW004) have been identified as intermediate outfalls for sampling purposes. - S WOOI : 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%n impervious. - S WO02: This outfall drains approximately 3.1 acres of the 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. SW005: 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 S WO04 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", -80' 51'49"), 002A (35' 13'23", -80' 51'42"), 004 (35° 13'27", -800 51'39"), 005 (350 13'29", -80° 51'41"), 006 (350 13'34", -80° 51'45"), and 007 (350 13'34", -80° 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 Creek, 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. Page 4 of 9 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. 7. Analytical Monitoring Notes: 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 41h year. The application only included one sample for each out/all. The samples had values over our current benchmarks for Cr, Cu, Pb, 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 permit. CP&F personnel indicated that more than 55 gallons of new motor oil were used but no records of quantities have been 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. Page 5 of 9 NUIRIIIIZII M 1 Table 1: Analytical Monitoring Outfall Sample Date Total Flow 1M Precipitation (in) Duration (hours) O Cu Pb Ni Zn TKN Phenol COD TSS Banchrrark 1 mg'L Benchmark: 1 0.007 nxjL Bent mark: 1 0.03 mgIL Benchmark I 026 ng'L Berchma,k: 0.067 m qL Bench,rerk: 20 mg'L B3 hmarlc 4.5 mgA- Bewturak 1 120 mg/L Bemtrrark: I 100 mg'L SW-001 62312D04 t.i .' r : " 0.1 0,079 F'_ � '' O:S5.r,;_ . 0.033 1,, ? 7 - 0Slvr_- 1.9 0.29 210, ' . - :. Mx'210,r- SVV-002 6(24/2D04 4 T 9 is _ . ] ` bzN " %?}. '}. 0.15 O;112W 0.056 =-MV2,M 1.6 0.17 220 1 , 250y`„ i SW-002A 612512D04 ae e , , .-i3 « •.2. - 12,EWOF45MI M32 4 0_3= MJW7;M 1.5 0.09 900 850 t SVV-004 6/26/2004 wr ; p K ?+;" 1 0.27 2*0�42= 9MI13Sj 0.18 2'.5.N 8.5 ;, ..3. ° k1700Y 5400 ` SVV-005 6/27/2D04 _ Y ' i ; x ` � 'x ` - :- °; 0.61 MPW 0.,12, ? 0.016 O'29i7N <1.0 1.4 4M W500 S1N-001 2/26/2D08 -" ti r'_'•. ND 0.'0i167 0.0203 ND f.WO.3,24QI 0.99 0.02 77226 T 30 SVV-002 2/26/20D8 0.0182 NUOM9PA 041@'a 0.0111 0.411 1.4 0.063 119 @W94 5 SVV-002A 2/26/2008 ... VIa sc . ,. -. �741195 1156 9T52 0.181 . W,-7 • ;• . 2,1z2n 1.8 M042MI a 961Q SW-004 2262008 s� 'M 2F . ' ''? 0.0132 NSW02m, 0.0199 0.0067 O1173 0.92 0.023 36 109 i" SW-005 2/26/2008 ' ' �1, , c - Y ,rx .. 0.0143 0:0,461 0.14 0.0119 0 81; 1.9 0.032ua}251+' SVV 006 2/2&2D08 } `�.« "= 0.0128 9.0195; 0.0265 0.006 0}21WJ 0.92 0.055 50 1_26 SVJ 007 212&2D08 { ;' 0.0906 0:0611 X0'08911` } 0.0345 ' 0815:: 2.2 0.015 80 1a Over Current Bendirrork Data Not Collected Page 6 of 9 L NC$000040 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 pennittee 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 pennittee to increase monitoring, increase management actions, increase record keeping, and/or install stonnwater Best Management Practices (BMPs) in a tiered program. 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 1 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 I 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 11 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 I of Tables 1, 4, and 5. 7. The flow reporting requirement has been removed per D WQ 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 II Section A. 2. Additional requirements for the Stonnwater Management Plan have been specified in Part 11 Section A. More details regarding secondary containment are provided. 3. Additional requirements for the Stormwater Pollution Prevention Plan have been specified in Part II 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. Page 7 of 9 NCS000040 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. Page 8 of 9 NCS000040 Recommendations: Based on the documents reviewed, the application information submitted on July 4, 2004 sufficient to issue an Individual Stormwater Permit. Prepared by (Signature) Date Stormwater Permitting Unit Supervisor Lr-/ Repo Date 3 A o for Bradley Bennett Concurrence by Regional RO Water Quality Date Regional Office Staff Comments (attach additional pages as necessary) Page 9 of 9 HC®EHR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary March 10, 2009 Mr. David Waggoner Charlotte Pipe & Foundry Company PO Box35430 Charlotte, NC 28208 Subject: NPDES Permit Renewal Application Charlotte Pipe & Foundry Company Permit Number NCS000040 Individual Stormwater Permit Mecklenburg County Dear Mr. Waggoner: The Division of Water Quality's Stormwater Permitting Unit (SPU) acknowledges receipt of your renewal application for coverage under NPDES Permit Number NCS000040 on July 7, 2004. We apologize for the lengthy delay in responding to your submittal and are now making every effort to review your permit renewal as expeditiously as possible. Our Unit anticipates making significant progress on individual permits over the next six months to reduce our backlog. We are currently beginning our review of your renewal application. Please continue to comply with all conditions and monitoring requirements in your expired NPDES stormwater permit. As long as you have submitted a complete renewal request package and maintain compliance with those permit conditions, stormwater discharges from this facility are authorized by that permit until the Division issues a renewal permit or notifies you of an alternative action. No additional information is required at this time, but we may contact you in the future. Please notify us if any significant changes have taken place at this facility since you submitted the renewal package. If you have any questions about this matter, please contact me at (919) 807-6368, brian.lowther@ncmail.net. Sincerely, Brian Lowther Environmental Engineer Stormwater Permitting Unit cc: Mooresville Regional Office eStormwater-Peimifting--Unit-Fifes Central Files Wetlands and Stormwater Branch One t, 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 1 1� rv QPt11Cc`trOhlla Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 q// Phone: 919-807-6300 \ FAX 919-807-6494 \ Customer Service: 1-877-623-6748 Naturally Internet: www.ncwaterquallty.org ll�� / An Equal Opportunity \ Affirmative Action Employer Lasmigona decorata 3 http: //nhpweb.enr.state.nc.us/nhis/partner/fortns/eo/eo_py_eo_info.phtml?gid=3792&cmd=Up... i Element Occurrence Information Element Occurrence ID 7236 Scientific Name Lasmigona decorata I Element Occurrence 3 Number Common Name Carolina Heelsplitter Most Recent Survey 1987 Date Date First Observed 1880-PRE Date Last Observed 1880-PRE Element Occurrence X - Extirpated Rank Directions CTB/Irwin Creek P: The site is located in central Mecklenburg County and consists of Irwin Creek from its source to its confluence with Taggart Creek. . Element Occurrence This was the location of a syntype of L. decorata. Nine specimens are deposited in the Academy of Natural Data Sciences at Philadelphia. Habitat Description Small Piedmont stream whose headwaters are located in the western part of Charlotte, NC. Owner Name and Comments Protection Comments - Management Comments Additional Comments 1 of 1 3/25/2009 10:16 AM Laura, Thanks for following up on this and talking with us on the phone this morning. After our last phone conversation Ken and I were asked to talk with Bradley Bennett to discuss the site and the possibility of delaying the permit. We have talked with Bradley and informed him of the permittees concerns and of the issues with the site and the permit. Bradley understood it was a difficult site given the location and recommended contacting Charlotte/Mecklenburg County for more information, which we have done. Bradley noted that we can be somewhat flexible with time and parameters; however he noted we could not raise the benchmarks. He said that we would not delay the permit itself but could do a minor modification of the monitoring schedule without going through the public notice and public comment period. We understand this is a difficult site given the site location, land constraints and probable upstream pollutant contributions. However, we want to protect the water quality as much as possible and strive to reach a balance between these with our permit. We understand our current permit is not favorable to the permittee because they will probably be over some of the benchmarks. We hope to work with the permittee in a cooperative r+e� no f * mode in order to address benchmark exceedances to the extent realistically feasible. We do encourage collecting samples to identify the magnitude of offsite contributions. We feel that aethe current permit gives time for this sampling to occur before more sampling is required, potentially in excess of 12 months, depending on the timing of sampling events. There is some trust required from the permittee that the state will work with the permittee in order to address the exceedances of the benchmarks. We feel the permit sets up viable options in this case which include but are not limited to: • require that the permittee increase or decrease the monitoring frequency for the remainder of the permit; • require the permittee to install structural stormwater controls; • require the permittee to implement other stormwater control measures ;`or) Again though, we feel that the state will do its best to work with the permittee to balance protecting water quality and to work with the physical constraints of the site. DWQ will provide a written record of any agreements, modifications, conditions or amendments to the permit resulting from negotiation and interpretations of on -going data collection. Please let me know if you have any questions or comments. Brian Lowther e tit YWI ^ je 1't / Case 08-01789-8-ATS Doc 297 Filed 04/01/09 Entered 04/01/09 15:45:10 Page 52 of 83 Sellers to consummate the transactions contemplated by this Agreement or perform their obligations under this Agreement except, in each case, for any such effect resulting from any of the following: (A) any action by a Purchasers or any of its Affiliates or the omission of an action that was required to be taken by a Purchaser or any of its Affiliates, (B) any action taken by a Seller at the request or with the prior written consent of the Purchasers or (C) the commencement of the Chapter 11 Cases. (fl) "Ordinary Course of Business" means the ordinary and usual course of normal day to day operations of the Business consistent with past practice, which may include modifying operations to conserve cash flow to the extent approved in advance by the Purchasers. (gg) "Owned I\ llectua] Property" means all "Intellectual Property owned by a Seller, and used, or held for use, in connection with the operation of the Business. (hh) "Permits" means all environmental, construction and operation per waivers, clearances, exemptions, classificai\il schedules and other similar documents and aut Seller and used, or held for use, in connection ownership of the Purchased Assets or assumpti (ii) "Permitted Encumt easements, rights of way, restrictive a encumbrances or non -monetary impedime individually or in the aggregate, adversely the Leased Real Property and the Lumber aggregate, adversely affect the use or oa ifcations, licenses, pennits (including franchises, certificates, approvals, consents, ,pstrations, variances, orders, tariffs, rate tions issued by any Governmental Body to a he operation of the Business or applicable to the Assumed Liabilities. ces" means (i) Encumbrances for utilities, (ii) rants, encroachments and similar non -monetary against any of the Purchased Assets which do not, ;ct the operation of the Business and, in the case of Real Property which do not, individually or in the incy of such Leased Real Property or Lumberton Real Property as it relates to the operation of the Business or materially detract from the value of the Leased Real Property or Lumberton Real Property, (iii) applicable zoning Laws, building codes, land use restrictions and other similar restrictions imposed by Law, (iv) materialmans', mechanics', artisans', shippers', warehousemen or other similar common law or statutory liens incured in the Ordinary Course of Business, including the lien of Nalco Mobetee, hnc., if any, (v) ad valorem or property Taxis on the Purchased Assets, the Lumberton Real Property, the Leased Real Property, and the/Leasehold Improvements and (vi) such\other Encumbrances or title exceptions as the Purchasers may approve in writing in their sole discretion or which do not, individually or in the aggregate, adversely affect the operation of the Business. 0j) "Person" means an individual, corporation, partnership, limited liability company, joint venture,lassociation, trust, unincorporated organization, laborunion, estate, Governmental Body or otIher entity or group. i (kk) "Petition Date" means the date on which involuntary petitions were filed commencing the Sellers' Chapter 11 Cases. (11) "Prepetition Credit Facility" means that certain Credit Agreement, dated as of June 7, 2006, by and among Del Mar Onshore Partners, L.P., as agent, the lenders party LEGAL_US_E # 82611875.8 29 /t%$ ae do ¢O Pickle. Ken From: _ Waggoner, David [dwaggoner@charlottepipe.com] Sent: Friday, August 14, 2009 9:15 AM To: Pickle, Ken Cc: 'Laura Moody'; Lowther, Brian Subject: RE: Charlotte Pipe That is fine with me. Thanks, David From: Pickle, Ken [mailto:ken.pickle@ncdenr.gov] Sent: Friday, August 14, 2009 9:14 AM To: Waggoner, David Cc: 'Laura Moody'; Lowther, Brian Subject: RE: Charlotte Pipe David, At this stage I was thinking a phone call....... contrary perspective? Ken From: Waggoner, David [maiIto: dwaggoner@charlottepipe.com] Sent: Friday, August 14, 2009 8:56 AM To: Pickle, Ken Cc: 'Laura Moody'; Lowther, Brian Subject: RE: Charlotte Pipe Ken that is fine. Will this be a conf call or actual meeting? Thanks, David From: Pickle, Ken [mailto:ken.pickle@ncdenr.gov] Sent: Friday, August 14, 2009 8:12 AM To: Pickle, Ken; Waggoner, David Cc: 'Laura Moody'; Lowther, Brian Subject: RE: Charlotte Pipe David, 2 2 452� i 939972 1531$r` Oh, no, not next Tuesday. I'm out all day. Wednesday looks better for me. Will you be available then? I agree with looking at preventing exposure first. In general, we like the idea of preventing stormwater contact as a more effective step than stormwater runoff treatment units. (This is the specific program goal of offering our permittees the No Exposure Exclusion from Permitting option.) Typically the specific site conditions determine what's feasible/effective, whether reducing exposure or providing treatment, or some combination. I hope on Wednesday we can discuss the options you identify, or at least a plan for identifying options that you consider feasible. Ultimately after our discussions bring us into agreement, we'd like to receive a written request to amend the permit. By NC rule, our ability to amend the permit as a 'minor modification' (as opposed to a 'major modification' which requires going through the public notice procedure again), is limited to modifying schedule and monitoring elements only. But I think we can accomplish what we need to with those tools. '}� N L WfSCMIi W S'S' �v. 1 a "a Netzler Design DATE: z r8 oq P.M.: acr 1,14101, Charlotte wNorth 2:rOB NO�ell�o8f- n BY: 1tL r 1 ioolVIoruehead quare Dr,Suite 530TO �aSt44a ar Caiolinas282o3�iS�a ao REVISED: 7/7/2009N,1#.�5.'.r,'.!ysBasinData'�'"`^FW Rational Method w/ Tc Calculated i-yr Basin 2 - Bioretention at Entrance Side Open Field = 0.48 Ac. Te = 24 Min I = 0.12 0.25'0.12'0.48 = 0.014 cfs Total C'I'A for 1-yr 24hr Release Check Time of Concentration: Pre Development m :o ir... ,"T�,rsi7YmeConcentrahoris„ 8 '�TXtahFloww` Total T _ 7.0 Minutes s(�UnaiiY'4arz Sk"�s TrAe=0.6xT. JITLAG= TlAG —4.2 Minutes 0.07 Hours Page 1 of 1 Ken From: Pickle, Ken Sent: Friday, August 14, 2009 7:38 AM To: 'Waggoner, David' Cc: 'Laura Moody'; Lowther, Brian Subject: RE: Charlotte Pipe David, OK, good. Brian and I will contact you Tuesday when he is back in the office. Moving forward? - Until Brian gets back Tuesday and we re-establish contact, it might be good preparation if you would: - look at the listed parameters in your permit; identify those with recurring exceedences likely due to pollutants originating on your site; identify feasible management actions that could be taken now - it may be that some on -site sources are readily identifiable; determine which of those feasible management actions provide the most bang for your buck. - be prepared to offer those actions up front as the basis for a revised permit also featuring delayed kick -in of the Tiered structure. Ken From: Waggoner, David[mailto:dwaggoner@charlottepipe.com] Sent: Thursday, August 13, 2009 8:45 AM To: Pickle, Ken Cc: 'Laura Moody' Subject; RE: Charlotte Pipe Ken, I like your idea. I think instead of installing treatment systems, because there isn't enough room, we would took at BMPs that would stop the TSS by slopping the storm water contact. This will take an evaluation on our part but I think it is cheaper to eliminate the source than to treat it forever. Your thoughts moving forward? Thanks, David From: Pickle, Ken [mailto:ken.pickle@ncdenr.gov] Sent: Wednesday, August 05, 2009 3:09 PM To: Justice, Max E. Cc: Waggoner, David; Bennett, Bradley; Lowther, Brian; Laura.Moody@erm.com Subject: RE: Charlotte Pipe Thanks, Max. I called for David to discuss his receptivity to this idea, but couldn't reach him. I understand he's out for a few days. Brian is also out until next week. I wanted to respond to you right away, so here's one idea: ONE OPTION: We recently had a permit renewal where we offered the permittee a 2-year delayed kick -in of the Tiered approach in exchange for the up -front JOB NO.: 08-044 BY: nrr 1+tooi'Morehead,SquareDr,Suite53o''i "ID/ DATE. 2181091 P.M.: xr,•r : §i, Chailotte, North;Carohnal28zo tF...r:,,a_.4 hi REVISED: 51141091 Curve Number: ostDeve[oped� ON ffSasin+#2`Piped CoverT e; s1 k Kos # 3/IIRWIN real.1% ?a' %5L%J t'• CNi,aWtdWN.-P Landscaping / Grass Soil C 98561 0.39 74 28.90 Walks, Roof, Pavement Soil C 15383 0.61 98 59.73 0.00 Total 25239 88.63 Composite CN 88.83 11 0.58 Use CN = 88.6 Time of Concentration: Post -Development Tc=S Min for Post Page 1 of 1 installation of a BMP. In that case the site circumstances identified TSS as the parameter to be managed better, and the BMP approach was almost self-evident in that they had available land, and the presumed stormwater treatment scheme was likely to work well for TSS removal. Brian was the permit writer for that permit, as well. The Charlotte Pipe site may be a little more complicated, but a somewhat similar approach might be agreeable as part of an overall approach for them. If so, we could re -issue the permit with a minor mod to the monitoring program, presuming we could agree on a similar kind of trade: CP&F agreement to up -front stormwater treatment with the installation of a BMP; in exchange for a delayed triggering of the Tiered approach. In the previous case, the permittee still took the samples as per the schedule in the permit, we just wrote the permit to allow her time to design, install, and test out the operation of her up -front BMP installation before the benchmark -Tiered response connection was activated. That permittee sounded quite relieved to incur the nominally small expense for a stormwater BMP in exchange for the time to develop and install it at no risk of regulatory action, and for the delay in their responsibilities under the Tiered system (of course, they and we both have the expectation that the BMP will be effective in reducing stormwater TSS discharges.) Our perspective on the previous permit was that we accelerated the installation of a BMP that likely would have been installed anyway sometime after the fourth exceedence. That's good for our mission. On the other hand, the permittee's plant environmental manager had fears similar to David's about explaining 'exceedences' up the corporate ladder, and so she was amenable to the permit as re -written; and again, it's likely she would have had to install a BMP after the fourth exceedence, anyway. Finally, I'd like to emphasize again a couple of points: a) We understand that Charlotte Pipe should not be held responsible for stormwater pollutants originating off -site; but they are responsible for pollutants from their site. We'll work with Charlotte Pipe in accordance with this understanding, and with the understanding that, at least at the beginning, it's unclear what is coming from off site. b) While DWQ wants all our permittees to respond to benchmark exceedences with effective management, we acknowledge that feasible management actions may be limited at some sites, including Charlotte Pipe. Our specific intent in instituting the new permit template in 2007 (approx 2500 general permittees, and 100 individual permittees now covered under that template), was to deliberately construct the Tiered program language so that DWQ would have the latitude to make the rational decisions as to feasible mangement actions and monitoring programs at sites where benchmark exceedences seem intractable. Ken From: Duplissey, Vickie D.[mailto:vickieduplissey@parkerpoe.com] On Behalf Of Justice, Max E. Sent: Wednesday, August 05, 2009 11:22 AM To: Pickle, Ken Cc: David, Waggoner,; Bennett, Bradley; Lowther, Brian; Laura.Moody@erm.com Subject: RE: Charlotte Pipe Ken, Thanks for what you are doing. What kind of modification to the monitoring requirements are you thinking about? Regards, Max r- en all WIy+� y •RA0No8-oqq BY ncl h+tootMorchead Squae Dysrute 53oz r8 o P W REI6 sChaHotte, NorthlCnmhna 282031�'S kt ` REVISED: 71 09iMu""i.'i3'1a�'.1'rBtOx�RCIC/1tiO1tBIVIPrd"1..dAad WATER OUALITYREOUIREMENTSFOR BASIN #2 Drainage basin data Drainage area to pond (Da)= 0.58 ac Post -development impervious percentage = 61 Hydrologic Input Data Acres CN Tc Pre -Developed: 0.48 74.0 7.0 Post -Developed (P): 0.58 88.6 5.0 Preliminary SCS Modelino Calculations Q-lin Q-1 yr Q70-yr Pre -Developed: - 0.47 0.78 Post -Developed (P): 0.63 1.72 3.55 Post -Developed (S): Minimal Flow Rolled into Piped Category WQv Calculation Using the runoff volume calculations in the "Simple Method": Rv = 0.05 + .009 (1) Rv= 0.60 in/in WQv = (Design rainfall) (Rv) (Drainage Area) WQv = 1" rainfall x Rv intin x 1112 infft x Da = WQv= 0.029 ac-ft WQv= 0.60 in Release Rate Calculations for "yi For Standard Efflcieny use 1.0 days, 2' depth to obtain 85%TSS, 60%TP Q(WQv)= WQv(ac-R) ' 43,560 /(24hr+3hr) ' 3,600sec for 1.0 day hold. Q(WQv): 0.013 cfs Surface area requirements Initial Calculation for 12' pending depth Maximum At-- 1259 sqft WQv'43,560/IIt Surface`Area.Calculationst r`� ,*I"f k !Permeability coefficient=_ Df.... __ IFilter bed depth ft) _ l i.___ P 2 ..- Hf . _!_—.__—_. _ IAverage height of water (in) = _ 6 _ Tf fI IFilter bed drain time (days) = 1.125 At Required Surface Area (sft) = 1,259 aft V 112" Storage Volume = 1 1,259 eft Minimum Surface Area Required= 1259 sqft Maximum Surface Area Required= 1679 In or Surface Area Prorvided= 1634.0 ftr 1" Treatment Volume= 1259 ft' 1" Treatment Height= 0.77 It or Full Tem era Pool Water Surface= 656.27 msl 1,259 cft Sta-wMecharue'tllrulMedlaU Surface Q Area cfs cfs cfs cfs 3M16341„ 0.25 0.005 1634 0.50 0.006 1634 0.75 0,007 1634 1.00 0.007 4j634P.z Qo(cfs) = (SA ' 0.50ft/day ' (h+d)/d) 124 ' 3600 9.25 In From: Pickle, Ken [mailto:ken.pickle@ncdenr.govj Sent: Wednesday, August 05, 2009 10:21 AM To: Lowther, Brian; Laura. Moody@erm.com Cc: David, Waggoner,; Justice, Max E.; Bennett, Bradley Subject: RE: Charlotte Pipe Hi Laura, I have just a bit of commentary to add to our email yesterday. We tried to go to some lengths to emphasize our flexibility in working with Charlotte Pipe, including a minor modification to the permit monitoring requirements. The specifics are lacking, because those need to be worked out together. We are motivated by an interest in pre-empting Max's filing with the CA11. We understand that petitioners may feel the need to preserve their rights by filing for a hearing. And Charlotte Pipe certainly has that right, as they should. Is there anything else from us that would allow Charlotte Pipe to stay with us in the engineering and regulatory world, rather than the legal world? Ken From: Lowther, Brian Sent: Tuesday, August 04, 2009 1:10 PM To: Laura.Moody@erm.com Cc: Pickle, Ken; David, Waggoner,; maxjustice@parkerpoe.com Subject: RE: Charlotte Pipe Laura, Thanks for following up on this and talking with us on the phone yesterday. In our last phone conversation Ken and I were asked to talk with Bradley Bennett to discuss the site and the possibility of delaying the permit. We have talked with Bradley and informed him that the permittee is concerned about continuing benchmark exceedences, and the possibility that stormwater pollutant discharges may never be completely below benchmark values, and of the issues with the site and the permit. Bradley understood it was a difficult site given the location and recommended that we contact Charlotte/Mecklenburg County stormwater staff for more information, which we have done. Bradley noted that we can be somewhat flexible with time and parameters; however he noted we could not raise the benchmarks. He said that we would not delay the permit itself but could do a minor modification of the monitoring schedule without going through the public notice and public comment period. We understand this is a difficult site given the site location, land constraints, and probable upstream pollutant contributions. However, we want to protect the water quality as much as possible and strive to reach a balance between these with our permit. We understand our current permit is not favorable to the permittee because they will probably be over some of the benchmarks. We want to reiterate that a benchmark exceedence is not a permit violation. An exceedence is intended to just trigger additional stormwater management action by the permittee. We hope to work with the permittee in a cooperative mode in order to address any benchmark exceedences to the extent realistically feasible. We do encourage your current plan to collect additional samples to identify the magnitude of offsite contributions. We feel that the current permit gives time for this sampling to occur before more sampling is required, potentially in excess of 12 months, depending on the timing of sampling events. There is some trust required from the permittee that the state will take into account the feasibility of potential stormwater management actions as the permittee addresses any exceedences of the benchmarks. We acknowledge that offsite contributions, A'�T P lleni sI,�,�'r4 ISP W, T u31, JOB NO.: 08-044 BY: Rr r r n#k tooMoreheerSq re�'Di^�Sulle 83a AW 5' ! i twPm •M�' uM '.uv e tMY Ww DATE z is og P.M.: Rr r t;+4, �.nls _ a1kdCharlotte NorthCarolmn z82o REVISED: 7 r o9 t'+!+aK+�'".�,">'2raa'`�sB1o=R('teTtLlOn�BMP-':#+sk��,' 00%Gt$cieneu Calculation Increase of 15%-20% of Surface Area to Gain Additional Efficiency Af= 1634 sgft Design Surface Area % Eft-- 29.80 % Underdrain Design Calcs Average Drawdown Thru Media Drawdown= 0.006 cfs Design Rate= 0.061 cfs Single Pipe Calculation D= 0.492 In Per Table 5- Underdrain Requirement for Subject Bioretension 4" Die Underdrain 2 Min Number Qo(cfs) _ (SA ' 0.50R/day ' (h+d)/d) / 24 ' 3600 Q design = 10 ' Do D = ((16'Q'n)/s^0.5)^3/8 lirnited available land, and other site constraints may very well limit Charlotte Pipe's feasible stormwater management options. We feel the permit already indicates that DWQ intends to work with difficult sites in that it sets up viable options where benchmark exceedences continue; the options already identified in the permit include, but are not limited to: require that the permittee increase or decrease the monitoring frequency for the remainder of the permit; require the permittee to install structural stormwater controls; or require the permittee to implement other stormwater control measures; Again though, we feel that the state will do its best to work with the permittee to balance protecting water quality and to work within the physical constraints of the site. DWQ will provide a written record of any agreements, modifications, conditions, or amendments to the permit resulting from negotiation, limitations of feasibility considerations, and interpretations of on -going data collection. Please let me know if you have any questions or comments. Brian Lowther From: Laura Moody [mailto: Laura. Moody@erm.com] Sent: Monday, August 03, 2009 10:38 AM To: Pickle, Ken Subject: Charlotte Pipe Ken - Hope you had a great weekend and you have recovered from having the grandkids there! Have you had an opportunity to talk with Bradley in regards to the stormwater permit options for Charlotte Pipe? Thanks, Laura Laura Rohe Moody ERM NC, PC 8000 Corporate Center Drive Su i to 200 Charlotte, NC 28226 Phone: 704-541-8345 Fax: 704-541-84-16 This electronic mail message may contain information which is (a) LEGALLY PRIVILEGED, PROPRIETARY IN NATURE, OR OTHERWISE PROTECTED BY LAW FROM DISCLOSURE, and (b) intended only for the use of the Addressee (s) names herein. If you are not the Addressee Is), or the person responsible for delivering this to the Addressee (s), you are hereby notified that reading, copying, or distributing this message is prohibited. If you have received this electronic mail message in error, please contact us immediately at (704) 541-8345 and take the steps necessary to delete the message completely from your computer system. Thank you, ERM NC, PC. This electronic mail message may contain information which is (a) LEGALLY PRIVILEGED, PROPRIETARY IN NATURE, OR OTHERWISE PROTECTED BY LAW FROM DISCLOSURE, and (b) intended only for the use of the Addressee (s) names herein. If you are not the Addressee (s), or the person responsible for delivering this to the Addressee (s), you are hereby notified that reading, copying, or distributing this message is prohibited. If you have received this electronic mail message in error, please contact us immediately at our Atlanta office (770) 590-8383 and take the steps necessary to delete the message completely from your computer system. Thank you, Environmental Resources Management. IRS CIRCULAR 230 NOTICE: To ensure compliance with requirements imposed by the IRS, we inform you that any U.S, federal tax advice contained in this communication (or in any attachment) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (it) promoting, marketing or recommending to another party any transaction or matter addressed in this communication (or in any attachment). PRIVILEGED AND CONFIDENTIAL: This electronic message and any attachments are confidential property of the sender. The information is intended only for Hydraflow Table of Contents Hydraflow Hydrographs by Intelisolve v9.02 RG20neYrBWC.gpw Monday, Jul 6, 2009 Hydrograph Return Period Recap................................................................... 1 10 - Year HydrographReports........................................................................................................ 2 Hydrograph No. 1, SCS Runoff, Post#2....................................................................... 2 Hydrograph No..3, Reservoir, Bioretention#2................................................................ 3 PondReport - Bioretention2...................................................................................... 4 OFReport ......................................................................................................... 5 Material Safety Data Sheet U.S. Department.of Labor May be LAW to Comply lvith OSHA's Hazard Communlaalian Steedard, Occupwonal Safety ied Health Administration 29 CFR 19M1200. $landard must be (Non-Menda,ory Farm) consulted for spocilic rtpulromonls. Form A pprovad OMR No. 1210-0079 IDENTITY(AS UmdMleber uep CA$No. 1 65996-77-2 Y.N,&.Aapetvs ero nd pdrrY((ed,hyty hem4mrepp'ceAb,an. et yr Sa Coke arm ma ko d aswbNe, vw apaoo mull 6o mertev, Io so m Mat. $acllon 1 snare,. name ARC Coke alyision. erunu..nd Co., Inc, Em.,g.�..y Telopborro number (205) 849-1330 Adaross ((antlrv, Sb.el. C.y, sraro, aN SM CohI Alabama 800 523-a661 Other 60 ToNptwna NurtWal Iw e,rmmallat &.o. 8ax' nota9 me A9 n DAN P,Opared All.-i-Sh-Bb Ala 35212 2/7/e5 99newr. m Naps,. F7p ,,.f eocuon N — Hazardous In$Tedlentsildentlty, Intannatlon HazvdWa Ca,aironwee (Sp.dra Clronrcal Ide0sM Oanlmn N ma(s)) OSHA PEI- ACpH TLVRec.,r tl e,oMud %fwo Carbon N/A N/A N/A 93 - 94 Aar, Sentlon III - PhyslcattChamloal CRarlaClads[IO.a Bell, Pam N/A .Spoofp eta vdy lHlA-11 1.92 Vepw Preewry (nen Hp) ----j MoLLlrp Pdm N/A I N/A VNv penally (MR • 1) - Evapwall.n Palu Sdub1AM'IAW®m N/A (p ACMa1. I N/A NTT, - AHq ur10 Odor arcattillar dark gray lamps. No djsrfngqjpjIj,g d SedNprs IV — rue and:@xploslon Hazard Data _ . water SpoGm Pea fWallrq proc.Cums .. Ur.,neFgk .,k kapi000-Heavy (Reproduce bwllyj - - OSHA 174, Sept. I= MATERIAL SAFETY DATA SHEETS Date Prepared: 5-9-03 1. CIIEMICAL PRODUCT AND COMPANY IDENTIFICATION Product Name: Metallurgical Coke CAS No. 65996-77-2 MANUFACTURER A13C Coke Division, Drummond Co., Inc. P.O. Box 10246 Birmingham, AL 35202 General Information: (205) 849-1342 EMERGENCY TELFPHONF NUMBERS ABC Coke: (205) 849-1330 Alabama: (800) 523-8661 Other: (800) 321-4015 2. COMPOSITION/INFORMATION ON INGREDIENTS OSI to PEI- Carbon N/A - ACGIH'HN N/A % 90-95 Ash N/A N/A 5-9 Sulfur N/A N/A 0.5-1.0 3. IIAZARDS INDENTIFICATION Immediate Contents: Not classified as a hazardous substance under fire, spill, leak conditions. Carbon monoxide may evolve during combustions. Potential health Effects: This product may be irritating to the skin; eyes, and respiratory and gastrointestinal tract. Inhalation of dusts may lead to irreversible lung disease and/or cancer. 4. FIRST AID MEASURES Eyer: Plush with water for at least 15 minutes. If irritation -occurs and persists, obtain medical attention. S'kitr: Wash with plenty of soap and water. Get medical attention if irritation occurs and persists. Page I of 5 Ingestion: Drink plenty of water. Never give anything by mouth to an unconscious person. If any discomfort persists, obtain medical attention. Inhalation: Remove to fresh air. If breathing difficulty or discomfort occurs and persists, obtain medical attention. 5. rIRE FIGHTING MEASURSES Plash Point 1,000 deg. I-'LI'L N/A UEL N/A Extinguish Media Water Special Fire Fighting Procedures None Unusual Fire and explosion Hazards None Known G. ACCIDENTAL RELEASE MEASURES Avoid breathing dust. Sweep up material and dispose of using the procedure under water disposal method. 7. HANDLING AND STORAGE Waste Disposal Mcthod: Generally landfilling, but must comply with federal, state, and local regulations. Precautions to be Taken in Handling and Storing_ Use respiratory protection if generation of airborne dust is anticipated Other Precautions: None known S. EXPOSURE CONTROLS / PERSONAL PROTECTION Respiratory Protection Protective Gloves Other protective Clothing or Equipment Work/Hygienic Practices Local cxhauq Ventilation Yes. irexecnivo dust Page 2 of 5 Approved dust respirator Abrasive resistant N/A NIA Mechanical Spcoinl 01hcr NIA N/A NIA 9. PHYSICAL AND CHEMICAL. PROPERTIES Boiling Point Freezing Point Vapor Pressure (man Hg) Vapor Density (AIR = 1) Solubility in Water Specific Gravity (H20 = 1) Melting Point Evaporation Ratc Odor Appearance Ph N/A N/A N/A N/A 0 1.92 N/A N/A None Irregular dark gray Imnps N/A 10. STA B ILITY AND REACTIVITY Stability Conditions to Avoid Incompatibility 1lazuird Decomposition Products Idazardous Polymerization Stable None Known None Known Carbon Monoxide may evolve during combustion. Will not occur ILTOXICOLOGICAL INFORMATION Eye Effects: No data available for the product, Skin effects: No data available for the product. Derma! LD50: No data available for the product. Ora( LD50: No data available for the product. Inhalation LC50: No data available for the product. Acute effects from overexposure: No data available for the product. This product may be irritating to the skin, eyes, respiratory and gastrointestinal tract. Chronic effects from overexposure: No data available for the product, 12.ECOLOGICAL INFORMATION FcotoxicoloEical hJormation: No data available for the product. This product is composed primarily of fixed carbon, and as, which arc anticipated to readily dissipate Page 3of� upon release to the environment. Leachate from this product may contain various heavy metals. Chemical fate -information: No data available for the product. Al high concentrations, this product may affect the turbidity, BOD, COD, and suspended solid concentration of aquatic systems. _ 13.DISPOSAI, CONSIDERATION Waste Disposal Method: Generally landfilling, but must comply with federal, state, and local regulations. 14.TRANSPORT INFORMATION U.S. DOT (Department of Transportation) Proper Shipping Name: Not regulated Primary Hazard Class/Division: Not applicable UN/NA Number: None Placards: None Label: Not applicable Other Shipping Information: DOT MARKING: Coke HAZARDOUS SUBSTANCE/RQ: Not applicable 49 STCC Number: None Special Shipping Notes: IMDCI: Not regulated rATA: Not regulated 15.RLGULATORY INFORMATION All uomponcrim arc in compliance with the following inventories: U.S. TSCA, 171) EINICS, Canadian DSL, Australian AICS, Korean, Philippine PICCS, Chinese Canadian WIAWS classification: Not Controlled Page 4 of 5 SARA Hazard Notification: Hazard Categories Under Title III Rules (40 CFR 370): Not applicable Section 302 Extremely Hazardous Substances: Section 313 Toxic Chemicals: CERCI.A Reportable Quantity: Not applicable 16. OTHER INFORMATION HMIS RATING: NFPA RATING: Health 0 Ilealth 0 Flammability 0 Flammability 0 Reactivity 0 Reactivity 0 Protection F Special None Key: 4 = Severe 3 = Serious 2 — Moderate I = Slight 0 = Minimal I[MIS RATINGS NOTES: Health = 0 (chronic effects), Protection = F (Safety glasses, gloves, apron, dust respirator) While the information contained in this Material Safety Data Sheet (MSDS) is based on technical data, which ABC Coke believes to be correct, it is nevertheless intended for use by persons possessing technical skill and at their own discretion and risk. Since the conditions of use are beyond the control of ABC Coke, no warranty, expressed or implied, is made, and no liability in connection with any use of this information is assumed. Page 5 ol'5 A Pickle; Ken From: Pickle, Ken Sent: Wednesday, May 13, 2009 11:11 AM To: 'Laura Moody' Cc: Jones, Jennifer M. Subject: RE: Charlotte Pipe Hi Laura, a) SHORT ANSWER: At this time, for this facility, my sense is that a 100sf coke pile would be considered as an incidental/insignificant issue as far as stormwater runoff from the whole site. At this time, my guess is that the presence of this uncovered bunker would not preclude sw permit coverage, nor would it result in any special permit conditions. b) LONG ANSWER: I've added the qualifiers, "at this time" above because we are currently considering several related issues as our program evolves. 1 really can't reliably predict where the stormwater program may be in a year with these related issues. The attention occasioned by the catastrophic ash pond spill in Tennesse (TVA) has resulted in direction to the DWQ to be sure that NC is doing what we should wrt wastewater, surface water, and groundwater. Even though that disaster was basically a civil engineering failure, the results were, in part, environmental. Within DWQ we have a live issue now as we re-examine our regulatory programs status concerning ash ponds at coal-fired power plants. Because we suspect that a key element in environmental impact is the presence of leachable heavy metals, our re-examination is spreading to consider not just ash ponds at coal-fired power plants, but also other facilities with coal piles, and coal ash (like Frito-Lay off Westinghouse in Charlotte.) In stormwater we are beginning to require monitoring for a lengthy suite of heavy metals (" 10 to 20 metals) in stormwater discharges from some of these facilities. For the stormwater unit, a complicating factor is the established precedent within DWQ to address coal pile runoff at power plants as wastewater. I think we have had only a small number of coal piles NOT at power plants. In the past we have addressed some of those flows as stormwater discharges. We are re-evaluating that strategy now. Intuitively, I don't see much difference between the heavy metals pollution potential from coal, coal ash, OR C01<E. It seems to me that the coking process might drive off some fraction of the potential for organic pollutants, but I would expect almost all of the metals to remain in the coke (possibly excepting Hg?) I note that the MSDS you sent to me reports that leachable heavy metals may be present in the coke. For this new facility these two issues operate to make me think it's not an issue now for Charlotte Pipe: - the relatively small size of the overflow bin compared to the large plant site and contributing drainage area. The KEY ELEMENT in my opinion. - the not yet fully settled nature of DWQ's posture on coal ash ponds and how that posture might expand to cover a small coke bin. the fact that the site scheme we looked at together last year included ponds providing substantial settling provisions. We're uncertain what BMPs might find application in runoff for metals removal. Bioretention or sand filtration might be able to strain out metals associated with particulates. Any sort of media BMP (sand filtration or bioretention or proprietary devices) might be able to sorb some fraction of dissolved metals. Our experience with these types of pollutants is very limited. That argues that we will be very cautious in the permitting of runoff with such potential pollutants. c) It's good to see that this project is still in development, given the current economic conditions. O Page 7 date: N o K Visible Sediment leaving the project right of way and into jurisdictional areas: INin the answer is YES, intlicate locations and Rainfall: No ❑ Yes amt. gs in Are there any signs of fuels, lubricants, coolants, or other contaminants corrective actions taken Evaluator: dischar ad on the ground or surface waters? 4/N below. nspe a eroswn and se<umern control.measures ,- Commens and ComecGve Actions:�- on projects that are one acre or greater atleast once every' Tcalenderdaysdis' least tvnce'every 7, UlenEar days for facilities dischargmg`t`o;303(d)�, listed wateis impeirad forturbidrty or sediment) antl (� ✓` �/ Date: `' Visible Sediment leaving the project right of way and into jurisdictional areas: N If the answer is YES, �S' t r2 In intlicate locations and Rainfall: No ❑ Y/ m Are there any signs of fuels, lubricants, coolants, or other conta 'nants wmective actions taken Evaluator G✓/ discharged on the round or surface waters? V7N below. Inspect ali erosion and sediment control measures Ca"n'ants and Cortecwe Acuans: — AL - Date: - D c Visible Sediment leaving the project right of way and into jurisdictionaldM� areas , If the answer is YES, indicate locations and Rainfall: No []Ye ❑amt. in Are there any signs of fuels, lubricants, coolants, or other contamirants corrective actions taken Evaluator: -C discharged on the ground or surface waters- -- i� below. MLr:1L Comments and Corrective Actions: ,Inspect all eroswn and sediment control measures on prolecLk that are one acre o[ greater;at leasl'r C rC_ Date: - 2 8-O$ G f/ Vsible Sediment leaving the project right of way and into jurisdictional areas: /N_ he answer is VES, ry indicate locations and Rainfall: No ElYe CJafTlt.;ln Are there any signs of fuels, lubricants, coolants, or other contaminants wnective actions taken Evaluator - L r%r . discharged on the ground or surface waters */N below. tl- 'y Comments antl Comedive AUi_on.: Inspect all erosion and sediment Contra measures :f nmiects t at ate one acre or. greater at least I; �/,.,�,'� / Date: 9- N-O Visible Sediment leaving the project right of way and into jurisdictional areas: N/N ✓ If the answer is VES, B' indicate locations and Rainfall: No des ❑arflt. In Are there any signs of fuels, lubricants, coolants, or other contaminants corrective actions taken !— Evaluator: �F.. dischar ed on the round or surface waters? °PIN below. O -w T: Comments ono Comectiva Actions: Inspect all erosion ana sediment control measures r/n d) I recall that this project is confidential, but I've copied Jennifer here because she is dealing with Frito Lay (referenced above), and because she is leading the re-evaluation effort in our Unit on coal piles and ash ponds. I hope Dave's job is still good, given the state of the building industry. All ok there? 1 spoke at length with Rick the other day, it's always good to hear from him. Pesonally, we're all good, too. Erin has delivered grandchild #3, Carolina Laurel Neese. Emily has started keeping bees at her house. Kenny is finishing his first year in law school. Sharon is looking forward to the end of the school year. I hope she makes it. Work is still good for me. Ken From: Laura Moody [mailto:Laura.Moody@erm.com] Sent: Tuesday, May 12, 2009 9:40 AM To: Ken Pickle Subject: Charlotte Pipe Ken - I hope all is well on your end. We are good. The kids are on a count down until school gets out. I have a question concerning the new facility at Charlotte Pipe. They would like to design a 100 sq ft overflow coke storage bunker. It would be fed by dump truck, so they would like to have it uncovered. Would this be allowable for stormwater reasons? I have attached the MSDS for the material. Thanks, Laura Laura Rohe Moody ERM NC, PC 8000 Corporate Center Drive Suite 200 Charlotte, NC 2822E Phone:704-541-8345 Fax:704-541-8416 This electronic mail message may contain information which is (a) LEGALLY PRIVILEGED, PROPRIETARY IN NATURE, OR OTHERWISE PROTECTED BY LAW FROM DISCLOSURE, and (b) intended only for the use of the Addressee (a) names herein. If you are not the Addressee (a), or the person responsible for delivering this to the Addressee (a), you are hereby notified that reading, copying, or distributing this message is prohibited. If you have received this electronic mail message in error, please contact us immediately at (704) 541-8345 and take the steps necessary to delete the message completely from your computer system. Thank you, ERM NC, PC. This electronic mail message may contain information which is (a) LEGALLY PRIVILEGED, PROPRIETARY IN NATURE, OR OTHERWISE PROTECTED BY LAW FROM DISCLOSURE, and (b) intended only for the use of the Addressee (s) names herein. If you are not the Addressee (s), or the person responsible for delivering this to the Addressee (s), you are hereby notified that reading, copying, or distributing this message is prohibited. If you have received this electronic mail message in error, please contact us immediately at our Atlanta office (770) 590-8383 and take the steps necessary to delete the message completely from your computer system. Thank you, Environmental Resources Management. t Page& �' _ If the answer is YES, indicate locations and Rainfall: No ❑ Yes D Date: �7 — d `O Zi Visible Sediment leaving the project right of way and into jurisdictional areas: Y7N� r�r� arnt:- Z—in Are there any signs of fuels, lubricants, coolants, or other contaminants corrective actions taken i Evaluator: discharged on the ground or surface waters? YIN :✓ below. Inspect all erosion and sediment control measures Comments and Corrective Actions: r'+ on profectsthat are one acre or greater at east / ..ro n,mv 9'� Inndm dove lm lmaJw�o uJav ]` To .O•/fn i s ^�^. C Date: i ' /7- o O Rainfall: No ❑ Yes 5rnt. r / in Visible Sediment leaving the project right of way and into ju sdictional areayt(/N i� If the answer is YES, indicate locations a nd corrective actions taken Are there any signs of fuels, lubricants, coolants, or other contaminants Evaluator: discharged on the ground or surface waters?dr/N below. ;Inspect all`erosion and sediment control measunis r ton projecle that are one acre or greater at least,, oInce eve 7 calendar da 'v iy,s. ys'(at least tnwece every 7y calendar days for facilities Eischargmg l0 303(d)R listed waters Impaired for turbidRy or sediment)and comments and corrective A tors ., v r-3 j vnthm 24 hours after any stone event of greater',' thaeOSlnch of ram per 24 hour period:" Date: --2S -(r-I� Visible Sediment leaving the project right of way and into Jurisdictional areas:6Y/N If the answer is YES, Rainfall: NoE2Ye LW .t. In indicate locations and Are there any signs of fuels, lubricants, coolants, or other contaminants corrective actions taken Evaluator: / y /� . discharged on the around or surface waters? */N'--� below. _. „, ....fin _iia...... w....w:me... �,..e�'...�.::... .:-2 Commend end Corrective Actions: /7_ .. .4— ✓ Date: '7 % %'Ct (( Visible Sediment leaving the project right of way and into jurisdictional areas: y/N/t/ H the answer is YES, indicate locations and Rainfall: No ❑ Yes rmr t. • In Are there any signs of fuels, lubricants, coolants, or other contaminants corzective actions taken Evaluator: //�i" 4 _ discharaed on the around or surface waters?�%Ni+ ' below. Date: - —Oc Visible Sediment leaving the project right of way and into jurisdictional areas: /Njl If the answer is YES, Rainfal:No❑ Ye ndicatelocationsaM /�j t in Are there any signs of fuels, lubricants, coolants, or other contaminants corrective actions taken EValuator, (�/P. disrhnrnpd nn the nrnund nr surface waters? g/N /ram below. C State of North Carolina Department of Environment and Natural Resources Division of Water Quality Michael F. Easley, Governor William G. Ross Jr., Secretary Alan W. Klimek, P.E., Director May 3, 2004 CI IARLOTTE PIPE & FOUNDRY CO ATTN:BILL WIEBKING, OR SUCCESSOR PO BOX 35430 CHARLOTTE, NC 28235 1 NCDENR NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES Subject: NPDES Stormwater Permit Renewal Charlotte Pipe & Foundry Co Permit Number NCS000040 Mecklenburg County Dear Permittee: Your facility is currently covered for stormwater discharge under NPDES Permit NCS000040. This permit expires on December 31, 2004. North Carolina Administrative Code (15A NCAC 2H.0105(e)) requires that an application for permit renewal be. filed at least 180 days prior to expiration of the current permit. In order to assure your continued coverage under your permit, you must apply to the Division of Water Quality (DWQ) for renewal of your permit. To make this renewal process easier, we are informing you in advance that your permit will be expiring. Enclosed you will find an individual permit renewal application form, supplemental information request, and Stormwater Pollution Prevention Plan certification. Filing the application form along with the requested supplimental information will constitute your application for renewal of your permit. As stated above, the application form must be completed and returned along with all requested information by July 9, 2004 in order for the permit to be renewed by December 31, 2004. Failure to request renewal by July 9, 2004 may result in a civil assessment of at least $500.00. Larger penalties may be assessed depending on the delinquency of the request. Discharge of stormwater from your facility without coverage under a valid stormwater NPDES permit would constitute a violation of NCGS 143-215.1 and could result in assessments of civil penalties of up to $25,000 per day. If you have any questions regarding the permit renewal procedures please contact Bill Mills of the Stormwater and General Permits Unit at (919) 733-5083, ext. 548. Sincerely, Bradley Bennett, Supervisor Stormwater and General Permits Unit cc: Central Files Stormwater and General Permits Unit Files Mooresville Regional Office 1617 Mail service Center, Raleigh, North Carolina 27699-1617 Telephone 919-733-5083 Fax 919-733-9919 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10 % post -consumer paper _State of North Carolina Department of Environment and Natural Resources Division of Water Quality James B. Hunt, Jr., Governor Bill Holman, Secretary Kerr T. Stevens, Director December 3, 1999 Mr. Bill Wiebking Charlotte Pipe and Foundry P.O. Box 35430 Charlotte, North Carolina 28253 �f NCDENR NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES Subject: Permit No. NCS000040 Charlotte Pipe and Foundry Mecklenburg County Dear Mr. Wiebking: In response to your renewal application for continued coverage under NPDES stormwater permit NCS000040, the Division of Water Quality (DWQ) is forwarding herewith the subject state - NPDES permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215 .1 and the Memorandum of Agreement between North Carolina and the US Environmental Protection agency dated December 6, 1983. A condition of your permit is to evaluate sources of stormwater pollution. It is expected that this is an ongoing activity. The Division has received comments on the draft permit from the Mecklenburg County Department of Environmental Protection (MCDEP) concerning elevated levels of metals in your stormwater discharge. We also understand that MCDEP has requested that you evaluate the site to determine and eliminate the source of these pollutants and that your staff is working with MCDEP to accomplish this task. In their draft permit comments, MCDEP requested that several metals be added to your permit, however at this time the Division will defer that decision and encourage your facility to continue working with MCDEP to identify and eliminate the pollutant source. The Division requests that the Stormwater and General Permits Unit staff be periodically updated on your efforts to identify and eliminate these pollutant sources. If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of this letter. This request must be in the form of a written petition, conforming to Chapter I50B of the North Carolina General Statutes, and filed with the Office of Administrative Hearings, Post Office Drawer 27447, Raleigh, North Carolina 27611 -7447. Unless such demand is made, this decision shall be final and binding. Please take notice this permit is not transferable. Part III, B.2. addresses the requirements to be followed in case of change in ownership or control of this discharge. 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone 919-733-5083 FAX 919-733-9919 An Equal Opportunity Affirmative Action Employer 50 % recycled/ 10% post -consumer paper Page 2 This permit does not affect the legal requirements to obtain other permits which may be required by the Division of Environmental Management or permits required by the Division of Land Resources, Coastal Area Management Act or any other Federal or Local governmental permit that may be required. If you have any questions concerning this permit, please contact Darren England at telephone number 919/733-5083 ext. 545. Sincerely, I lam' for Kerr T. Stevens cc: Mr. Roger O. Pfaff, EPA Mooresville Regional Office Mr. Rusty Rozzelle, MCDEP Permit No. NCS000040 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY PERMIT TO DISCHARGE STORMWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Charlotte Pipe and Foundry Company is hereby authorized to discharge stormwater from a facility located at Charlotte Pipe and Foundry Company 1335 South Clarkson Street Charlotte Mecklenburg County to receiving waters designated as Irwin Creek, a class C stream, in the Catawba River Basin, in accordance with the discharge limitations, monitoring requirements, and other conditions set forth in Parts 1, II, III, IV, V and VI hereof. This permit shall become effective January 1, 2000. This permit and the authorization to discharge shall expire at midnight on December 31, 2004. Signed this day December 6, 1999. for Kerr T. Stevens, Director Division of Water Quality By the Authority of the Environmental Management Commission Permit No. NCS000040 TABLE OF CONTENTS PART I INTRODUCTION Section A: Individual Permit Coverage Section B: Permitted Activities Section C: Location Map PART II MONITORING, CONTROLS, AND LIMITATIONS FOR PERMITTED DISCHARGES Section A: Stormwater Pollution Prevention Plan Section B: Analytical Monitoring Requirements Section C: Qualitative Monitoring Requirements Section D: On -Site Vehicle Maintenance Monitoring Requirements PART III STANDARD CONDITIONS Section A: Compliance and Liability I. Compliance Schedule 2. Duty to Comply 3. Duty to Mitigate 4. Civil and Criminal Liability 5. Oil and Hazardous Substance Liability 6. Property Rights 7. Severability 8. Duty to Provide Information 9. Penalties for Tampering 10. Penalties for Falsification of Reports Section B: General Conditions 1. Individual Permit Expiration 2. Transfers 3. Signatory Requirements 4. Individual Permit Modification, Revocation and Reissuance, or Termination 5. Permit Actions Section C: Operation and Maintenance of Pollution Controls I. Proper Operation and Maintenance 2. Need to Halt or Reduce Not a Defense 3. Bypassing of Stormwater Control Facilities Section D: Monitoring and Records I. Representative Sampling 2. Recording Results 3. Flow Measurements 4. Test Procedures 5. Representative Outfall 6. Records Retention 7. Inspection and Entry Permit No. NCS000040 Section E: Reporting Requirements I. Discharge Monitoring Reports 2. Submitting Reports 3. Availability of Reports 4. Non-Stormwater Discharges 5. Planned Changes 6. Anticipated Noncompliance 7. Bypass 8. Twenty-four Hour Reporting 9. Other Noncompliance 10. Other Information PART IV LIMITATIONS REOPENER PART V ADMINISTERING AND COMPLIANCE MONITORING FEE REQUIREMENTS PART VI DEFINITIONS Permit No. NCS000040 PART I INTRODUCTION SECTION A: INDIVIDUAL PERMIT COVERAGE During the period beginning on the effective date of the permit and lasting until expiration, the permittee is authorized to discharge stormwater associated with industrial activity. Such discharges shall be controlled, limited and monitored as specified in this permit. SECTION B: PERMITTED ACTIVITIES Until this permit expires or is modified or revoked, the permittee is authorized to discharge stormwater to the surface waters of North Carolina or separate storm sewer system which has been :adequately treated and managed in accordance with the terms and conditions of this individual permit. All discharges shall be in accordance with the conditions of this permit. Any other point source discharge to surface waters of the state is prohibited unless it is an allowable non-stormwater discharge or is covered by another permit, authorization or approval. This permit does not relieve the permittee from responsibility for compliance with any other applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or decree. Part I Page I of 2 Permit No. NCS000040 PART II MONITORING, CONTROLS, AND LIMITATIONS FOR PERMITTED DISCHARGES SECTION A: STORMWATER POLLUTION PREVENTION PLAN The permittee shall develop a Stormwater Pollution Prevention Plan, herein after referred to as the Plan. This Plan shall be considered public information in accordance with Part III, Standard Conditions, Section E, Paragraph 3 of this individual permit. The Plan shall include, at a minimum, the following items: Site Plan. The site plan shall provide a description of the physical facility and the potential pollutant sources which may be expected to contribute to contamination of stormwater discharges. The site plan shall contain the following: (a) A general location map (USGS quadrangle map or appropriately drafted equivalent map), showing the facility's location in relation to transportation routes and surface waters, the name of the receiving water(s) to which the stormwater outfall(s) discharges, or if the discharge is to a municipal separate storm sewer system, the name of the municipality and the ultimate receiving waters; and accurate latitude and longitude of the point(s) of discharge. (b) A narrative description of storage practices, loading and unloading activities, outdoor process areas, dust or particulate generating or control processes, and waste disposal practices. (c) A site map drawn to scale with the distance legend indicating location of industrial activities (including storage of materials, disposal areas, process areas and loading and unloading areas), drainage structures, drainage areas for each outfall and activities occurring in the drainage area, building locations, existing BMPs and impervious surfaces, and the percentage of each drainage area that is impervious. For each outfall, a narrative description of the potential pollutants which could be expected to be present in the stormwater discharge. (d) A list of significant spills or leaks of pollutants that have occurred at the facility during the 3 previous years and any corrective actions taken to mitigate spill impacts. (e) Certification that the stormwater outfalls have been evaluated for the presence of non-stormwater discharges. The certification statement will be signed in accordance with the requirements found in Part 111, Standard Conditions, Section B, Paragraph 3. 2. Stormwater Management Plan. The stormwater management plan shall contain a narrative description of the materials management practices employed which control or minimize the exposure of significant materials to stormwater, including structural and nonstructural measures. The stormwater management plan, at a minimum, shall incorporate the following: (a) Feasibility Study. A review of the technical and economic feasibility of changing the methods of operations and/or storage practices to eliminate or reduce exposure of materials and processes to stormwater. Wherever practical, the permittee shall prevent exposure of all storage areas, material handling operations, and manufacturing or fueling operations. In areas where elimination of exposure is not practical, the stormwater management plan shall document the feasibility of diverting the stormwater runoff away from areas of potential contamination. (b) Secondary Containment Schedule. A schedule to provide secondary containment for bulk storage of liquid materials, storage of Section 313 of Title III of the Superfund Amendments and Reauthorization Act (SARA) water priority chemicals, or storage of hazardous substances to prevent leaks and spills from contaminating stormwater runoff. If the secondary containment devices are connected directly to stormwater conveyance systems, the connection shall be controlled by manually activated valves or other similar devices [which shall be secured with a locking mechanism] and any stormwater that accumulates in the containment area shall be at a Part 11 Page I of 6 Permit No. NCS000040 minimum visually observed for color, foam, oulfall staining, visible sheens and dry weather flow, prior to release of the accumulated stormwater. Accumulated stormwater shall be released if found to be uncontaminated by the material stored within the containment area. Records documenting the individual making the observation, the description of the accumulated stormwater and the date and time of the release shall be kept for a period of five years. (c) BMP Summary. A narrative description shall be provided of Best Management Practices (BMPs) to be considered such as, but not limited to, oil and grease separation, debris control, vegetative filter strips, infiltration and stormwater detention or retention, where necessary. The need for structural BMPs shall be based on the assessment of potential of sources to contribute significant quantities of pollutants to stormwater discharges and data collected through monitoring of stormwater discharges. Spill Prevention and Response Plan. The Spill Prevention and Response Plan (SPRP) shall incorporate an assessment of potential pollutant sources based on a materials inventory of the facility. Facility personnel (or team) responsible for implementing the SPRP shall be identified. A responsible person shall be on -site at all times during facility operations that have the potential to contaminate stormwater runoff through spills or exposure of materials associated with the facility operations. The SPRP must be site stormwater specific. Therefore, a SPCC plan may be a component of the SPRP, but may not be sufficient to completely address the stormwater aspects of the SPRP. The common elements of the SPCC with the SPRP may be incorporated by reference into the SPRP. 4. Preventative Maintenance and Good Housekeeping Program. A preventative maintenance program shall be developed. The program shall document schedules of inspections and maintenance activities of stormwater control systems, plant equipment and systems. Inspection of material handling areas and regular cleaning schedules of these areas shall be incorporated into the program. 5. Employee Training. Training schedules shall be developed and training provided at a minimum on an annual basis on proper spill response and cleanup procedures and preventative maintenance activities for all personnel involved in any of the facility's operations that have the potential to contaminate stormwater runoff. Facility personnel (or team) responsible for implementing the training shall be identified. 6. Responsible Party. The Stormwater Pollution Prevention Plan shall identify a specific position(s) responsible for the overall coordination, development, implementation, and revision to the Plan. Responsibilities for all components of the Plan shall be documented and position assignments provided. 7. Plan Amendment. The permittee shall amend the Plan whenever there is a change in design, construction, operation, or maintenance which has a significant effect on the potential for the discharge of pollutants to surface waters. The Stormwater Pollution Prevention Plan shall be reviewed and updated on an annual basis. The Director may notify the permittee when the Plan does not meet one or more of the minimum requirements of the permit. Within 30 days of such notice, the permittee shall submit a time schedule to the Director for modifying the Plan to meet minimum requirements. The permittee shall provide certification in writing (in accordance with Part 111, Standard Conditions, Section B, Paragraph 3) to the Director that the changes have been made. 8. Facility Inspection Program. Facilities are required to inspect all stormwater systems on at least a semiannual schedule, once in the fall (September -November) and once in the spring (April - June). The inspection and any subsequent maintenance activities performed shall be documented, recording date and time of inspection, individual(s) making the inspection and a narrative description of the facility's stormwater control systems, plant equipment and systems. Records of these inspections shall be incorporated into the Stormwater Pollution Prevention Plan. Stormwater discharge characteristic monitoring as required in Part 11 of this permit shall be performed in addition to facility inspections. Part 11 Page 2 of 6 Permit No. NCS000040 9. Implementation. The permittee shall document all monitoring, measurements, inspections and maintenance activities and training provided to employees, including the log of the sampling data and of activities taken to implement BMPs associated with the industrial activities, including vehicle maintenance activities. Such documentation shall be kept on -site for a period of five years and made available to the Director or his authorized representative immediately upon request. Part 11 Page 3 of 6 Permit No. NCS000040 0Q O Ada 0 ➢` 110 too ib0 2D q,S 1r�i) O.01'k ,001 0.03 ,2¢ 0.12 .o�Z SECTION B: ANALYTICAL MONITORING REQUIREMENTS During the period beginning on the effective dale of the permit and lasting until expiration, the permittee is authorized to discharge stormwater subject to the provisions of this permit. Analytical monitoring of stormwater discharges shall be performed as specified below in Table 1. All analytical monitoring shall be performed during a representative storm event. The required monitoring will result in a minimum of 7 analytical samplings being conducted over the term of the permit at each stormwater discharge outfall (SDO). The permittee shall complete the minimum 7 analytical samplings in accordance with the schedule specified below in Table 2. Table 1. Analytical Monitoring Requirements ` c') 4 Dtsehar e� r,It h "'GY g, c y r ,x <i�gt, , a * 1 v= 1 +iSam (, Measurement Frequency ffl +' S i`s`'+.. ,p p lelx ,ia f Sample 1i i h 7 h 2 i}i x,y. ti s"+-e 6'. s s."+��` '.5' 'va` 2 _a+,Un3tslr, y, f`,',a�',ra',*.Y: .t.,x+T. e?:i. fr13 P" ocahon3, Chemical Oxygen Demand mg/1 Annually year 1, 2, 3 Grab SDO Quarterly year 4 - Total Suspended Solids mg/I Annually year 1, 2, 3 Grab SDO Quarterly year 4 Total Kjeldahl mg/I Annually year 1, 2, 3 Grab SDO Quarterlyyear 4 Phenols ug/I Annually year 1, 2, 3 Grab SDO Quarterly year 4 Total Copper ug/I Annually year 1, 21 3 Grab SDO Quarterly year 4 Total Recoverable Lead ug/I Annually year 1, 2, 3 Grab SDO Quarterly ear 4 Total Nickel ug/I Annually year 1, 2, 3 Grab SDO Quarterly year 4 Total Zinc ug/I Annually year 11 21 3 Grab SDO Quarterly year 4 Total Chromium ug/I Annually year 1, 2, 3 Grab SDO Quarterly year 4 Total Rainfall4 inches Annually year 1, 2, 3 Quarterly year 4 ///// Annually year 1, 2, 3 Event,Duration4 minutes Quarterly year 4 - - '-%' ,Total"FI6w4 MG Annually year 1, 2, 3 - SDO Quarterly year 4 0.1!S-Toot At I Measurement Frequency: Once per year during years 1, 2, and 3 of the permit term. Each quarter during the 4ih year of the permit term. A year is defined as the 12 month period beginning on the month and day of issuance of the Permit. See Table 2 for schedule of monitoring periods. 2 If the stormwater runoff is controlled by a stormwater detention pond, a grab sample of the discharge from the pond shall be collected within the first 30 minutes of discharge. If the detention pond discharges only in response to a storm event exceeding a ten year design storm, then no analytical monitoring is required and only qualitative monitoring shall be performed. 3 Sample Location: Samples shall be collected at each stormwater discharge outfall (SDO) unless representative outfall status has been granted. 4 For each sampled representative storm event the total precipitation, storm duration, and total flow must be monitored. Total flow shall be either; (a) measured continuously, (b) calculated based on the amount of area Part 11 Page 4 of 6 Permit No. NCS000040 draining to the outfall, the amount of built -upon (impervious) area, and the total amount of rainfall, or (c) estimated by the measurement of Flow at 20 minute intervals during the rainfall event. Table 2. Monitoring schedule 5 �,�3�iVlo itorthggpenod ,� 'i T Sample+Number ; 5 S F F Y.f ;, -,� _ Start i Year I January1,2000 December 31, 2000 Year 2 2 January 1, 2001 December 31, 2001 Year 3 3 January 1, 2002 December 31, 2002 Year 4 - I" quarter 4 January 1, 2003 March 31, 2003 Year 4 - 2"d quarter 5 April I, 2003 June 30, 2003 Year 4 - 3" quarter 6 July 1, 2003 September 30, 2003 Year 4 - 4" quarter 7 October 1, 2003 December 31, 2003 SECTION C: QUALITATIVE MONITORING REQUIREMENTS Qualitative monitoring requires a visual inspection of each stormwater outfall regardless of representative outfall status and shall be performed as specified below in Table 3. Qualitative monitoring is for the purpose of evaluating the effectiveness of the Stormwater Pollution Prevention Plan (SPPP) and assessing new sources of stormwater pollution. No analytical tests are required. Qualitative monitoring of stormwater outfalls does not need to be performed during a representative storm event. In the event an atypical condition is noted at a stormwater discharge outfall, the Permittee shall document the suspected cause of the condition and any actions taken in response to the discovery. This documentation will be maintained with the Stormwater Pollution Prevention Plan. All qualitative monitoring will be performed twice per year, once in the spring (April - June) and once in the fall (September - November). Table 3. Oualitalive Monitoring Requirements Iil Y n Discharge,Characteshc5' "'. ' dr. rtfi^,t tt< PY fW {f Frequency tt� Momtonng . 5 -FL >Loratiohl:.a.•? .Color Semi -Annual SDO Odor Semi -Annual SDO Clarity Semi -Annual SOO Floating Solids Semi -Annual SDO Suspended Solids Semi -Annual SDO Foam Semi -Annual SDO Oil Sheen Semi -Annual SDO Other obvious indicators of stormwater pollution Semi -Annual SDO Footnotes: I Monitoring Location: Qualitative monitoring shall be performed at each stormwater discharge outfall (SDO) regardless of representative outfall status. Part 11 Page 5 of 6 Permit No. NCS000040 SECTION D: ON -SITE VEHICLE MAINTENANCE MONITORING REQUIREMENTS Facilities which have any vehicle maintenance activity occurring on -site which uses more than 55 gallons of new motor oil per month when averaged over the calendar year shall perform analytical monitoring as specified below in Table 4. This monitoring shall be performed at all outfalls which discharge stormwater runoff from vehicle maintenance areas. All analytical monitoring shall be performed during a representative storm event. The required monitoring will result in a minimum of 7 analytical samplings being conducted over the term of the permit at each stormwater discharge outfall (SDO) which discharges stormwater runoff from vehicle maintenance areas. The permittee shall complete the minimum 7 analytical samplings in accordance with the schedule specified in Table 2 (Part 11, Section B). Table 4. Analvtical Monitoring Requirements for On -Site Vehicle Maintenance DtWifte.Characteristia, �yc ; ',t"_Unias f ^Measurement- Sampler ti �`#,'rS—-19N '� fV. z 1.�,'_ a a ;fit..-.,�1 ,Fre uenc �..:T e24. t?Locatton?..a pH standard Annually year 1, 2, 3 Grab SDO Quarterly year 4 Oil and Grease mg/1 Annually year 1, 2, 3 Grab SDO Quarterly year 4 Total Suspended Solids mg/I Annually year 1, 2, 3 Grab SDO Quarterly year 4 New Motor Oil Usage gallons/month Annually year 1, 2, 3 Estimate - Quarterly year 4 Total Flow4 MG Annually year 1, 2, 3 Grab SDO Quarterly year 4 Footnotes: I Measurement Frequency: Once per year during years 1, 2, and 3 of the permit term. Each quarter during the 4i° year of the permit term. A year is defined as the 12 month period beginning on the month and day of issuance of the Permit. See Table 2 for schedule of monitoring periods. 2 If the stormwater runoff is controlled by a stormwater detention pond, a grab sample of the discharge from the pond shall be collected within the first 30 minutes of discharge. If the detention pond discharges only in response to a storm event exceeding a ten year design storm, then no analytical monitoring is required and only qualitative monitoring shall be performed. 3 Sample Location: Samples shall be collected at each stormwater discharge outfall (SDO) that discharges stormwater runoff from area(s) where vehicle maintenance activities occur. 4 Total flow shall be; (a) measured continuously, (b) calculated based on the amount of area draining to the outfall, the amount of built -upon (impervious) area, and the total amount of rainfall, or (c) estimated by the measurement of flow at 20 minute intervals during the rainfall event. Total precipitation and duration of the rainfall event measured shall result from the sampled representative storm event. Part 11 Page 6 of 6 Permit No. NCS000040 PART III STANDARD CONDITIONS FOR NPDES STORMWATER INDIVIDUAL PERMITS SECTION A: COMPLIANCE AND LIABILITY Compliance Schedule The permittee shall comply with Limitations and Controls specified for slormwater discharges in accordance with the following schedule: Existing Facilities: The Stormwater Pollution Prevention Plan shall be developed and implemented within 12 months of the effective date of the initial permit and updated thereafter on an annual basis. Secondary containment, as specified in Part II, Section A, Paragraph 2(b) of this permit, shall be accomplished within 12 months of the effective date of the initial permit issuance. Proposed Facilities: The Stormwater Pollution Prevention Plan shall be developed and implemented prior to the beginning of discharges from the operation of the industrial activity and be updated thereafter on an annual basis. Secondary containment, as specified in Part II, Section A, Paragraph 2(b) of this permit shall be accomplished prior to the beginning of discharges from the operation of the industrial activity. 2. Duty to Comply The permittee must comply with all conditions of this individual permit. Any permit noncompliance constitutes a violation of the Clean Water Act and is grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or denial of a permit upon renewal application. a. The permittee shall comply with standards or prohibitions established under section 307(a) of the Clean Water Act for toxic pollutants within the time provided in the regulations that establish these standards or prohibitions, even if the permit has not yet been modified to incorporate the requirement. b. The Clean Water Act provides that any person who violates a permit condition is subject to a civil penalty not to exceed $25,000 per day for each violation. Any person who negligently violates any permit condition is subject to criminal penalties of $2,500 to $25,000 per day of violation, or imprisonment for not more than 1 year, or both. Any person who knowingly violates permit conditions is subject to criminal penalties of $5,000 to $50,000 per day of violation, or imprisonment for not more than 3 years, or both. Also, any person who violates a permit condition may be assessed an administrative penalty not to exceed $10,000 per violation with the maximum amount not to exceed $125,000. [Ref: Section 309 of the Federal Act 33 USC 1319 and 40 CFR 122.41(a). I C. Under state law, a daily civil penally of not more than ten thousand dollars ($10,000) per violation may be assessed against any person who violates or fails to act in accordance with the terms, conditions, or requirements of a permit. [Ref: North Carolina General Statutes 143-215.6A] d. Any person may be assessed an administrative penalty by the Director for violating section 301, 302, 306, 307, 308, 318, or 405 of the Act, or any permit condition or limitation implementing any of such sections in a permit issued under section 402 of the Act. Administrative penalties for Class I violations are not to exceed $10,000 per violation, with the maximum amount of any Class I penalty assessed not to exceed $25,000. Penalties for Class 11 violations are not to exceed $10,000 per day for each day during which the violation continues, with the maximum amount of any Class II penalty not to exceed $125,000. Part III Page 1 of 8 Pages Permit No. NCS000040 Duty to Mitigate The permittee shall take all reasonable steps to minimize or prevent any discharge in violation of this individual permit which has a reasonable likelihood of adversely affecting human health or the environment. 4. Civil and Criminal Liabilitv Except as provided in Part ❑I, Section C of this permit regarding bypassing of stormwater control facilities, nothing in this individual permit shall be construed to relieve the permittee from any responsibilities, liabilities, or penalties for noncompliance pursuant to NCGS 143-215.3, 143-215.6A, 143-215.6B, 143- 215.6C or Section 309 of the Federal Act, 33 USC 1319. Furthermore, the permittee is responsible for consequential damages, such as fish kills, even though the responsibility for effective compliance may be temporarily suspended. 5. Oil and Hazardous Substance Liabilitv Nothing in this individual permit shall be construed to preclude the institution of any legal action or relieve the permittee from any responsibilities, liabilities, or penalties to which the permittee is or may be subject to under NCGS 143-215.75 et seq. or Section 311 of the Federal Act, 33 USC 1321. 6. Property Rights The issuance of this individual permit does not convey any property rights in either real or personal property, or any exclusive privileges, nor does it authorize any injury to private property or any invasion of personal rights, nor any infringement of Federal, State or local laws or regulations. Severability The provisions of this individual permit are severable, and if any provision of this individual permit, or the application of any provision of this individual permit to any circumstances, is held invalid, the application of such provision to other circumstances, and the remainder of this individual permit, shall not be affected thereby. 8. Duty to Provide Information The permittee shall furnish to the Director, within a reasonable time, any information which the Director may request to determine whether cause exists for modifying, revoking and reissuing, or terminating the permit issued pursuant to this individual permit or to determine compliance with this individual permit. The permittee shall also furnish to the Director upon request, copies of records required to be kept by this individual permit. Penalties for Tampering The Clean Water Act provides that any person who falsifies, tampers with, or knowingly renders inaccurate, any monitoring device or method required to be maintained under this individual permit shall, upon conviction, be punished by a fine of not more than $10,000 per violation, or by imprisonment for not more than two years per violation, or by both. If a conviction of a person is for a violation committed after a first conviction of such person under this paragraph, punishment is a fine of not more that $20,000 per day of violation, or by imprisonment of not more than 4 years, or both. 10. Penalties for Falsification of Reports The Clean Water Act provides that any person who knowingly makes any false statement, representation, or certification in any record or other document submitted or required to be maintained under this individual Part III Page 2 of 8 Pages Permit No. NCS000040 permit, including monitoring reports or reports of compliance or noncompliance shall, upon conviction, be punished by a fine of not more than $10,000 per violation, or by imprisonment for not more than two years per violation, or by both. SECTION B: GENERAL CONDITIONS Individual Permit Expiration The permittee is not authorized to discharge after the expiration date. In order to receive automatic authorization to discharge beyond the expiration date, the permittee shall submit forms and fees as are required by the agency authorized to issue permits no later than 180 days prior to the expiration date. Any permittee that has not requested renewal at least 180 days prior to expiration, or any permittee that does not have a permit after the expiration and has not requested renewal at least 180 days prior to expiration, will be subjected to enforcement procedures as provided in NCGS § 143-2153.6 and 33 USC 1251 et. seq. 2. Transfers This permit is not transferable to any person except after notice to and approval by the Director. The Director may require modification or revocation and reissuance of the permit to change the name and incorporate such other requirements as may be necessary under the Clean Water Act. Permittee is required to notify the Division in writing in the event the permitted facility is sold or closed. 3. Signatory Requirements All applications, reports, or information submitted to the Director shall be signed and certified. All applications to be covered under this individual permit shall be signed as follows: (1) For a corporation: by a responsible corporate officer. For the purpose of this Section, a responsible corporate officer means: (a) a president, secretary, treasurer or vice president of the corporation in charge of a principal business function, or any other person who performs similar policy or decision making functions for the corporation, or (b) the manager of one or more manufacturing production or operating facilities employing more than 250 persons or having gross annual sales or expenditures exceeding 25 million (in second quarter 1980 dollars), if authority to sign documents has been assigned or delegated to the manager in accordance with corporate procedures. (2) For a partnership or sole proprietorship: by a general partner or the proprietor, respectively; or (3) For a municipality, State, Federal, or other public agency: by either a principal executive officer or ranking elected official. b. All reports required by the individual permit and other information requested by the Director shall be signed by a person described above -or by a duly authorized representative of that person. A person is a duly authorized representative only if: (1) The authorization is made in writing by a person described above; (2) The authorization specified either an individual or a position having responsibility for the overall operation of the regulated facility or activity, such as the position of plant manager, operator of a well or well field, superintendent, a position of equivalent responsibility, or an individual or position having overall responsibility for environmental PartIII Page 3 of 8 Pages I'�iiiilli�►�►L�IiY1I1I1I1if17 matters for the company. (A duly authorized representative may thus be either a named individual or any individual occupying a named position.); and (3) The written authorization is submitted to the Director. C. Any person signing a document under paragraphs a. or b. of this section shall make the following certification: "I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations." 4. Individual Permit Modification- Revocation and Reissuance, or Termination The issuance of this individual permit does not prohibit the Director from reopening and modifying the individual permit, revoking and reissuing the individual permit, or terminating the individual permit as allowed by the laws, rules, and regulations contained in Title 40, Code of Federal Regulations, Parts 122 and 123; Title 15A of the North Carolina Administrative Code, Subchapter 2H .0100; and North Carolina General Statute 143-215.1 et. al. After public notice and opportunity for a hearing, the individual permit may be terminated for cause. The filing of a request for a individual permit modification, revocation and reissuance, or termination does not stay any individual permit condition. The permit shall expire when the individual permit is terminated. 5. Permit Actions The permit may be modified, revoked and reissued, or terminated for cause. The notification of planned changes or anticipated noncompliance does not stay any individual permit condition. SECTION C: OPERATION AND MAINTENANCE OF POLLUTION CONTROLS I. Proper Operation and Maintenance The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of this individual permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems which are installed by a permittee only when the operation is necessary to achieve compliance with the conditions of this individual permit. Need to Halt or Reduce Not a Defense It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the condition of this individual permit. Bypassing of Stormwater Control Facilities Bypass is prohibited and the Director may take enforcement action against a permittee for bypass unless: Part III Page 4 of 8 Pages Permit No. NCS000040 a. Bypass was unavoidable to prevent loss of life, personal injury or severe property damage; and b. There were no feasible alternatives to the bypass, such as the use of auxiliary control facilities, retention of stormwater or maintenance during normal periods of equipment downtime or dry weather. This condition is not satisfied if adequate backup controls should have been installed in the exercise of reasonable engineering judgment to prevent a bypass which occurred during normal periods of equipment downtime or preventive maintenance; and C. The permittee submitted notices as required under, Part 111, Section E of this permit. If the Director determines that it will meet the three conditions listed above, the Director may approve an anticipated bypass after considering its adverse effects. SECTION D: MONITORING AND RECORDS Representative Sampling Samples collected and measurements taken, as required herein, shall be characteristic of the volume and nature of the permitted discharge. Analytical sampling shall be performed during a representative storm event. Samples shall be taken on a day and time that is characteristic of the discharge. All samples shall be taken before the discharge joins or is diluted by any other waste stream, body of water, or substance. Monitoring points as specified in this permit shall not be changed without notification to and approval of the Director. 2. Recording Results For each measurement, sample, inspection or maintenance activity performed or collected pursuant to the requirements of this individual permit, the permittee shall record the following information: a. The date, exact place, and time of sampling, measurements, inspection or maintenance activity; b. The individual(s) who performed the sampling, measurements, inspection or maintenance activity; C. The date(s) analyses were performed; d. The individual(s) who performed the analyses; e. The analytical techniques or methods used; and f. The results of such analyses. 3. Flow Measurements Where required, appropriate Flow measurement devices and methods consistent with accepted scientific practices shall be selected and used to ensure the accuracy and reliability of measurements of the volume of monitored discharges. 4. Test Procedures Test procedures for the analysis of pollutants shall conform to the EMC regulations published pursuant to NCGS 143-215.63 et. seq, the Water and Air Quality Reporting Acts, and to regulations published pursuant to Section 304(g), 33 USC 1314, of the Federal Water Pollution Control Act, as Amended, and Regulation 40 CFR 136. Part III Page 5 of 8 Pages Permit No. NCS000040 To meet the intent of the monitoring required by this individual permit, all lest procedures must produce minimum detection and reporting levels and all data generated must be reported down to the minimum detection or lower reporting level of the procedure. 5. Representative Outfall If a facility has multiple discharge locations with substantially identical stormwater discharges that are required to be sampled, the permittee may petition the Director for representative outfall status. If it is established that the stormwater discharges are substantially identical and the permittee is granted representative outfall status, then sampling requirements may be performed at a reduced number of outfalls. 6. Records Retention Visual monitoring shall be documented and records maintained at the facility along with the Stormwater Pollution Prevention Plan. Copies of analytical monitoring results shall also be maintained on -site. The permittee shall retain records of all monitoring information, including all calibration and maintenance records and all original strip chart recordings for continuous monitoring instrumentation, and copies of all reports required by this individual permit for a period of at least 5 years from the date of the sample, measurement, report or application. This period may be extended by request of the Director at any time. Inspection and Ent The permittee shall allow the Director, or an authorized representative (including an authorized contractor acting as a representative of the Director), or in the case of a facility which discharges through a municipal separate storm sewer system, an authorized representative of a municipal operator or the separate storm sewer system receiving the discharge, upon the presentation of credentials and other documents as may be required by law, to; a. Enter upon the permittee's premises where a regulated facility or activity is located or conducted, or where records must be kept under the conditions of this individual permit; b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of this individual permit; C. Inspect at reasonable times any facilities, equipment (including monitoring and control equipment), practices, or operations regulated or required under this individual permit; and d. Sample or monitor at reasonable times, for the purposes of assuring individual permit compliance or as otherwise authorized by the Clean Water Act, any substances or parameters at any location. SECTION E: REPORTING REQUIREMENTS 1. Discharge Monitoring Reports Samples analyzed in accordance with the terms of this permit shall be submitted to the Division on Discharge Monitoring Report forms provided by the Director. Submittals shall be received by the Division no later than 30 days from the date the facility receives the sampling results from the laboratory. Part III Page 6 of 8 Pages Permit No. NCS000040 2. Submitting Reports Duplicate signed copies of all reports required herein, shall be submitted to the following address: Division of Water Quality Water Quality Section ATTENTION: Central Files 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Availability of Reports Except for data determined to be confidential under NCGS 143-215.3(a)(2) or Section 308 of the Federal Act, 33 USC 1318, all reports prepared in accordance with the terms shall be available for public inspection at the offices of the Division of Water Quality. As required by the Act, analytical data shall not be considered confidential. Knowingly making any false statement on any such report may result in the imposition of criminal penalties as provided for in NCGS 143-215.613 or in Section 309 of the Federal Act. 4. Non-Stormwater Discharges If the storm event monitored in accordance with this individual permit coincides with a non-stormwater discharge, the permittee shall separately monitor all parameters as required under the non-Stormwater discharge permit and provide this information with the Stormwater discharge monitoring report. 5. Planned Changes The permittee shall give notice to the Director as soon as possible of any planned changes at the permitted facility which could significantly alter the nature or quantity of pollutants discharged. This notification requirement includes pollutants which are not specifically listed in the individual permit or subject to notification requirements under 40 CFR Part 122.42 (a). 6. Anticipated Noncompliance The permittee shall give notice to the Director as soon as possible of any planned changes at the permitted facility which may result in noncompliance with the individual permit requirements. Bypass a. Anticipated bypass. If the permittee knows in advance of the need for a bypass, it shall submit prior notice, if possible at least ten days before the date of the bypass; including an evaluation of the anticipated quality and affect of the bypass. b. Unanticipated bypass. The permittee shall submit notice within 24 hours of becoming aware of an unanticipated bypass. Twenty-four Hour Reporting The permittee shall report to the central office or the appropriate regional office any noncompliance which may endanger health or the environment. Any information shall beprovided orally within 24 hours from the time the permittee became aware of the circumstances. A written submission shall also be provided within 5 days of the time the permittee becomes aware of the circumstances. The written submission shall contain a description of the noncompliance, and its causes; the period of noncompliance, including exact dates and times, and if the noncompliance has not been corrected, the Part III Page 7 of 8 Pages Permit No. NCS000040 anticipated time compliance is expected to continue; and steps taken or planned to reduce, eliminate, and prevent reoccurrence of the noncompliance. The Director may waive the written report on a case -by -case basis if the oral report has been received within 24 hours. Other Noncompliance The permiltee shall report all instances of noncompliance not reported under 24 hour reporting at the time monitoring reports are submitted. 10. Other Information Where the permittee becomes aware that it failed to submit any relevant facts in an application for an individual permit or in any report to the Director, it shall promptly submit such facts or information. Part III Page 8 of 8 Pages Permit No. NCS000040 PART IV LIMITATIONS REOPENER This individual permit shall be modified or alternatively, revoked and reissued, to comply with any applicable effluent guideline or water quality standard issued or approved under Sections 302(b) (2) (c), and (d), 304(b) (2) and 307(a) of the Clean Water Act, if the effluent guideline or water quality standard so issued or approved: Contains different conditions or is otherwise more stringent than any effluent limitation in the individual permit; or b. Controls any pollutant not limited in the individual permit. The individual permit as modified or reissued under this paragraph shall also contain any other requirements in the Act then applicable. PART V ADMINISTERING AND COMPLIANCE MONITORING FEE REQUIREMENTS The permittee must pay the administering and compliance monitoring fee within 30 (thirty) days after being billed by the Division. Failure to pay the fee in timely manner in accordance with 15A NCAC 2H .0105(b)(4) may cause this Division to initiate action to revoke the Individual Permit. PART VI DEFINITIONS Act See Clean Water Act. 2. Arithmetic Mean The arithmetic mean of any set of values is the summation of the individual values divided by the number of individual values. 3. Allowable Non-Stormwater Discharges This permit regulates Stormwater discharges. Non-Stormwater discharges which shall be allowed in the Stormwater conveyance system are: (a) All other discharges that are authorized by a non-Stormwater NPDES permit. (b) Uncontaminated groundwater, foundation drains, air -conditioner condensate without added chemicals, springs, discharges of uncontaminated potable water, waterline and fire hydrant flushings, water from footing drains, flows from riparian habitats and wetlands. (c) Discharges resulting from fire -fighting or fire -fighting training. 4. Best Management Practices (BMPs) Measures or practices used to reduce the amount of pollution entering surface waters. BMPs may take the form of a process; activity, or physical structure. Parts IV, V and VI Page I of 5 Permit No. NCS000040 Bypass A bypass is the known diversion of stormwater from any portion of a stormwater control facility including the collection system, which is not a designed or established operating mode for the facility. 6. Bulk Storage of Liquid Products Liquid raw materials, manufactured products, waste materials or by-products with a single above ground storage conlainerhaving a capacity of greater than 660 gallons or with multiple above ground storage containers located in close proximity to each other having a total combined storage capacity of greater than 1,320 gallons. 7. Clean Water Act The Federal Water Pollution Control Act, also known as the Clean Water Act (CWA), as amended, 33 USC 1251, et. seq. 8. Division or DWO The Division of Water Quality, Department of Environment and Natural Resources. 9. Director The Director of the Division of Water Quality, the permit issuing authority. 10. EMC The North Carolina Environmental Management Commission. 11. Grab Sample An individual sample collected instantaneously. Grab samples that will be directly analyzed or qualitatively monitored must be taken within the first 30 minutes of discharge. 12. Hazardous Substance Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the Clean Water Act. 13. Landfill A disposal facility or part of a disposal facility where waste is placed in or on land and which is not a land treatment facility; a surface impoundment, an injection well, a hazardous waste long-term storage facility or a surface storage facility. 14. Municipal Separate Storm Sewer System A stormwater collection system within an incorporated area of local self-government such as a city or town. 15. Overburden Any material of any nature, consolidated or unconsolidated, that overlies a mineral deposit, excluding topsoil or similar naturally -occurring surface materials that are not disturbed by mining operations. Part VI Page 2 of 5 Pages Permit No. NCS000040 16. Permittee The owner or operator issued a permit pursuant to this individual permit. 17. Point Source Discharge of Stormwater Any discernible, confined and discrete conveyance including, but not specifically limited to, any pipe, ditch, channel, tunnel, conduit, well, or discrete fissure from which Stormwater is or may be discharged to waters of the state. 18. Representative Storm Event A storm event that measures greater than 0.1 inches of rainfall and that is preceded by at least 72 hours in which no storm event measuring greater than 0.1 inches has occurred. A single storm event may contain up to 10 consecutive hours of no precipitation. For example, if it rains for 2 hours without producing any collectable discharge, and then stops, a sample may be collected if a rain producing a discharge begins again within the next 10 hours. 19. Representative Outfall Status When it is established that the discharge of stormwater runoff from a single outfall is representative of the discharges at multiple outfalls, the DWQ may grant representative outfall status. Representative outfall status allows the permittee to perform analytical monitoring at a reduced number of outfalls. 20. Rinse Water Discharge The discharge of rinse water from equipment cleaning areas associated with industrial activity. Rinse waters from vehicle and equipment cleaning areas are process wastewaters and do not include washwaters utilizing any type of detergent or cleaning agent. 21. Secondary Containment Spill containment for the contents of the single largest tank within the containment structure plus sufficient freeboard to allow for the 25-year, 24-hour storm event. 22. Section 313 Water Priority Chemical A chemical or chemical category which a. Is listed in 40 CFR 372.65 pursuant to Section 313 of Title III of the Superfund Amendments and Reauthorization Act (SARA) of 1986, also titled the Emergency Planning and Community Right - to -Know Act of 1986; b. Is present at or above threshold levels at a facility subject to SARA title III, Section 313 reporting requirements; and C. That meet at least one of the following criteria: (1) Is listed in Appendix D of 40 CFR part 122 on either Table II (organic priority pollutants), Table III (certain metals, cyanides, and phenols) or Table IV (certain toxic pollutants and hazardous substances); (2) Is listed as a hazardous substance pursuant to section 311(b)(2)(A) of the CWA at 40 CFR l 16.4; or (3) Is a pollutant for which EPA has published acute or chronic water quality criteria. Part VI Page 3 of 5 Pages Permit No. NCS000040 23. Severe Property Damage Means substantial physical damage to property, damage to the control facilities which causes them to become inoperable, or substantial and permanent loss of natural resources which can reasonably be expected to occur in the absence of a bypass. Severe property damage does not mean economic loss caused by delays in production. 24. Significant Materials Includes, but is not limited to: raw materials; fuels; materials such as solvents, detergents, and plastic pellets; finished materials such as metallic products; raw materials used in food processing or production; hazardous substances designated under section 101(14) of CERCLA; any chemical the facility is required to report pursuant to section 313 of Title III of SARA; fertilizers; pesticides; and waste products such as ashes, slag and sludge that have the potential to be released with stormwater discharges. 25. Significant Spills Includes, but is not limited to: releases of oil or hazardous substances in excess of reportable quantities under section 311 of the Clean Water Act (Ref: 40 CFR 110.10 and CFR 117.21) or section 102 of CERCLA (Ref: 40 CFR 302.4). 26. Stormwater Runoff The flow of water which results from precipitation and which occurs immediately following rainfall or as a result of snowmelt. 27. Stormwater Associated with Industrial Activity The discharge from any point source which is used for collecting and conveying stormwater and which is directly related to manufacturing, processing or raw material storage areas at an industrial site. Facilities considered to be engaged in "industrial activities" include those activities defined in 40 CFR 122.26(b)(14). The term does not' include discharges from facilities or activities excluded from the NPDES program. 28. Stormwater Pollution Prevention Plan A comprehensive site -specific plan which details measures and practices to reduce stormwater pollution and is based on an evaluation of the pollution potential of the site. 29. Ten Year Design Storm The maximum 24 hour precipitation event expected to be equaled or exceeded on the average once in ten years. Design storm information can be found in the State of North Carolina Erosion and Sediment Control Planning and Design Manual. 30. Total Flow The flow corresponding to the time period over which the entire storm event occurs. Total flow shall be either; (a) measured continuously, (b) calculated based on the amount of area draining to the outfall, the amount of built -upon (impervious) area, and the total amount of rainfall, or (c) estimated by the measurement of flow at 20 minute intervals during the rainfall event. 31. Toxic Pollutant Any pollutant listed as toxic under Section 307(a)(I) of the Clean Water Act. Part V I Page 4 of 5 Pages Permit No. NCS000040 32. Upset Means an exceptional incident in which there is unintentional and temporary noncompliance with technology based permit effluent limitations because of factors beyond the reasonable control of the permittec. An upset does not include noncompliance to the extent caused by operational error, improperly designed treatment or control facilities, inadequate treatment or control facilities, lack of preventive maintenance, or careless or improper operation. 33. Vehicle Maintenance Activity Vehicle rehabilitation, mechanical repairs, painting, fueling, lubrication, vehicle cleaning operations, or airport deicing operations. 34. Visible Sedimentation Solid particulate matter, both mineral and organic, that has been or is being transported by water, air, gravity, or ice from its site of origin which can be seen with the unaided eye. 35. 25-year,24 hour storm event The maximum 24-hour precipitation event expected to be equaled or exceeded, on the average, once in 25 years. Part V I Page 5 of 5 Pages State of North Carolina Department of Environment and Natural Resources Division of Water Quality James B. Hunt, Jr., Governor Wayne McDevitt, Secretary A. Preston Howard, Jr., P.E., Director GREG SIMMONS CHARLOTTE PIPE & FOUNDRY PO BOX 35430 CHARLOTTE, NC 28253 Dear Permittee: February 19, 1999 1! NCDENR NORTH CAROLINA DEPARTMENT OF ENVIRONMENT ANo NATURAL RESOURCES Subject: NPDES Stormwater Permit Renewal Charlotte Pipe & Foundry Permit Number NCS000040 Mecklenburg County Your facility is currently covered for stormwater discharge under NPDES Permit NCS000040. This permit expires on August 31, 1999. In order to assure your continued coverage under your permit, you must apply to the Division of Water Quality (DWQ) for renewal of your permit. To make this renewal process easier, we are informing you in advance that your permit will be expiring. Enclosed you will find an individual permit renewal application form, supplemental information request, and Stormwater Pollution Prevention Plan certification. Filing the application form along with the requested supplimental information will constitute your application for renewal of your permit. The application form must be completed and returned along with all requested information within thirty days of receipt of this letter in order to constitute a timely renewal filing. Recent legislation modified the fee structure for DWQ permits. Renewal fees have been eliminated and annual fees have been changed. The new annual fee for your permit is now $715.00 (you will be invoiced later this year for your annual fee.) A copy of the new fee schedule is enclosed in this package. Failure to request renewal within the time period indicated may result in a civil assessment of at least $250.00. Larger penalties may be assessed depending on the delinquency of the request. Discharge of stormwater from your facility without coverage under a valid stormwater NPDES permit would constitute a violation of NCGS 143-215.1 and could result in assessments of civil penalties of up to $10,000 per day. If you have any questions regarding the permit renewal procedures please contact Darren England of the Stormwater and General Permits Unit at (919) 733-5083, ext. 545. Sincerely, Bradley Bennett, Supervisor Stormwater and General Permits Unit cc: Central Files Regional Office P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone 919-733-5083 FAX 919-733-9919 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper State'bf North Carolina Department of Environment, Health and Natural Resources Division of Environmental Management James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary A. Preston Howard, Jr., P.E., Director July 31, 1995 Mr. David G. Waggoner, Engineer Charlotte Pipe and Foundry Co. P.O. Box 35430 Charlotte, North Carolina 28235 Subject: Stormwater Sampling - Charlotte Pipe and Foundry Co. Permit No. NCS000040 Mecklenburg County, North Carolina Dear Mr. Waggoner: This letter is in response to your letter of May 23, 1995, to Mr. Bill Mills of our staff regarding representative sampling for the Subject stormwater permit at Charlotte Pipe and Foundry. Your request was to sample Outfalls SW001, SWO02 (HA and IIB) and SW004, to fulfill the permit sampling provisions. You indicated that drainage areas III and VI which were listed in the application for permit have been combined with other drainage areas. Further, you proposed that since the sand stored in drainage area V has been relocated and secondary containment is proposed to be installed for bulk storage tanks in this area, sampling for Outfall SWO05 not be required and that Outfall SW001 be considered representative of SW005. After staff review of your permit, permit application, and maps of the site, we have concluded that representative outfall status should not be granted at this time. The sampling results from the permit application revealed that the contaminant level of SWO05 was quite high (i.e. BOD was 200 mg/l, COD was 1462 mg/l, Suspended Solids was 1613 mg/l, TKN was 88 mg/I, Lead was 42 mg/I, Zinc was 54 mg/1). Because of these high levels, we feel it inappropriate to allow representative outfall status to the permit at this time that would eliminate the sampling of SW005. Once new samples for this year have been collected at SWO05 which reflect the changes that have been made in that drainage area and we have a chance to review the data, we will be willing to reconsider such a request. Since drainage -areas III and VI have -been combined with other drainage - areas there will be no separate sampling required for these areas. If you have any questions concerning this matter, please contact Mr. Bill Mills in the Permits and Engineering Unit at 733-7015 ext. 548. cc: Mooresville Regional Office Coleen Sullins P.O. Box 29535, Raleigh, North Carolina 27626-0535 An Equal Opportunity Affirmative Action Employer kSincerelt,,ward, Jr., P.E. Telephone 919-733-7015 FAX 919-733-9919 50% recycled/ 10% post -consumer paper CHARL40TTE PIPE AND FOUNDRY COMPANY P.O. Box 35430 • Telephone 704/332-2647 j CHARLOTTE, NORTH CAROLINA28235 May 23, 1995 Foundry Fax No.332-4581 Mr. Bill Mills North Carolina Department of Environment, Health and Natural Resources Division of Environmental Management Water Quality Section, Permits and Engineering Unit 512 N. Salisbury Street P.O. Box 29535 Raleigh, North Carolina 27626-0535 Re: Stormwater Individual Permit No. NCS000040 Charlotte Pipe Bc Foundry Co. Petition for Representative Outfall Status AEI Project No. N188-18 Dear Mr. Mills; We are currently developing a strategy for conducting the required stormwater monitoring at Charlotte Pipe & Foundry Co. to comply with the above referenced Permit. In accordance with Part I, Section A; Paragraph 2.a. of the Permit, we hereby request the number of stormwater outfalls at which we are required to -collect stormwater samples be modified and reduced. As indicated on the attached Stormwater Drainage Maps (Figures 2-2 to 2-4 from the draft SWP3 currently under development), drainage from the Charlotte Pipe & Foundry Co. — - property is discharged 1romfour 4 outfalls SW001--SW002—,SW0041- and SW005 Six 6 drainage outfalls were listed in the Permit application. Drainage zones III and VI have been combined with Zones IV and I respectively, reducing the drainage areas from six (6) to four (4). Sample loacations for each outfall were selected based on assessability, safety, and providing representative samples. Note that Outfall SWO02 has two (2) sampling points (SW002A and SW002B). 1 The stormwater data from the Permit application is presented in the Summary Table labelled Attachment A. The surface runoff from the north end of Zone V is represented as Outfall _ 005 in Attachment A. The elevated parameters from Outfall 005 resulted from runoff from a pile of used sand (BH on Figure 2-3), located near the propane tanks. This used sand pile has since been relocated to Zone IV. Based on current conditions, we believe Outfall SWO01 to be representative of Outfall SW005, because the activities occurring in Zone V also occur within Zone I. The bulk storage tanks located iW Zone V will receive secondary containment based on recommended BMP's contained in the draft SWP3 currently being reviewed. The fitting coating operation is already contained. As mentioned previously, the former used -foundry sand pile (BH) has been relocated to Zone IV, and the hydrostatic water discharge will be sent to the process sewer. The remaining Zone V activities include finished product storage, transfer of coated cast products, and vehicle parking. These activities are low risk activities which also occur in drainage Zone I. Therefore, we request four (4) sampling points be approved for characterizing the stormwater runoff from the Charlotte Pipe & Foundry Co. property. These sampling points are presented in the following table. DRAINAGE AREAS OiITFALL ZONE AREA; APPROXIMATE I' (acres)! %IMPERVIOUS SW001 I 7.19 95 - - -- _.. _._._ - - IIA (E -of Clarkson) -----2.38-- SW002 IIB (W. of Clarkson) 0.74 .95 NONE III (deleted) Part of IV ---- SW004 IV 11.06 99 SWO05 V 2.52 100 (Visual Only) NONE VI (deleted) Part of I -- 2 We understand that visual monitoring of all outfalls will be required, regardless of the number of outfalls sampled. The attached stormwater drainage maps are in "Draft" form only and do not show BMP's which will be implemented in accordance with the Stormwater Pollution Prevention Plant (SWP3) currently being developed. We would appreciate a timely response concerning this matter so that we can finalize development of our stormwater monitoring plan. Feel free to contact us if you have any questions or require further information. Thank you so much for your assistance. Sincerely, David G. Waggoners Engineer Attachments cc: Greg Simmons, CP&F Carol Hambridge, AEI Allen Scott, AEI K ATTACHMENT A STORMWATER ANALYSIS SUMMARY CHARLOTTE PIPE AND FOUNDRY COMPANY SAMPLE COLLECTION DATE: 11/12/92 PARAMETERS UNIT OUTFALL 001 FIRST COMPOSITE FLUSH OUTFALL 002 FIRST COMPOSITE FLUSH OUTFALL 003 FIRST COMPOSITE FLUSH OUTFALL 004 FIRST COMPOSITE FLUSH OUTFALL 005 FIRST COMPOSITE FLUSH OIL &.GREASE mg/1 i9.1 NR 1.6 NR 6.0 NR 3.4 NR 12.2 NR BOO mg/I j 16 11 3 2 10 6 17 3 200 70 COD mg/I 180 105 119 353 62 31 170 165 1462 1272 SUSPENDED SOLIDS mg/I DNA NA 200 788 96 36 410 520 1613 2870 TKN mg/l 14.7 5.9 11.8 99.9 4.7 3.5 14.7 17.6 88.2 58.8 NITRATE + NITRITE mg/1 11.6 0.825 1.3 0.50 3.5 1.6 1.25 0.450 2.55 0.380 TOTAL PHOSPHORUS mg/I 0.65 0.35 0.66 0.65 0.50 0.25 0.60 0.25 1.1 0.63 pH mg/I i6.3 NR 9.4 NR 8.5 NR 8.5 NR 10.4 NR CADMIUM mg/I 0.002 0.001 0.009 0.001 <0.001 <0.001 0.001 <0.001 0.018 0.108 CHROMIUM mg/I <0.010 <0.010 0.02 0.023 <0.010 <0.010 <0.010 0.024 0.135 0.129 COPPER mg/1 0.248 0.032 0.223 0.228 0.056 0.044 0.068 0.060 1.08 0.857 LEAD mg/I 1.32 0.40 7.8 4.2 0.170 0.024 0.70 0.35 13.0 42.0 NICKEL mg/I 0.075 0.040 0.070 0.090 0.070 0.030 0.035 0.11 0.085 0.105 ZINC mg/I 0.92 0.34 6.7 2.19 0.20 0.070 0.5 0.32 33.4 54.9 PHENOLS mg/1 6.36 0.05 0.90 0.37 <0.05 <0.05 0.67 0.31 2.4 1.4 IRON mg/I 6.28 5.96 18.6 10.3 4.49 2.13 11.9 15.8 144 98.6 MANGANESE mg/I 0.50 0.22 2.16 1.08 0.24 0.075 0.33 0.26 23.2 15.6 NA Not analyzed NR Not required filename: 1192 SW.WKt Fedex info.txt NCDENR - Stormwater Permitting Program Individual Permit Renewal 1612 Mail Service Center Raleigh, NC 27699-1612 919.807.6378 15206-724000 � Please call jenny (x5513) with tracking number. THANKS! Jenny Page 1 I IRWIN Ii CREEK ding Dock fit, r / w aBin Storage 1 I A It 2 -�� Asphalt g AREA 1 y Warehouse Gravel - OLD Sample Pavement t--' ----" qs halt Location SW°D> _„ � -_.►�f ,� P % Bin Storage SWoos Asphalt Parking �� Asphalt II Parking L� AL SW SAMPLE LOCATION OR Dc (SWDOZA) /- Asphalt t' Asphalt Bin Storage Asphalt AREA \\ IV A "GRASIS SUMMIT ,AVENI.IP AR \ DIRECTION OF STORM WATER FLOW - LOCATION OF STORM WATER OUTFALLS OUTFALL LATITUDE LONGITUDE 001 35°13'27"N 80°51'51"W 002 3501329"N 80051'49"W 002A 35°13'23"N 80°51'42"W 004 35`13'27"N 80°51'39"W 005 35e13'29"N 80°51'41"W 006 35013'34"N 80051'45"W AREA PERCENT (ACRES) IMPERVIOUS AREA 1 5.75 _ 90% ~' AREA 11 2.90 95% AREA 111 3.33 85% AREA IV 10.23 95% AREA V 2.28 95% AREA VI 8.53 85% AREA VII 12.06 95% DUTFALL POTENTIAL POLLUTANTS 001 METALS, CHEMICAL RESIDUES, OIL & GREASE '... 002 METALS, CHEMICAL RESIDUES, OIL & GREASE 002A METALS, CHEMICAL RESIDUES, OIL & GREASE 004 METALS, CHEMICAL RESIDUES, OIL & GREASE I 005 METALS, CHEMICAL RESIDUES, OIL & GREASE 006 METALS, CHEMICAL RESIDUES, OIL & GREASE Outside Bulk Storage Areas Summary The following storage areas are located outside: • One 15,000-gallon hot dip storage tank is located on an asphalt -paved surface south of the main building. The tank is provided with secondary containment in the form of an open -top containment area concrete sump. The sump is approximately 23.2 feet by 17.4 feet by 5 feet, which equates to an approximate storage capacity of 2,018ft3, or approximately 15,097 gallons. Spilled material collected within the containment area is removed and disposed of in accordance with applicable regulations. • Two 6,000-gallon asphalt emulsion storage tanks are located on an asphalt -paved surface west of the Water Test building. The tanks are provided with secondary containment in the form of an open -top containment area concrete sump. The sump is approximately 15 feet by 37 feet by 3 feet, which equates to an approximate storage capacity of 1,665 ft3, or approximately 12,455 gallons. Spilled material collected within the containment area is removed and disposed of in accordance with applicable regulations. • A 6,000-gallon hot dip storage tank is located on an asphalt -paved surface west of the 5-Foot Water Test building. The tank is provided with secondary containment in the form of an open -top containment area concrete sump. The sump is approximately 15 feet by 37 feet by 3 feet, which equates to an approximate storage capacity of 1,665 ft3, or approximately 12,455 gallons. Spilled material collected within the containment area is removed and disposed of in accordance with applicable regulations. • One 50-ton sand silo is located west of the main production building. In addition, one feldspar silo and one silica flour silo is located south of the waste treatment building. The silos are not equipped with secondary containment. However, since the contents are not liquid, spilled material will be easily cleaned up and should not impact stormwater. One 550-gallon used oil storage tank is located on an asphalt -paved surface south of the Oil House. The tank is provided with secondary containment in the form of metal walls. The containment area is approximately 4 feet X 6 feet X 2 feet, which equates to an approximate storage capacity of 48 ft3, or approximately 359 gallons. Spilled material collected within the containment area is removed and disposed of in accordance with applicable regulations. • One 10,000-gallon gasoline storage double walled tank and one 10,000-gallon diesel storage double walled tank are located on an asphalt -paved surface near the northeast corner of the property. The tanks are provided with secondary containment in the form of concrete walls. The containment area is approximately 30 feet by 30 feet by 3 feet, which equates to an approximate storage capacity of 2,700 ft3, or approximately 20,200 gallons. Spilled material collected within the containment area is removed and disposed of in accordance with applicable regulations. One fueling station with four pumps is located on an asphalt -paved surface near the northeast corner of the property. The fueling station is covered and equipped with an emergency shut off valve. The fueling station is provided with secondary containment in the form of a trench drain. Spilled material collected within the containment area is removed and disposed of in accordance with applicable regulations. • Oil drums are stored under cover outside the Oil House. The area is not equipped secondary containment or with a berm. • Materials are stored in totes and drums in a covered shed located at the northeastern portion of the facility. The entrance to the shed is equipped with an asphalt berm to minimize the potential impact of spills on stormwater. • Materials are stored in totes and drums in a covered shed located at the southeastern portion of the facility. This area is not equipped with a berm. • Two totes of oil are stored on the ground without secondary containment in the shell core unloading area. Summary of Analytical Monitoring Results swool 12/2/2009 7/19/2010 5/27/2011 10/11/2011 5/9/2012 1/14/2013 7/11/2013 Characteristic Units 8.1.09-1.31.10 2.1.10-733.10 1.1.11-731.11 8.1.11-1.31.11 2.1.12-Z33.12 8.1.12-1.31.13 2.1.13-731.13 8.1.13-1.31.14 1.1.14-Z31.14 Oil & Grease mg/L 13.8 ND NO Note 3 NO NO Note 3 Cr mg/L 0.0055 NO ND Note 0.0084 NO Note Cu mg/L 0.014 0.007 NO Note 3 0.016 NO Note 3 Pb mg/L 0.040 NO 0.014 Note 3 0.045 0.012 Note 3 Ni mg/L ND ND NO Note 3 0.005 NO Note 3 Zn mg/L 0.198 0.077 0.195 Note 3 0.143 0.045 Note 3 TSS mg/L 51.0 8.7 7.3 Note 3 67.5 6.5 Note 3 Note 4 Note 4 pH mg/L 7.1 7.6 Note 2 Note 3 7.2 7.8 Note 3 TKN mg/L 0.85 ND 0.93 Note 0.84 NO Note Phenols mg/L 0.015 NO 0.016 Note 3 0.039 0.021 Note 3 COD mg/L 100.0 NO 44.0 Note 3 58.0 NO Note 3 Total Rainfall in 1 0.11 0.13 1 1.06 1.08 1.14 0.13 3.94 SWO02 12/2/2009 7/19/2010 5/27/2011 10/11/2011 5/9/2012 1/14/2013 7/11/2013 Characteristic Units 8.1.09-1.31.10 2.1.10-Z31.10 1.1.11-731.11 8.1.11-1.31.12 2.1.12-731.12 8.1.12-1,21.13 2.1.13-731.13 8.1.13-1.31.14 2.1.14-7.31.14 Oil & Grease mg/L 6.5 NO NO ND NO NO NO Cr mg/L 0.012 NO NO NO NO NO 0.0063 Cu mg/L 0.031 0.015 0.009 0.003 ND NO NO Pb mg/L 0.042 0.005 NO 0.014 0.022 0.012 0.058 Ni mg/L 0.0072 NO NO ND ND NO NO Zn mg/L 0.375 0.114 0.067 0.028 ND NO 0.158 TSS mg/L 140.0 14.1 93.6 15.6 20.0 21.0 92.0 Note 4 Note 4 pH mg/L 7.4 7.0 7.4 6.0 7.1 7.6 6.4 TKN mg/L 1.5 0.92 0.78 NO NO ND 1.1 Phenols mg/L 0.089 0.01 NO 0.022 NO 0.0068 0.023 COD mg/L 124.0 ND 57.0 34.0 NO NO 91.0 Total Rainfall in 1 0.11 1 0.13 1.06 1.08 1.14 0.13 3.94 Summary of Analytical Monitoring Results SWO04 12/2/2009 7/19/2010 5/27/2011 10/11/2011 5/9/2012 1/14/2013 7/11/2013 Characteristic Units 8.1.09-1.3110 2.1.10-7.31.10 2.1.114.31.11 8.1.11-1.31.12 2.1.12-7.31.12 8.1.12-1.31.13 2.1.13-7.3113 8.1.13-1,31.14 2.1.14-7.31.14 Oil & Grease mg/L 7.6 Note 1 NO ND ND NO ND Cr mg/L 0.017 Note 1 NO ND 0.0058 NO ND Cu mg/L 0.044 Note 1 0.006 0.0004 0.003 0.008 ND Ph mg/L 0.062 Note 1 ND 0.008 ND 0.008 0.061 Ni mg/L 0.013 Note 1 ND NO ND ND NO Zn mg/L 0.647 Note 1 ND 0.080 0.024 0.075 0.297 TSS mg/L 234.0 Note 1 16.0 32.0 37.8 11.8 25.3 Note 4 Note 4 pH mg/L 7.3 Note 1 Note 2 6.7 7.4 7.8 7.1 TKN mg/L 2.9 Note 1 NO ND NO NO 1.1 Phenols mg/L 0.048 Note 1 0.016 0.017 0.02 0.0073 0.021 COD mg/L 176.0 Note 1 116.0 27.0 NO 84.0 56.0 Total Rainfall in 1 0.11 1 0.13 1 1.06 1 1.08 1.14 0.13 3.94 SW005 12/2/2009 7/19/2010 5/27/2011 10/11/2011 5/9/2012 1/14/2013 7/11/2013 Characteristic Units 8.1.09-1.31.10 2.1.10-7.31.10 2.1.11-].31.11 8.1.11-1.31.12 2.1.12-7.31.12 8.1.12-1.31.13 2.1.13-231.13 8.1.13-1.31.14 2.1.14-7.31.14 Oil & Grease mg/L 87.4 Note 1 ND ND NO NO ND Cr mg/L 0.105 Note 1 NO 0.0071 0.0102 0.0419 ND Cu mg/L 0.138 Note 1 0.011 0.002 0.003 0.064 ND Ph mg/L 0.269 Note 1 0.056 0.019 0.034 0.299 0.025 Ni mg/L 0.052 Note 1 0.009 ND 0.008 0.019 ND Zn mg/L 3.1 Note 1 0.569 0.060 0.471 0.852 NO TSS mg/L 1550.0 Note 1 107.0 82.0 92.2 307.2 10.7 Note 4 Nate 4 pH mg/L 7.3 Note 1 6.5 9.0 7.1 8.3 7.3 TKN mg/L 13.2 Note 1 2.0 0.83 NO 2.5 1.4 Phenols mg/L 0.200 Note 1 0.028 0.010 NO 0.022 0.017 COD mg/L 2170.0 Note 1 98.0 53.0 28.0 179.0 35.0 Total Rainfall in 0.11 0.13 1.06 1.08 1.14 0.13 3.94 Summary of Analytical Monitoring Results SW006 12/2/2009 7/19/2010 5/27/2011 10/11/2011 5/9/2012 1/14/2013 7/11/2013 Characteristic tJnitS 8.1.09-1.31.30 2.1.30-7.31.10 2.1.11-7.31.11 8.1.11-1.31.12 2.1.12-Z33.12 8.3-12-1.31.13 2.1.13-7.31.13 8.1.13-1.31,14 2.1.14-Z31.14 Oil & Grease mg/L 7.0 Note 1 NO ND NO ND ND Cr mg/L 0.016 Note 1 ND ND 0.0056 NO ND Cu mg/L 0.035 Note 1 ND 0.007 0.0006 NO 0.001 Pb mg/L 0.036 Note 1 0.007 0.007 0.021 0.0098 ND Ni mg/L 0.010 Note 1 NO ND NO ND ND Zn mg/L 0.346 Note 1 NO 0.063 ND ND ND TSS mg/L 217.0 Note 1 12.4 6.5 73.6 18.2 15.3 Note 4 Note 4 pH mg/L 7.4 Note 1 Note 2 6.0 3.2 7.7 7.7 TKN mg/L 1.3 Note 1 0.73 1.2 NO 0.65 0.57 Phenols mg/L 0.050 Note 1 ND NO 0.043 0.0077 0.0088 COD mg/L 115.0 Note 1 ND ND 49.0 ND NO Total Rainfall in 1 0.11 0.13 1.06 1 1.08 1.14 0.13 3.94 Notes: 1. Samples were collected for SWOs 001 & 002 only. Due to the short duration of the storm event on July 19, 2010, representative samples from the remaining permitted locations (SW004, SW005, SW006, SW007) could not be collected. Further attempts to redo the sampling event while staying with the confines of a representative event were unsuccessful before the end of the sampling period date of July 31, 2010. 2. Laboratory spilled sample and was unable to take measurement. 3. Sample not collected due to unsafe conditions reaching outfall. 4. Analytical data not yet reported for this timeframe at time of renewal submittal. 5. Analytical data is not available for the August 2010 -January 2011 timeframe as the attempt to sample on November 16, 2010 was unsuccessful due to it not being a representative storm event. Further attempts to redo the sampling event while staying with the confines of a representative event were unsuccessful before the end of the sampling period date of January 31, 2011. 6. Sampling/visible inspections are no longer required for SWO07 in line with guidance provided by Michael Parker of DWq during May 2009 inspection. Summary of Visible Inspection Results SW001 12/2/2009 7/19/2010 5/27/2011 10/11/2011 5/9/2012 1/14/2013 7/11/2013 Characteristic 8.1.09-1.31.10 2.1.10-7.31.30 2.1.11-73111 8.1.11-1.31.12 2.3.12-7.31.12 8.1.12-1.31.33 2.1.13-Z31.13 8.1.13-1.31.14 2.1.14-7.31.14 Med Brown- Very Light Cloudy/ Light Color Clear Inaccessible Dark Gray Clear Black Brown Tint Brown Odor None None None Inaccessible None None None Clarity 2 1 1 Inaccessible 4 1 4 Floating Solids 1 1 1 Inaccessible 1 1 4 Note 1 Note 1 Suspended Solids 2 1 2 Inaccessible 2 1 4 Foam No No No No No No No Oil Sheen No No No Inaccessible No No No Erosion/Deposition No No No No No No No SW002 12/2/2009 7/19/2010 5/27/2011 10/11/2011 5/9/2012 1/14/2013 . 7/11/2013 Characteristic 8.1.094.31.10 2.1.10-7.31.10 Z1.11-Z31.11 8.1.11-1.31.12 2.1.12-7.31.12 8.1.12-1.31.13 2.1.13-7.31.13 8.1.13-1.31.14 2.1.14-7.31.14 Med Brown- Very Light Light Brown- Cloudy/ Very Color Clear Light Tan Clear Black yellow Tint Gray Lgt Brown Odor None None None None None None None Clarity 3 1 1 2 2 2 2 Floating Solids 1 1 1 2 2 2 2 Note 1 Note 1 Suspended Solids 3 1 2 1 2 1 1 Foam No No No No No No No Oil Sheen No No No No No No No Erosion/Deposition No No No No Yes2 No No SW004 12/2/2009 7/19/2010 5/27/2011 10/11/2011 5/9/2012 1/14/2013 7/11/2013 Characteristic 8.1.09-1.31.10 2.1.10-7.31.10 2.1.11-7.31.11 8.1.11-1.31.]2 2.1.12-7.31.12 8.1.12-1.31.13 2.1.13-7.31.13 8.1.13-1.31.14 2.1.14-7.31.14 Dark Brown- Brown -Gray Color Note 3 Clear Light Brown Clear Clear Black Tint Odor None Note None None None None None Clarity 4 Note 3 1 2 2 2 4 Floating Solids 1 Note 3 1 2 2 2 2 Note 1 Note 1 Suspended Solids 4 Note 3 1 2 2 2 2 Foam No Note 3 No No No No No Oil Sheen No Note 3 No No No No No Erosion/Deposition No Note 3 No No No No No Summary of Visible Inspection Results SWO05 12/2/2009. 7/19/2010 5/27/2011 10/11/2011 5/9/2012 1/14/2013 7/11/2013 Characteristic 8.1.09-1.31.10 2.1.10-Z31.30 2.1.11-7.31.11 8.1.11-1.31.12 2.1.12J.31.12 8.1.12-1.31.13 2.1.13-7.31.13 8.1.13-1.31.14 2.1.14-Z3114 Light Brown- Cloudy / Dark Color Dark Black Note 3 Clear Dark Brown Gray/ Cloudy Gray Brown Odor None Note None None None None None Clarity 5 Note 3 1 2 3 3 4 Floating Solids 1 Note 3 1 2 3 3 3 Note 1 Note 1 Suspended Solids 5 Note 3 2 2 3 3 3 Foam No Note 3 No No No No No Oil Sheen No Note 3 No No No No No Erosion/Deposition No Note 3 No No No No No SWO06 12/2/2009 7/19/2010 5/27/2011 10/11/2011 5/9/2012 1/14/2013 7/11/2013 Characteristic 8.1.09-1.31.10 2.1.10-Z31.10 2.1.11-7.31.11 8.1,114.31.12 2.1.12-Z31.12 8.1.12-1.31.13 2.1.13-7.31.13 8.1.13-1.31.14 2.1.14-731.14 Light Brown - Color Med Brown Note 3 Clear Light Tan Clear Cloudy Gray Odor None Note None None None None None Clarity 2 Note 3 1 2 3 1 4 Floating Solids 1 Note 3 1 1 2 1 2 Note 1 Note 1 Suspended Solids 3 Note 3 2 1 2 1 2 Foam No Note 3 No No No No No Oil Sheen No Note 3 No No No No No Erosion/Deposition No Note 3 No No No No No Notes: 1. Inspection and sampling data not yet reported for this timeframe at time of renewal submittal. 2. Storm drain inlet covered by woody debris. 3. Inspections completed for SWOs 001 & 002 only. Due to the short duration of the storm event on July 19, 2010, representative sampling from the remaining permitted locations (SWO04, SWO05, SWO06, SWO07) could not be completed. Further attempts to redo the inspection event while staying with the confines of a representative event were unsuccessful before the end of the sampling period date of July 31, 2010. Since inspections are completed in conjunction with sampling, inspections were not completed for this timeframe. 4. Inspection data is not available for the August 2010 -January 2011 timeframe as the attempt to sample/inspect on November 16, 2010 was unsuccessful due to it not being a representative storm event. Further attempts to redo the sampling event while staying with the confines of a representative event were unsuccessful before the end of the sampling period date of January 31, 2011. 5. Sampling/visible inspections are no longer required for SWO07 in line with guidance provided by Michael Parker of DWQ during May 2009 inspection. BMP Summary General Practices The facility performs inspections of all outside areas and notes any issues that need to be corrected. Trash is collected in dumpsters. Materials Storage Charlotte Pipe encourages proper material storage to prevent the release of materials and pollutants that may cause stormwater runoff pollution. Proper storage techniques include: • Store materials inside of the facility or under cover, when possible. • Store materials so that there is adequate aisle space to facilitate material transfer and inspections. • When appropriate and/or otherwise required, post signs or placards on the periphery of the storage areas to indicate the hazards associated with the materials stored within. • Store containers and drums away from heavy traffic routes, when possible, to minimize accidental spills. • Store containers according to the manufacturer's instructions to avoid damaging the containers from improper weight distribution. Material Inventory Control Improved material inventory practices can reduce the waste that results from overstocking and the disposal of out -dated materials. Careful tracking of all materials ordered may also result in more.efficient material usage. The following material inventory BMPs are implemented at the facility: Material Safety Data Sheets (MSDS) are maintained for all products used at the facility. A MSDS is requested and maintained on file prior to the use of the product for which it was written. • Containers are labeled to show the name and type of substance contained therein. When appropriate and/or otherwise required, containers will also be labeled as to the stock numbers, hazards of the materials stored therein, expiration date, suggestions for proper handling, and first aid information. Equipment Operations and Maintenance C—harlotte-Pipe-personnel-implement the -following equipment -operation -and — maintenance BMPs as part of the facility's good housekeeping program: • Stormwater drains are labeled to facilitate employee familiarity with drain locations and to remind employees that non-stormwater discharges are not allowed; • Trash and other solid waste materials are regularly collected and disposed of appropriately; • Asphalted outside areas are cleaned each day with a sweeper to remove any settled particulate debris; • Equipment is inspected for leaks or conditions, that could lead to discharges of pollutants or contact of stormwater with raw waste materials; • Mobile vehicles (company automobiles, forklifts, general purpose vehicles, etc.) are maintained to prevent leaking; and • Equipment, which is not working properly, is promptly repaired. Structural Control Measures Charlotte Pipe currently employs three types of structural control measures at the facility to prevent pollutant contact with stormwater. These structural control measures include: (1) Preventive Covering, (2) Substance Containment, and (3) Vegetative Cover. Each of these is discussed in more detail below. • Preventive covering comprises the physical enclosure of material, equipment, or process operations, when feasible. Charlotte Pipe has built a 150'L x 120'W x 35'H building along the northeastern portion of our property to enclose the aggregate waste storage areas thus reducing stormwater exposure. Substance containment measures are used to physically contain or capture a release of solid, liquid, or gaseous material. These containment measures provide a second line of defense by preventing a release of material from the primary containers to reach down gradient surface water. Containment will prevent both run-on and run-off. Secondary containment and spill response and prevention procedures for the bulk liquid storage containers at -the facility (i.e. the fuel and asphalt above ground storage tanks located in Area VII) are described in detail in the Spill Prevention Control and Countermeasures (SPCC) Plan. Charlotte Pipe also employs secondary containment for non -petroleum based products by storing most products used in the manufacturing process inside of the foundry buildings or under cover and surrounding bulk material spent storage area with berms to prevent stormwater runoff. Stormwater which accumulates in the containment areas is at a minimum visually observed for color, foam, outfall staining, visible sheen, and dry weather flow prior to release of the accumulated stormwater. Accumulated stormwater is released only if found uncontaminated by the materials stored within the containment area. • Vegetative cover on non -impervious areas prevents erosion and improves the infiltration capacity of the soil. In addition, the vegetation should be maintained in all areas to prevent erosion. Charlotte Pipe ensures that all areas of the facility that are not covered in buildings, concrete, asphalt, and gravel pavement, are provided with vegetative cover. Significant Changes in Industrial Activities Charlotte Pipe has made the following significant changes in industrial activities in the last five (5) years: Replacement of the fittings emulsion asphalt dip line with an E-coat system. The fittings emulsion asphalt dip line, which partially ran outside, was removed from service mid-2013 and is currently in the process of being dismantled. This modification has the potential to significantly impact stormwater as the new E- coat system is located inside a building; thus, there is no potential stormwater impacts associated with its operation. The new E-coat applied to castings is expected to be more rust -resistant than the emulsion asphalt coating previously used; therefore, stormwater impact from water run-off of the fittings product stored outside should be reduced. Installation of a 150'L x 120'W x 35'H aggregate waste storage building along the northeastern portion of our property. This building enclosed the aggregate waste storage areas thus eliminating stormwater exposure from waste aggregate pile run-off. STORMWATER POLLUTION PREVENTION PLAN DEVELOPMENT AND IMPLEMENTATION CERTIFICATION North Carolina Division of Energy, Mineral, and Land Resources — Stormwater Permitting Facility Name: Charlotte Pipe & Foundry Company Permit Number: NCS000040 Location Address: 1335 S Clarkson St. Charlotte, NC 2B208 County: Mecklenburg "1 certify, under penalty of law,: that the Stormwater Pollution Prevention Plan (SPPP) document and all attachments were developed and implemented under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information required by the SPPP. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information gathered is, to the best of my knowledge and belief, true, accurate and complete." And "I certify that the SPPP has been developed, signed and retained at the named facility location, andtheSPPP has been fully Implemented at this facility location In accordance with the terms and conditions of the stormwater discharge permit" And "1 am aware that there are significant penalties for falsifying. information, including the possibility of fines and imprisonment for knowing violations" Sign (according to permit signatory requirements) and return this Certification. DO NOT SEND STORMWATER POLLUTION PREVENTION PLAN WITH THIS CERTIFICATION. 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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. o O&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 <bradley. ben nettPncdenr.gov> Sent: Tuesday, August 28, 2018 11:05 AM To: Pappalardo, Jenny L.<ipappalardo(acharlottepipe.com> Cc: Waggoner, David G. <daggoner@charlotteoipe.com> 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 (NC5000040 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. L•1 g1217 `lg C^ . QLV A�Pa �oia4 �— • Gj IWAOi w 0%^ IJMR rr,�. v* ,4 c . w '9" uQ9rodG ou+ W Is L-W us"*s Ys w as.� s . Say, u6-1..;,0 �u r �► / 2y�ao aU Cot 4 7n Ujr rT k44 ( to i H- • � SCAAS curruj OIJ dztAS La c ad; j WLA &W4, Q arc SLOW' i;\s dwl lls wit;A &.vs arc Au" r� • C"ca�"�. a9g� s �y� - b;� tYT.•� 0... s Vaut 6,d km as aoo9 �„An;F. rb«LS Gka+�. c (� Se 4..04 � AO S 4t Lwcge-ie `., s have Ntok U51.rv!. J Csr Clr4, r N ql a • tnf \ c.,,t2... 1 1 3 r • � i +I i ii. P. I . i . 1 �C Jr I} n 9/6/2018 Mail - bradley.bennett@ncdenr.gov RE: [External] RE: Stormwater Permit Renewal - NCS000040 Pappalardo, Jenny L. <jpappalardo@charlottepipe.conn> Thu 9/6/2018 1:10 PM To:Bennett Bradley <bradley.bennett@ncdenr.gov>; CcWaggoner, David G. <daggoner@charlottepipe.com>; 0 3 attachments (968 KB) Outfall Sampling Data, Updated 9-2018.pdf; CPF Site Layout, Revised 9-2018.pdf; NCS000040 Contacts Report, Updated 9-2018.pdf; CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to Report Spam. See answers below. Please let me know if you need anything else. Thank you, Jenny From: Bennett, Bradley <bradley.bennett@ncdenr.gov> Sent: Tuesday, August 28, 2018 11:05 AM To: Pappalardo; Jenny L. <jpappalardo@charlottepipe.com> Cc: Waggoner, David G. <dwaggoner@charlottepipe.com> Subject: RE: [External] RE: Stormwater Permit Renewal - NC5000040 Jenny, 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 OOOSA 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) — (SWO03 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. https://outlook.office365.com/owa/?realm=nc.gov&path=/mail/inbox 1/3 9/6/2018 Mail - bradley.bennett@ncdenr.gov • You indicated in our discussion that corrected. Please forward me the i (NCS000040 Contacts Report, Upda to our regional office. We are trying t large plans. Please see attached file (! • We also discussed the possibility of ge since the renewal application in 2014. could easily_ provide. Please see attac I hope I hit all the major areas. If you have a send it toy you for comment in the next few Thanks for your help M. From: Pappalardo, Je Sent: Monday, Augu To: Bennett, Bradley Subject: RE: [External] RE: Stormwater Permit contact information that we forwarded for your review is out of data and needs to be ections and I will make the needed changes in our system. Please see attached file 9-2018). get more information available electronically, but we don't have the ability to scan e Layout, Revised 9-2018). ing updated summary information on your facility's qualitative monitoring results file (Outfall Sampling Data, Updated 9-2018). lions please let me know. As I mentioned, we will prepare a draft permit and Our regional office will also schedule a site visit once the draft is available. Renewal - NCS000040 CAUTION: External email. Do not click links or open Yes, please call 704.348.5513. Thank you, Jenny From: Bennett, Bradley <bLadley.bennett@nci Sent: Monday, August 27, 2018 7:13 AM To: Pappalardo, Jenny L. <jpappalardo@chark Subject: RE: [External] RE: Stormwater Permit Jenny, Sorry for the late response. If today at 1:30 still m hments unless verified. - all suspicious email as an attachment to Rgport Spam. From: Pappalardo, Jenny L. fmailto jppppalardo@� Sent: Thursday, August 23, 2018 7:47 AM To: Bennett, Bradley < radl y.be n @nc nr ggy>; Subject: [External] RE: Stormwater Permit Renewal - n>; Waggoner, David G. <dwaggoner@charlo eRpe com> NCS000040 for you then that will be fin, just let me know what number to call you at. David G. <dwaggoner@c rlo 21pe.com> CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to Report Spam. Bradley, Can we plan to talk Monday, Aug 27th at 1:30pm. Thank you, I Jenny https://outlook.office365.com/owal?realm=nc.gov&path=/mailfinbox 1 213 9/6/2016 Mail - bradley.bennett@ncdenr.gov From: Bennett, Bradley <bradley.benne @ncdenr.gov> Sent: Tuesday, August 7, 201810:50 AM To: Pappalardo, Jenny L. <jpap alar o@charlo epipe.com>; Waggoner, David G. <�ggoner@charlo pep com> Subject: Stormwater Permit Renewal - NCS000040 Hello, and first let me apologize for how long it has taken us to get going on your permit renewal. A number of issues over the last few years have led to a backlog on renewal of our Individual permits. I would like to set up a time where I can call and talk with you, or other staff as appropriate, about the renewal. I will be working on this process. Since the previous renewal application came in back at the end of 2013 I'm guessing there may be some changes that we should discuss and possibly have documented for the renewal. In addition, here are a few other items that would be helpful if you can provide updates: • I have attached a printout of contacts we have in our database for the facility. Can you please review this and let me know if there are changes to contacts and if the owner/facility information is still accurate? • Federal regulations changed in the last few years to require electronic reporting of data. We are not yet at the stage of being able to collect stormwater data this way, but we will have to work to get accurate outfall location information in our system in order to meet federal requirements for electronic reporting when our systems can handle the data. If you could provide the lat/long coordinates for your facility's outfall points that would be helpful. • If you can provide a summary of monitoring information since your application submittal in December 2013 that would be help as well. • I am very interested in any changes that may have occurred in your facility or processes since your application submittal that could affect pollutants discharged in stormwater runoff. I see in our files that there were some adjustments to activities in 2016 due to land being sold to NC DOT. If there are other changes on site or changes in your process we would like to know about those. • If there have been changes, a new site map showing the most up to date layout of activities, outfalls and drainage will be needed. I work part time and I am generally in the office three days a week (Monday— Wednesday). Maybe we can find a day/time soon that works to talk. For this week I will be in the office Today and Wednesday (8/7-8/8). Next week 1 will be out of the office and then I'll be back Aug 20-22. Thanks for your help! Bradley Bennett Stormwater Program Note New Phone Number NC Division of Energy, Mineral & Land Resources Phone: (919) 707-3646 512 N. Salisbury Street Fax: (919) 807-6494 1612 Mail Service Center Email: Bradley Bennett@n enr.gov Raleigh, NC 27699-1612 Email correspondence to and from this address may be subject to public records laws https://outlook.o(fice365.com/owal?realm=nc.gov&path=/mail/inbox 3/3 Bennett, Bradley From: Bennett, Bradley Sent: Tuesday, August 28, 2018 11:05 AM To: 'Pappalardo, Jenny U Cc: Waggoner, David G. Subject: RE: [External] RE: Stormwater Permit Renewal - NCS000040 Jenny, 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. • 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). • 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. • 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. • 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. • 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. • 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. 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 toy 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. M. From: Pappalardo, Jenny L. [mailto:jpappalardo@charlottepipe.com. Sent: Monday, August 27, 2018 7:34 AM To: Bennett, Bradley <bradley.bennett@ncdenr.gov> Subject: RE: [External] RE: Stormwater Permit Renewal - NCS000040 I ufION External email. Do not slick li ks or open attach ents uIII s verified S . III suspicious mail as n attar ment to Yes, please call 704.348.5513. Thank you, Jenny From: Bennett, Bradley <bradley.bennett@ncdenr.gov> Sent: Monday, August 27, 2018 7:13 AM To: Pappalardo, Jenny L. <jpappalardo@charlottepipe.com>; Waggoner, David G. <dwaggoner@charlottepipe.com> Subject: RE: [External] RE: Stormwater Permit Renewal - NCS000040 I Jenny, Sorry for the late response. If today at 1:30 still works for you then that will be fin, just let me know what number to call you at. BB From: Pappalardo, Jenny L. [mailto:jpappalardo@charlottepipe.com] Sent: Thursday, August 23, 2018 7:47 AM To: Bennett, Bradley <bradley.bennett@ncdenr.gov>; Waggoner, David G. <dwaggoner@charlottepipe.com> Subject: [External] RE: Stormwater Permit Renewal - NCS000040 Bradley, Can we plan to talk Monday, Aug 27th at 1:30pm. Thank you, Jenny From: Bennett, Bradley <bradley.bennett@ncdenr.gov> Sent: Tuesday, August 7, 2018 10:50 AM To: Pappalardo, Jenny L. <jpappalardo@charlottepipe.com>; Waggoner, David G. <dwaggoner@charlottepipe.com> Subject: Stormwater Permit Renewal - NCS000040 Hello, and first let me apologize for how long it has taken us to get going on your permit renewal. A number of issues over the last few years have led to a backlog on renewal of our Individual permits. I would like to set up a time where I can call and talk with you, or other staff as appropriate, about the renewal. I will be working on this process. Since the previous renewal application came in back at the end of 2013 I'm guessing there may be some changes that we should discuss and possibly have documented for the renewal. In addition, here are a few other items that would be helpful if you can provide updates: • I have attached a printout of contacts we have in our database for the facility. Can you please review this and let me know if there are changes to contacts and if the owner/facility information is still accurate? • Federal regulations changed in the last few years to require electronic reporting of data. We are not yet at the stage of being able to collect stormwater data this way, but we will have to work to get accurate outfall location information in our system in order to meet federal requirements for electronic reporting when our systems can handle the data. If you could provide the lat/long coordinates for your facility's outfall points that would be helpful. • If you can provide a summary of monitoring information since your application submittal in December 2013 that would be help as well. • 1 am very interested in any changes that may have occurred in your facility or processes since your application submittal that could affect pollutants discharged in stormwater runoff. I see in our files that there were some adjustments to activities in 2016 due to land being sold to INC DOT. If there are other changes on site or changes in your process we would like to know about those. If there have been changes, a new site map showing the most up to date layout of activities, outfalls and drainage will be needed. I work part time and I am generally in the office three days a week (Monday— Wednesday). Maybe we can find a day/time soon that works to talk. For this week I will be in the office Today and Wednesday (8/7-8/8). Next week I will be out of the office and then I'll be back Aug 20-22. Thanks for your help! Bradley Bennett Stormwater Program Note New Phone Number NC Division of Energy, Mineral & Land Resources Phone: (919) 707-3646 512 N. Salisbury Street Fax: (919) 807-6494 1612 Mail Service Center Email: bradley.bennett(a)ncdenr.gov Raleigh, NC 27699-1612 Email correspondence to and from this address may be subject to public records laws Final 2016 Integrated Report -All Assessed Waters Assessment Unit Name Assessment Unit Number Irwin Creek 11-137-1 Catawba River Subbasin Assessment Unit Description Water Quality Classification From source to Sugar Creek C Criteria Status Reason for Rating Parameter of Interest Catawba River Basin Units 11.8 FW Miles Category Exceeding Criteria I I> 10% and >90 conf . - I ;Copper (7 µg/I, AL, FW).. 'IS Data Inconclusive , I> 10% and < 90%conf I ;Copper (7 µg/I, AL, FW) 3e Exceeding Criteria J 0 0 I> 10/o and < 90% conf `Zinc (50 µg/I AL FW) ,5e Exceeding Criteria > 10% and < 90% conf Lead (25 µg/I, AL, NC) ` 5e Meeting Criteria I I< 10% !Nickel (88 µg/l, AL, FW) l Meeting Criteria J '< 10% _._ 1__ pH (6 su, AL, FW) ` _ 1`� Meeting Criteria , l (< 10% Cadmium (2 µg/I, AL, FW) !rl,- Meeting Criteria < 10% _ 1 __ _,_,.. . _ ._.... -- __._ Water Temperature (32°C AL LP&CP) . . - , ,_ .. _ -_ -_,_ 1 Meeting Criteria _.. . < 10% --— --- ---- ) 'Mercury (0.012 µg/I, FC FW) --- 1 Meeting Criteria < 10/ Arsenic (50 µg/I AL, NC) It ... Meeting Criteria I I< 10% I BOD 1t Meeting Criteria ,< 10% i '.Turbidity (50 NTU, AL, FW miles) ai --- — Meeting Criteria L10%— _ -.._...-- 1 pH (9 0 AL FW) 1 Meeting Criteria j < 10% ^Total Suspended Solids It Meeting Criteria I I< 10% I ;Dissolved Oxygen (4 mg/I, AL, FW) 1i Meeting Criteria i< 10% 'Arsenic (10 µg/l, HH, NC) 1 Exceeding Criteria _ l� Poor l Fish Community (Nar, AL, FW) 4s Data Inconclusive l FCB AP GM>200 or >20% Fecal Coliform (GM 200/400, REC, FW) 4t Data Inconclusive 4/11/2018 2016 Integrated Report -All Assessed Waters Page 350 of 1306 Fish tissue assessments for mercury apply to all waters and are not individually listed FI ourcnu x 8 _ swoox \ swop+ 7 e t � s — swoom KC \ i —U O 1 DSO RE W nu c Xcuwu CH CHA — nn[ suMc S- d swE o' mozoa' \ �-M u 5-,RW U'E1 tiN: s.�*o+asasw�+mwrcros OUfFALL LAT E EONCINOE 001 35°1328'N .80151ww 002 35°1399'N W5114m 002A 351137iN -80'S1YTW 004 35°132YN -W5119W DOS 35'13'29N 80'S1'41W OOSA 35113'm W51'4OW ON 35'1313'N -W51'441W 005A 35'1313'N -W514M AREA PERCENt P worm AREA[ 9.19 50% ARE" 290 95% MEAN 3.33 W% AREA TV 1023 95% AREAV 228 95% AREA 8.14 15% AREAVN 12.E 95% OUTFALL POTEI ML POWAO 00i METALS, CMEMICALRESOIES. a. S GREASE 002 METALS. CHO" RESDUES.a M GREASE 002A METALS. CHEMICAL RESUK OR B GREASE ON METALS. CHU" EESOUES. a S GREASE 005 METALS, CHEMICAL RESDUES, GI S CREASE 005A METALS. CHO" RESOUES. OR M GREASE OM METALS. CHEMICAL RESUUES. OI B CREASE OOSA METALS. CHEMICAL RESUUES. Ot B GREASE